Federal Office of Management and Budget (OMB) Circular A-110 sets forth standards for obtaining consistency and uniformity among Federal agencies in the administration of grants to and agreements with institutions of higher education, hospitals, and other non-profit organizations.
Included in the standards are close out procedures.
Section .71 requires that:
- Recipients shall submit, within 90 calendar days after the date of completion of the award, all financial, performance, and other reports as required by the terms and conditions of the award. The Federal awarding agency may approve extensions when requested by the recipient.
- Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Specific closeout requirements may vary from project to project and sponsor to sponsor. As stated above, most final reports of expenditures, including those from non-federal sources, are due within 90 days of the end date. If the university is a subrecipient, the due date is usually earlier (45 to 60 days is typical) in order to give the prime awardee enough time to file their final expenditure report with the sponsor. All expenditures related to the project must be processed, open encumbrances closed, cost sharing verified, and the account(s) reviewed for errors or necessary changes in order to prepare the final financial report.
In order to facilitate closing an account, attention to closeout requirements should be given throughout the life of the project. Ongoing monitoring of expenditures will help ensure only allowable expenditures are charged to the sponsor.
Prior to the End Date
Approximately two to three months before an award ends, a notice is sent to PIs and their administrators reminding them of the pending end date and suggesting, that if needed, a no cost extension be requested.
The notice includes a summary of the total budget, expenditures to date, open encumbrances and the remaining budget balance.
At this the time the PI should review all open encumbrances and process any remaining purchases to ensure that all required materials are delivered within the time allowed by the project. Most federal awards require items purchased to be received by the end date of the project. Equipment purchases should be timed to ensure there is a benefit to the project. Equipment should not normally be purchased in the last few months of a project.
Salary transfers should be completed as well to ensure payroll is transferred to another account timely.
After the End Date
The ORA will generate a report of expenditures from the PeopleSoft system. Expenditures will be reviewed for adherence to the award terms and conditions. The ORA will send the PI a draft report of expenditures along with any questioned costs. The PI will be asked to review the draft, identify any unrecorded costs and resolve any open items/ questions. Costs identified as unallowable will have to be transferred to an appropriate account. These costs include expenditures after the end date, expenditures in excess of the budget and expenditures deemed not allowable as a direct charge to the grant. Any cost not accepted by ORA as allowable on the project or transferable to another project will have to be transferred to an unrestricted account.
The ORA will also review cost sharing documentation, ensure final technical reports and invoices have been received from subrecipients, patent reports and any other required forms prior to submitting the final report of expenditures.
In closing accounts, the PI should be mindful that transferring expenditures to resolve a deficit or use up a remaining budget balance are not allowable. Once the final costs have been determined, ORA will send the completed final report of expenditures and final invoice to the sponsor. If a refund is due, ORA will process the refund. The PI is responsible for submitting the final technical report.
Upon final payment from the sponsor the PeopleSoft award and contract will be closed.
Fixed Price Account Close Out
Sometimes awards are issued to the University on a task based or fixed price agreement. Rather than reimburse expenditures, the sponsor pays a fixed amount based on the work completed. If expenditures exceed the awarded amount, the PI must cover them from an unrestricted account. If a surplus remains and the sponsor does not require reimbursement, the residual amount is then available for use.
The ORA reviews fixed price accounts at the end date to ensure that all work has been completed and all expenditures have been charged to the project. The PI is asked to sign off that all requirements have been met.
In cases where the direct cost budget balance is less than 10% of the original direct cost budget, the direct cost balance will be transferred to an unrestricted account of the PI. When the remaining budget exceeds 10%, the PI will be asked to explain budget to actual variance. Budgets should be a reasonable estimate of the costs that will be incurred to complete a project. All expenditures incurred to complete a project should be charged to that project.
Other projects and institutional accounts should not be used to pay for project specific expenses. Once all documentation is accepted by ORA the residual balance in the direct cost budget line will be transferred to an unrestricted account of the PI. The balance in the indirect budget will be allocated according to the indirect revenue allocation. The fixed price account will not be in active use after the end date.
Go back to Award Management Guildlines