In this Open Comment: Section 16 - Sponsored Project Closeout
The Federal Office of Management & Budget has issued new Federal policy CFR Title 2 Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (also called OMB Uniform Guidance). The Office of Business and Financial Services (OBFS) must update University business and financial polices and procedures to be consistent with new federal standards. The following are proposed updates relating to the sponsored project closeout process.
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Read the policy, below...
Sponsored Project Closeout
Policy Statement
The University of Illinois has a responsibility to close out completed sponsored projects in compliance with federal regulations, sponsor policy, and award terms and conditions. Office of Management and Budget (OMB) Circular A-110 (2 CFR 215) and Uniform Guidance (2 CFR 200) require that final financial, performance, and other reports be submitted within 90 calendar days after the project end date. It is the University's policy that all required closeout deliverables be submitted to the sponsor within this stated timeframe. In the event that sponsor policy or specific award terms and conditions prescribe otherwise, such policy or terms and conditions shall prevail.
Reason for the Policy
This policy alerts the campus to the urgency of timely submission of final deliverables and the prompt closeout of expired sponsored projects. Non-compliance with sponsored project closeout requirements has adverse consequences for the University including, but not limited to, forfeiture of final payment, delayed or reduced future funding, less favorable award terms and conditions, and audit finding risks. The submission of final financial, performance, and other reports to the sponsor and the closeout of completed projects within 90 days of expiration, or a sponsor-specific deadline, help the University mitigate risks and negative consequences.
Applicability of the Policy
In order to maintain consistency in the treatment of sponsored projects, the policy on sponsored project closeout applies to all awards regardless of the funding source. Requirements and considerations for closing out fixed price agreements are subject to the Fixed Price Agreement policy.
Sponsored Project Closeout Procedures and Related Information
Close a Sponsored Project
Before you Begin
Sponsored project closeout is the shared responsibility of principal investigator (PI), unit business office or department administrator, and central offices. Collectively, they are responsible for the closeout of expired awards no later than 90 days after the project end date unless otherwise prescribed by sponsor policy or specific award terms and conditions.
As the administrator of your sponsored project, be mindful of the end date and terms and conditions, and accordingly take the necessary actions leading to a timely closeout.
Begin
To close a sponsored project, the Principal Investigator (PI) and the Unit Business Office are expected to take actions before and after project end date, as outlined in this procedure.
What to Do BEFORE Project End Date
Approximately 90 days before the expiration of a sponsored project, your campus post-award office, Grants & Contracts Office (GCO), sends you (unit business office) a monthly report of your projects that will end in 90 days. Between that time and expiration date, the Principal Investigator (PI) and Unit Business Office are expected to do the following:
- Inform GCO immediately if you have information about a continuation or extension of any expiring projects. This will stop the closeout process.
- Process extension requests as required per sponsor guidelines, or 90 days prior to project end date.
- Review accounting statements to date and ensure that all expenses charged to the award thus far are allowable, per the OMB Circular A-110 or Uniform Guidance and the terms of the award.
- Determine whether the project will end up with an unobligated (or unexpended) balance, and be aware of the award terms regarding treatment of such a balance: Can the unobligated balance be automatically carried forward? Or must it be returned to the sponsor? (Consult your campus GCO sponsored award contact, if you need assistance.)
- Review status of subrecipient invoicing to date as to accuracy and timeliness.
- Ensure that all project costs, except incidental costs related to the creation of the final report (for example, photocopying or binding) are incurred or obligated by the project end date.
- Promptly remove cost overruns (overdrafts) if no additional funding is expected from the sponsor.
- Notify your campus GCO of issues with the sponsoring agency that would prevent collection of any outstanding accounts receivable.
What To Do AFTER Project End Date
The closeout process starts with the project end date. Within the next 45 to 60 days, the Principal Investigator (PI) and Unit Business Office are expected to do the following:
- Remove all costs incurred outside the performance period, except allowable pre-award costs.
- Generally, “pre-award” costs are allocable to the time period of the forthcoming new or competing continuation award and may be incurred up to 90 days prior to the beginning date of the project or budget period in accordance with the sponsor’s guidelines. Also, pre-award costs must be adequately justified to indicate that advanced funding is necessary for the effective and economical conduct of the project, and must be allowable under the terms of the forthcoming award.
- Post-award or after-term charges that are deemed non-applicable or unallowable must be transferred off to an appropriate funding source.
- Remove cost overruns (overdrafts) within 45 days after the project has expired to allow for submission of the federal financial report no later than 90 days after the project end date. Overdrafts must be transferred to an unrestricted funding source.
- Remove costs resulting from sponsor disallowances, or other unallowable costs per the terms of the award--as advised by your campus GCO sponsored award contact.
- Review open obligations (encumbrances/purchase orders/payroll commitments), and ensure that they are liquidated, cancelled, or moved to other appropriate funding sources.
- Confirm that all subrecipients have completed their scope of work, including all required deliverables, and submitted their final billing according to the terms of their agreement.
- Ensure that all project costs have been recorded. Process final expenditures per the due date of a final bill or financial report to allow for timely submission of the bill or report, as indicated in the following table.
