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GIM 39

Closeout of Sponsored Programs

UNIVERSITY OF WASHINGTON

Office of Research
Office of Sponsored Programs

GRANTS INFORMATION MEMORANDUM 39

May 13, 2011

Purpose

Federal and many other sponsored programs require final reports be submitted at the time of or soon after the award end date. In accepting sponsor funding, the University has an obligation to comply with the sponsor's reporting requirements. Failure to submit these final reports can lead to closer monitoring by the sponsor, future award delays, or the sponsor withholding future funding to the Principal Investigator, the Principal Investigator's Department and the University. 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.

Background

The federal government has established uniform administrative requirements for grants and agreements with institutes of higher education, which are outlined in the Office of Management and Budget (OMB) Circular A-110. These federal government requirements set out the reporting needed at the end of a sponsored program, including equipment accountability and fiscal reporting. Additionally, most federal sponsors require a final invention statement and final technical report to be submitted within ninety (90) days of the end of the program. Lastly, other final reporting requirements may be mandated in the terms of the award. These may include a requirement to submit a list of publications or a security report.

Persons / Offices Impacted

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 responsibility to prepare the final technical report and invention statement. The University's Office of Sponsored Programs (OSP) requires that the Principal Investigator of a federally sponsored program submit:

OSP will not review and submit new proposals on behalf of a Principal Investigator if the Principal Investigator is currently more than thirty (30) days delinquent (i.e. 30 days past the sponsor closure date) in submitting any final technical report that is due to a federal sponsor.

If the Principal or Co-Investigator (s) 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 technical report is submitted and information required to complete equipment, patents and fiscal 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.

Process and Guidance

Forty five (45) Days Prior to Award End Date

OSP will send a notification to the PI and departmental administrative contacts 45 days prior to the end date of the award, informing that the award is scheduled to end and that closeout responsibilities may exist. The PI must check the terms of the award for the specific reports needed to fulfill sponsor requirements, and follow up with the OSP Closeout Specialist if there are any questions about his/her obligations.

The PI may request a no-cost extension at this time by completing the Extension Request Form on OSP's website. Once an extension is approved, the OSP Closeout Specialist will cease sending further communication until 45 days prior to the new award end date.

Award End Date

If a no-cost extension has not been approved, OSP will send a notification to the PI and departmental administrative contacts on the end date of the award, informing that the award has ended and detailing closeout responsibilities.

Sponsor Deadline for Award Closure

If the OSP Closeout Specialist has not received a copy of the required technical report and invention statement by the sponsor's deadline, OSP will notify the PI and departmental administrative contacts, informing that the PI is delinquent on completing closeout responsibilities. The email notification will also include a reminder of the policy that OSP will not process new proposals for PIs who are more than one (1) month delinquent on submitting a required technical report for federally sponsored grants and contracts. Separate notification will be sent to the appropriate Chair and Dean's offices from the Executive Director of OSP, notifying them of the delinquency.

One (1) Month Delinquent Notification

If at one (1) month following the sponsor deadline for closeout documentation, the PI has not submitted the final technical report for which his/her input is required, OSP will no longer review and submit new proposals on behalf of that PI. This notice will come from the Closeout Specialist to the PI and department administrative contacts, and the Vice Provost for Research will notify the Chair and Dean. This restriction will be lifted once the final technical report is received by the OSP Closeout Specialist.

Extenuating Circumstances

At times there may be extenuating circumstances that prevent the PI from completing his/her closeout reporting requirements. A request for an exception to this GIM must be made by the PI or Chair to the Executive Director of OSP, in which the circumstances are provided. The Executive Director of OSP will determine whether the circumstances justify an exception and notify OSP Closeout to remove the PI from the delinquent closeout list.

Exceptions may be granted under these circumstances:

If the PI is unable to meet his/her closeout obligations, the Chair of the Department is responsible for assuring that a final technical report is submitted and information on equipment, patents and fiscal status submitted to appropriate University offices in order to meet sponsor requirements.

Responsibilities

Principal Investigator:
OSP:
Chair of the Department in which the Principal Investigator is located:
Dean's office:
GCA:
EIO:
C4C:

Other Related Resources

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.
No-cost 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.

Content Creator

Office of Sponsored Programs