Effective Closeouts Hints and Systems

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Effective CloseoutsHints and Systems

• Pam Whitlock
• Director, Sponsored Programs
• University of North Carolina Wilmington

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Critical Points

• When the proposal is designed!!!!!!
• When the award is accepted
• Extensions/Supplements
• Prior to termination
• At termination

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Why Start Early?

• Identify problematic issues
• Include justification in proposal
• Document as you go along
• Identify special issues to be handled
• Define activities within institutional
  capabilities and???

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Issues To Consider

• Time constraints - yours, subs, vendors
• MIS System
• Lead time
• Documentation required
• Retention requirements
• Format

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Management Information SystemsGetting the word
out

• Tracking system for termination dates
• Cost sharing documentation
• Building in lead time
• Notifying everyone
• Stopping charges
• Personnel issues

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Effectively Communicating Grant Contract
Procedures

• Sponsored programs office
• Grants accounting
• Campus departments
• Partners
• Administration
• Sponsor

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Suggested Methods

• Check lists
• Tickler files
• Reconciliation
• Education

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What you needto know the rules!

• Familiarity with the agency costing principles
• Award terms and conditions
• All reference documents listed in the award but
  not attached
• Financial records
• Approvals, justifications, modifications

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The Backbone

• Circular A-110
• Uniform Administrative Requirements for Grants
  and Other Agreements with Institutions of Higher
  Education, Hospitals and Other Non-Profit
  Institutions
• Circular A-21
• Cost Principles for Educational Institutions
  (A122)
• Circular A-133
• Audits of States, Local Governments, and
  Non-Profit Institutions (also includes Circular
  A-133 Compliance Supplement)

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Planning Ahead Internally

• Organizational requirements and policies
• Accounting system
• Fiscal year constraints
• Early notice
• Over expenditures
• Clear procedures and responsibilities

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Planning Ahead, Sponsor Needs

• Deadlines for reports
• Types of reports
• Restrictions on extensions
• Details required for reports
• Sub reports

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Types of Closeouts

• Total program
• Same program/new award
• Transfer of project
• Suspension and termination

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Considerations on Subagreement

• Due dates yours, theirs, sponsor
• Scope of work
• Intellectual property rights
• Integration of final programmatic report

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Transfer of Grants

• Request/Receive Approval from Agency
• Grant transfers to another institution
• Substitute Principal Investigator is approved
• Negotiate subagreement

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Fixed Price Contracts

• Close-out
• Cost overruns
• Remaining balances
• FA cost recovery
• UBIT liability
• Organizational policies

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Sponsor Regulations

• Applicable only to the award on which they are
  listed.
• Can be more restrictive than Federal Agency
  Regulations and Federal Regulations
• Identify who will prepare fiscal reports

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Federal Regulations

• The OMB Circulars provide guidance to federal
  agencies.
• OMB Circular A-110 - Guidance for administrative
  processes - cash management, reporting, program
  income
• OMB Circular A-21 - Guidance on calculating FA
  costs, examples of allowable direct and FA
  costs. A-122 same for non-profits.
• OMB Circular A-133 Audits of States, Local
  governments and Non Profit Organizations

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Allowability of Costs OMB A-21

• Must be reasonable
• Must be allocable to sponsored agreement
• Must be given consistent treatment
• Must conform to any limitations or exclusions
• Cost transfers well documented
• Effort documented

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Contracts

• Contracts generally have more requirements than
  grants
• On federal contracts a contractors release is
  required at the expiration of the contract
• Generally require monthly or quarterly reporting
  using a standard contract report format (2076).

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Mandatory Cost Sharing

• Required by the sponsor as a condition of the
  award.
• If its included in the proposal, its mandatory
• Must be met by expiration for reporting purposes.
• Failure to meet obligations could have an adverse
  impact on the Universitys ability to obtain
  future federal funds.
• Must be documented.

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Financial Reporting

• Methods of Payment - Letter of Credit, Cost
  Reimbursable Pay in Advance
• Due Dates - generally 90 days after expiration
• Special forms
• Common reporting periods - covering entire
  period, annually, semi-annually, quarterly,
  monthly

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Technical Reports

• Contents of Technical or Performance Reports
• Comparison of actual accomplishments to goals
  established for the awarded period
• Findings/results from the project
• Reasons why the expected goals were not met
• Explanations, when appropriate, of high unit
  costs, cost overruns, excessive carryovers, etc.

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Reports

• Final FSR
• Final draw
• Final Progress Report
• Final Invention Report (some)
• Within 90 days
• May request an extension

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Implications of Late Invoices/Reports

• Cash
• Future Funding
• Unallowable Costs
• Expanded Authority
• Inability to draw funds (Letter of Credit)

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Record Retention

• OMB Circular A-110, Subpart C, 53 Retention and
  Access Requirements for Records
• Federal awarding agencies shall not impose any
  other record retention or access requirements
  upon recipients.

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Record RetentionThree Years UNLESS

• Litigation requires retention until resolved
• Real property and equipment records retained for
  3 years from date of final disposition
• When records are transferred to or maintained by
  the Federal agency, the retention requirement
  ends

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Close-Out Requirements

• OMB Circular A-110, Subpart D
  After-the-Award Requirements
• Purpose is to establish procedures for
  close-outs, disallowances and adjustments

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Close-Out RequirementsOMB Circular A-110

• All reports must be submitted within 90 days
• All obligations must be liquidated within 90 days
• Agency must make prompt payment
• Recipient shall refund any unobligated cash
  advance

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Close-Out RequirementsOMB Circular A-110

• Agency makes adjustments after reports are
  received
• Recipient must account for real and personal
  property
• Agency retains right to recover disallowances
  until final audit

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Close-Out

• Close-out of an award does not affect any of the
  following (A-110, Subpart D, 72)
• Right of agency to disallow and recover funds
• Obligation of recipient to return funds due as a
  result of refunds
• Audit requirements of Subpart C, 26
• Property management requirements in Subpart C, 31
  37
• Records retention as required in Subpart C, 53

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Close-Out

• OMB Circular A-110, Subpart D, 73 Collection of
  Amounts Due
• Any funds paid to a recipient in excess of the
  amount to which the recipient is finally
  determined constitute a debt to the Federal
  Government
• Administrative offset against other awards
• Withhold advance payments
• Other actions permitted by statute
• May charge interest on unpaid amounts

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Summary

• Review early and often for compliance
• Know deadlines and adhere to them
• Understand reporting requirements
• Purge file
• Retain for specified period usually 3 years
• Audit findings