Award Management and Closeout
The policy provides requirements that are intended to facilitate the timely and accurate processing and recording financial transactions and the management and closeout of sponsored projects.
2 CFR §215, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
2 CFR §200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
2 CFR §200.343, Effects of suspension and termination
Who is Governed by this Policy
While the university is responsible for the stewardship of an award, the Principal Investigator (PI) is accountable to the sponsor, the university, the school, and the department in which the project is conducted. In addition to bearing the responsibility for conducting the project in a manner that is consistent with professional standards and in compliance with any federal, state, and local government laws and regulations, PIs also must be aware of and observe all of the terms and conditions of the award and university policies throughout the life cycle of the project.
The award closeout process is the culmination of the sponsored project life cycle and ultimately results in the completion of required deliverables/reports, the final billing, the collection of the outstanding accounts receivable, the submission of the final financial report, and the disposition of residual funds. The university has established a timeline that allows for a timely progression through the sponsored project life cycle. Final financial reports and/or invoices are submitted by Grants & Contracts Accounting Services (GCAS) by the specified due date by the awarding agency to protect against the university not meeting deadlines. GCAS has sole signature delegation for preparing and submission of financial reports and invoices on sponsored projects.
Closeout Process Timeline and Responsibilities
The closeout timeline begins 90 days prior to the award end date and culminates with the submission and/or acceptance of the final financial and technical reports. The university has assigned responsibility for management of the financial aspects of sponsored projects to the PI, the department chair, the dean or the dean’s official designee, the department administrators/school support staff, the Pod, and GCAS.
The PI is responsible for indicating that expenditures are accurate and are allowable, allocable, and reasonable in a timely fashion prior to the close of the award. In addition, PI supervises the technical performance of the project, oversees compliance with award terms, university policies and the Sponsored Projects Handbook, manages the project expenditures by reviewing reports monthly, and completes the deliverables. The PI is responsible for properly treating confidential materials, completing all technical/progress reports, final patent report and royalty reports, if any, completing the plant and property clearance report, and confirming instructions for disposal of all property in accordance with the terms and conditions of the award.
The relevant department chair and dean are responsible for overseeing PIs under their purview, but ultimate responsibility for management of the award remains with the individual PI.
The PI and/or department/school are responsible for any adverse financial consequences (i.e., unallowable costs, overages, sponsor default on payment, etc.). Expenditures charged to a department account during the financial closing process are not eligible for cost transfers.
Determination and use of Residual Funds
Some sponsored projects are negotiated on a fixed-price or fixed-amount basis, meaning that the university guarantees to deliver a product or perform a service within a specified period of time and at a fixed priced or fixed amount agreed in advance, regardless of actual costs incurred. Proposals created for fixed priced/amount awards are expected to estimate costs close to the actual costs. For federal awards, the cost principles should be used as a guide in creating the budget.
It is the responsibility of the PI to take all necessary steps so that all appropriate costs are charged to the sponsored project and that all required technical deliverables/progress reports, except financial reports and invoices, are submitted and accepted by the sponsor. On occasion, a residual balance exists when there are funds remaining on the award. Overages on these types of awards are the responsibility of the PI and department. The PI does not have the authority to negotiate with the sponsor on the use of remaining funds without the participation in such negotiations of OSP.
Residual fund transfers are distributed in accordance to the Residual Fund Transfer procedures. Residual funds must be utilized by the designated department with the approval of the dean of the school to further enhance the sponsored project related activities of the department. The PI and the department are responsible for ensuring residual funds transferred are spent in accordance with university policy.
Procedures for award closeout are specified in federal regulation, agency policies and procedures, and the terms and conditions of the award. Detailed procedures for award closeouts for federal awards are found in 2 CFR § 200.16 and 200.343, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, and 2 CFR § 215; collectively referred to as Federal Guidance. These procedures describe the responsibilities of federal funding recipients and are intended to provide the sponsor assurance that the awardee has complied with the terms and conditions set forth in the award, including the timely submission of all deliverables.
|Grants and Contracts Accounting Services (GCAS)
Responsible University Official: Director, Grants and Contracts Accounting Services
Responsible Office: Grants and Contracts Accounting Services
Non-compliance with this policy can be reported through this website.