“Award Closeout” involves the final reconciliation and reporting of expenses and technical activities to the sponsor, and is generally governed by the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR Part 200 (“Uniform Guidance”) — in particular 2 CFR 200.343. Some activities include, but are not limited to, reviewing project expenditures for allowability (i.e., allowability, allocability and reasonableness), filing invention and property disclosures, resolving open commitments and submitting final financial reports, invoices and technical reports. During this process, the Boise State University (“University”) and the sponsor determine whether all applicable administrative actions and all required work have been completed by the University.
The University’s Office of Sponsored Programs (“OSP”) is responsible for the management and facilitation of the sponsored project closeout process. The OSP Sponsored Project Administrator (“SPA”), the Principal Investigator (“PI”) and appropriate college and departmental administrators must work collaboratively to ensure that all project work has been completed, that required reports have been filed and that any outstanding financial and programmatic matters have been resolved prior to closing out the sponsored project. The following procedures have been developed to facilitate the closeout process. If you have any questions, please contact your assigned SPA.
Even though Principal Investigators (“PIs”) and their college and departmental administrators are required to regularly review the financial and programmatic status of an award, it’s a good idea to evaluate the award’s status approximately ninety (90) days before the end of the project period. As a reminder, Oracle Financials Cloud (“OFC”) will automatically email the PI’s Departmental Administrator (as routed through Frevvo) and the assigned SPA a “90 Day Close Notification” email. The PI’s Departmental Administrator is responsible for notifying the PI about the pending closeout and working with the PI to do the following:
- Identifying the remaining direct and indirect cost balances, which must consider encumbrances, pending payroll and adjustments (e.g., running an Account Analysis Report and using the Grant Account Analysis Macro and associated instructions);
- Determining whether it’s necessary to increase or decrease performance activity to complete the work and spend within the budget;
- Ensuring all appropriate payroll expenses have been charged to the project;
- Submitting cost share documentation to the assigned SPA;
- Addressing any outstanding purchase orders or contracts that need to be issued or paid;
- Canceling recurring charges to the project (e.g., cell phone charges, OIT charges, rental agreements);
- Submitting any necessary Employment Action Forms (“EAF”) or Grant Funding Distribution Forms (“GFDF”) to change employees’ funding sources;
- Verifying that subrecipients or subcontractors have submitted final invoices, financial reports and technical reports;
- Submitting all required technical reports to the sponsor; and
- Determining whether a “no-cost extension” is necessary (i.e., a request to the sponsor for additional time to complete the project with no expectation of additional funds).
These are some of the numerous decisions that should be made well before the end of the project period. SPAs can advise PIs about the implications of each of these decisions, and will work with PIs and their college and departmental administrators to implement next steps.
If applicable, after the 90 Day Close Notification, the SPA will request (via e-mail) the PI to certify (via e-mail) that subrecipient or subcontractor performance has been acceptable and that all deliverables, as set forth in subawards or subcontracts, have been met.
Once the PI confirms the award/project is ending and that no pending continuations or no-cost extensions are anticipated, the SPA shall initiate project closeout.
Timeliness of final reporting is crucial to ensure compliance with sponsor requirements. Late reports can lead to audit findings, delayed reimbursement of costs incurred by the University, delayed funding for the PI’s or other faculty members’ future projects with the sponsor, bad past performance and damage to the PI’s and the University’s reputation. For these reasons, Oracle Financials Cloud (“OFC”) will automatically email reminder notifications to: (1) the PI 45 days before technical reports are due; and (2) the assigned SPA 20 days before financial reports are due. Typical deadlines for sponsored projects are listed below:
|Award Type||Reporting Due Date|
|Federal Prime Award||90 calendar days after expiration (2 CFR 200.343)|
|Federal Flow-Through Award||60 - 90 days after expiration|
|Other (e.g., State of Idaho)||See the award terms and conditions.|
All expenses being used as cost share must fall within the start and end dates of the award. All cost share documentation (e.g., expenses on cost share projects, Cost Sharing Affidavits (older awards), Third-Party Cost Share Forms/Certifications) must be provided to the assigned SPA well before financial reporting and invoicing due dates (see above).
PIs and others involved in the management of sponsored projects should at all times ensure that expenditures are allowable, allocable reasonable and timely. Expenditures are expected to be posted on a timely basis; however, for federal prime awards, adjustments and transactions may be posted to a sponsored project within ninety (90) days of the end date of the project pursuant to 2 CFR § 200.343. Adjustments and transactions for federal flow-through and non-federal awards may be posted in accordance with the terms and conditions of the awards.
