Closing Out an Award
Various activities are required by ORSP staff, the Department and the PI to close out a sponsored project or award. Some of these activities involve reporting obligations to the sponsor, financial reconciliations, forms and reports for the institution and account closeout tasks.
How to Close Out an Award
Research Compliance Closing
If your research project has met all of the criteria to be closed, the PI must also submit a Final Report to the appropriate compliance committee (i.e., IRB, IACUC, or IBC). Please refer to How to Close a Project in IRBNet.
Final Invoices & Reports
Upon termination of the project, the Grant & Contract Administrator(GCA) will review the award and work with the Department Administrator to determine the final figure that will be reported to the sponsor on the financial report or final invoice. As part of the closeout process, the Department Administrator needs to do the following (if necessary):
- Notify internal departments and payroll of FOAP changes for recurring costs such as printing, telephone, postage and salary/fringe.
- Promptly transfer all erroneous charges, clearing deficits
For most Federal awards, final financial reports must be submitted within 120 days from the award end date and final expenditures that were incurred within the period of performance must be charged to the grant fund within 90 days. Non-federal deadlines may vary by sponsor. To meet the sponsor deadlines, there needs to be clear and timely communication between Department Administrator and GCA. The GCA will submit the final financial report/invoice to the sponsor upon agreement with the department once the final figure is reported.
FDP - 60 Days
DU Template 30 Days
In order to accurately report expenditures to the prime sponsor, final Subagreement invoices must be submitted in accordance with the terms set out in the agreement, at a minimum 30 following the end date of the Subagreement. It is the responsibility of the Department Administrator and PIs to ensure that Subagreement invoices are being submitted and processed in a timely manner.
Overruns cannot be resolved by transferring the deficit to another sponsored award. The Department needs to transfer the overrun to an department operating fund within three months of the award.
Unallowable and Unallocable Costs
Unallowable and unallocable costs are defined as sponsored project expenditures that are not in compliance with OMB Uniform Guidance, University of Denver policy or the sponsor’s terms and conditions. The University of Denver cannot request reimbursement for the payment of any of these costs. Some examples include:
- Advertising and public relations costs
- Bad debt
- Donations and contributions
- Entertainment costs
- Fines and penalties
- Goods and services for personal use
- Housing and personal living expenses
- Pre-award costs unless allowed by the sponsor
- Selling and marketing
Award Audit & Record Retention
Under the legal terms of awards to the University, auditors have the right of access to all official University records associated with a project. The University is obligated to make such records are readily available for examination.
Because auditors may visit departments to review supporting documentation and interview personnel who have certified effort on projects, departments must maintain complete records. In addition, individuals who have completed their effort certification must be able to confirm that the effort is accurate as certified.
The PI must retain:
- Scientific Records and Data
- Animal and Human Subjects Materials
The department must retain:
- Financial and Personnel Records
ORSP will retain:
- Pending proposals for two years after the fiscal year in which they were submitted
- Awarded proposals and award files for four years after the project closeout
What items are usually audited?
- Cost transfers
- Payroll charges and effort certifications
- General-purpose equipment purchased at the end of the project
- To an auditor, a cost transfer means that something happened that should not have occurred. They will look at the transfer documents to see if they are appropriate and timely.
- Auditors question whether the equipment was needed or just purchased to use up funds. They will select a number of equipment items purchased on the project, review the transaction date in comparison with the grant end date, and discuss with the PIs all those purchases within 60 days of the end date.
What are the types of audits?
- General Financial Audit
- Uniform Guidance
- Sponsor Requested Audit
- University’s Department of Audits
- An audit that is part of the annual general financial audit of University financial statements.
- A sponsored-project-specific audit of financial systems and expenditures in accordance with Uniform Guidance. The University is required to provide these audits to the federal government.
- The sponsor can request that an individual award be audited. These audits can be financial or programmatic.
- All University funds are subject to inspection and audit by the University's Department of Audits.
What kind of records do auditors typically review?
- Central Records from offices such as ORSP, Purchasing and Payroll
- Departmental Files
- Laboratory Records
The sponsor or auditors should contact ORSP before beginning an audit. ORSP will then notify the department. If the PI or department is contacted by the auditor directly, refer them to ORSP before scheduling any visits or releasing any documents.
Financial liability for audit disallowances, other than for those which result from deficiencies in the University's policies and procedures, rests with the department, school or center having primary responsibility for the project on which costs are questioned.