Award Closeout for Grants and Contracts | Policies

Policy on Award Closeout for Grants and Contracts

Purpose:

To establish guidelines for award closeout on sponsored awards and contracts which are consistent with federal, state, city, and private grantor regulations.  This policy is intended to comply with the requirements from the Office of Management and Budget Uniform Guidance (UG) closeout section 200.343 as well as requirements from our federal/non-federal sponsors.

 Scope:

This policy is applicable to faculty and staff who are involved in administering sponsored awards and contracts. 

Responsibility:

The interpretation and administration of this policy shall be the responsibility of the Grants and Contracts Accounting Office in consultation with the Associate Vice President and Controller.

Policy:

This policy applies to all sponsored awards and contracts at Teachers College (TC). The Grants and Contracts Accounting Office (GCA) is committed to maintaining an award closeout system that provides accurate, current, and full disclosure of all grant accounting and management activities.  GCA’s award closeout system ensures compliance with laws, regulations, and provisions of awarding/contract agencies.  GCA, as a recipient of the funds, is responsible for compliance with all applicable federal and state laws, regulations, and provisions of awarded grants and contracts.  To ensure that the College meets this responsibility, GCA must remain familiar and comply with the directives of the Federal Office of Management and Budget (OMB) as well as requirements from our non-federal sponsors.

Overview for Award Close Out System

Prudent financial management of sponsored accounts and contracts includes timely and accurate reporting to sponsors. These functions are tested as part of the annual OMB single audit as well as by other sponsoring agencies when requested.

On a monthly basis, GCA creates a 30,60,90 days memo of awards ending within those days. These are sent to the Principal Investigators (PI) and Budget Administrators (BA) requesting that they should ensure that all project costs are appropriately charged. As the project nears termination it is important to review all costs, remove any unallowable charges, and update coding for any recurring charges.  This memo also reminds PI’s that the project is approaching expiration and instructs them to begin the necessary technical and administrative actions to close out the sponsored award (or consider requesting a No Cost Extension, if appropriate). PI should communicate with the Office of Sponsor Programs (OSP) Pre-Award if a no-cost extension is being considered, or to verify the status of award renewal or continuation.

An award closeout is the final reconciliation and reporting of expenses and activities. This involves reviewing project expenditures, resolving open commitments, collecting sub-recipient documents, and preparing required final reports and deliverables for submission to the sponsor including:

• Financial Reports/Invoices
• Scientific/Technical Reports
• Milestone Deliverables
• Invention/Property Statements

Timeliness of final reporting is crucial to ensure compliance with sponsor requirements. Typical deadlines are outlined below.

Failure to submit reports by the deadline can result in the suspension of the principal investigator (PI) and/or university from receipt of additional funding, reimbursement for current costs, and the ability to submit future proposals. TC closeout policies and procedures were developed to ensure that all sponsor requirements are met in accordance with UG standards as well as non-federal standards.

Procedures for Award Close Out System

The PI’s and GCA will work on the following:

• Communicate with OSP Pre-Award: discuss 1) the status of the award’s renewal or continuation, or 2) the request of a No Cost Extension, if appropriate.
• Review any outstanding invoices and follow up on purchases processed through Unimarket that have not arrived.
• Ensure all project costs are incurred by the project end date. Review project expenses for consistency, allowable, allocable, and reasonableness; see also TC’s Allowable and Unallowable Costs Policy.

• Ensure any subcontractor(s) on the award have completed all necessary deliverables, submitted all required reports, and will submit their final invoice within forty-five (45) to ninety (90) calendar days of the subcontract end date (days differ on each sub-award). 

• Verify all payroll charges are correct. Review all salaries and associated fringe to ensure they have been expensed correctly. Ensure personnel is transferred off the award by the end of the project period if applicable.
• Process cost transfers and labor distributions if necessary; see TC’s Cost Transfer Policy.
• Verify all cost-share commitments have been fulfilled, and are properly recorded, if applicable.
• Ensure any adjusting journal entries have been posted, including the elimination of deficits; see TC’s Cost Transfer Policy.
• Reconcile any travel advances charged to the award.
• Reconcile all monthly P-Card statements according to TC Purchasing Card Policy.
• PI prepares the Final Progress Report and any other required deliverables.
• PI/BA to confirm the disposition of any equipment.
• GCA prepares the Final Invoice/Report to sponsors.
• Review GCA's reconciliation detailing the final expenditures and award balance to verify the accuracy of the final Financial Report/Invoice. Submit any adjustments to GCA, including those related to unallowable, questionable, or overdraft expenditures.
• Prepare and submit any required Scientific/Technical Reports or Milestone Deliverables to the sponsor.
• Complete any required forms related to Invention and/or Property Statements.
• Provide GCA with the PI’s approval confirmation of the final account balance, completion of all contractual commitments, and submission of all reports required by the sponsor.

Roles & Responsibilities

It is the role of each Principal Investigator and staff with delegated approval authority to:

It is the role of the Grants and Contracts Accounting Office to:

• Provide the PI/BA with the account reconciliation for review and coordinate with the PI/BA to ensure that all expenditures are finalized, and adjustments are processed in order to reach a final account balance.
• Prepare and submit the final Financial Report/Invoice according to the finalized account reconciliation.
• Submit any required Invention/Property Statements completed by the PI to the sponsor.
• Close sponsored award fund sources/indices in the financial system.

Responsible Office: Grants and Contracts Accounting Office

Effective Date: May 15, 2020