Research OSPA:Close Out Process

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Effective Date

September 1, 2013

Statement of the Issue

Reports required and procedure to follow once a project has been completed.

Applicable Policy/Regulation

Uniform Guidance (UG) 2 CFR 200.343 requires all financial, performance, and other reports as required by the terms and conditions of the award, be completed and submitted within 90 days after the date of completion of the award.

Failure to submit timely and accurate final reports may adversely affect future funding to the organization and/or awards with the same Principal Investigator (PI). Accordingly, sponsors may impose sanctions on institutions that fail to correct recurring reporting problems. Such sanctions may include restriction of facilities and administrative (F&A) costs, removal of authorities, delay or withholding of further awards to the project or program, removal from participation in funded awards under the Federal Demonstration Project, and/or designation as a high-risk grantee.

Other Considerations

When a subaward is received on a sponsored project, check for language regarding the need for a contract release form upon expiration or termination of the subaward. This will likely be a flow down from a prime sponsor that is Defense, Energy, NASA, etc., that uses FAR clauses. The particular FAR clause that provides for a release is 52.216-7(h). You can ask for the release when negotiating the contract.

Process

  • Every month, the Office of Post Award Management (OPM) will send the Assistant Director (AD) a spreadsheet of all the projects ending in 120 days. The AD will forward the list to the Grant Specialists with a request they identify any projects that will not end – i.e., a continuing project, extensions forthcoming, etc. Once all Specialists have completed the list, the AD will send it back to OPM.
  • 90 days prior to the end date of the award, OPM will use the spreadsheet to send a project termination notice email to the PI, admin, SFO, and respective Grant Specialist. (See template at the end of this process.) During this 90 day period, the PI needs to begin close-out activities following the [[1]].
  • The PI will also need to begin working on the technical progress report. The PI is responsible for submitting the final technical or performance report to the sponsor by the date specified in the agreement.
  • Accounting and Financial Reporting (AFR) is responsible for preparing and submitting the Final Financial Report (FFR) to the sponsor by the date specified in the agreement. UG 2 CFR 200.343 requires all financial reports to be submitted within 90 calendar days after the project end date.
  • OPM monitors end dates of projects to make sure the close-out process is commencing after the term of the agreement concludes. Monitoring is done to ensure all expenses have cleared and have been billed for.
  • On the project end date and 30 days after the end date, AFR will send a notice to the PI, admin, and SFO reminding them to submit all expenses.
  • To allow AFR sufficient time to complete the closeout process with the sponsor, no cost revisions are allowed after 45 days from the end date of the project. Adjustments must be completed by the department prior to this deadline. If overages exist, AFR will obtain an alternative cost center from the department. If not provided within 45 days of the end date, excess expenditures will be transferred to research enhancement cost center(s) in the following order:
    • PI Research Enhancement cost center
    • School Research Enhancement cost center
  • The departmental staff, PI, OPM, and AFR should make every effort to have finalized closeouts prior to submission of reports. In the event of a downward adjustment to expenditures, AFR will work with the sponsor to refund excess funds and submit a revised report, if required.
  • When all invoices are paid and necessary final financial reports are filed with the sponsor by the Office of Finance (no later than 90 days or sooner if the contract requires), AFR will submit the project to OPM to change the bill plan and revenue plan to “completed” in order to change the contract line to “closed”. The project status is also changed to “closed”.
  • OPM emails Systems Administration for inactivation in PeopleSoft and the sponsored project is considered closed. OPM will send an email to the PI, admin, SFO, and respective Grant Specialist notifying them of the closed status. (See example at the end of this process.)
  • If the project is fixed price, OPM and OSP will determine if the unspent funds can be kept or returned to sponsor. If the PI can keep the funds, AFR will transfer the unspent funds to the cost center indicated by the department. By default, federal sponsors require the unspent funds be sent back. Finance processes a check and sends it to the sponsor.
  • Once the Grant Specialist receives the closed cost center email, the Specialist will contact the PI for a copy of the final technical progress report. If no reports are required, the PI will need to provide written confirmation that all terms and conditions of the agreement were satisfied. (See templates at the end of this process.) Nonfinancial reports should be uploaded in the Award Profile Attachments section in PeopleSoft and saved on the G:drive. Invention and patent reports will need to be verified with the Office of Technology Commercialization (OTC).
  • For projects requiring a contract release form at the end of the award, whether received as part of the contract negotiation or when the subaward ends, be sure to verify that, (a) the contract requires OSP to sign the release and, (b) that the release conforms to the FAR clause provisions. AFR will complete, sign, and submit this form. AFR will also complete and sign final inventory/property reports, if required.

For additional information, refer to the [process] and the [process] for closing out projects.

