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GIM 39

Closeout of Sponsored Programs

UNIVERSITY OF WASHINGTON

Office of Research
Office of Sponsored Programs

GRANTS INFORMATION MEMORANDUM 39

Effective December 26, 2014

Supersedes: GIM 39 (May 11, 2011)

This GIM is updated to conform to the Federal "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards" (Uniform Guidance) effective December 26, 2014. This GIM applies to new awards and new funding for existing awards received on or after Dec 26, 2014.

For awards in existence prior to December 26, 2014 that have not received supplemental funding or are not otherwise subject to the Federal Uniform Guidance per sponsoring agency award terms and conditions, please refer to the Archived GIM 39.

Purpose

Federal and many other sponsored programs require final reports be submitted and all obligations incurred under the award liquidated no later than 90 days after the end of the period of performance. All unobligated funds paid in advance, if applicable, must be refunded to the awarding agency.

In accepting sponsor funding, the University has an obligation to comply with the sponsor's reporting and fiscal closeout requirements. Failure to submit these final reports and manage the fiscal closeout appropriately can lead to closer monitoring by the sponsor, future award delays, the sponsor withholding future funding to the Principal Investigator, the Principal Investigator's Department and the University, or the use of an alternative source of funds to cover sponsored program activity for costs not properly accounted for prior to the closeout of the award. This policy, in conjunction with the associated process and guidance, establishes the University's roles and responsibilities with respect to meeting these final closeout report and submission requirements and final fiscal management of sponsored programs.

Background

The federal government has established Uniform Administrative Requirements for federal awards as set out in 2 CFR 200. These requirements set out the final administrative actions, including reporting, needed at the end of a sponsored program. This final reporting consists of a final performance report, a final fiscal report and also usually includes a final invention statement and equipment inventory report. Other final reporting requirements may be mandated in the terms of the award from federal or non-federal sponsors. These may include a requirement to submit a list of publications or a security report.

Persons/Offices Impacted

UW Principal Investigators (PIs) with federally sponsored programs, Chair and Dean, Office of Sponsored Programs (OSP), Center for Commercialization (C4C), Grant and Contract Accounting (GCA), Equipment Inventory Office (EIO), Facility Security Officer (FSO)

University Policy

The University of Washington requires closeout of sponsored programs in accordance with federal regulations, specific sponsor policies and the terms of the award within the timeframe required by the sponsor. The exact nature of the reports required and the deadlines for their submission are typically outlined in the award terms and conditions or published sponsor policies.

It is the Principal Investigator's (PI) responsibility to prepare final performance documentation, for submission to the sponsor, per sponsor requirements.

If the PI responsible for completion of the closeout documents is no longer with the University of Washington, the Chair of the Department is responsible for assuring that a final performance report is submitted and information required to complete equipment, patents and financial reporting is submitted to appropriate University offices. For severely delinquent reports, the Chair may need to request a waiver from the sponsor in order to submit late closeout documentation.

OSP will not review and submit new proposals on behalf of a PI if the PI is currently more than thirty (30) days delinquent (i.e. 30 days past the sponsor closure date) in submitting any final performance report that is due to a sponsor. If the PI has not supplied necessary information to University offices in order to complete other required final closeout documentation in a timely fashion, OSP reserves the right to place a hold on future funding or other administrative actions until such time the PI is no longer delinquent.

Final Performance (Technical) Report

The University's Office of Sponsored Programs (OSP) requires that the PI of a federally sponsored program submit a final performance report to the sponsor per sponsor submission requirements, with a copy and proof of submission to the OSP Closeout Specialist, within (90) days of the award end date or the sponsor's deadline, whichever is sooner.

Final Financial Report

All expenditures incurred in support of the sponsored program must post to the sponsored program budget number no later than the final action date as indicated on the Notice of Expiration (NOE) from Grant and Contract Accounting (GCA) in order for GCA to liquidate all obligations incurred and to reflect accurate expenditure and balance information on the final financial report. Invoices must be received by the named department contact in approved UW invoicing systems within 60 days after the overall sponsored project end date, including subrecipient invoices.

Late posting of expenditures to the sponsored program budget do not constitute a revised financial report by GCA and become the responsibility of the PI to resolve a resulting deficit under the UW Deficit Resolution Policy. Late invoicing by a vendor or subrecipient are subject to nonpayment per the terms and conditions of the specific agreement with the vendor or subrecipient.

Final Equipment Inventory Report

All final equipment inventory reports are prepared and approved by the UW Equipment Inventory Office (EIO). It is necessary for the PI and department administrators to provide necessary information to EIO, upon request, in order to fulfill this requirement.

Final Invention Statement

A negative (no patentable innovations to report) invention statement is completed by the PI and the authorized signature is OSP. A positive invention statement (patentable innovations occurred on the project, including any subrecipient patentable innovations) is completed by the PI and forwarded to the UW Center for Commercialization (C4C). C4C must ensure all reporting of inventions are compliant with Federal regulations prior to authorizing the positive invention statement.

The PI is responsible for the coordination of the required final invention statement information directly with his/her subrecipient PI collaborator for inclusion in the final invention statement submitted by UW to the sponsor.

Process and Guidance

Responsibilities

Principal Investigator
Department Contact listed in UW Invoicing Systems
OSP
Chair or Department Head
Dean's office
GCA
EIO
C4C

Definitions

Award End Date:
The project period end date as specified in the terms and conditions of the award.
Closure Date:
For federal awards, typically ninety (90) days past the award end date.
Departmental Administrative contact:
The administrative and fiscal contacts listed on the eGC1.
Fiscal report:
Final report reflecting a summary of transactions within the reporting period for the subject grant or contract.
Invention Statement:
Form detailing all inventions conceived or first reduced to practice during the course of the work under the grant or contract and the inventing party.
Budget Extension:
An extension grants a PI additional time on a sponsored project without additional funding.
Technical report:
A technical description of the project results and additional information as required by the sponsor. Additional information requested can include an abstract and a list of publications.

Related Resources

SubjectDocument
Deficit Resolution UW Deficit Resolution Policy
OSP Budget Extension Process Information OSP Manage Award - Budget Extensions
Subaward Administration and Subrecipient Monitoring Information GIM 7: Sponsored Program Subaward Administration
GIM 8: Subrecipient Monitoring
GCA Closeout Process (Financial) GCA Closeout webpage
Federal Uniform Administrative Requirements, Cost Principles, and Audit Requirements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Content Creator

Office of Sponsored Programs

Research Accounting and Analysis:

Review Schedule

This policy is reviewed by the Office of Sponsored Programs as necessary to reflect changes in Federal regulation or University policies.