(updated OGC 10/10)
SPONSORED PROJECTS CLOSEOUT PROCEDURES
Best Practices and Requirements for the Departmental Administrator and PI
Even for multi-year projects, each award should be managed for potential closeout
procedures on an annual basis; as of the anniversary date of the budget. Sponsors may
terminate awards early or not issue continuations or other problems may arise that will
limit the University’s ability to recoup expenditures if the health of the account is not
monitored on at least an annual basis. Closeout review begins upon receipt of the award.
Upon Receipt of Award
Review and note terms and conditions for:
Allowable Costs
Reporting Requirements
Cost Share Requirements
Effort Requirements
Program Income Requirements
Rebudgeting Restrictions
Prior Approval Requirements
Carryover Restrictions or continuation/renewal processes
Unusual Inventory or other Tracking Requirements
The PI and the Departmental Administrator (and others as appropriate) should meet at the
beginning of each award to review and discuss projected expenditures, the individuals to
be paid and the timing, approvals and other requirements needed to process payroll
(PCF/EPAF) and any other administrative aspects of the award. (OGC is available to
answer questions or to participate in the award meeting, as needed.)
Throughout the life of the award, monitor the project to assure that all compliance
requirements are being met.
Six months to five months before the budget end date Review actual expenditures, budget balance and projected expenditures with the PI. Is
the award under/over expended?
Projections and actions should be taken to plan for the budget balance to be -0- or with a
small deficit as of the budget end date. It is better to have a small deficit rather then a
balance at the budget end date. There is a higher audit profile and potential penalty for
charges being put on an award after the end date. You may not be able to transfer costs
onto the award after the end date but you will always be allowed to move charges off of
the award.
Check effort status. Are the PI and other key personnel meeting the proposed effort
requirements? Are adjustments in EPAFs needed? Are all individuals working on the
project (compensated or cost share) effort certifying? If the PI or Key Personnel are not
meeting their effort requirements, contact OGC to discuss options/requirements for
correction or sponsor approval.
If the project requires cost share/match, check the documentation to date for cost share.
Review projected expenditures and take the same appropriate actions, as you would for
the grant expenditures, to assure that all necessary match requirements can be
documented by the budget end date.
If it is anticipated that the project will not be able to meet the cost share/match
requirements, contact OGC as soon as possible. It may be necessary to contact the
sponsor for approval to reduce the match requirements and/or you may not be able to
expend all of the sponsor’s funding without the full match commitment.
Make sure that any necessary equipment purchases are processed, as soon as possible.
Restrictions may apply that will prevent you from making last minute equipment
purchases. All equipment needs should be processed a minimum of 90 days before the
end date. Except for emergency replacements, equipment purchases will not normally be
allowed in the last 60 days of the award period. In order to be charged to the award, all
equipment must be received and in use and of benefit to the project prior to the end date.
Large supply orders will not normally be allowed in the last 60 days of the award period
and/or without additional justification. Supplies should not be stockpiled for future use
and should only be purchased based on receipt and use within the award period.
Review rebudgeting needs. Are projected expenditures in line with the awarded budget?
Does the sponsor require prior approval for rebudgeting? Contact OGC if rebudgeting
approval may be needed.
Check for unallowable costs. Remove any unallowable costs immediately.
Remind the PI of due dates for progress reports, data sets, or other reporting requirements
that may need to be met before or immediately after the budget end date.
If there are subawards or consultants, check with the PI that satisfactory scientific
progress is being made and that the sub/consultant is meeting all reporting requirements.
If there are any problems/issues with performance discuss with OGC for possible
additional action.
If the subs/consultants have not submitted bills or if billing is lagging, contact the
sub/consultant and request invoices to be submitted. If needed, contact OGC for
assistance.
For fixed fee awards (e.g., clinical trials) verify that revenue received is in line with data
submitted and the payment terms of the award.
For multi-year projects, check to see if carryover is automatic or will need sponsor
approval. If sponsor approval is needed, the fund number will change each year.
If applicable, check the status of program income. Depending upon whether program
income is treated under additional, deductive or hybrid requirements your program
income could affect what expenditures you can make against the award account.
