Policies, Procedures and Guidance

GIM 39 – Closeout of Sponsored Programs

Contents

Purpose & Background

Federal and many other sponsored awards requires all final technical, programmatic and financial reports submission by the institution no later than 90-120 days after the project period end date. All expenditures must be booked and all unobligated funds received as advance payments refunded to the awarding agency.

This final reporting consists of a final performance report, a final financial report and also usually includes a final invention statement and equipment inventory report when applicable.

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.

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
• Sponsor withholding future funding to the Principal Investigator, the Principal Investigator’s Department and the University.
• Use of departmental alternative sources of funds to cover sponsored program activity when costs are 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 complying with the closeout requirements and final fiscal management of sponsored programs.

Persons/Offices Impacted

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

University Policy

UW requires closeout of a sponsored award in accordance with specific sponsor requirements & policies within the required timeframe, but no later than the timeframes specified below for the final performance and financial reports and final invention statement.

It is the Principal Investigator’s (PI) responsibility to prepare final performance documentation, for submission to the sponsor, per timelines below in order to meet institutional requirements. When the PI responsible is no longer with the UW, 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 OSP is made aware that the PI is more than 120 days delinquent with final performance report submission (e.g. 120 days past the award end date).

OSP reserves the right to place a hold on future funding or other administrative actions if the PI has not supplied necessary information to other University offices to complete required final closeout documentation, until such time the PI is no longer delinquent.

Final Performance (Progress/Technical) Report

Within 90 days of the award end date or the sponsor’s deadline, whichever is sooner, OSP requires PI’s of federally sponsored programs submit:

• A Final Performance Report to the sponsor per sponsor submission requirements.
• A copy with 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 sponsored programs must post to the sponsored program budget number no later than the Final Action Date as indicated in GrantTracker in order for GCA to reflect accurate expenditure and balance information on the final financial reports and/or invoices.

GCA provides the GrantTracker Departmental View for monitoring expiration & final action dates of sponsored award budgets. More information on the fiscal closeout process of sponsored award budget can be found on GCA’s pages for Closing Budgets and Final Action Date.

Vendor, subrecipient, and internal (e.g., cost center) invoices must be received by the named department contact in approved UW invoicing systems per the terms and conditions of the specific agreement with the vendor or subrecipient. All cost share obligations must be reported to GCA.

Late posting of expenditures to a sponsored program budget will not be included in the final financial report or invoice unless communicated to GCA via GrantTracker on or before the final action date. Revised financial reports and invoices require authorized sponsor approval. 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. Such expenditures become the responsibility of the PI to resolve a resulting deficit under the UW Deficit Resolution Policy.

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. Departments should ensure to report all equipment purchases to the Equipment Inventory Office (EIO) within 45 – 90 days after end of award (or earlier depending on close out requirement).

Final Invention Statement

Final Invention Statement information is completed by the PI on the sponsor’s specific form; the authorized signature is OSP within 90 days of the award end date or the sponsor’s deadline, whichever is sooner.

When a subrecipient is part of the project, the PI is responsible for the coordination of the required final invention statement information with his/her subrecipient.

For positive invention statement (patentable innovations occurred on the project, including any subrecipient patentable innovations) CoMotion must ensure all reporting of inventions are compliant with Federal regulations prior to the UW authorizing or submitting the positive invention statement.

Process and Guidance

• End of Award/Budget Review Recommendations
• Budget Extensions (No-cost Extensions)
• Subaward Final Report and Invoice
• Closeout Property Report
• Final Invention Statement
• Final Performance Report
• Final Financial Report
• OSP Closeout Notification Process (Non-Financial)

Responsibilities

Principal Investigator (PI)

• Review award terms and conditions for all closeout requirements approximately 45 days prior to award end date.
• Review all costs for allowability & allocability.
• If no cost extension/budget extension is necessary, request via OSP’s Extension Request Form.
• Complete final technical/progress report and submit to sponsor per University policy above.
• Submit a copy of the final technical/progress report & confirmation of sponsor submission to OSP Closeout Specialist for Federally sponsored programs.
• Determine whether final invention statement is negative or positive and submit invention statement via sponsor required submission system/form.
• Notify all subrecipients of requirement to submit final invoice, invention statement and technical report to the Department, per the terms and conditions of the subaward agreement.

