Facilitating Closure of Sponsored Projects Award Close-Out Facilitating Closure of Sponsored Projects

What is Close-Out? The final reconciliation and reporting of expenses and activities of the project, required by the sponsor Combined effort among Principal Investigators, Department Administrators and Sponsored Program Administration

Close-Out begins during the life of the grant Expenses should be monitored for accuracy at least monthly Ensure that all required technical reports are completed and submitted Reporting requirements are time sensitive Non-compliance can lead to debarment of the PI from receiving funds from the sponsor Can also affect future funding from the sponsor for the entire university

Reports Most sponsors require a standard set of reports for award close-out: Final Technical Report Final Financial Report Final Invention or Patent Report Final Equipment Report Miscellaneous Articles of Incorporation The schedule for submitting required financial reports is generally specified in the award documents of a grant or contract.

Reports – in Detail What information is required? Technical A statement of progress toward the originally stated aims; A list of all significant results, both positive and negative; A list of publications, if any, resulting from the project; A description of any data, research materials or other information that is available to be shared with other researchers

Reports – in Detail Financial A statement of expenditures sent to the sponsor of a grant or contract; prepared and submitted by SPA on behalf of the Principal Investigator (PI). Financial Status Reports (FSR) are usually due at the end of both the Budget Period and Project Period within 30-90 days after the expiration date, depending on sponsor’s guidelines, and may be required at interim times as well.

Financial Reporting – Information to Consider Direct Cost Overview – Provide the amount of the balance or deficit of the index as of the memo date. Award Compliance – Review and verify that the award terms and conditions were met. If there are issues, SPA should be notified. Extension Check – Alert the SPA accountant if an award extension is being requested. Contact SPA grant/contract officer and coordinate submission of the extension request. The SPA accountant will make note of this, and will continue to review the index until the extension becomes official. Open Commitments – Verify the commitments/encumbrances still charged on the grant. This is to determine if there are any pending expenses that have not been paid. If the encumbrance will be closed, they should notify the report accountant, and close out the encumbrance. If there is a pending expense, invoices must be provided to the report accountant to include on the financial report. Expenditure Review – Review all expenses charged to the award and verify they are correct. Award terms and conditions should also be reviewed to verify if there are any expense restrictions. If there are corrections needed, they should communicate with the report accountant and submit Expense Transfer Request forms as needed. For Federally funded awards, expenses must also be verified that they are deemed allowable due to A-21 guidelines. If there are missing expenses, backup should be provided to the SPA accountant to include on the financial report. [Note: The Cognos report, “A21 Cost Restriction Report”, can be run to gather expenses in A-21 questioned account codes.] Payroll – Review and verify all personnel were correctly charged to the award. The DA should review the budget to verify the level of effort budgeted versus the actual effort paid. If there are errors or corrections needed, copies of the CLDRs should be sent to the report accountant to include on the financial report.

Salary Cap – Review and verify that the agency’s salary cap guidelines were followed. Amounts over the salary cap will be transferred to the corresponding cost share index. STU/TE Roles –Review personnel paid as students/technicians, and to provide their role/responsibility. This is asked for Federally funded awards, as they generally do not allow administrative duties to be paid directly from the award funds. Cost Sharing – Review the cost sharing index and third party backup to make sure any cost sharing was completed accurately. Verify personnel’s level of effort is correct and for the time period of the award based on the budget. This effort level review should also consider any extension periods of the grant. Depending on the award, this information may have to be provided on the report to the agency (mandatory cost sharing). Program Income – Review whether the project earned program income and to provide documentation to the report accountant. Tuition/Stipends – Verify that the tuition and stipends paid were correct, and to list who received them. Please note that students should be payroll charged at the same percentage to this restricted account unless there are special circumstances. Tuition is considered a fringe benefit. Stipends should only be paid to non-WSU individuals, and generally only for training and fellowship grants Foreign Travel – Verify foreign travel was budgeted and allowable. If a Federally funded grant, verify all foreign travel met the Fly America Act guidelines.

Account Codes - Are expenses charged to the correct account code Account Codes - Are expenses charged to the correct account code? If not, the SPA Accountant should be notified to make corrections. Subcontracts - Have final invoices been received? Contract subcontractors to verify submission of all invoices. Forward copies of unpaid invoices to SPA Accountant for inclusion on the financial report. Deficit Clearance - If there is a deficit, provide an unrestricted index number to the SPA Accountant to make necessary transfer. Agency Correspondence - Provide all correspondence to sponsors regarding rebudgeting requests, variance explanations and/or carry forward requests; correspondence will be included in financial report. Additional Information - Alert the SPA Accountant of additional relevant information. Detailed backup may be required by the sponsoring agency including a narrative report.