If the project includes program income, check the documentation to date for program
income. Review projected expenditures and take the same appropriate actions, as you
would for the grant expenditures, to assure that all necessary program income
requirements can be documented by the budget end date.
90-60 Days before the end date –
Review actual expenditures, budget balances and projected expenditures with the PI.
Check for “final” projections – effort, equipment needs, cost transfer, purchases, travel,
etc. so that all necessary transactions can be processed prior to the end date.
Double-check for under/over-expenditure projections and take appropriate actions to
assure that the final month’s ledger is as close to -0- budget balance as possible.
Follow-up on any expenditures that may have been incurred but have not
processed/posted in the accounting system. Look for “late” items – especially travel,
reimbursements to individuals, invoices/payments to subcontractors/consultants and
service center billings.
Contact subs/consultants and remind them to get invoicing up-to-date and remind them of
the due date for the final invoice to be received. ECU may not be able to pay their
invoice if it is received late. Contact OGC for assistance with subs/consultant invoicing
reminders.
All necessary cost transfers must be processed within 90-days of the cost incurred and
should be posted prior to the end date of the grant. Carefully review your award
expenditures and make sure that any charges that need to be removed or need to be added
to the grant fund are processed before the end date.
Change all HR paperwork, standing orders, service center accounts or ProCard defaults,
as needed. Make sure that PCF/EPAFs, etc. are changed, ahead of time, to assure that
payroll charges do not continue to hit the grant fund after the end date.
Check for unallowable costs. Remove any unallowable costs immediately. The final
month’s ledger should not have any unallowable costs.
Contact OGC/OSP if a rebudgeting request needs to be processed. All sponsor required
approvals should be processed and approved before the end date.
Contact OSP/OGC if a no-cost-extension will be needed. All requests for an extension
should be processed and approved before the end date. All requests for an extension
should be submitted to OSP at least 60 days before the end date. Some sponsors will not
approve extensions if the request is received late in the award period or after the budget
end date.
Remind the PI of due dates for progress reports, data sets or other reporting requirements.
If there are subawards or consultants, check with the PI that satisfactory progress is being
made and that the sub/consultant is meeting all reporting requirements. If there are any
problems/issues discuss with OGC for possible additional action concerning
performance.
For fixed fee awards (e.g., clinical trials) verify that revenue received is in line with data
submitted and the payment terms of the award. Follow up with the sponsor, as needed.
If there are cost-share/match or program income requirements, be sure you are checking
all transactions and projections as you would with the grant fund. Cost-share and
program income documentation requirements are the same as for the grant fund.
If carryover is not automatic or if the next budget year will be a competing renewal or if
the sponsor normally issues separate awards for annual appropriations, a new fund
number will need to be established in the accounting system for the next budget cycle.
Submit a Financial Guarantee Form, as early as possible, to set up the new fund and
avoid unnecessary cost transfers. Advance accounts can be set up as early as 120 days
before the budget end date.
If this is a collaborative project, across departmental/college lines…be sure to contact and
coordinate with all collaborating departments to assure that all necessary actions are
being taken to -0- out expenditures and comply with all financial and other reporting
deadlines.
Review equipment title restrictions. If title does not vest with ECU, equipment may need
to be transferred to the sponsor or authorization may need to be requested to retain the
use of or title to the equipment. Contact OGC for processing requests to the sponsor.
Check with OSP, ahead of time, concerning RAMSeS procedures, so that there will be no
delays for no-cost-extensions, rebudgeting requests, carryover requests, financial
guarantees for successor funds, etc.
Budget Month-End Ledger -
Finalize review for all expenditures, unallowable costs, additional costs, cost-share, etc.
Because effort reporting may not be in sync with the budget end date, it is important to
specifically review effort reporting plans/commitments with the PI and all individuals
paid on the award. If effort to be reported is different than the actual payroll to date a
Banner HR redistribution should be immediately forwarded so that the accounting will
reconcile with the effort reporting.
Do not wait for the effort certification process to make adjustments on payroll for closing
awards. Due to sponsor and accounting reporting and processing deadlines you may not
be able to make the adjustments after the end date or as part of ERS. All necessary
adjustments must be accrued for the financial report; as well as processed/documented
through the effort system. Make sure that OGC is aware of any pending transactions for
effort reconciliation so that costs may be included in the financial report.
