Closeout Procedures
Closeout
Overview
Closeout is the process in which the awarding agency determines that all applicable administrative actions and all required work with the award have been completed by the recipient. Closeout is a post Award activity that officially ends the award relationship.
Closeout starts the day you begin to think about your proposal. Effective research administration over the life of the award will help eliminate problems at closeout. Manage the project closely during the award, not just during the 90 days after the end of the award. Keep faculty and staff informed of the rules.
Set up early and extended PTAs. Review PTAs regularly to avoid last minute transfers. All expenses must post to the PTA within 60 days of the project end date.
Federal Sponsor Requirements
Federal sponsors have a requirement that closeout documents be submitted to the government within 90 days after the end of the period of performance; therefore the research administrator must ensure that expenses are complete and have posted to the PTA within 60 days of the project end date.
The Office of Sponsored Research (OSR) reviews sponsored projects at closeout to ensure that costs are allowable, allocable, reasonable, and consistent. OSR then prepares the final financial report and submits it to the sponsor.
Sponsors have up to four years after the official closeout date to conduct a closeout audit. It is also critical that the PI submit all technical and invention reports that are due.
Reports
During closeout Stanford must submit all required financial, performance, and other reports as required by the award, and liquidate all obligations incurred under the award. Sponsors must make prompt payments for allowable, reimbursable grant costs. The award notice specifies the closeout report requirements.
| Report | Detail |
|---|---|
| Technical Report |
Does the report include:
|
| Financial Report |
OSR will prepare the final financial report and submit it to the sponsor. Sponsors have up to four years after the official closeout date to conduct a closeout audit. All financial records should be retained for a minimum of four years after closeout, longer if circumstances require it. The four-year retention period can be expanded in the case of lawsuits, patent applications, charges of misconduct, conflict of interest, etc. Have all project expenditures been posted, i.e., have they appeared on monthly expenditure statements? Are all project expenditure statements certified? Is the summary of expenditures (for NIH awards) certified? |
| Invention Report |
Does your report include:
|
| Property Report |
Have you identified all materials and equipment acquired under this award, including property that was:
Equipment records must be kept for four years after final disposition of equipment or four years after project closeout, whichever is later. |
Checklists and Procedures
Use these checklists to make sure you complete closeout activities.
| Checklists |
| Federal Award Closeout Checklist |
| Non Federal Award Closeout Checklist |
| Advance Award Closeout Checklist |
| Final Award Closeout Checklist |
| Clinical Trial Closeout Checklist |
The School of Medicine outlines its closeout procedures on the RMG website.
Clearing an Overdraft After the Award End Date
If an error is discovered after the end of the award, a transfer of expense should be made by removing the expense prior to award closeout.
If after the end date of an award an expense is determined to be unallowable to the project (but did benefit the project), the expense must be transferred to a Cost Sharing PTA for accounting purposes, although it cannot be counted towards a Cost Sharing commitment.
Documentation
The documentation of a cost transfer made after a project end date will be closely scrutinized. In addition to including all the necessary element of a cost transfer justification large cost transfers that exceed $10K or 10% of the award, and transfers within the first or last 90 days of a project, and transfers that do not meet the timeliness criteria receive additional central review. For the transfer of all non-salary charges subject to the above criteria, a PDF of the general ledger** showing the expenditure(s) requesting to be moved MUST be attached to the cost transfer transaction by the originator. Attaching detailed documentation for these transfers will facilitate their timely review by the Office of Sponsored Research (OSR).
Examples
These charges are for effort expended before [insert Project Y’s end date] and they are appropriate per the Project Y award agreement.
These charges could not be processed in a timely manner because PI Smith was traveling in Mongolia, and was not available to review and approve the charge.
If a Project Ends In Overdraft
An overdraft exists if after the end date of an award expenses exceed funding.
If the award is in overdraft at the end of the project period, remove the overdraft from the award according to rules outlined in Stanford Policy. Federal regulations state an overdraft is unallowable on any other sponsored project, therefore unless there was an error, the overdraft must be treated like cost sharing. This must be done in a timely manner. Expenses removed as a result of an overdraft should have been incurred during the last 6 months of the project.
- Do it in a timely manner
- If total overdraft is less than $500, transfer lump sum (net of indirect costs) Expenditure type 56135 (which allows the Cost and Management Analysis group to segregate these costs for purposes of indirect cost calculation)
- If the overdraft is greater than $500 dollars the overdraft is transferred to a cost sharing PTA.
- Explain reason for the transfer. For example: Charges are legitimate project expenses, but funds were inadequate. This is accounted for in the same manner as cost sharing.
Subaward Closeout
A subaward is closed out when its period of performance comes to an end, regardless of whether Stanford's research project is ending or continuing. When feasible, it is advisable for a subaward period of performance to be slightly shorter than Stanford's to allow sufficient time for collection and review of the subrecipient's final reports, verification of subrecipient data, and incorporation of the subrecipient's research results into Stanford's final technical report to the sponsor.
PIs are responsible for obtaining final technical reports from their subrecipients, and retaining a copy in their project file. PIs are encouraged to remind subrecipients of this need well in advance of the due date for such reports.
Other final reports, including property reports, patent reports, small/small disadvantaged business reports, and Assignment and Release documents may be required. PIs and departments may be asked to assist OSR in obtaining necessary closeout reports from the subrecipient in a timely manner.
In order for Stanford to comply with its financial report requirements, subrecipients are required to submit a final invoice, clearly marked “Final”, to Stanford by the date that is required in the subaward agreement, typically no later than 60 days after the end of the Subrecipient's period of performance. In the event no invoice is received within the required timeframe, Stanford may treat the Subrecipient's last invoice as the final invoice. Payment for Subrecipient invoices submitted to Stanford later than the due date may not be paid. PIs and departments are responsible for assisting OSR in obtaining final closeout information, including final invoices, from their subrecipients.
The PI and Administrator |
OSR |
|---|---|
|
Ninety days before the end date of the subaward, confer with the subrecipient to determine whether work will be completed on time. If not, request a no cost extension from the prime sponsor. If a no cost extension is granted, pass it through to the subrecipient. Review the period of performance of the subaward and initiate closeout actions before completion of the subaward, or earlier as designated in the terms & conditions of the subaward. Ensure the invoice marked Final has been paid before the end date of the prime award. Process the invoice through Accounts Payable. Send OSR a copy of the invoice marked Final. Ensure final technical reports are submitted within the contractually specified days of the subaward end date. Receive and incorporate all reports as required by the sponsor. |
Obtains the subrecipient’s release and subrecipient’s assignment of refunds, rebates, credits and other amounts, if applicable. Receives a copy of subrecipient's approved invoice marked Final |
