Departmental Research Administrators Training Track Award Closeout Process 1 Closeout Guidance and Procedures Module 1 – General Information and Requirements Module 2 – OSP/OCGA Procedures Module 3 – Closeout Forms Module 4 – Closeout Checklists Questions to Answer… 1. Who is responsible for closing out grants and contracts at UMBC? 2. Where do I find required final report forms? 3. When are final reports due? 4. Who can I ask to help me close a grant? 5. Does every agency require the same thing? Module 1 – General Closeout Information Closeouts and Compliance Project Transfer If a project is transferred to another institution or terminated early for the convenience of the Sponsor, closeout procedures remain the same or are specified by the Sponsor and should be processed by OSP. Project Termination Accurate and timely submission of closeout documents is an essential compliance focus for the federal government. Processing closeouts on time is becoming more important with American Recovery and Reinvestment Act (ARRA) funds. Documentation required to terminate a project early should be handled by OSP. OSP and OCGA websites A helpful resource for closeout information and forms http://www.umbc.edu/research/OSP/policies%20and%20procedures/policies_procedures.html http://www.umbc.edu/FinancialServices/grantacct.html 4 Module 1 – General Closeout Information Most sponsors require final reports to be submitted within 90 days of termination of the project. Meeting the 90 day deadline is very important when the award document clearly states that final invoices/billings received after the 90 day deadline will not be acceptable and will not be paid. Not every Sponsor requires the same reports, and Sponsors do not use uniform forms. OSP will find out what forms are required and are responsible to submit the right form for each specific agency. Most Sponsors require a final technical report, final property report, final patent report and final financial report. These deadlines can only be met when OSP, the PI, OCGA, and Department Administrators work together. Module 2 – Closeout Procedures 1. 2. 3. 4. 5. OSP will receive notice from the Sponsor stating that it is time to close an award OSP will send via email a project closeout notification to the PI and Department administrator. The email will state the project end date and date required for closeout. The email will also state which final reports are needed. OSP will send a reminder email if final documents are not received 30 days before Sponsor deadline. The PI is responsible for preparing the final technical report, and responding to OSP’s email concerning any property or patents associated with the grant or contract. The Department Administrator is responsible for preparing the final certification of expenses and sending a copy to the Office of Contract and Grant Accounting. Module 2 – Closeout Procedures (Cont’d) • • • • • When OSP receives the appropriate closeout documents from the PI and Department, OSP will process the final technical report, final patent report, and final property report. OSP will also keep on record the final certification of expenses. OSP waits to receive confirmation from the Sponsor’s closeout official that documents are complete before officially closing the grant. OSP keeps terminated files for at least three years or amount required by Sponsor. Office of Contract and Grant Accounting provides the Department closeout checklists and final expense certification form to be completed. Office of Contract and Grant Accounting is responsible for completing all final financial reports and submitting to the Sponsoring Agency. Module 2 – Closeout Procedures (Cont’d) • • Since sub-awards often require the same reports, these procedures usually pertain to sub-awards as well. Inactivation of award components in Peoplesoft occurs once all necessary adjustments are made, final invoices are processed and payments are received. OCGA performs the following: • HR Account Codes are removed • Project Activity is set to “Inactive” status • Project is set to “Inactive” status • Contract is set to “Closed” status • Award is set to “Closed” status Module 2 – Closeout Procedures The letter to the left is a common format for federal agencies. Letters like this inform OSP that a grant needs to be closed and what reports are needed. Occasionally these letters are sent to the PI; if that happens that PI should forward to OSP. Module 2 – OSP Closeout Procedures The PI and Business Manager will receive this letter after an award’s project end date. The PI is responsible for filling out the letter ASAP and returning to the OSP member that sent it. If property or patents are associated with the project, OSP will work with OTD and Asset Management, along with the PI and Business Manager to file reports. Module 3 – Closeout Forms After the PI returns the closeout letter, OSP will know if patents/inventions were associated with the project. OSP is responsible for filling out the invention report. OTD is also responsible to assist OSP if inventions are associated with the grant. The report template to the left is the most common final invention report but there are others as well. This form can also be used to report inventions on a subaward. Module 3 – Closeout Forms Final Property Report Unless the Sponsor has a specific final property report template, OSP uses the form to the left. It is the PI’s responsibility to answer the closeout letter correctly to inform OSP if Government furnished property is under the grant or if grantee-acquired items are under the grant. “Equipment means tangible nonexpendable personal property including exempt property charged directly to the award having a useful life of more than one year and an acquisition cost of $5000 or more per unit.” (A-110) Government furnished property is any property that the government loans to the grantee for the life of the grant, or property that the grantee purchases with government money, where the title does not automatically vest with the grantee. The Grantee will have to request ownership at the end of