Effort During the No-Cost Extension Period
Post-Award
Jun 4, 2026Federal agencies have different requirements. Some agencies may require the same level of effort as was proposed during the original term of the award, others will not. For example, NIH currently only requires a "measurable" level of effort for the PI and other key personnel during the term of the award, including any NCE periods. NSF takes a different view and assumes that the originally proposed effort will be spread over the entire award period, including any NCE periods. As a best practice, we recommend following sponsor specific terms and conditions, which may include FAQs.
It is also important to note based on NIH Grants Policy Statement, that for mentored and non-mentored CDA K award recipients are required to devote and maintain a minimum level of effort to the award. During a no-cost extension, the recipient is required to maintain any effort minimum and can only reduce their effort with prior approval of the awarding IC.
In the absence of guidance from the sponsor, if committed faculty effort will be reduced 25% or more during the extension period, a request for approval to reduce faculty effort should be submitted to the sponsor at the same time as the NCE request or notification. If no mention is made of faculty effort reduction during the NCE, then there is an expectation that the effort will remain at the same level as committed during the original award period.
For more information from Post-Award Administration, click here.