Effective Closeouts Hints and Systems

1. Effective CloseoutsHints and Systems Pam Whitlock Director, Sponsored Programs University of North Carolina Wilmington

2. Critical Points When the proposal is designed!!!!!! When the award is accepted Extensions/Supplements Prior to termination At termination

3. 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…???

4. Issues To Consider Time constraints - yours, subs, vendors MIS System Lead time Documentation required Retention requirements Format

5. Management Information Systems…Getting the word out Tracking system for termination dates Cost sharing documentation Building in lead time Notifying everyone Stopping charges Personnel issues

6. Effectively Communicating Grant & Contract Procedures Sponsored programs office Grants accounting Campus departments Partners Administration Sponsor Central admin communication w/ campus depts. - compliance training via web, formal and informal training. Central admin. Communication w/ sponsors -process improvements, development, notification Campus depts. Communication w/ sponsors - requesting approvals - Central admin communication w/ campus depts. - compliance training via web, formal and informal training. Central admin. Communication w/ sponsors -process improvements, development, notification Campus depts. Communication w/ sponsors - requesting approvals -

7. Suggested Methods Check lists Tickler files Reconciliation Education

8. What you need…to 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

9. 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)

10. Planning Ahead Internally Organizational requirements and policies Accounting system Fiscal year constraints Early notice Over expenditures Clear procedures and responsibilities

11. Planning Ahead, Sponsor Needs Deadlines for reports Types of reports Restrictions on extensions Details required for reports Sub reports

12. Types of Closeouts Total program Same program/new award Transfer of project Suspension and termination

13. Considerations on Subagreement Due dates – yours, theirs, sponsor Scope of work Intellectual property rights Integration of final programmatic report

14. Transfer of Grants Request/Receive Approval from Agency Grant transfers to another institution Substitute Principal Investigator is approved Negotiate subagreement

15. Fixed Price Contracts Close-out Cost overruns Remaining balances F&A cost recovery UBIT liability Organizational policies

16. 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

17. 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 F&A costs, examples of allowable direct and F&A costs. A-122 same for non-profits. OMB Circular A-133 Audits of States, Local governments and Non Profit Organizations

18. 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

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

20. Mandatory Cost Sharing Required by the sponsor as a condition of the award. If it’s included in the proposal, it’s mandatory Must be met by expiration for reporting purposes. Failure to meet obligations could have an adverse impact on the University’s ability to obtain future federal funds. Must be documented.

21. 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

22. 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.

23. Reports Final FSR Final “draw” Final Progress Report Final Invention Report (some) Within 90 days May request an extension

24. Implications of Late Invoices/Reports Cash Future Funding Unallowable Costs Expanded Authority Inability to draw funds (Letter of Credit) Cash- late invoices may not be paid or payments may be delayed. Late reports may result in non payment. Future funding- sponsors may require final reports before they will release supplements and renewal funds. Unallowable costs- cost reported after the required due date may result in a disallowance. Expanded authority- failure to submit reports in a timely manner may result in the loss of expanded authority. Inability to draw funds- sponsors may withhold authorization through the letter of credit process if reports are not submitted in a timely manner. Cash- late invoices may not be paid or payments may be delayed. Late reports may result in non payment. Future funding- sponsors may require final reports before they will release supplements and renewal funds. Unallowable costs- cost reported after the required due date may result in a disallowance. Expanded authority- failure to submit reports in a timely manner may result in the loss of expanded authority. Inability to draw funds- sponsors may withhold authorization through the letter of credit process if reports are not submitted in a timely manner.

25. 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.

26. 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

27. Close-Out Requirements OMB Circular A-110, Subpart D: After-the-Award Requirements Purpose is to establish procedures for close-outs, disallowances and adjustments

28. 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

29. 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

30. 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

31. 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

32. 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