the grant. If property was purchased with a grant, Asset Management may assist OSP with reporting. Module 3 – Closeout Forms Retaining Property at Closeout Time • • • Under Expanded Authorities, property purchased on a grant usually remains with the University after the grant is completed. However, if the property belongs to the government, like with some government contracting companies, UMBC will need to write a disposition letter requesting title of the property to vest at the University. The item, cost of the item, and purchase date are needed for a letter of disposition. Module 3 – Closeout Forms Reporting Property for a Sub-award If UMBC is a sub-awardee, the university is still held responsible for submitting final reports to the prime sponsor. The form to the left is the form that UMBC uses to report property used on the sub-award. Timely submission of this form to the prime sponsor is essential for compliance. Likewise, UMBC needs final reports from sub-awards given to maintain compliance. Module 3 – Closeout Forms Final Financial Report The Business Manager/PI are responsible for preparing the final certification of expenses and submitting promptly to OCGA. OCGA has a schedule and or receives notices from the Sponsor indicating when the final Financial Status Report (FSR) is due. OCGA must submit the Final FSR within 90 days of the end date of the award for all Federal awards. Non federal awards may have different deadlines. OCGA attaches final FSR . in the Projects/ Attachments tab in Peoplesoft. OSP requests a copy of the final FSR for filing purposes. Module 3 – Closeout Forms Final Technical/Progress Report It is the PI’s responsibility to prepare the final technical report promptly after a project’s end date. There is not a uniform template for all final technical reports. Some agencies have template forms and some do not. It is the PI’s responsibility to draft the final technical report according to agency regulations. Some PI’s find that calling their program person for advice is helpful, and other times the Sponsor will be specific in what should be covered in the final technical report in the grant notice. It is the PI’s responsibility to send OSP a copy of the final technical report to send out. If the PI submits their technical report electronically, like with NIH, OSP still needs a copy for filing purposes. Module 3 – Closeout Forms The letter to the left is one we received from NIST stating that a grant was officially closed. All agencies are a little different, but it is common to get a letter similar to this once a Sponsor has received all final reports. If OSP receives a letter like the one given and some final reports are not on record, then the letter is sufficient enough to close the grant. Module 4 – Closeout Checklists SPONSORED ACTIVITY CHECKLIST Review, verify and reconcile the award amount, actual expenditures, F & A and encumbrances from the ledger to your internal records. Lists of selected items of cost contained in OMB Principles Circulars can be viewed at http://www.whitehouse.gov/omb/fedreg/ Order all supplies and equipment and submit PO’s 90 days before the end of the project/grant. Reconcile P-card clearing account and allocation is complete. Verify that personnel and time and efforts being charged to the grant are according to the budget and the rules and regulations of the awarding agency. Send closing letter to subrecipients on the project/grant informing them of their remaining balance, the time frame that they have to close their subcontract and submit the final invoice to us within 45 days after the close of the grant. Submit all information concerning extensions, continuations or carry forwards to the OCGA. JE entries must be completed and submitted before the end of the grant and a copy sent to all those concerned. Communicate with your project/grant accountant concerning any issues or concerns that you may have in relation to the grant closing. Communicate any changes to the project/grant that may have an effect on the closing (e.g. change in end date) Submit Cost Sharing data to the Office of Contract and Grant Accounting. Module 4 – Closeout Checklists Grant Closing Checklist for Department Verify correct calculation of F&A Verify completion of all Purchase Orders/Requisitions Verify receipt and payments of final invoice for all subcontracts Verify completion or de-obligation of all commitments/encumbrances Verify posting of all P-card allocation. Verify the posting and accuracy of all expenditures, include all JE’s Verify the posting of all payroll transactions, including Retro’s Verify that there are no DBE’s or Positions associated with the project Verify and submit certification and expenses to OCGA Verify certification of all Effort Reports Verify the fulfillment of cost sharing commitment Verify submittal of all final reporting according to the grant terms (i.e. final invention statement, final property report, final financial report, and final progress report) Module 4 – Closeout Checklists The checklists have been developed to help us facilitate a closeout that is timely, accurate and according to the rules and regulations of the awarding agency, OMB A21, and OMB A-110. Departments should review projects for inactivation within 60 days after the end date. This is necessary so that the final financial report is accurate and submitted to the agency according to the regulations. Departments will be responsible for expenditures that cannot be legitimately charged to the project/grant. Please keep in mind that government regulations strictly prohibit the indiscriminate spending of funds merely to fully utilize award dollars. Furthermore, OMB Circular A21 states, “any cost allocable to a particular research agreement… may not be shifted to other research agreements in order to meet deficiencies caused by overruns or other fund considerations…”(C.4.b). However, if a legitimate explanation exists as to why the funds could not be expended before the expiration date, please contact Sponsored Programs immediately to discuss a no-cost extension. Questions????