Closeout Timeline
Closeout Process
·
Begins up to 120 days before the award or project
end date
·
No equipment purchases within the last 90 days of
an award unless the award is for the equipment purchase
o
Federal regulations
o
Justification -not useful for the project if
purchased at the end of the project
·
No new transactions past the end date
o
Do not place orders for supplies, copying, etc.
after the end date
o
Includes salary – salary for work performed after
the end date cannot be charged to the award
·
Expiration notice sent four months before the end
date
o
Sent to Principal Investigator, business managers
and the Office of Research
o
Automatically sent from the UNO financial system
(PeopleSoft)
o
Do no reply to the email – email the Office of
Research if there are questions
§
See the Office of Research website
http://www.uno.edu/orsp or SharePoint site
http://sharepoint.uno.edu/research
for contact information
o
Questions to consider:
§
Will the
project be completed by the end date?
·
If so, inform the Office of Research and
Sponsored Programs Accounting
§
Does the
investigator need to request a no-cost extension?
·
If so, follow sponsor requirements for extension
requests – may be 90 days or more before the end date
·
Fixed price awards may also need an extension
request if the project is not complete by the end date
§
Does the
investigator already know that an extension is pending or additional funding is
being sent to UNO?
·
If yes, inform the Office of Research and provide
any correspondence from the sponsor
·
The Office of Research will work with Sponsored
Programs Accounting to update the financial system
Fixed Price Award Extension
·
May be entitled to a one-time, internal no-cost
extension for two years
o
Refer to AP 19.01
o
Assuming the project is completed (submit all
required deliverables) by the project end date
o
If the fund balance is more than $500:
§
Balance used to cover any of the investigator’s
overdrawn awards
§
Remaining balance (assuming more than $500) will
be available for the investigator’s use
o
If the fund balance is $500 or less
§
Will be closed within 90 days after the original
expiration date
Sponsor Extension
·
Can be a no cost extension or an extension with
additional funding
·
Principal Investigator works with the Office of
Research
·
Need to follow sponsor guidelines/requirements
o
Each sponsor will be different
o
Must be submitted by the sponsor’s deadline
o
Check the award document or contract
·
Do not assume the request will be granted – be
prepared to complete the project by the end date
Closeout – Nearing the End Date
·
Be concerned with completing the work on the
project
·
Need to address financial issues within 30 days
of the end date
o
Payroll
§
Complete paperwork to change the source of
funding
§
Submit before the end date
o
Commitments or orders
§
Make sure not outstanding
§
All merchandise ordered must be received before
the end date
§
Invoices paid prior to the completion of the
final financial report to the sponsor
·
Work with Sponsored Programs Accounting on when
this needs to be done
§
Make sure purchase order encumbrances have been
cleared
·
Done by Purchasing, but the investigator or
business manager needs to make sure it has been done (check the encumbrance
column on one of the award reports in the financial system)
Subcontract Closeout
·
Investigator should be monitoring the work of the
subcontractors throughout the project
·
At the end of the award:
o
Obtain subcontractor’s final invoice
§
Must be received on time – as per the subcontract
§
Must be paid before UNO’s final invoice is
submitted to the sponsor
o
Obtain final progress report, if applicable
§
Must be
received on time – as per the subcontract
·
More details are provided in the Subcontract
document
Closeout – At End Date
·
Inform Sponsored Programs Accounting of any
outstanding expenditures
o
Subcontract invoices
o
Invoices for purchased items
o
Etc.
o
Gives knowledge of trailing charges – what needs
to be posted before the final invoice and/or report is submitted to the sponsor
Responsibilities
·
Need to submit the sponsor required forms/reports
and close the award in the UNO financial system
o
Different offices involved
·
Each award may have different requirements
o
Refer to award document
o
Could have audit finding if not met
§
Could lead to UNO returning funds to the sponsor
or loss of potential future funding
Principal Investigator
·
Ultimately responsible for meeting all
requirements
·
Primary responsibility – complete and submit
final progress report and/or deliverable on time
o
If report is to be submitted with financial
report, coordinate with Sponsored Programs Accounting
·
Work with Sponsored Programs Accounting to make
sure all trailing charges have posted to the financial system
·
Work with the Office of Research to closeout
subcontracts, if applicable
·
File patent application, if applicable (contact
Economic Development office for assistance)
·
Submit invention report
o
Some sponsors require even if nothing to report
Office of Research and Sponsored
Programs
·
Monitor due dates for final reports
·
Assist with submission of patent application and
invention report
Sponsored Programs Accounting
·
Prepare financial reports – invoice and financial
status report if applicable
o
Balance expenditures to project budget – some
sponsors will not allow for budget overruns
o
Coordinate with Principal Investigator on
trailing charges
o
Review cost share commitments and balance with
expenditures
§
UNO’s invoice may be reduced if the commitment is
not met
·
Coordinate with Property Control for completion
of a property report
·
Close the award in the financial system
(PeopleSoft) upon receipt of final payment
Emergency Closeout
·
Two main scenarios:
1.
An investigator leaves UNO to take a position at
another university and would like to transfer the award to their new university
o
Must be approved by the respective Chair and
Dean, the Office of Research and the sponsor
o
If all parties approve, the award end date at UNO
will be the investigator’s last day of employment
o
The Office of Research, with information from the
investigator and Sponsored Programs Accounting, will prepare the necessary
transfer paperwork
2.