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If Sponsor Final Billing/Closeout Is Required
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Then, Final Submission of Expense Transactions in Banner Is Due
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30 days after project end date
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15 days after project end date
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60 days after project end date
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30 days after project end date
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90 days after project end date
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60 days after project end date
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*120 days after project end date
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75 days after project end date
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*Relates to the National Institutes of Health (NIH) and the National Science Foundation (NSF), which have opted for a deadline of 120 days for the submission of financial closeout documents.
- Validate final expenditure report prior to submission of final invoice or federal financial report.
- Confirm that the final technical report and/or deliverables have been delivered to the sponsor.
- Submit form listing invention disclosures, or indicate that there were none.
- Submit a final inventory of federally-funded equipment, if any.
- Submit, for federal projects, an accounting of unused expendable supplies (including expensed equipment) with an aggregate value of $5,000 or more, as applicable.
- Provide your campus GCO an accounting of program income or cost share commitments, as applicable, if these items are not tracked centrally on your campus.
Additional Resources
Campus Central Office Responsibilities
Sponsored project closeout is the shared responsibility of principal investigator (PI), unit business office or department administrator, and central offices. Collectively, they are responsible for the closeout of expired awards no later than 90 days after the project end date.
The University’s Pre-Award and Post-Award offices are an integral part of the closeout process. These central offices are responsible for the following:
- Sign and/or submit all documents and forms that require institutional certification.
- Inspect select cost items for allowability, and notify PI and/or unit business office of appropriate action to take.
- Confirm with PI and unit business that all expenses are final.
- Submit financial report to the sponsor, based on final expenditures.
- Submit final invoice to the sponsor, if applicable.
- Prepare final cash draw, if necessary.
- Dispose of unexpended cash balance--per award terms and conditions, and campus policy.
- Process final project budget and general ledger closing entries.
- Receive confirmation from PI and unit business office that all deliverables for which they are responsible have been met.
- Set termination dates in the financial systems to close award.
Closeout Documents and Responsibilities
Reports required at the end of a project vary by the type of sponsored project and by sponsoring agency. Most federal sponsors will require financial, invention, and programmatic reports. Federal contracts may also require a property report, contractor’s release form, and a contractor’s assignment of refunds, rebates, and credits form. Consult the award terms and conditions and sponsor policy for submission deliverables and deadlines. The following table lists the most common reports and the unit(s) responsible for their completion and submission.
Document Responsibility Table |
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Document/Report Name
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PI/Unit Business Office
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Central Office (Pre-Award)
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Central Office (Post-Award)
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Final Financial Report
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X
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Final Payment Request/ Invoice
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X
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Final Cost Sharing Certification
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X
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X
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Property Report
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X
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X
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Contractor’s Release, Refund, Rebates, and Credits
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X
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Final Technical/Progress/ Programmatic Report
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X
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X *
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X *
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Final Invention Statement
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X
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X *
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X *
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Final Patent Certification
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X
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X *
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X *
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* When institutional signature is required, please refer to your respective campus Central Office’s procedures relating to the submission of these documents.
Frequently Asked Questions
Q. Why are we submitting final reports and closing awards within 90 days?
A. The Uniform Guidance requires that all federal award reports be issued within 90 days from the project end date. For awards with letter of credit drawdowns, all cash draws must be made prior to the 90-day period and reconciled to the amounts reflected on the final financial report. Cash draws after the 90-day period will require the submission of adequate supporting documentation and, probably, agency approval in order for the funds to be received. Note that some sponsors, such as the NIH and NSF, have elected to extend their deadline to 120 days. Sponsor policy and award terms and conditions should be consulted for submission deadlines.
Q. We always continue to charge salary costs to the expired award until the renewal award is received. Will this be allowed under the Uniform Guidance?
A. No, this practice is never allowed. An anticipation account should be requested for the renewal award.
Q. As a service center, we usually allocate charges to sponsored awards on a quarterly basis. Is this procedure still acceptable?
A. Due to the closeout timeline, service centers are required to allocate cost on a monthly basis. Failure to allocate the charges in accordance with the guidance provided in this policy, will compromise our ability to collect from the sponsor and therefore may result in the charges being transferred against a state, institutional, or gift account due to late posting on the sponsored awards. As a Business Manager, be mindful of service center billing dates to ensure charges are posted by the end of the project and future charges are suspended in a timely manner.
Q. How can we as a PI and unit business office comply with the policy of closing awards within 90 days?
A. Monthly review and reconciliation throughout the life of the project facilitate the project closeout within the required timeframe. The PI is responsible for ensuring that all costs charged to a grant are reasonable and allowable with the assistance of the unit business office. The PI should request timely corrections for any cost deemed unallowable for any reason, including posting errors.
Q. An error was discovered after the final financial reports have been submitted to the sponsor, and the award terminated in Banner (the University’s financial systems). Can we or should we correct this error?
A. If the sponsor was overcharged due to the error, then the account will be reopened, the credit processed, and a refund issued to the sponsor. If the sponsor was under-charged (i.e., a late subcontractor invoice was received), then sponsor-specific guidelines will be applied. That is, only if the sponsor allows for the correction and is willing to pay for the costs, will GCO reopen the project for the business unit to post the costs.
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