Definitions

  • Contract Release form
    • Sponsor or Prime Recipient form verifying total amount expended on a sponsored project at the end of an award and that all other funds have been de-obligated. The purpose is to accept the termination of the agreement.
  • Final Financial Report - (See UG 2 CFR 200.327-329)
    • This document is the formal record of the financial activities related to the sponsored project and provides details about the amount spent by the PI and the amount received from the sponsor.
    • The financial report is completed by Office of Budget and Finance and submitted to the sponsor.
  • Final Invoice
    • This document outlines any remaining financial obligations on the part of the sponsor. The final invoice is prepared by Office of Budget and Finance and submitted to the sponsor.
    • If the PI has not submitted the technical report to the sponsor, it is possible that the sponsor may not pay the final invoice.
  • Invention Report
    • This document lists all inventions which were conceived or first actually reduced to practice during the course of work under the grant or award, from the original effective date of support through the date of completion or termination
    • Includes any inventions reported previously for the grant or award as part of a non-competing application c. Applicable to all grants and awards by the Department of Health and Human Services
  • Inventory Report - (See UG 2 CFR 200.329 and 200.310-316)
    • When the total equipment purchased for a project is valued at $5,000 or more, an inventory representative will prepare a report providing details about the equipment, and in some cases, requesting disposition of the equipment. This report is submitted to the sponsor by AFR.
    • Equipment purchased on sponsored projects usually becomes the property of The University of Texas at Dallas and will be inventoried with other departmental equipment annually. If the contract specifies that equipment is to be returned, the equipment will be returned to the sponsor.
  • Patent Report
    • Most federally sponsored projects and some other projects require a patent report, which provides a list of inventions or new technology resulting from the project.
    • Patents and inventions are processed by the Office of Technology Commercialization.
  • Subrecipient
    • The legal entity to which a subaward is made and which is accountable to the recipient for the use of the funds provided. The activities of a subrecipient will have significant impact on the total project with distinct deliverables for work that is unique to the project. The terms of UTD subrecipient relationships are documented in Subgrant/Subcontract or consortium agreements.
  • Technical Report – (See UG 2 CFR 200.328)
    • This document describes the process, progress, and/or results of technical or scientific research, or the state of a technical or scientific research problem.
    • The technical report is completed by the PI and submitted to the sponsor.
    • If the PI does not submit the technical report to the sponsor, it is possible that the sponsor may not pay the final invoice.
  • Uniform Guidance - In effect December 26, 2014 and published by the federal Office of Management and Budget (OMB), this guidance supersedes and streamlines requirements from OMB Circulars A-21, A-87, A-110, and A-122; Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up. This guidance provides a governmentwide framework for grants management which will be complemented by additional efforts to strengthen program outcomes through innovative and effective use of grant-making models, performance metrics, and evaluation. <a href="http://www.whitehouse.gov/omb/grants_docs">http://www.whitehouse.gov/omb/grants_docs</a>

Email Templates

90 Day Notice Sample

March 22, 2016

PI,

I am currently reviewing project XXX which ends on 12/31/2015. Below is the available balance for cost center XXXXXXXX which is currently deficit. In order to clear the deficit, $147.92 in direct expenses will need to be moved to another cost center.

Please initiate the following actions to ensure a smooth closeout:

  • If needed, complete PAFs to move future salary/benefit charges to a new account so no expenses will hit the account after the expiration date.
  • Cease telecommunication, postage, and equipment charges.
  • Evaluate the account to ensure there is enough budget to cover known future expenditures.
  • Analyze the account for any charges that may be in question.
  • Confirm that you have received and processed all Sub Contractor’s invoices for their work completed on the award.
  • Review all encumbrances and process all invoices and/or journals if required.

For questions regarding reporting requirements or requesting an extension, please contact your Grants Specialist or the Office of Sponsored Projects, x2313.For financial questions, please contact [|Office of Post Award Management]<meta charset="utf-8">and any staff member will be able to help you.

Cost Center Closed Sample

Dear Dr. Smith,

This is to notify you that project XXXX has been closed. The related cost center XXXXXXXX has been added to the inactivated list by system administration and should not be used. Please note, account reconciliation of the cost center may be required for the remainder of the fiscal year if there has been any current year activity.


Please let me know if you have any questions.

Request for Final Technical Report Sample

Dear Dr. Smith,

Project XXXX/Cost Center XXXX entitled “enter title here” has been closed. Please send a copy of the final technical report so that the Office of Sponsored Projects can complete the file. Please let me know if you have any questions.

Request for Final Written Confirmation Sample

Dear Dr. Smith, Project XXXX/Cost Center XXXX entitled “enter title here” has been closed. Please verify the project has been completed, deliverables met, and the sponsor is satisfied. Please let me know if you have any questions.

Dear Dr. Smith, In order to complete and close the OSP file for this project, please verify the project has been completed, deliverables met and the sponsor is satisfied. If a final report was provided to XXX, please send it to me and I’ll add it to our file.

Thank you,