Award Closeout

Closeout is the final reconciliation and reporting of the expenses and activities of the project. This is a combined effort between the PI, local departmental/unit administration and University Research Administration. Throughout the life of the award, award management steps should be taken to ensure timely, accurate closeouts. This includes the allocation of expenditures, the monthly monitoring and reconciliation of the account,  and reviewing the account activities and plans with the PI, making adjustments as necessary. 

URA is responsible for submitting all interim and final financial reports required under grant and contract agreements. 

Preparing for Closeout

The closeout process should being 120 days prior to the award end date. The timeline and checklist below are provided to assist the Unit in preparing for award closeout.

 

120 Days Prior to the Award End Date

 

1. Review the account with the PI and determine whether a No Cost Extension is needed.
   1. If a No Cost Extension is needed, route an AMR through AURA to process this.
2. Subcontracts
   1. Review past invoices from any sub-awardees and ensure they have been processed.
   2. If a recent invoice has not been received, contact the sub-awardee to determine a timeline for invoices.

 

90-30 Days Prior to the Award End Date

 

1. Review the account again to ensure a No Cost Extension has been requested, if needed.
2. Contact any recharge services that have been scheduled to bill regularly, provide project end date and when to stop charging the award.

 

30 Days Prior to the Award End Date Through the End of the Award

 

1. Review cost share associate accounts
   1. Review the original cost share commitment in the award agreement and/or proposal. For non-federal sponsors, you may need to consult with Foundation & Corporate Relations to assist in reviewing the commitments and whether they have been met.
   2. Review the contributed F&A for cost share, if applicable. Ensure the appropriate rate and base were included on the cost share account and the calculations match the proposed cost share amount.
2. Confirm appropriateness of expenses against the award agreement. This may include the following:
   1. Any rebudgeting was within agency threshold
   2. Review charges in the last 60 days prior to the award end date for allowability and allocability, paying close attention to computer purchases and/or lab supplies/equipment purchased in this time frame. 
   3. Personnel costs
      1. Verify effort commitments are appropriate
         1. As a reminder, for all research proposals, one PD/PI must have committed effort per University policy. If salary for that effort was not recovered on the award, it should be appropriately captured on an associate cost share account (see above).
         2. NSF Award- Senior Personnel Effort Policy- Review senior personnel effort to verify their total effort on NSF projects active during the period of this award does not exceed 2 months of their regular salary in any one year.
      2. DHHS Salary Cap Limitations- Confirm the appropriate salary cap was applied to all individuals with salaries over the current NIH salary cap.
   4. Ensure participant support is expended appropriately.
      1. Review participant support associate account for allowable costs. Confirm that all charges posted to participant support account were truly for participant support and were allowable per the award agreement.
      2. Ensure indirect costs were not charged to this associate account.
   5. Pre-award charges
      1. Ensure any pre-award expenditures are allowable per the award agreement
      2. Ensure the appropriate indirect cost rate has been assessed on these charges.
   6. Ensure post-expiration charges (appropriate trailing activity) has posted to the account.
   7. Review any encumbrances and determine whether there is are outstanding invoices to be paid.
   8. Travel restrictions- Ensure any travel charged to an award is allowable per the award agreement.
   9. Administrative and clerical salaries- Ensure these are appropriate and allowable per the award agreement.
   10. Lab animals- Ensure all invoices for animal costs have been paid and follow up with the appropriate University office to ensure additional charges do not post to the account.
   11. Human subject payments- Ensure all subjects have been paid.
3. Review F&A costs- Ensure the base, rate, calculated F&A, and the F&A charged are consistent. Review for any differences and work with your URA Post-Award Research Administrator to make any required adjustments.
4. Subcontracts
   1. Verify final invoice has been received and submitted for payment
   2. Verify all reports have been received
5. Reports
   1. Ensure PI submits any reports that do not require institutional endorsement
   2. Contact the Polsky Center to determine if an Invention Statement needs to be filed
6. Recharge Services- Contact any recharge services prior to the award end date to provide a date services should be stopped
7. Collaborations- Contact lab staff and any collaborating units prior to the end date to provide new account information or to indicate they should stop spending

 

Closing Memo

After the award end date, administrators should ensure that all allowable charges have been posted to each SL account. Administrators should complete any final cost transfers to ensure all allowable and allocable expenses for the award are moved to the correct account.

After all expenses have posted, administrators will e-mail a Closing Memo and a copy of the ledger for each SL account to closeout@lists.uchicago.edu. It is required to use the ledger of the month the award ended. If there are trailling transactions the required backup documentation (see below) must be included in the closeout.  

The URA Post-Award Research Administrator will review the Closing Memo and contact the account administrator with any questions.

Once the Closing Memo is finalized, URA will prepare the final financial report and submit the report to the agency and/or submit a final invoice. URA will close the account in FAS once all final payments have been posted.

URA will follow up with the unit to ensure all other final reporting requirements have been met and will close the award in AURA as well.

 

Backup Documentation

 

 

Technical Reports

 

In accepting awards, the University is assuming responsibility for meeting all of the technical and financial reporting requirements of the sponsor. Specific interim and final report requirements are usually included in the sponsor’s terms and conditions or other award documents or in a policy guide or manual. These requirements vary from sponsor to sponsor.

The Principal Investigator bears responsibility for preparing and submitting the technical reports to the sponsor. It is URA policy not to close out an award until we have received some form of confirmation that the PI has met the technical reporting requirements. University Research Administration does not want to receive a copy of the Final Technical Report. However, URA does require a copy of the transmittal letter or dated face page of the report to document for audit purposes that the reporting requirement has been satisfied. With electronic reporting procedures, such as NSF’s, where URA receives notification from the sponsor, no further action from the PI is necessary.

 

Record Retention

 

The University is the recipient of the grant funds and as such is the formal owner of the data. Federal funding sponsors generally describe the institution as responsible for the retention of data, but in practice at the University of Chicago the Principal Investigator is charged with custodial responsibility for his/her own research data in accordance with Office of Management & Budget (OMB) Federal Regulations, which requires financial records, supporting documents, statistical records and all other records shall be retained for a period of 3 years (with some exceptions – see OMB Federal Regulations). Specific agencies may have different retention requirements and thus is it essential to review the agency specific guidance.

Grantees generally must retain financial and programmatic records, supporting documents, statistical records, and all other records that are required by the terms of a grant, or may reasonably be considered pertinent to a grant, for a period of 3 years from the date the annual FSR is submitted. For awards under SNAP (other than those to foreign organizations and Federal institutions), the 3-year retention period will be calculated from the date the FSR for the entire competitive segment is submitted. Those grantees must retain the records pertinent to the entire competitive segment for 3 years from the date the FSR is submitted to NIH.

Longer periods of retention may be recommended when the data is in support of a patent or other protected intellectual property. It is suggested the retention period be extended at least through the life of the patent.

If there are any ongoing allegations of misconduct, conflict of interest, the data should be maintained until the case is closed or resolved.

If the data relates to a student research project, the data should be retained until at least the student’s degree is awarded or the student leaves the institution (abandons the project).

If a faculty member leaves the university, there should be a formal agreement on the dispensation of the research data. It may be that the data is maintained in a departmental resource or that the PI will provide the University with reasonable access to the original data if there is a need.

 

Relinquishing or Transferring a Sponsored Award

See Relinquishing an Award

 

Related Links

• Account Closeout and Financial Report Policy
• Residual Transfers

Related Files

• Account Closeout Procedures
• Closing Memo
• Residual Fund Transfer Form