For nine-month employee buyouts, remember that all buyouts must be processed before
the University’s fiscal year end (6/30). When the award date is close to the academic
year/summer period make sure that your grant reconciliation spreadsheet takes into
account that some of the academic buyout pay may not post to the grant fund until the
June/July payroll. You will need to accrue any necessary amounts for the academic
period payments that post during the summer months.
Note: Some sponsors may have early reporting deadlines (e.g., 15 days after budget end
date). For such projects, all activities should be accelerated and appropriate action taken
before the month-end ledger so that the report can be submitted on time.
Meeting the sponsor reporting deadline is extremely important. OGC will submit
reports/invoices based on information “in hand” for the reporting deadline.
Reports/invoices cannot be revised due to late receipt of information from the
department.
For fixed fee awards (e.g., clinical trials) verify that revenue received is in line with data
submitted or services performed and the payment terms of the award. Send follow-up
requests as needed.
If a no-cost-extension is needed but has not yet been requested, be sure that the request is
submitted to OSP before the budget end date. Some extension requests cannot be
approved if submitted after the end date.
30-days After Budget-End All final transactions and reconciliations for costs charged to the award should be
processed in the accounting system or be “in hand” at OGC within 30-days of the budget
end date (if not earlier due to sponsor requirements). OGC must have all of the final
transaction detail in order to complete the reconciliation process and report to the sponsor
and the auditors.
All unallowable and deficit expenditures must be transferred off of the award.
All final transactions and reconciliations for cost share and program income reporting
should be processed in the accounting system or be “in hand” at OGC within 30-days of
the budget end date (if not earlier due to sponsor requirements). OGC must have all of
the final transaction detail in order to complete the reconciliation process and appropriate
report cost share and program income to the sponsor and the auditors.
Make sure that all unliquidated encumbrances are cleared or transferred to another fund.
For non-titled equipment, the sponsor must be contacted to request title, transfer or
disposition instructions. Contact OGC for processing requests to the sponsor.
60-90-days after Budget-End All financial transactions should have cleared the system and the fund should have a -0balance and be ready for closeout in the accounting system. The expenditures posted
should reconcile to the financial report/invoice submitted.
All overruns should be cleared. OGC may implement deficit clearing procedures if the
fund is not at -0-.
All under-expenditures (from report/invoice) should be cleared. OGC may need to revise
the financial report/invoice and return funds to the sponsor if the fund does not reconcile
to the report/invoice and/or the fund is not at -0-.
Fixed fee awards should have all revenue payments reconciled/processed against activity.
If additional revenue is anticipated, but has not been received, contact OGC for a possible
internal extension for closeout processing.
For fixed fee awards, residual funds should be transferred to an appropriate nonsponsored fund after the account reconciliation. Residuals should be processed within
60-90-days after the budget end date.
All funds should be closed in the accounting system within 90-120 days of budget end
date (earlier is better). This is a UNC FIT requirement and we are subject to audit
findings if funds are not cleared/closed in a timely manner.
If the project is on-going but carryover is not automatic, a request to carryover funds
should be processed immediately after or simultaneously with submission of the financial
report/invoice. The sponsor may not authorize late requests for carryover. Carryover
requests, including a budget as to how the funds will be expended, should be routed to
OGC/OSP for review/signature prior to submitting to the sponsor.
Other Items –
As needed, follow-up on the following reports. When required by the sponsor these must
be submitted on a timely basis or there may be disallowed costs, audit findings,
termination of the agreement, or delays in receiving future awards.
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Final inventory report and/or request to dispose of equipment or retain title (if
not automatic) - (submit necessary info to OGC; report prepared and signed
by OGC before submitting to sponsor).
Final progress report from subawardee or consultant to our PI.
Final progress report to sponsor from our PI.
Final Patent/Royalty reports (submit info to OSP/OTT; form signed by OTT
and OSP before submitting to sponsor).
Final Reassignment, refunds, rebates forms (prepared and signed by OGC
before submitting to sponsor).
Other reports or documents that may be required by sponsor.