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1.1: Award Closeout - General

Purpose

The purpose of the guidance is to ensure timely and accurate award closeout of sponsored projects in keeping with the sponsor and the university's guidelines. For federal awards, unless the sponsor authorizes an extension, the university must liquidate all obligations incurred under the award no later than120 calendar days after the end date of the period of performance as specified in the Uniform Guidance 200.343 - Closeout

Guideline

Post-Closeout Adjustments

An award closeout does not affect the sponsor's right to disallow cost and recover funds based on a later audit. After closeout, the university may continue its internal review and clearing of project cost centers to remove overages and unallowable costs not invoiced and refund overpayments. (Uniform Guidance 200.344 - Post-Closeout Adjustments). )

Pre-award-Closeout

90, 60, and 30 days before the expiration of an award, the Principal Investigator and business manager will receive notices which will allow them to begin the closeout process. Only expenses recorded in General Ledger can be included in the Final Financial Report to the sponsor. When a no-cost extension is needed, the Principal Investigator must work with the research administrator and sponsor to extend the award end date.

Purchases Near or After Award Expiration

The purchase of equipment and computing devices in the last six months of an award or restocking materials and supplies three months before the award expiration with little or no time left for the item to be used for the research conduct is discouraged. These costs will be removed by OCG during closeout if there is no written prior approval from the sponsor for equipment and computers or a justification on the voucher for materials and supplies that addresses the exact nature of the supply and its need for the project completion.

Definitions

  1. Budget Period – The budget period is a specific interval of time for which sponsoring agency funds are provided to fund approved activities, usually a fiscal year.
  2. Period of Performance – Typically, this is indicated by the start & end date of an award and includes all budget periods. It is the time during which the university is expected to complete award activities, incur costs, and expend approved funds. For federal awards, the Uniform Guidance clarifies that although the period of performance may include one or more budget periods, it does not commit funding beyond the currently approved budget period.
  3. Period of Availability – The period of performance  plus  a period before the award start date (usually 90 days) if Pre-Award spending is allowed, and a period after the award end date (usually 120 days) per the sponsor or award specific guidelines.
  4. Grant/Award Expiration Date – The last day of the period of performance, also referred to as the Award End Date.  Expenses incurred after this date are unallowable. In the finance system, invoice dates must be within the period of performance and before the grant expiration date.
  5. Accounting End Date – The last date transactions can post to the general ledger of an award cost center. This date may be extended as needed for clean-up activities leading to cost center in-activation.
  6. Budget Balance Available (BBA)  – The current award budget, less all expenses and encumbrances posted to the general ledger.
  7. Cash Balance (CB) – The total amount paid by the sponsor, less all expenses. It is the "claim on cash" amount on the balance sheet of the cost-center general-ledger report.

Procedures

The Department Business Administrators and Principal Investigator completes the following:

  • Review the project cost center/s verification report to ensure that all posted transactions are related to the award and are accurate, authorized, acceptable, and within the period of performance.
  • Address any overspending by initiating the reallocation journal to correct it. The department will be able to post correcting transactions up to the accounting end date. Discuss any discrepancy in the IDC with OCG. Only OCG is authorized to post IDC adjustments to the grant.
  • Confirm all required payroll posted correctly and that travel and/or tuition expenses on the award ties back to individuals on the payroll. Travel and tuition paid to employees or students not funded on the award require an additional explanation in the uploaded supporting documentation.
      For example, voucher transactions for student tuition paid in lieu of salary for work on the project must include the tuition remission form that contains the effort attestation and the grant number signed by both the student and the PI.
  • Verify cost-sharing expenditures, if required, are properly recorded in the general ledger. If it is payroll, it should be certified in effort reports. Cost Sharing reports should be prepared and submitted to OCG before the end of the closeout period.
  • Work with the office of contracts and grant to deactivate the project cost center by ensuring all projects have a zero-budget balance available and a zero cash balance.

The Office of Contracts and Grants does the following:

  • Send a final notification at the end of the award to the PI and DBA. The notice provides the award budget, expenses, and balance and advises that they review the detailed transaction on the PI portal online award summary.
  • Complete a final financial overview and reconciliation of the award and work with the department staff and PI to resolve any issues, including asking for additional documentation and explanation for questionable costs.
  • Remove any unallowable cost to the department IDC cost center associated with the award and make final adjustments to IDC to correct the allocation if necessary.
  • Submit all final financial reports, invoices, and other non-technical reports to the sponsor. If there are delays, OCG will notify the sponsor and request approval for a late submission.
  • After closing the award with the sponsor, OCG will continue to work with the department and PI to deactivate the project cost center in the financial system. In the cases where projects cannot be inactivated due to sponsor non-payment, it will be handled in the following manner:
    • If non-payment is due to a sponsor breach of contract, the matter will be investigated, and after two years, if it is not resolved, OCG will submit the account for a write-off.
    • If non-payment is due to PI's non-performance or lack of project delivery, the matter will be investigated and could result in the PI's department covering the overage.

Revised: December 14, 2020