GAP 200.180, Closeout of Sponsored Project

  1. General
  2. Submission and  Processing of Closeout Documentation
  3. Management of Late Activity
  4. Procedure for Closing Projects Without Established End Dates
  5. Issue Escalation
  6. Resource

I. GENERAL

When a sponsored project is ending, it is imperative that certain procedures are followed to ensure the University meets sponsor reporting requirements. Costs charged to the project should be stopped as of the project end date with very limited exceptions. The “Closeout Period” represents the time during which the research administrator must complete all closeout activities for the sponsored project. This period includes the 90 days before the project ends and runs through the Closeout Docs Due Date (for internal documents) and the Sponsor Due Date (for the final report/invoice). During the Closeout Period, all project expenses should be confirmed for allowability, allocability, reasonableness, and consistent application, as well as completeness; closeout documents are due by the Closeout Docs Due Date to ensure the final report/invoice is submitted by the Sponsor Due Date. Refer to the Projects Approaching End Date (pdf) or Project Obligations (pdf) reports to determine the Closeout Docs Due Date and the Sponsor Due Date.

If cost transfers and/or expenditures post late or closeout documentation is submitted late, financial reporting may be delayed to sponsors and the chance of the cost being disallowed is substantially increased. Please see GAP 200.150, Cost Transfers on Sponsored Projects for additional guidance.

In light of Federal enforcement on both reporting and drawing/billing of funds, it is critical that all applicable deadlines are met. The time period leading up to the Project End Date through the Sponsor Due Date is a critical window requiring proactive oversight and management to safeguard institutional and sponsor funds and reduce the risk of non-compliant reporting.

The Sponsored Projects Closeout Timeline Quick Reference Guide (pdf) provides research administrators with a timeline and associated tasks/responsibilities that facilitate a timely and effective closeout. Automated email reminders are sent at specific intervals to the research administrator, business manager and PI. These notifications serve as reminders of the Project End Date, the Closeout Docs Due Date and the required closeout documentation.

The Closeout Tasklist is required as part of the closeout documentation. It is intended to facilitate the completion of necessary processes and documentation throughout the closeout process. The submission of this document communicates that the WBSE has all appropriate activity posted to the general ledger and the final financial report or invoice is ready to be completed and submitted to the sponsor.

Upon receipt of closeout documents, the Implementation Teams and the Office of Sponsored Programs (OSP) review closeout documents for accuracy and completeness prior to submission of the final report and/or invoice.

II. SUBMISSION AND PROCESSING OF CLOSEOUT DOCUMENTATION [Reportable Projects: 20x-28x and 30x-38x]

The following closeout documentation is required to be submitted by the department by the Closeout Docs Due Date. The timely and accurate submission of these documents is critical to ensure that the University receives reimbursement for incurred expenses and does not generate unnecessary financial risk:

  1. Closeout Tasklist: including the appropriate grant manager (and business manager if applicable) attestation.
  2. PI Attestation: completed independently from the Closeout Tasklist but should be submitted with the Closeout Tasklist.
  3. Obligation Worksheet: required for institutional training grants funded by NIH.

By the sponsor-driven internal deadline, all appropriate financial transactions and project related activity is posted to the project WBSE before submitting closeout documents for final financial report preparation.

Overdrafts (allowable expenses in excess of the award/revenue amount) will be transferred by OSP to the WBSE’s backstop code that is reflected in Master Data. Grant Managers must not remove expenses from a project that are allowable, allocable and reasonable; to ensure institutional reporting of sponsored activity is accurate, overdrafts can only be removed by OSP.

OSP will approve submission of the required final financial report or invoice to the sponsor only after acceptable closeout documentation is received from the department.

After all of the project’s closeout documentation requirements have been satisfied, the final financial report/invoice has been submitted, and the project’s balance in SAP is zero, OSP will close the WBSE(s).

III. MANAGEMENT OF LATE ACTIVITY

Submission of the Closeout Tasklist will update the WBSE user status to “FINL”. Once a project is in this final state, a nightly automated email notification will be sent to the GM1 and GM2 for any additional activity that posts to the WBSE. Details for each transaction will be provided, including whether the expense was automatically transferred off or not. The grant manager is responsible for reviewing all late transactions identified in the email notification and following up as appropriate. Timely response to these notifications is critical to ensure an effective and timely closeout. Management of Late Activity Notifications Quick Reference Guide (pdf) provides additional guidance on determining follow up action.

The FINL status will enable an automated Transfer Off JV (Doc Type YF). In a nightly posting, many types of late expenses will be transferred to the WBSE backstop code. Grant managers should review these expenses to understand if any additional action is needed to appropriately assign the expense.

A few expense categories are excluded from this process and must be reviewed manually. Grant managers must contact their Implementation Team as soon as possible to resolve any late activity not automatically transferred off with a YF-type JV:

  • Payroll and associated expenses
    Payroll corrections must be completed through iForms transactions for effort tracking. Grant managers must contact their Implementation Team to resolve, either through cost sharing or with a cost distribution if the payroll has posted to the WBSE in error. Departments should understand and communicate any associated tuition remission and cost sharing that may be impacted by iForms transactions.
    G/L accounts: 600000-619999, 634700, 808000
  • Credits
    For cost-reimbursable projects, credits received after project closeout must be returned to the sponsor. Therefore, credits posting after Tasklist submission will be included in final reporting unless otherwise indicated by the Department. If it is determined that the credit is not appropriate, contact the Implementation Team as soon as possible.
  • Subrecipient invoice payments
    Subrecipient invoices can be received after Tasklist submission and are an expected and allowable type of late activity. These payments go through departmental review and approval through the eCR workflow process. Approval of subrecipient invoices received after their due date is guided by GAP 200.285, Subrecipient Invoicing: Late Final Invoices. No additional action is required from the departments at the time these expenses post to the ledger.
    G/L accounts: 691641-691660, 691675-691679, 697141-697160, 697175-697179
  • F&A and OSP-specific activity
    F&A adjustments, cost overrun transfers, and residual balance transfers are final transactions completed by OSP at the time of project closeout. No action is required from the departments for these transactions.
    G/L accounts: 694600, 696700, 696800, 752800-753200, 756700, 756800, 801325

IV. PROCEDURE FOR CLOSING PROJECTS WITHOUT ESTABLISHED END DATES [Non-Reportable Projects: 29x and 39x]

When the project’s balance in SAP has been zero with no financial activity for at least one month, the department must notify Treasury Billing Services (TBS) in writing to close the WBSE(s). TBS will then close the WBSE(s), thus allowing for no further transactions. Industry-sponsored clinical research managed by School of Medicine units must have a Closeout Tasklist submitted to the appropriate School of Medicine office(s) to support the closeout processes for this type of project. Once the School of Medicine steps are complete, the completed Closeout Tasklist should then be included with the email request to TBS to close the WBSE.

V. ISSUE ESCALATION

The nature of complex research often leads to multiple inter-dependencies that span the institution. Due to the urgency inherent in the closeout process, the timely escalation of issues is critical. Unresolved issues that may impact these deadlines should be escalated as appropriate to the business manager, chair’s office, dean’s office or management center’s Implementation Team, as applicable. Please refer to GAP 200.190, Parent/Child Sponsored Project Management for specific issues related to Parent-Child relationships.

VI. RESOURCES

Note: This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.