Closeout of Federally Sponsored Assistance Awards

APRIL 20, 2018

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I. Purpose of Policy

As a recipient of federal funding, the University must comply with the 2 CFR, section 200, OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D §200.343, Closeout.

In accepting a grant or contract from a governmental agency, the University is obliged to comply with a number of rules and regulations promulgated by the government. The purpose of this policy is to provide guidance for award closeout and timely submission of reports to federal sponsors.

II. Scope of this Policy

This Policy is applicable to all Principal Investigators and other University personnel involved in administering federally-sponsored awards. Closeout of awards not covered by this policy are subject to the terms and conditions of the relevant award.

III. Statement of Policy

Brandeis University policy for closeout of federally-sponsored awards is to comply with the Office of Management and Budget Uniform (OMB) Uniform Guidance requirements for award closeout described in 2 CFR 200.343.

Federal regulations require that final reports (e.g., FFRs, Progress/ Technical reports) be submitted within 90 calendar days following the expiration of either the budget year of the project (as is the case for Program Project and similar awards), or more commonly, following the expiration of a competitive segment of a Sponsored Project. For certain agencies e.g., NIH, NSF and Dept. of Energy closeout requirement is 120 days. For other sponsors, reporting deadlines vary and are dictated by the policies of those sponsors or stated terms and conditions of the award.

IV. Procedures

Federal award closeout requirements are generally the same for all federal agencies; however, closeout procedures vary by award and terms of each award should be considered during the closeout. The timing of the closeout process is a critical step to ensure all grant obligations have been met and to prevent any further expenditure’s from occurring on the grant.

An award is considered closed once there is acceptance by the sponsor of closeout documents, validation of cash collected and the inactivation of the award in Brandeis’s Financial System.

The closeout process has 3 phases:

Phase 1:

Review payroll distributions to ensure the payroll will cease to post once the project end date has been reached.Submit any pending cost transfer requests.Reconcile any open travel advances.Review any subcontracts and subrecipient agreements to confirm all necessary closeout documents have been received and invoices have been submitted and paid.

Determine if a no-cost extension is required. Submit request to ORA (requests may be submitted up to the project termination date, depending on agency). ORA processes no-cost extension as needed. Review Terms and Conditions of Award to make sure all requirements are met.
Determine if a carryover justification is required to move the unexpended balance to a new account or if a new account is required.
Review the budget and F&A / Indirect cost charged to ensure both are in line with the award agreement terms and conditions. Initiate a cost transfer if necessary.
Coordinate with the appropriate individuals to complete any inventory, progress, invention, patent, and financial reports. Submit inventory, progress/ technical, invention, patent reports, as required.
Review all open encumbrances.
Ensure all expenses charged are allowable. Remove any unallowable costs.

Phase 2:

Validate the F&A/Indirect cost charged to the project.
Create and process any adjusting journal entries.
Submit any necessary budget revisions.
The SPA Accountant will create and submit the FFR to the awarding agency.
The SPA Accountant will also adjust the budget to match actuals reported.
Confirm all sponsor requirements have been met.

Phase 3:

Confirm all journal entries have been posted.
Overruns will be cleared to a department account which the DA will provide SPA with the account to transfer the overrun. Transfer direct cost expenditure overruns to a non-sponsored project supplied by the Department Chair, Dean or Center Director.
Transfer any unallowable costs (not already removed by the DA in Phase 1 to a non-sponsored project supplied by the department

Review any remaining open encumbrances and work with department to liquidate and/or close those encumbrances.

Address any unresolved travel advances with department.

Reconfirm the F&A/Indirect cost charged to the project.
Confirm all payments from sponsor have been received.
Review the awards terms of agreements if there is an overrun or unspent funds to determine if they should be refunded to the sponsor or retained by the University.
If actual expenditures are less than what was reported on the Final FFR due to a credit, the budget will be reduced to match actuals and a revised FFR will be submitted.
The SPA Accountant will manually change the project status in PeopleSoft to close.

Regulatory Sources