Once the SPA, PI and appropriate college and departmental personnel are comfortable with the costs incurred, the SPA will submit the final financial report to the sponsor prior to the reporting deadline (see above). This report tells the sponsor exactly how much money was spent on the award and commits the University to release (or pay back with if there were advance payments) any unused funding; provided, OSP will not return funding on fixed-price awards as long as the award was adequately performed. External auditors carefully review a sample of final financial reports each year for accuracy and timeliness. Consequently, to permit SPAs enough time to accurately complete final financial reports, it is crucial that final expenditures are provided to OSP well before reporting deadlines.
Most sponsors require a final technical report, which must be filed in accordance with the terms and conditions of the award (e.g., timing, format, length). Timely submission of the final technical report is the responsibility of the PI, and a copy of the submitted report must be: (1) promptly forwarded to OSP at firstname.lastname@example.org; and (2) retained in departmental files until the records retention deadlines set forth in the award have passed (see, e.g., 3 years per 2 CFR 200.333).
In addition to a final technical report, many federal sponsors and their prime contractors (e.g., Department of Energy (“DOE”), Idaho National Laboratory (“INL”)) require a final patent or intellectual property report. The form will generally request a list of any copyrightable works “fixed” and patentable inventions “reduced to practice” during the performance of the award. These forms are submitted to the sponsor by the assigned SPA after consultation with the PI and the Office of Technology Transfer (“OTT”). If PIs have not previously disclosed their copyrightable works or inventions, PIs are required to do so during the closeout process.
Certain sponsors (e.g., DOE, INL, NASA) also require a final property report. In some cases (e.g., DOE, INL), title to the supplies and equipment vests with the sponsor, so the sponsors’ contracting personnel must make a determination as to the disposition of these items at the end of the award. Final property reports are submitted to the sponsor by the assigned SPA after consulting with the PI. (Note: For INL awards, see the Office of Sponsored Programs Implementation of DEAR 970.5241-1, Property, for more information.)
Once the above activities have been completed, OSP will “deactivate” the award and associated project number(s) in Oracle Financials Cloud (including the Project Portfolio Management module), so no further costs may be incurred after the award end date. Next, the the assigned SPA will change the project status in InfoEd to “Closed,” add the effective closed date to the data entry/setup checklist and e-mail a final closeout notification to the PI, the PI’s respective department and/or college administrators, Fixed Assets & Inventory Control and the appropriate OSP administrators after all adjusting entries have been completed and the project has been closed in all systems. Afterwards, the assigned SPA, Financial Technician or other designee will label the award’s/project’s physical file(s) as “Closed” and file it/them in the designated “Closed File” drawers. The Coordinator, Research Services then will move all associated electronic files to the OSP shared drive folder for closed files. OSP’s goal is to have all awards/projects closed within 120 days after the award/project end dates.
The University will maintain records consistent with 2 CFR 200.333 – 200.337, Boise State Policy # 1020 (University Records, Archives, and Publications) and the terms and conditions of the specific award documents.
During the closeout process, the the assigned SPA must reduce the fund balance (revenue vs. expenditures) to zero. If the fund balance is not at zero at the end of the project, it may be in deficit status (i.e., expenditures exceed revenues) or in surplus status (i.e., revenues exceed expenditures). For additional guidance, refer to University Policy # 6090 (Disposition of Balances of Unrestricted or Fixed-Fee Grants and Contracts).
1. Deficit Balances
Deficit balances occur when cumulative expenses exceed the amount awarded by the sponsor, or when expenditures exceed the amount of revenue received from the sponsor.
While the SPA will make every effort during the invoicing process to identify potential problems with deficits, it is the responsibility of the PI to maintain fiscal oversight of the project during the project period and thus prevent deficits at the end of the project.
If the project is expected to continue, the assigned SPA may submit a request to the funding agency (if necessary) to transfer the deficit balance from one budget period to the next, but within the overall project period. However, if the project has ended, the PI or the PI’s college and/or department administrator shall provide a local account number to absorb the deficit.
2. Surplus Balances
Surplus balances occur when revenues exceed expenditures at the end of a project. The SPA shall refer to the award document to determine appropriate next steps. If the project’s revenue is based on the cost-reimbursement payment method, the SPA shall return excess funds to the sponsor. If the project’s revenue is based on the fixed-price payment method, the surplus balance is transferred to an appropriate local account for use by the PI, department and/or college.
Costs charged to sponsored projects that are disallowed by the sponsor or uncollectible (e.g., bankruptcy or other non-payment) shall be the responsibility of the PI’s department or appropriate administrative unit.