SPONSORED PROJECTS CLOSEOUT Pat Dodson, Office of Contracts & Grants James Lei, Sponsored Project Accounting

AWARD CLOSEOUT - Overview Mandated by the sponsor UG (2 CFR 200.343) More applicable to grants FAR (4.704) More applicable to contracts However, each sponsor can have specific requirements Can be simple or complex Common denominator = multiple moving parts

AWARD CLOSEOUT - Overview Definition: A process – to document & assure fulfillment of award T&Cs Determines all required work and administrative tasks are completed All disputes are settled All allowable expenditures are accounted for Property purchased with federal $s accounted for Patents & royalties accounted for Final payments have been made CU releases sponsor from further payments, when applicable Submission/completion needs to be timely & accurate

AWARD CLOSEOUT - Overview Lots of moving parts Two major categories, based on function & focus Financial Contractual Both categories must be completed Only then is the award considered closed

ONE COIN – TWO SIDES Financial Contractual Payments Invoicing Financial draw Cost Share Close SpeedTypes Contractual Final technical report Inventions/patents Property Release of claim Assignment of refunds Subs

AWARD CLOSEOUT - Contractual For Contractual = InfoEd is OCG’s tool Closeout actually starts when we receive award Review all new awards for obligations Record deliverable and closeout requirements Deliverables screen in InfoEd List what it is List due date Can track fulfillment Contract docs may contain required forms From July’15-Dec’16 used Closeout Checklist If already uploaded, will be retained

AWARD CLOSEOUT - Contractual First step toward closeout = Ending Award notices Temporarily suspended with PS 9.2 implementation Will be resuming this initiative Notices sent 1x/month List to PIs will reference by AWARD List to Dept Admin will reference by SPEEDTYPE for the closing awards Both reports = comprehensive list of all awards scheduled to end within 90 days Will assist both financial and contractual Does PI need to request extension? If actually ending, start financial side EARLY

AWARD CLOSEOUT - Contractual OCG’s process driven by obligation deadlines Not necessarily just the end date Also run deliverables report Review the list for priority closeouts Then start working through each award Some sponsors reach out to us

AWARD CLOSEOUT - Contractual Grants pretty straightforward Typically, only few contractual obligations Final technical reports = standard Sometimes property or patents, depending on agency If required, can be all-in-one form or separate reports

AWARD CLOSEOUT - Contractual Contracts get complicated Not a “one size fits all” Can vary along spectrum Depends on the agency or sponsor DoD, DoE, NASA Non-university federal flowthroughs very stringent SwRI JPL Ball Aerospace & Technologies National Labs Sometimes1800 Grant St for signature & CU Seal

RELEASE PROCESS Yes Is Release required? No END Validate interim deliverables done Determine type of Release Yes Is Release required? Validate interim deliverables done Upload final report into infoED No END

RELEASE PROCESS OR END All-in-1 Release Validate invoice, patent, property Final Patent Report (w/TTO) & Final Property Report Complete Close Out Certification process Check box in infoED that all non-financials are complete OR END

RELEASE PROCESS ? Release & Assign Validate interim deliverables done Validate against expenses & payments Release & Assign Are reports needed? ?

RELEASE PROCESS ? END Yes No Are reports needed? Final Patent Report Confirm to Sponsor License Properly Filed Property Report Indirect Cost Report Are reports needed? ? Sign Release & Assignment END No Notified from Sponsor Deobligation needed Deobligation (Opt) Sponsor confirms Closure

AWARD CLOSEOUT - Contractual As with financial side, may need assistance from others PI = technical reports, patents/inventions DRA = Dept Closeout Property Report SPA = if ST not yet inactivated invoicing completed (get copy of final) payments received and posted Grant Accountant = financial review complete Subs/Contracts = Sub completed closeout form

Examples

FINANCIAL CLOSEOUT

EXTERNAL VS. INTERNAL REQUIREMENTS External – 2 CFR 200 “All applicable administrative actions and all required work of the Federal award have been completed by the non-Federal entity.” Internal – University of Colorado Boulder Closeout Procedures

EXTERNAL REQUIREMENT All financial, performance, and other reports must be submitted as required no later than 90 days after the end date. Must liquidate all obligations incurred no later than 90 days after the end date. Awarding agency/pass-through entity must make prompt payments for allowable costs.

EXTERNAL REQUIREMENT Non-Federal entity must promptly refund any unobligated cash. The non-Federal entity must account for any real and personal property. The Federal agency/pass through should complete all closeout actions no later than one year after receipt and acceptance of all final reports.

POST CLOSEOUT Recover funds on the basis of a later audit or review. Return any funds as a result of collections or other transactions. Audit requirements. Property management and disposition. Records retention.

INTERNAL REQUIREMENTS Grant closure in PeopleSoft. Transactions clean up – See Cost Principles Policy Statement, who has the primary responsibility for the project? Encumbrances, P-Card Cost Transfers PETS Review Expenditures Review Budgets Cost Share F&A Effort Reporting

INTERNAL REQUIREMENT Final Invoice and FFR Financial Statements clean up: Residual/Overdraft Receivables Revenue Project Resource Assets and Liabilities

INTERNAL REQUIREMENTS Close out ST in PeopleSoft Inactivate ST Change project status Enter retire date Administrative Clean up files/Record retention Notification

INTERNAL REQUIREMENTS Closeout Contract in PeopleSoft: Closeout bill plan Closeout revenue plan Change award status Closeout the contract

CURRENT CLOSEOUT STATUS Projects closed since 08/2017 1,700 Projects remained to be closed Ended prior to 01/01/2017 890 Ended between 01/01/2017 and 02/28/2018 1,000

MAJOR ISSUES-INTERNAL Residual balance Ready to be closed Deficit In-Review with the departments Unallowable Others

MAJOR ISSUES-EXTERNAL AR/Billing issues Missing payments System issues NIH carry forward