Reports – in Detail Invention/Patent If any new technology is derived from work on a sponsored project, it must be reported to the sponsor Negative reports must also be generated PIs are responsible for initiating report Processed through SPA GCO who works with WSU Technology Commercialization to finalize and submit reports

Reports – in Detail Property The university must account for any real or personal property acquired with the use of federal funds Any equipment purchased must be identified Cost Make Model Serial number WSU inventory number If the terms of the award do not automatically give title to the University, a letter is sent to the agency requesting transfer of title to the University. All required reports regarding property and equipment are processed through SPA in conjunction with WSU Fiscal Operations in obtaining necessary signatures for completion and submission of reports

ROLE RESPONSIBILITY Technical Report Financial Report Property Report Invention/Patent Report Property Report Principal Investigator Develops and submits Works with SPA to ensure accuracy Provides initial information/completes paperwork Initiate report; work with SPA to ensure proper completion and submission Department Administrator Assists as necessary Sponsored Program Administration Ensures submission or submits on University’s behalf Prepares; works with PI to ensure accuracy; submits on University’s behalf Works with PI and Technology Commercialization; submits on University’s behalf Coordinate with PI and Fiscal Operations to ensure completion and submission

Principal Investigator Department Administrator Determines allocability of costs. PI has firsthand knowledge of project and has primary responsibility for determining whether or not a cost benefits a project Assists PI in utilizing the Researcher’s Dashboard and other administrative tools Monitors expenditures using the Researcher’s Dashboard Works with SPA on fiscal matters Notifies SPA of any significant changes to the project – e.g. change in scope of work or level of effort Communicates with SPA any errors or problems with account Understands terms and conditions of the award Obtains necessary approvals for project changes – e.g. No-cost extensions, re-budgeting Submits all required periodic non-financial reports Ensures costs are within sponsor and university guidelines Initiates payroll changes, purchases, travel, etc. Monitors project expenditures and use of funds Coordinates fiscal aspects of close-out

Procedure Most often, reporting requirements or links for information regarding close-out reporting can be found within the award or contract document.

Many sponsors list reporting requirements on the Notice of Award National Institutes of Health National Science Foundation

Procedure Some sponsors have streamlined the process whereby reports can be uploaded within the agency system. National Science Foundation – Fastlane National Institutes of Health - eCommons

Grantees can track grants that are in closeout status Grant Closeout- eRA Commons Purpose: Allows grantees to electronically file information necessary for completion of closeout requirements Features: Grantees can track grants that are in closeout status Grantees can use the module to submit required closeut reports – reports can be submitted independently but closeout is not complete until all reports have been submitted and accepted by the NIH awarding unit The Financial Status Report portion of Closeout actually links the external user to the separate FSR system within eRA Commons Benefit: Keeps track of the multiple reports needed to close out a grant and reminds grantees of the importance of providing the Federal Government with timely and accurate information

Close-Out for NIH Awards Processed through eCommons After initial log-in and search under PI name, a list of grants populates and, if closeout is necessary, it will be indicated in the Actions column.

After selecting the Requires Closeout link, a list of reporting requirements and corresponding Statuses and Actions populates. Select report to process.

TIPS for CLOSEOUT Review terms and conditions of the award at establishment to determine the closeout timeframe. Create reports to track projects nearing closeout. Coordinate with your post-award administrator at the Office of Grants & Contracts to determine division of duties in the closeout process. Prepare and use a closeout checklist. Know in advance that a project will require an extension.  Understand how to obtain an extension. (Prior approval letter, contract amendment, etc) Reconcile funds properly and ON TIME. Pursue final invoices from subcontractors, and ensure all other pending expenses are processed and posted to the general ledger. Ensure all outstanding encumbrances in the general ledger have been resolved and zeroed out. Remove or re-designate salaries and other recurring charges immediately before termination of the project. Review sensitive and administrative type expenses on a continuing basis leading up to the closeout. Review expenses in the last 90 days of the project and subsequently after the project end date to ensure appropriateness. Transfer off any unallowable expenses before closeout, if any. Ensure all personnel effort reports have been certified. Ensure cost sharing requirement and reporting have been met, if applicable. Confirm with the PI that the project is programmatically and financially ready for close out (you may document this communication and include it in the closeout/project file) Close out multi-year awards; if necessary request prior approval for carry forward balances and/or process internal paperwork accordingly. Request a pre-award spending account for the next budget period (if new projects are created for each budget year of the award) before the current budget period ends. Meet deadlines for technical and financial reporting requirements of the sponsor. Close out projects within 90 days from the budget end date. Establish residual accounts in advance (only applies to fixed price grants and contracts.) Additional approval for keeping residuals may be required. Retain appropriate records, per the guidelines of the individual sponsor where applicable. Include in the project file noting the date closed, final financial reports, and any other relevant documents produced from the closeout process.