GAP 200.180, Closeout of Sponsored Project | Accounting

Procedure:
GAP 200.180, Closeout of Sponsored Project

Effective Date:
September 1994

Review/Revision History:
October 2001
July 2002
February 2003
July 2006
January 2010
November 2014
May 2015
June 2016
June 2019

III. Submission and Processing of Closeout Documentation

IV. Management of Late Activity

V. Procedure for Closing Projects Without Established End Dates

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 mangement 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.

II. Definitions

Closeout period: Represents the time during which the reserch administrator must complete all closeout activities for a project or budget period. The Sponsored Projects Closeout Timeline Quick Reference Guide provides research administrators with a timeline and associated tasks/responsibilities that facilitate a timely and effective closeout. 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 Projects Approaching End Date, Master Data WBSE and One-Line Summary (ZF600), or CONS (Closeout Notification System) 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 Projects Approaching End Date or CONS 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 deadline for 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 (OSP or 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 by the Closeout Docs Due Date, all appropriate financial transactions and project related activity is posted to the WBSE in preparation for the final financial report/invoices submission. The WBSE must be reportable and the closeout submission on time. The department/center/institute must complete and submit the following documentation by the Closeout Docs Due Date. The specific approval routing is determine by department/center/institute workflow.

Closeout Tasklist: A completed Closeout Tasklist includes answers to all applicable questions, WBSE closing balance details and a grant manager attestation.
PI Attestation: A completed PI Attestation includes the PI verifying all applicable statements, project balance information and committing to meet all sponsor programmatic deadlines.
Obligation Worksheet: Note: this form is require only for institutional training grants funded by NIH to reflect outstanding obligations past budget period entd date.

The Award Management Teams (AMT) review submitted materials and the general ledger to ensure accuracy and compliance with institutional expectations for submission of the closeout tasklist. The AMTs also review reports to confirm that there is no pending activity for the WBSE.

Once fully approved, closeout documents are imaged and referenced by the Office of Sponsored Projects (OSP) for final reports or invoices. Prior to issuing final reports or invoices, OSP will review documentation for appropriate cost sharing procedures (incliding NIH Salary Cap), compliance with federal and sponsor regulations and transfer any overdrafts and/or residuals to the WBSE backstop code that is reflected in Master Data. Overdrafts can only be removed by OSP.

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

Complex project managment may involve multiple depatments/center/institutes that span Management Centers. Unresolved issues that may impact above deadlines should be escalated as appropriate to the business manage, chair's office, dean's office or management center's AMT and OSP, 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 the appropriate AMT:

Payroll and associated expenses
Cost distribution corrections must be completed through iForms transactions for effort tracking. Grant managers must contact their AMT 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/institue. If it is determined that the credit is not appropriate, contact the applicable AMT as soon as possible.

Subrecipient invoice payments
Subrecipient invoices can be received after Tasklist submission and are an 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

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]

If there are no reporting requirements for a project, and the CONS setting in SAP is set to "not required," 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 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 workflow includes TBS, who then closes the WBSE.

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 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 previos GAP versions, Duke Policies, Guidelines, etc.

VII. 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.