Effective March 2, 2017, the National Institutes of Health (NIH) has implemented the ability to electronically submit two additional types of prior approval requests via the eRA Commons system:

• Request for No-cost Extension (NCE) which requires NIH prior approval;
• Request for Change of PD/PI

These requests are in addition to the original features of the NIH Prior Approval module that rolled out in the fall of 2016:

• Request for Withdrawal of an Application
• Request to Submit an Unsolicited Application exceeding $500,000 or more in direct costs (these requests must be initiated by an NIH PO after initial contact from a PI)

While the Prior Approval module in Commons is available for the submission of these types of requests, its use is not yet required. Please note that these features are only available for NIH awards and not for awards from other agencies which use Commons (e.g., CDC, AHRQ).

Important Information about New Prior Approval Request Types

No-cost Extension (NCE)

In the Prior Approval module, requests for a No-cost Extension must be initiated by a Signing Official for the University. NCE requests cannot be initiated by the PI. Additionally, the following criteria must be considered when making a request:

• A grant IS eligible for submission of an NCE through Prior Approval when:
  • an NCE under expanded authority has already been used and the grant is within 90 days of the project end date.
  • the grantee is not under expanded authority and the grant is within 90 days of the project end date.
  • the project end date has expired and has not been closed or has not entered unilateral closeout, whichever comes first.
• A grant IS NOT eligible for an NCE through Prior Approval when:
  • an NCE under expanded authority has never been requested and the grant is within 90 days of the project end date. In this case, the NCE will be processed normally through the Extension link in Status.
  • the grant is closed.
  • the grant is a fellowship grant.
• What information will an SO need to provide?
  • The NCE request form includes:
    • Request Detail – the number of months you wish to extend the project end date; the amount of unobligated money still available, and other pertinent information.
    • Three PDF upload fields: Progress Report, Budget Document, Justification Document

NIH has recommended contacting the appropriate Institute/Center prior to submission of the request to ensure that the request includes appropriate documentation.

Change of Principal Investigator

In the Prior Approval module, requests for a Change in PI must be initiated by a Signing Official for the University. PI Change requests cannot be initiated by the PI. Additionally, the following criteria must be considered when making a request:

• The following conditions must be met for a grant to be eligible for a Change of PD/PI Request:
  • The grant is awarded, and the Project Period End Date has not passed.
  • The grant is not a Fellowship (F) or Career Development Award (K).
• The details for the request require some basic information:
  • Who is being replaced, removed or added to the grant?
  • What will their level of effort be?
  • What is the effective start date for the requested changes?
• Additionally, some files will need to be uploaded as an attachment to the request.
  • Biosketch for any new PD/PI
  • Other Support for any new PD/PI
  • Justification Document

Once an NCE request is submitted via the Prior Approval module, the system will combine all materials into a single PDF and will sent notification to the University Signing Official, the NIH Grants Management Specialist and the NIH Program official so that they may receive the request.

Internal Processes

All requests for No-cost Extensions and Change of PD/PI should be submitted to the Office of Sponsored Programs through the usual processes, including submission of all required material through the SAM Kiosk. Once all materials are submitted through SAM, OSP will work with the appropriate RAS contact to submit the Prior Approval request to NIH.