Federal Financial Reporting Guidelines

Responsible Offices: Sponsored Projects Accounting
Effective Date: December 2022
PDF version: Federal Financial Reporting Guidelines

The following guidelines for the Federal Financial Report (FFR or SF 425) apply to NIH awards specifically.

Timing

The Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2CFR 200.343, (Uniform Guidance) states:

  • The recipient must submit no later than 90 or 120 calendar days after the end date of the period of performance all financial, performance and other reports as required by the terms and conditions of the Federal award.
  • Most NIH grants follow the 120 day timing noted in the Uniform Guidance, but some grants require reports to be submitted within 90 days of the end of the period of performance.

FFRs due by 90 days After End Date

 

Responsibilities

Principal Investigator and/or Departmental Administrative Staff

If the reporting due date is 90 days after end of the period of performance, the functions noted below should be performed and completed within 75 days of the project end date (based on the requirement for the award).

30-60 days before end date or budget end date (annuals)
  • Submit No-Cost Extension Requests, if applicable
  • Remind subawardees of the due date for the final invoice marked as “Final”. This is part of their contract and failure to submit the invoice by the deadline may result in non-payment.
0-30 days following and award end date or budget end date
  • Review the entire award and all grant lines allocated to other PIs/Cost Centers to ensure all expenses have been applied in WorkDay. All expenses must be in “ready to bill” status in order to be included on a Cost reimbursable invoice in Workday.
  • Process all Payroll Costing Allocations (PCA) and Payroll Accounting Adjustments (PAA) to ensure all applicable effort has been accurately posted to the grant line(s).
  • Process all Workday documents (manual journals, budget adjustments, expense reports, miscellaneous payments, supplier invoices, internal service delivery charges (ISD) etc…) and ensure that the appropriate department personnel approve them. Documents submitted after the end date of the award/grant should contain sufficient detail, which clearly states the applicability of the transaction to the project.
  • SPA recommends that the PI or their designee should submit the final set of PO and Supplier invoices at least 30 days before the end date of the award.  This timing will ensure the ordered items are received and processed for payment in a timely manner.  Note:  Items received after the end date of the project will typically not be allowed.
  • Remove or transfer open commitments or obligations to a proper cost center/grant.
  • Remove overdraft amounts (expenditures exceed available funding). If the overdraft contains expenses that were erroneously posted to the grant, they should be reclassified to the proper cost center/grant. If the overdraft contains expenses which actually relate to the project, a voluntary cost sharing grant line should be established and the expenses subsequently reclassified to it.
  • Review the actual amounts posted to the cost sharing grant lines and compare them to the amounts obligated in the proposal and/or stated in the award/sponsored agreement. Process additional adjustments, as necessary, to ensure that the cost sharing obligations have been met.
  • Review the subaward expenditures (SC462) and ensure that all invoices have been received and paid. Final invoice from subaward should be marked “FINAL”.Review the subaward expenditures (SC462) and ensure that all invoices have been received and paid. Final invoice from subaward should be marked “FINAL”.
31-75 days following award end date or budget end date (annual)
  • Confirm all expenses posted after end date of award are applicable and allowable with sufficient justification
  • Confirm all obligations and commitments have been zeroed out, closed, or ended
  • Confirm submission of final invoice from subawardees
  • Confirm overdrafts have been cleared

Sponsored Projects Accounting

The functions noted below should be performed and completed within 90 days of the project end date (based on the requirement for the award).

76-85 days following award end date or budget end date (annuals)
  • Prepare and submit the financial report and/or final invoice based upon the expenditure data contained in WorkDay. Contact the department regarding any issues.
  • Post a closing F&A expense adjustment, as necessary.
  • SPA will process last drawdown no later than day 85
86-90 days following award end date or budget end date (annuals)
  • SPA will submit FFR in PMS, close all grants lines, and attach a copy of FFR into Workday

FFRs due by 120 days After End Date

 

Responsibilities

Principal Investigator and/or Departmental Administrative Staff

If the reporting due date is 120 days after end of the period of performance, the functions noted below should be performed and completed within 90 days of the project end date (based on the requirement for the award).

30-60 days before end date or budget end date (annuals)
  •  Submit No-Cost Extension Requests, if applicable
  • Remind subawardees of the due date for the final invoice marked as “Final”. This is part of their contract and failure to submit the invoice by the deadline may result in non-payment.
0-60 days following an award end date or budget end date (annuals)
  • Review the entire award and all grant lines allocated to other PIs/Cost Centers to ensure all expenses have been applied in WorkDay. All expenses must be in “ready to bill” status in order to be included on a Cost reimbursable invoice in Workday.
  • Process all Payroll Costing Allocations (PCA) and Payroll Accounting Adjustments (PAA) to ensure all applicable effort has been accurately posted to the grant line(s).
  • Process all Workday documents (manual journals, budget adjustments, expense reports, miscellaneous payments, supplier invoices, internal service delivery charges (ISD) etc…) and ensure that the appropriate department personnel approve them. Documents submitted after the end date of the award/grant should contain sufficient detail, which clearly states the applicability of the transaction to the project.
  • SPA recommends that the PI or their designee should submit the final set of PO and Supplier invoices at least 30 days before the end date of the award.  This timing will ensure the ordered items are received and processed for payment in a timely manner.  Note:  Items received after the end date of the project will typically not be allowed.
  • Remove or transfer open commitments or obligations to a proper cost center/grant.
  • Remove overdraft amounts (expenditures exceed available funding). If the overdraft contains expenses that were erroneously posted to the grant, they should be reclassified to the proper cost center/grant. If the overdraft contains expenses which actually relate to the project, a voluntary cost sharing grant line should be established and the expenses subsequently reclassified to it.
  • Review the actual amounts posted to the cost sharing grant lines and compare them to the amounts obligated in the proposal and/or stated in the award/sponsored agreement. Process additional adjustments, as necessary, to ensure that the cost sharing obligations have been met.
  • Review the subaward expenditures (SC462) and ensure that all invoices have been received and paid. Final invoice from subaward should be marked “FINAL”.
61-90 days following award end date or budget end date (annuals)
  • Confirm all expenses posted after end date of award are applicable and allowable with sufficient justification
  • Confirm all obligations and commitments have been zeroed out, closed, or ended
  • Confirm submission of final invoice from subawardees
  • Confirm overdrafts have been cleared

Sponsored Projects Accounting

The functions noted below should be performed and completed within 120 days of the project end date (based on the requirement for the award).

91-115 days following award end date or budget end date (annuals)
  • Prepare and submit the financial report and/or final invoice based upon the expenditure data contained in WorkDay. Contact the department regarding any issues.
  • Post a closing F&A expense adjustment, as necessary.
  • SPA will process last drawdown no later than day 115
116-120 days following award end date or budget end date (annuals)
  • SPA will submit FFR in PMS, close all grants lines, and attach a copy of FFR into Workday

Please contact Lindsay Danner (ldanner@wustl.edu) or Devin Alfred (dalfred@wustl.edu) directly if you have any questions about this issue.