Project Closeout

Closeout Timeline

Closeout Timeline Example

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
      • Federal regulations
      • Justification -not useful for the project if purchased at the end of the project
    • No new transactions past the end date
      • Do not place orders for supplies, copying, etc. after the end date
      • 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
    • Sent to Principal Investigator, business managers and the Office of Research
    • Automatically sent from the UNO financial system (PeopleSoft)
    • Do no reply to the email – email the Office of Research if there are questions
      • Contact information is located on the Office of Research contacts page or within the Office of Research SharePoint site 
    • 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
    • Refer to AP 19.01
    • Assuming the project is completed (submit all required deliverables) by the project end date
    • 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
    • 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
    • Each sponsor will be different
    • Must be submitted by the sponsor's deadline
    • 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
    • Payroll
      • Complete paperwork to change the source of funding
      • Submit before the end date
    • 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:
    • 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
    • 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
    • Subcontract invoices
    • Invoices for purchased items
    • Etc.
    • 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
    • Different offices involved
  • Each award may have different requirements
    • Refer to award document
    • 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
    • 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
    • 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
    • Balance expenditures to project budget – some sponsors will not allow for budget overruns
    • Coordinate with Principal Investigator on trailing charges
    • 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
      • Must be approved by the respective Chair and Dean, the Office of Research and the sponsor
      • If all parties approve, the award end date at UNO will be the investigator's last day of employment
      • 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
      • The investigator or the investigator's college and/or department will provide the name of a substitute principal investigator
      • 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:
    • 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
    • Complete all closeout reports
      • If the investigator cannot complete the reports, someone with knowledge of project must complete and submit to sponsor
    • 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
    • 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
    • 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
    • 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"

    • Must be followed in order to avoid the potential for audit findings
  • Four potential reports:
    • Patent applications and/or invention report
    • Final financial or expenditure report
    • Final technical or progress report
    • 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
    • UNO's Office of Economic Development can provide assistance
  • Some sponsors require an invention report – refer to the award document
    • Even if there is nothing to report
    • A Research Administrator from the Office of Research will be in contact with the investigator
    • May need to submit an interim as well as a final
    • 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
    • Some don't require
    • Some require only a deliverable such as a software program, a product, seminar, etc.
  • Summary of the project results
    • Compares results to the initial goals of the project
    • Provides an explanation if the goals were not met
    • 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
    • Most federal sponsors require submission within 90 days of the end of the award
    • Louisiana Board of Regents requires receipt of progress reports by the end date for some awards
    • Refer to award document for details
    • 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
    • Paper copy, email, or on-line entry
    • 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
    • Most federal sponsors require submission within 90 days of the end of the award
    • If UNO is a subcontractor for the sponsor, UNO may only have one month for submission
    • 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
    • UNO, state, and federal policies, procedures, rules and regulations
    • Terms and conditions of the award
  • Auditors may provide solutions for problems discovered
    • Will help for future audits
  • Types of auditors
    • Internal auditors
      • Focus on quality control
    • State Legislative Auditors
      • Annual audit required by federal regulations
    • 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
    • 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:
    • Food is an expenditure on a federally funded award but the proposal did not mention food
    • 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
    • Expenditures were transferred to the project without proper justification
    • A computer was purchased in the last 90 days of a non-equipment award
    • Federal cost reimbursable award ended more than 90 days ago and still has cash on hand
    • 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