If the
investigator leaves UNO without transferring the award, retires from UNO or
passes away, the Office of Research can submit a request to the sponsor to
change the principal investigator
o
The investigator or the investigator’s college
and/or department will provide the name of a substitute principal investigator
o
If the sponsor does not approve the change, the
award’s new end date will be the last day the principal investigator was
employed by UNO
·
If the award ends at UNO:
o
All expenditures must stop on the new award end
date
§
Documents must be prepared to change salary
distribution
§
Purchase orders need to be stopped if possible
§
No new supply orders (or anything else) can be
processed
§
Subcontractors need to be notified to cease work
and submit a final invoice
·
The Office of Research will prepare an amendment
to the subcontract
o
Complete all closeout reports
§
If the investigator cannot complete the reports,
someone with knowledge of project must complete and submit to sponsor
o
Sponsored Programs Accounting must complete and
submit the final financial invoice/report and close the award in the financial
system
Remaining Funds
·
Some projects do not use all of the funds awarded
– award total is $50,000 but there were only expenditures for $45,000
·
Treatment of funds depends on nature of award –
cost reimbursable or fixed price
o
Cost reimbursable – UNO prepares an
invoice for the actual expenditures and the sponsor pays that amount
§
Remaining $5,000 is not requested from the
sponsor
·
Sponsored Programs Accounting will only request
reimbursement for the $45,000 actually spent
§
Remaining $5,000 in the budget will be removed
from the financial system
§
Funds are not available for the investigator to
spend
o
Fixed price – Sponsor pays a set amount
for the service to be completed or the item to be provided
§
Assuming the sponsor paid UNO the full award
amount, the funds are available for UNO’s use
§
Indirect cost budget is fully used first
§
AP 19.01 is used to determine how the remaining
funds will be used (see previous discussion)
Reports
·
Different reports required as per the award
document
·
Federal awards must follow Office of Management
and Budget Circular A-110
o
Section .71 Closeout Procedures states:
“Recipients shall submit, within 90 calendar days after the
date of completion of the award, all financial, performance and other reports as
required by the terms and conditions of the award”
o
Must be followed in order to avoid the potential
for audit findings
·
Four potential reports:
o
Patent applications and/or invention report
o
Final financial or expenditure report
o
Final technical or progress report
o
Property or equipment report
Patent/Invention Report
·
Protects UNO’s interest in the invention
·
Submit if the project resulted in a novel product
or process
o
UNO’s Office of Economic Development can provide
assistance
·
Some sponsors require an invention report – refer
to the award document
o
Even if there is nothing to report
o
A Research Administrator from the Office of
Research will be in contact with the investigator
o
May need to submit an interim as well as a final
o
May have to submit a certain form
§
DD Form 882 – “Report of Inventions and
Subcontractors” is the common invention report format
·
Also used when there are subcontracts with a
“Patent Rights” clause
§
Refer to the award document for specifics
§
The Office of Research or Economic Development
can provide assistance
·
If a subcontractor informs UNO of an invention,
UNO has two months to report the invention or UNO loses any rights to it
Technical/Progress Report
·
Different requirements based on the sponsor and
project
o
Some don’t require
o
Some require only a deliverable such as a
software program, a product, seminar, etc.
·
Summary of the project results
o
Compares results to the initial goals of the
project
o
Provides an explanation if the goals were not met
o
Include details of any conference presentation or
article publication
·
UNO’s final invoice may not be paid until the
report is submitted and approved
·
Due dates will vary depending on the sponsor
o
Most federal sponsors require submission within
90 days of the end of the award
o
Louisiana Board of Regents requires receipt of
progress reports by the end date for some awards
o
Refer to award document for details
o
The UNO financial system will send an email to
the investigator and business manager with the due date
·
Sponsors will dictate how the report should be
submitted
o
Paper copy, email, or on-line entry
o
Refer to award document for details
Financial Reports
·
Can include a final invoice and/or a financial
status report
·
Prepared by Sponsored Programs Accounting
·
May need a cumulative invoice
·
Sponsored Programs Accounting will work with the
principal investigator
·
Due dates will vary depending on the sponsor
o
Most federal sponsors require submission within
90 days of the end of the award
o
If UNO is a subcontractor for the sponsor, UNO
may only have one month for submission
o
Late invoices and/or reports could result in an
audit finding and/or an invoice not paid by the sponsor
Property/Equipment Report
·
Identifies the pieces of equipment purchased with
the award funds
·
Sponsored Programs Accounting will work with UNO
Property Control to complete the report and then submit the report
Audits
·
Performed to ensure UNO has complied with
required policies, procedures, rules and regulations
o
UNO, state, and federal policies, procedures,
rules and regulations
o
Terms and conditions of the award
·
Auditors may provide solutions for problems
discovered
o
Will help for future audits
·
Types of auditors
o
Internal auditors
§
Focus on quality control
o
State Legislative Auditors
§
Annual audit required by federal regulations
o
UNO’s cognizant federal agency – U.S. Department
of Health and Human Services
§
Periodic based on tip of possible misconduct or
federal sponsor audit request
o
Award sponsor
§
May examine all aspects of the award
§
Some sponsors perform annual audit
·
One project may be audited by multiple auditors
·
Audit preparation begins at the start of the
project
·
Can audit financial as well as performance
aspects of the project
·
Possible audit findings:
o
Food is an expenditure on a federally funded
award but the proposal did not mention food
o
Personnel Activity Report (PAR – effort report)
shows the principal investigator as being paid 100% from the award, but the
investigator actually worked on two other projects as well
o
Expenditures were transferred to the project
without proper justification
o
A computer was purchased in the last 90 days of a
non-equipment award
o
Federal cost reimbursable award ended more than
90 days ago and still has cash on hand
o
Reports and invoices were not submitted timely
·
Audit findings can lead to repayment of
unallowable expenditures, fines, or reduction in future funding
See
Audit document for more details on audits