Closing an Award

The timely closeout of an award is important in order to meet the obligations of the award. Closeout procedures may vary depending on the terms and conditions of a particular award. Typically, the university has 90 days to complete all of the activities associated with closeout. For awards with shorter closeout times, departments and PIs should take extra care in completing their tasks as quickly as possible.

OMB Circular A-110 contains requirements for a timely submission of final reports for grants, contracts and cooperative agreements. To be in compliance with A-110, all financial, technical and other required reports must be submitted within 90 days after the date of completion of the award. Delayed submission of reports extends the records retention period required for audit.

Some federal awards may include more restrictive closeout requirements in the terms and conditions of the award. If so, the more restrictive requirements should be adhered to in closing out the award.

Failure to closeout an award in a timely manner may result in the sponsor withholding new awards for the entire campus or the suspension of payments for costs incurred (by the university) for other projects under the same sponsorship.

A sponsor may require that the final report be signed by an authorized university official. In these cases, the report should be sent to OSP Pre-Award for signature. Pre-Award will then either submit the final report or return the signed report to the department for submission to the sponsor.

In order to closeout an award in a timely manner, OSP has identified the following tasks to be completed at specific times during the 90-day closeout period. Note that if a particular award has fewer than 90 days, these tasks must be completed in a much shorter timeframe.

Monthly throughout the award period:

• Review SAP financial reports. Identify and correct any errors noted within 30 days.

• Complete and return Personnel Activity Reports (PARs) when received.

• Monitor cost share requirements to ensure that the total required is met.

30 – 60 days prior to the end date of the award:

• Determine if an extension will be needed, and if so, process the request.

• Monitor SAP reports for potential deficits.

• Review technical report requirements and plan for completion.

• Process Personnel Action Forms PAFs to move salary to other cost objects where appropriate.

• Complete and return any PARs.

First 30 days after termination:

• Department should complete all financial transactions, pay invoices, review and correct any accounting errors, and process any needed PAFs.

• Document that cost share requirements have been met.

30 – 60 days after termination:

• Post-Award will review transactions and work with the department for any needed corrections.

• Central billings post.

• Final financial and technical reports should be completed.

• Department should complete and return any PARs.

• No payroll should post during this time period.

• Department should review its award files and ensure complete documentation exists for audit.

• Intramurals post in state's accounting system and reconciliation is performed when appropriate.

60 – 90 days after termination:

• Final reports are completed and submitted.

Retention

UNL requires that financial records be retained for five years. Department files should be available for audit during this time period. Federal retention requirements are found in OMB Circular A-110, Section 53, and require that award documentation be retained for three years after the final report is submitted.

If any litigation, claim, or audit is started before the expiration of the three-year period, the records must be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken. This also applies to the records of subaward recipients.

For multiyear awards, this means that the retention of some records may be longer than five years. (e.g., for a five-year award, first year records must be retained for eight years).

Records for real property and equipment acquired with Federal funds must be retained for three years after final disposition.

Additional retention guidelines:

• Post-Award retains copies of PARs. Be certain that we have them (especially if you destroy yours).
• Original invoices for operating expenses specifically authorized in the award are submitted to UNL Accounting. UNL Accounting will retain them for five years. Retain copies in your grant file, if needed, for more than five years.
• Keep all financial reports (e.g., Excel files) supporting grant expenditures or allocations.
• Obtain copies of FINANCIAL e-mails and final technical reports (or evidence of final technical report submission) from the PI for your departmental files.

Any records we have may be subject to audit. Destroy financial records for the time periods prior to the retention period. Develop an internal policy on technical and scientific records retention to ensure availability for audit.

Here is a list of final reports that may be required:

• Contractor's assignment
• Contractor's release
• Final Financial Status Report (SF-269)
• Final Federal Cash Transaction Report (SF-272)
• Technical report
• Property certification
• Patent/Invention Report
• MBE/WBE Report - EPA only