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.
2CFR§200.343 contains requirements for a timely submission of final reports for grants, contracts and cooperative agreements. To be in compliance with 2CFR§200, 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 your post-award specialist for signature. OSP will then either submit the final report or return the signed report to the department for submission to the sponsor, depending on sponsor requirements.
In order to closeout an award in a timely manner, OSP has identified the following tasks to be completed by the PI and department 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.
- Run PVS Simulation to monitor and ensure accurate personnel costs are being charged to Federal, Federal Pass-through, and cost shared projects.
- 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, send the request to your post-award specialist.
- 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.
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 verify final Project Verification Statement.
- 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.
- Files are stored for audit in accordance with the records retention schedule.
Guidelines for Equipment Purchased with Federal or Federal-Pass-Thru Funds
The Federal definition of equipment is: tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000. UNL’s policy is to capitalize items at $5,000.
UNL retains a conditional title to Equipment purchased with Federal funds unless the awarding agency notifies UNL of its intent to retain title. The equipment can be used in the project or program for which it was acquired as long as needed after the ending date of the grant or contract.
Before using the equipment for other activities or disposing of the equipment, please contact Sponsored Programs if the equipment is in working condition. Items not in working condition may be disposed of following UNL guidelines.
For items in working condition, Sponsored Programs will need a current fair market value of the item, the sponsor and grant number where the item was purchased. If the item was purchased with multiple funding sources, that information should be provided as well. If the intent is to use the proceeds from the sale of the item to purchase replacement equipment, that should also be indicated in the paperwork sent to Sponsored Programs. Note that replacement equipment should have the same major functionality as the original equipment. Sponsored Programs will review the documentation and if appropriate, will assist the department in requesting disposition instructions from the Federal awarding agency. Disposition can include returning the item to the sponsor or compensating the sponsor for the item. Sponsored Programs will assist the department in determining the amount of compensation that needs to be paid to the Federal Agency if the equipment is to be used for other activities.
Financial Responsibility for Uncollectable Costs on Sponsored Projects
Financial responsibility for sponsored projects resides with the Principal Investigator (PI), the Department, and the College. If a PI is aware of potential non-payment for an award, he or she should contact their department chair and/or staff and OSP immediately. If a sponsored agreement results in unrecoverable costs as a result of any of the following circumstances, it will be the responsibility of the PI, the Department, and the College to cover those costs.
- Expenditures Exceeding Awarded Amount
- Cost Transfers
- Audit Disallowances
- Withholding of Final Payment
- Delinquent Payments from Sponsors caused by Dissatisfaction with the Deliverables or Delinquent Reporting
- Delinquent Payments caused by Sponsor Financial Difficulties, up to and including Bankruptcy
- Non-payment by Sponsor
- Advance Payments
- Funding Regarding Pre-Award Spending
- Subsequent/Supplemental Funding not Awarded
The Office of Sponsored Programs Post Award (OSP) will invoice the sponsor as required by each agreement, and will make reasonable efforts to collect payment. The PI and department are expected to assist with collection efforts when OSP has provided notification that a payment issue exists.
The PI, department contact, and department chair will be notified by OSP that a problem receivable exists within 60 days after the original billing date, at which time a past due notice will be sent to the sponsor (unless contract terms with sponsor indicates their payment cycle is more than 30 days). Past due notices or correspondence will be documented by OSP on a monthly basis thereafter. At the department chair’s discretion, the project may be locked to prevent further posting of expenses. Note that for federal or Nebraska state agency sponsors, this timeline may be adjusted in accordance with their customary billing timelines.
If a receivable on an active sponsored project remains unpaid for more than six months from the original billing date, the PI, department contact, and department chair will again be notified. OSP will lock the project at this time unless there are extenuating circumstances. If a final invoice or payment due remains unpaid nine months after the date when a sponsored project would normally be closed, the unpaid balance will be transferred to a departmental account. If the department does not provide an acceptable account, one will be chosen by OSP.
UNL requires that financial records be retained for Seven years. Department files should be available for audit during this time period. Federal retention requirements are found in 2CFR§200.333 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 seven-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, the retention period of all records for the award begins when the final financial project report is filed. This is typically 90 days after the ending date of the award.
Records for real property and equipment acquired with Federal funds must be retained for three years after final disposition.
Additional retention guidelines:
- Original invoices for operating expenses specifically authorized in the award are submitted to UNL Accounting. UNL Accounting will retain them for seven years. Retain copies in your grant file, if needed, for more than seven 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 (SF425)
- Final Federal Cash Transaction Report (SF270)
- Technical report
- Property certification
- Patent/Invention Report
- MBE/WBE Report – EPA only