Department Contact listed in UW Invoicing Systems

• Remind subrecipients to submit final invoice per terms & conditions of their agreement with the UW in a timely manner to allow for proper closeout.
• Receive or reject invoices posting to UW systems in a timely manner, consistent with this policy and any associated agreement, such as a subaward agreement.
• Ensure all costs have been reviewed by the PI and posted to the UW Budget number before Final Action Date
• Report all equipment purchases to the Equipment Inventory Office (EIO) within 45 – 90 days after end of award (or earlier depending on close out requirement).
• Monitor expiring awards and support the PI in ensuring timely close out.
• End of Award/Budget Review Recommendations.

Office of Sponsored Programs (OSP)

• Assist PI with determining specific sponsor and/or award closeout requirements.
• Notify PI of upcoming closeout on federal awards.
• Access sponsor electronic systems to approve closeout documentation as Institutional Authorized Official, if required.
• Review and approve negative invention statements as Institutional Authorized Official.
• Document the closeout reports that have been received within sponsored programs file.
• OSP sends a series of reminders to the PI of the GIM 39 policy if they are made aware that a PI is delinquent on completing closeout responsibilities (either through sponsor delinquency notifications or sponsor or OSP records).
• OSP reserves the right to place a hold on future funding or other administrative actions if the PI has not supplied necessary information to other University offices to complete required final closeout documentation until such time the PI is no longer delinquent.
• Manages notification to PI, Dean’s office and Chair (in coordination with Vice Provost for Research) of delinquency.

Chair or Department Head

• Receive Delinquent PI notification from OSP/Vice Provost for Research.
• Per Chair’s office policies, contact PIs that are or are about to become delinquent on closeout submission requirements.
• Prepare and submit closeout reports as required by the sponsor if a PI is unable to do so (e.g. has left UW).
• Institute necessary internal controls to ensure final closeout documentation is supported by the department.

Dean’s office

• In coordination with Chair of the Department and according to Dean’s office policies, ensure closeout requirements are met for sponsored programs within unit/school/college.
• Receive Delinquent PI notification from OSP/Vice Provost for Research.

Grant and Contract Accounting (GCA)

• Provides the GrantTracker Departmental View to allow monitoring of expiration and Final Action Date of sponsored awards.
• Review and prepare UW budget number for closing and reporting.
• Prepare and submit final invoice and/or final financial statement per sponsor/award requirements.
• Attach completed Final invoice and/or final report to GrantTracker and a notification is sent to the PI and Fiscal staff through GrantTracker.
• Change status of UW budget number to status 4 (closed) within 120 days of award end date provided the budget is in balance.

Equipment Inventory Office (EIO)

• Authorizes the property closeout report and facilitates submission to the sponsor, in coordination with OSP.
• Submits official request for equipment disposition, if equipment is titled to sponsor.

CoMotion

• Reviews and concurs on positive final invention statement.
• Submits positive invention statements in some sponsor systems.
• Reports subject invention disclosures on iEdison.gov.

Definitions

Award Document

An Award is a sponsoring agency agreement to contribute funding to a specific project. The term does not include: technical assistance, which provides services instead of money; other assistance in the form of loans, loan guarantees, interest subsidies, or insurance; direct payments of any kind to individuals; and contracts which are required to be entered into and administered under procurement laws and regulations.

Award End Date

The project period end date as specified in the terms and conditions of the award.

Departmental Administrative Contact

The administrative and fiscal contacts listed on the eGC1.

Final Financial Report / Invoice

Final report or invoice reflecting a summary of all transactions on an award.

Invention Statement

Document detailing all inventions conceived or first reduced to practice during the course of the work under the award and the inventing party.

No Cost (aka Budget) Extension

An extension grants a PI additional time on a sponsored project without additional funding.

Project Period (Period of Performance)

The total time period stated in the Notice of Grant Award (aka NOA) (including any amendments) for which Federal support is recommended. The project period may consist of one or more budget periods. The total project period comprises the initial competitive segment, any subsequent competitive segment(s) resulting from a renewal award(s), and extensions.

Technical / Progress 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.

UW Budget Number

This reference number is the unique identifier contained in the Financial Accounting System assigned by Grant & Contract Accounting for the purpose of distinguishing budget and expenditure information for sponsored agreements and facilitates spending from the project budget. Salaries, benefits, supplies, equipment, services, etc. are all charged to the budget number.

Related Resources

Subject	Document
Deficit Resolution	UW Deficit Resolution Policy
OSP Budget Extension Process Information	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

 

Review Schedule

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

Change Notes

Details on changes to this GIM are available from the Office of Sponsored Programs, osp@uw.edu