GAP 200.180, Closeout of Sponsored Project

Contents

1. Purpose
2. Definitions
3. Submission and Processing of Closeout Documentation
4. Management of Late Activity
5. Procedure for Closing Projects without End Dates
6. Federal Regulations

I. Purpose

The closeout of a project or a budget period requires that all related financial reporting is completed and all commitments are resolved.  Grant Managers (GMs), Principal Investigators (PIs) and central office staff must adhere to internal and sponsor timelines and deadlines.  This procedure describes the reports, departmental expectations and management center approvals necessary to achieve a compliant closeout.  Failure to meet all applicable deadlines may result in non-compliant reporting, or put institutional and sponsor funding at risk.

Related information and resources may be found on the Award Closeout myRESEARCHpath page.

II.  Definitions

Closeout period:  Represents the time during which the research administrator, which may be a GM, must complete all closeout activities for a project or budget period.  This period includes the 90 days before the project or budget period 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 CONS Report (Duke@WORK Grants Management Tab) or Master Data WBSE and One-Line Summary (SAP transaction ZF600) reports to determine the Closeout Docs Due Date and the Sponsor Due Date.

Closeout Docs Due Date:  Department submission deadline for all required closeout forms.  Refer to the CONS Report (Duke@WORK Grants Management Tab) reports to determine.

Sponsor Due Date:  Date by which Duke, as an institution, submits final financial reports and/or invoices to the project sponsor.

Late Activity:  Any transaction that occurs after the initial submission of the closeout tasklist.  If the late transaction is performed as a cost transfer, these should also adhere to the requirements and procedures described in GAP 200.150, Cost Transfers on Federally Sponsored Projects.

Transfer off process:  A process which will move certain Late Activity expenses to the closing WBSE's backstop code identified in master data.  The Transfer Off Tool is activated by the submission of the tasklist into workflow.

Reportable award:  Projects where invoices and financial reports are submitted by an institutional office (Post Award Financial Management (PAFM) or Treasury Billing Services (TBS)); represented by the A03, 20x-28x and 30x-38x WBSE ranges.

III. Submission and Processing of Closeout Documentation

Reportable Projects: A03, 20x-28x and 30x-38x

The institutional expectation is that prior to submission of the closeout documents all appropriate financial transactions and project related activity is posted to the WBSE in preparation for the final financial report/invoices submission.  The GM should ensure the WBSE ledger is reportable and the closeout submission is submitted on or before the Closeout Docs Due Date.  The department/center/institute must complete and submit the following documentation by the Closeout Docs Due Date.

1. Closeout Tasklist: A completed Closeout Tasklist includes answers to all applicable questions, WBSE closing balance details and a grant manager attestation. The specific approval routing is determined by department/center/institute workflow.
2. PI Attestation: A completed PI Attestation includes the PI verifying all applicable statements, project balance information and committing to meet all sponsor programmatic deadlines. The PI is notified of approval requirement via the Universal Worklist.
3. Obligation Worksheet: A completed Obligation Worksheet should reflect outstanding obligations past budget period end date. Note: this form is require only for institutional training grants funded by elements of the Department of Health and Human Services (DHHS).

The Campus Award Management Teams (CAMT) or the Office of Research Administration (ORA) review submitted materials and the general ledger to ensure accuracy and compliance with institutional expectations for submission of the closeout tasklist.  The CAMT and ORA also review reports to confirm that there are no pending obligations for the WBSE.

Once fully approved, closeout documents are imaged and referenced by PAFM for final sponsor reports or invoices.  Prior to issuing final reports or invoices, PAFM will review documentation for appropriate cost sharing procedures (including NIH Salary Cap), compliance with federal and sponsor regulations and transfer any overdrafts to the WBSE backstop code that is reflected in Master Data or residuals to the code identified on the Closeout Tasklist.  Overdrafts should only be removed by PAFM.

Upon review, issuance of final invoices or reports, the collection of all receivables, and the general ledger showing a balance of zero in SAP, PAFM will close the WBSE(s).

Complex project management may involve multiple departments/center/institutes that span Management Centers.  Unresolved issues that may impact the above deadlines should be escalated as appropriate to the business manager, chair's office, dean's office or the CAMT or ORA and PAFM, as applicable.

IV. Management of Late Activity

Once a department/center/institute has submitted a Closeout Tasklist via the Duke@Work portal, the WBSE will display a user status of "FINL" in SAP.  Once this user status is displayed, any transaction entered into SAP will be considered late activity.  The department/center/institute is responsible for the timely resolution of late activity.

The following are expense categories that are excluded from the Transfer Off tool.  The resolution of these expenses must be managed by the department in consultation with CAMT or ORA:

Payroll and associated expenses

Cost distribution corrections must be completed through iForms transactions for effort tracking.  Grant Managers must contact the CAMT or ORA to resolve, either through cost sharing or with a cost distribution change 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/center/institute.  If it is determined that the credit is not appropriate, contact the CAMT or ORA as soon as possible.

Subrecipient Invoice Payments

Subrecipient invoices can be received after Tasklist submission and should be described in section 4 of the Closeout Tasklist as well as reflected in the balance. These are an allowable type of late activity.  These payments go through departmental review and approval through the check request 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 if properly reported on the Closeout Tasklist.

• G/L accounts: 691641-691660, 691675-691679, 697141-697160, 697175-697179

Facilities & Administrative (F&A) and PAFM specific activity

F&A adjustments, cost overrun transfers, and residual balance transfers are final transactions completed by PAFM 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

Debits not mentioned above are considered erroneous and will be transferred off to the backstop code reflected in Master Data. Please refer to the Management of Late Activity Notifications Quick Reference Guide for additional guidance.

V. Procedure for Closing Projects Without Established End Dates

Non-Reportable Projects: 29x and 39x

Industry-sponsored clinical research that have a Tasklist requirement and are managed by School of Medicine units must have a Closeout Tasklist submitted to the School of Medicine office Finance office. Once the School of Medicine Finance steps are complete, the completed Closeout Tasklist workflow includes TBS, who then closes the WBSE. For further information regarding the closeout process from this award type, please contact the School of Medicine Finance office.

For other types of non-reportable projects that do not have closeout document requirements, the GM should bring the balance to zero in accordance with institutional guidance and sponsor terms and conditions. 

When the project’s balance in SAP has been zero with no financial activity for at least one month, the department must notify TBS in writing to close the WBSE(s). TBS will then close the WBSE(s), thus allowing for no further transactions.

VI. Federal Regulations

This GAP reflects the provisions of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, otherwise referred to as the Uniform Guidance.  The UG became effective as of December 26, 2014, and revised as of November 12, 2020, and all awards issued on or after this date must be managed in accordance with its provisions.  It is important to verify the applicable regulations for an individual award, which may be found in the Award Notice issued by the funding agency.

These guidelines pertain to federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-federal sponsor's policies and/or procedures.

This GAP supersedes previous GAP versions, Duke Policies, Guidelines, etc.

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.