We Are All in This Together: Close Out Issues Researchers, Administration Teams and Sponsored Projects Staff Arriving Together at the End of a Sponsored Project The Destination is the Reason for the Voyage Prepare • “Begin with the end in mind” ”®©Franklin-Covey • Plan your sail, and sail your plan. Team • • • • Primary Investigator Research Administrators Sponsored Projects Office Grant and Contract Accounting Objectives • Understanding no matter what our responsibilities are during the life of a project, they can ultimately effect the closeout 5 Closeout Starts With Proposal Submission • • • • The Investigator and/or Team Your institution’s guidelines The sponsor’s regulations & references Award Requirements Review Items Complex Projects • • • • • Incrementally funded, multi-year Contains Subcontracts Excessive Cost Share Multi-disciplinary, Complex financial reporting (e.g., by task) CAS Exceptions Requested • CAS exceptions must be: – allowable, allocable, reasonable, identifiable with a sponsored work and approved by the sponsor, • Typical CAS exceptions are – e.g., Office supplies, clerical salaries, postage, local phone calls Subcontract A contract that assigns some of the obligations of an existing contract to another party. When the Award Arrives • Congratulate the researcher! • Setup Team Meeting to: – Verify the budget – Verify the cost-share – Schedule reports – Setup Internal Financial Tracking System – Other items as needed Final Closeout Checklist Start with This in Mind • Final Deliverables • Money Out = Money In • Documentation During the Life of the Project • Share your info • Prompt for reports • Prompt for documentation During the Life of the Project • Keep on top of it • Cost Share – On schedule? On target? Documented • Reinforcements Post Award Issues That Effect Closeouts • Anything not routine • Complex Projects • Unspent funds (FP) • Excessive Spending Review For Project Changes • A significant delay in project • Conflict of interest that cannot be resolved • Change in scope of work • Addition of a sub contract. Review for NonCompliance • Review for Non-compliance with Award Restrictions –Budget restrictions / limitations –re-budgeting between categories –prior approvals for equipment • Unallowable Costs • Other Review Items That Need Special Monitoring Special Monitoring Purchasing cards Cost Share Cash Advances Cost Transfers Encumbrances Subcontractors Hourly-paid Staff and/or Students Purchasing Cards All Purchasing Card costs on sponsored accounts MUST be directly related to the project and documented Cost Share Documentation • Audit Purposes • Mandatory reporting to sponsor • Voluntary Committed verified & Documented • Consequences of Under-reported Cost Share Cash Advance • Use sparingly • Not a “petty cash” fund • Costs must be directly related to the project • Mostly for field work Cost Transfers OMB Circular A-21 prohibition makes cost shifting audit sensitive • Post Term Charges –Largely unallowable (Final report costs only exception) Unallowable Costs –Costs that do not meet the criteria for A 21 Allocable costs. Open Encumbrances All encumbrances should be reviewed at least 30 days before the end of an award. Review Subcontracts • Activate Subcontract • All payments/financial reports being submitted in a timely manner • All deliverables, progress reports being submitted 23 Date Of Completion • “Date of completion means the date on which all work…is completed or the date… on which Federal or Non Federal sponsorship ends.” Project Termination & Closeout CAUTION CLOSEOUTS AHEAD At the End of the Project • Should be no surprises • Use your checklist • Project deliverables are the responsibility of the Investigator Final Closeout Review Purchasing Card Expenditures Documented Cost Share Documentation Completed Subcontracts Closed Refund to Sponsor Cleared Final Closeout Review Residual Transfers Completed (FP) Cash Advances Encumbrances All Cleared Cleared Cost Transfers Completed Other Final Closeout Review Final Deliverables Submitted Patents, Technical, Equipment, Inventory Final Financials, Others as required Revenue = Expenditures Records Retention & Access System • Retention required for three years after last action • Other standards may apply • Government requires timely and unrestricted access 30 At the End of the Project Requirements after the close of the project Hanauma Bay, Hawaii Fair Sailing!