Non-Financial Administration of Award Closeouts

1. Non-Financial Administration of Award Closeouts December 7th, 2011

2. What is “Closeout”? • Closeout is the process in which the awarding agency determines that all applicable administrative actions and all required work with the award have been completed by the recipient [and the awarding agency]. • Closeout is an “After-the-Award” activity officially ending the grant relationship. • Defined in 45 CFR Part 74.71

3. What is “Closeout”? All grants and contracts have end dates that require a variety of closeout procedures: • Final financial report; • Final invoice, Reporting of inventions and patent results; • Listing of equipment purchases and equipment ownership information; and • Final technical progress report providing the sponsor with the results of the research.

4. What is expected? • Timeliness of reporting and closing is crucial to sound grants/contracts management to assure full compliance with sponsoring agency regulations. • These functions are tested as part of the annual OMB A-133 audit as well as by other sponsoring agencies when they make periodic site visits.

5. NIH • Grantees must submit to NIH within 90 calendar days after the last day of the final budget period. • Final Progress Report • Final Financial Status Report • Final Invention Statement • Submit to eRA Commons (preferred) or NIH Centralized Processing Center • Requirements detailed in the NIH Grants Policy Statement (Section 8.6 Closeout) • http://grants.nih.gov/grants/policy/nihgps_2011/nihgps_ch8.htm#_Toc271264983

6. NSF • Final project report must be submitted electronically via the NSF FastLane System within 90 days following expiration of the grant; • Within 90 days following expiration of the grant, a project outcomes report for the general public must be submitted electronically via Research.gov; and • Federal Financial Report (FFR) must be submitted one full quarter after the expiration of the grant. http://www.nsf.gov/pubs/policydocs/pappguide/nsf11001/nsf11_1.pdf

7. Foundations & Other Not for Profit Organizations • Final Technical/Scientific reports; • Final Financial Reports; • Other reports as designated; and • Due dates vary by sponsor and will be specified in the the award documents.

8. Compliance Reminder • Failure to submit timely and accurate final reports may affect future funding to the organization and/or awards with the same PD/PI(s). Accordingly NIH may impose sanctions on institutions that fail to correct recurring problems. Sanctions may include: • Corrective Actions • Removal of Authorities • Delay or withholding of future awards to the project or program

9. ComplianceReminder • OMB Circular A-110 provides Information on Closeout Requirements* – Submit all sponsor required reports and liquidate all obligations within 90 calendar days; – Refund any balances of unobligated cash that was paid by the sponsor; and – Disclose information on any property acquired with funds or received from the sponsoring agency. *(OMB Circular A-110, Section 71)

10. Roles & Responsibilities

11. Roles & Responsibilities cont. • PI/BA work with Post-Award to complete Final Closeout; • PI/BA uploads Final Progress report via Era Commons/NSF, sponsor’s website or via e-mail as required by contract/grant agreement; • If final progress report needs to be signed off on or submitted by ORS, please forward to Tina Nemetz • Notify Tina Nemetz tnemetz@upenn.edu once Final Invention has been completed in Era Commons, alternatively complete Final Invention form and forward to Tina for processing; • Contact Tina Nemetz for clarification on non-financial closeout actions.

12. Recommended Practices to Improve the Closeout Process and Reduce Risk • The non-financial closeout process is often treated as a separate procedure from the completion of the final financial closeout, but it should ideally be an extension of this process. • Notify ORS when you are ready to begin the process. • If the project will not be completed by the end date, determine if you want to request a no-cost extension. If so, your Pre-award contact can facilitate that process.

13. Recommended Practices to Improve the Closeout Process and Reduce Risk • Timeframe.  • It is recommended that you begin the process 2-3 months prior to the end of the project.  • For NIH grants, you have *90 days after the grant end date to finalize all expenses and submit all documentation.  *Check with Post-Award Desk Accountant • For incoming subawards under NIH grants, you have 45-60 days after the end date to close out the project.  • For other projects, refer to your contract or other sponsor guidelines. • For clarity, once you have been notified by Post-Award that closeout action will begin please complete the non-financial closeout process (i.e. Final Invention and Final Progress Report). If at any point you are unclear of what is specifically required by your sponsor for non-financial closeout please feel free to contact Tina Nemetz.

14. Questions

15. Resources • How to Guide for Era Commons: http://era.nih.gov/grantees/how-to_steps.cfm • Reminder of NIH Requirements for Submission of Financial, Administrative, and Scientific Closeout Reports in a Timely and Accurate Fashion: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-128.html • Subpart D-After-The-Award Requirements http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=c7f392dac96e1efc24a5b821048f5243&rgn=div8&view=text&node=45:1.0.1.1.35.4.11.2&idno=45