The following guidelines for the financial closeout of a fund apply to NIH, NSF, NASA and other Federal Agencies.
The Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2CFR 200.343, (Uniform Guidance) states “The non-Federal entity must submit, no later than 90 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. The Federal awarding agency or pass-through entity may approve extensions when requested by the non-Federal entity.” Most federal agencies go on to clarify what kind of reports are required (invoice, SF270, SF269, SF272…) in their own specific administrative guidelines (i.e., the NIH Grants Policy Statement) or in the actual sponsored agreement.
Principal Investigator and/or Departmental Administrative Staff
The functions noted below should be performed and completed within 60 days of the project end date.
- Submit all payroll cost transfer (PCT) documents and ensure that the adjustments have been posted to the fund.
- Submit all on-line documents (journals, budget adjustment, travel request, check requests, interdepartmental charges…) and ensure that the appropriate department personnel approve them. Documents submitted after the end date of the fund should contain sufficient detail, which clearly states the applicability of the transaction to the project.
- Remove or transfer open encumbrances to a proper account/fund.
- Remove overdraft amounts (expenditures exceed available funding). If the overdraft contains expenses that were erroneously posted to the fund, they should be reclassified to the proper account/fund. If the overdraft contains expenses which actually relate to the project, a voluntary costs sharing allocation (V) should be established and the expenses subsequently journaled to it.
- Review the actual amounts posted to the cost sharing funds (X & V) 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 subcontract expenditures (BUOB 38XX) and ensure that all invoices have been received and paid.
- Some agencies require prior written approval to carry over funds from one grant period to the next. Typically, the PI must submit a written request which describes the reason for the remaining balance and how it will be utilized in future (competitive) grant periods. All requests of this nature should be co-signed by the PI and the designated official in the Office of Sponsored Research Services (OSRS). Please consult the award/contract document and contact OSRS if there are any questions.
- NIH awards which are not included under “Expanded Authorities” require written approval of carryover amounts.
- Balances remaining on NIH Fellowship awards (F31/32’s) cannot be carried forward.
- Subsequent to 60 Days: If the department is required to post transactions to the fund that will directly effect expenses (payroll cost transfer, inter-department, journal…) the responsible individual within SPA should be notified so that the amounts are properly included in the financial report or final invoice.
Sponsored Projects Accounting
The functions noted below should be performed and completed within 90 days of the project end date.
- Prepare and submit the financial report and/or final invoice based upon the expenditure data contained in the general ledger (FIS). Cost sharing expenses will be included in the report or invoice, as applicable. Recalculate and verify the Facilities and Administrative (F&A) costs and adjust as necessary. Calculate the remaining (unobligated) balance and determine if the funds should be returned (via a refund check) or carried forward to a new segment of the project.
- Post a closing F&A expense adjustment, as necessary. Post a closing adjustment to Accounts Receivable for NIH and NSF awards.
- Process and post budget adjustments related to carryover amounts.
- NIH Awards: Carryover adjustments will not be processed until the financial report has been “accepted” by the agency (approximately 90 to 120 days after the end date of the fund).
- Monitor the fund to ensure that the final invoice has been paid.
- Purge the account/fund after all postings, filings, closing entries have been completed