UNIVERSITY of NORTH DAKOTA RESEARCH & ECONOMIC DEVELOPMENT POLICY LIBRARY SPONSORED PROGRAM CLOSEOUTS Policy 6, Sponsored Program Closeouts Responsible Executive: VP Research & Economic Development Responsible Office: Grants & Contracts Administration Issued: April 20, 2015 Latest Review / Revision: April 20, 2015 POLICY STATEMENT The University of North Dakota (UND) has the responsibility to closeout a completed sponsored program in accordance with federal regulations and other sponsor requirements. This process certifies awardee compliance with applicable regulations, and makes final disposition of all award by-products, such as final vouchers, reports, patent disclosures, and property inventory. In addition, the closeout process includes the collection of outstanding accounts receivable and the distribution of residual funds. REASON FOR POLICY UND s closeout policy provides guidelines to facilitate the timely and accurate closeout of sponsored programs in accordance with federal regulations and other sponsor reporting requirements. SCOPE OF POLICY This policy applies to all members of the University community and should be read by: President Vice Presidents Deans, Directors and Department Chairs Faculty Grants & Contracts Administration Research Development & Compliance Intellectual Property Commercialization & Economic Development Staff Principal Investigators Students Others WEB SITE REFERENCES This policy: http://und.edu/research/_files/docs/policy/1-6-closeouts.pdf Vice President for Research and Economic Development: http://und.edu/research Page 1 of 5
CONTENTS Policy Statement 1 Reason for Policy 1 Scope of Policy 1 Web Site References 1 Related Information 3 Contacts 3 Definitions 3 Principles (overview) 4 Procedures 4 Potential Consequences of Not Following Closeout Policy 4 Responsibilities 4 Forms 5 Appendices (list) 5 Appendix 1 Notice of Sponsored Program Closing 6 Revision Record 5 Page 2 of 5
RELATED INFORMATION 2 CFR 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Cost Transfers on Sponsored Activity Policy NDUS Human Resource Policy Manual UND Grants & Contracts Administration Roles & Responsibility Matrix http://und.edu/research/_files/docs/policy/1-1-cost-transfers.pdf http://www.ndus.edu/makers/procedures/hr/ CONTACTS General questions about this policy can be answered by your department s administrative office. Specific questions should be directed to the following: Subject Contact Telephone E-Mail / Web Address Policy Content and Clarification Grants & Contracts Administration 777-4151 http://www.ecfr.gov/cgi-bin/textidx?tpl=/ecfrbrowse/title02/2cfr200_main_02.tpl http://und.edu/research/grants-and-funding/_files/docs/roles-andresponsibilities-matrix.pdf http://und.edu/research/grants-andfunding DEFINITIONS CFR Closeout Date PI Code of Federal Regulations. Codification of the general and permanent rules published in the Federal Register by the departments and agencies of the federal government. The date by which the awarding agency or pass-through entity determines that all applicable administrative actions and all required work of the award have been completed. Specific actions must be taken to complete the closeout process at the end of the sponsored program s period of performance. Principal Investigator. The individual, designated by the awardee, who is responsible for the scientific or technical aspects of the award and for day-to-day management of the project. The PI is a member of the awardee team responsible for ensuring compliance with the financial and administrative aspects of the award. This individual works closely with designated officials within the grantee organization to create and maintain necessary documentation, including both technical and administrative reports; prepare justifications; appropriately acknowledge federal support of research findings in publications, announcements, new programs, and other media; and ensures compliance with other federal and organizational requirements. Page 3 of 5
Sponsored Program Research, instruction and training, public service, evaluative testing, and other scholarly and creative activities conducted under the direction of University faculty and staff and funded by organizations external to the University in accordance with award instruments. PRINCIPLES OVERVIEW UND has the responsibility to closeout a completed sponsored program in accordance with federal regulations and other sponsor requirements. This process certifies awardee compliance with applicable regulations, and makes final disposition of all award by-products, such as final vouchers, reports, patent disclosures, and property inventory. In addition, the closeout process includes the collection of outstanding accounts receivable and the distribution of residual funds. UND s closeout policy is intended to facilitate the timely and accurate closeout of sponsored programs in accordance with federal regulations and other sponsor reporting requirements. Principal investigators (PIs) should refer to the sponsored program award letter for final closeout timeline. PROCEDURES The award closeout process is the culmination of the sponsored program life cycle, and it ultimately results in the completion of required financial and technical deliverables/reports, final billing, the collection of the outstanding accounts receivable, the submission of the final financial report, and the return or disposition of any residual funds. There are numerous steps involved in award closeout. To facilitate the closeout process, Grants & Contracts Administration (GCA) will send a letter to the PI approximately 90 days in advance of the award end date. This letter, found in Appendix 1, contains many of the important elements needed for a successful award closeout. Specific roles and responsibilities may be found in the Award Closeout Section of the Research Administration Roles and Responsibility Matrix. Potential Consequences of Not Following Closeout Policy GCA will transfer the charges to a departmental funding source if overdrafts and unallowable charges are not removed 30 days before final financial reports are due. Fines, penalties, and potential loss of awards are all possible consequences of incorrectly closing a project. Individuals or units not following the steps outlined may receive additional oversight and training. RESPONSIBILITIES Principal Investigator and/or Designee Grants & Contracts Administration Asset Management/ Human Resources/Facilities/Accounting Services/Purchasing Page 4 of 5
Deans/Directors/Department Chairs Research Development and Compliance FORMS No-Cost Extension Form Contact Grants & Contracts Administration APPENDICES Appendix 1 Notice of Sponsored Program Closing Contact Grants & Contracts Administration REVISION RECORD 04/20/2015 Policy Implementation Signed by President Robert O. Kelley Page 5 of 5
Sponsored Program Closeouts Appendix 1 Notice of Sponsored Program Closing Grants & Contracts Administration Principal Investigator: Department Name: Award Title: Project #: Sponsor Name: Agreement ID: UND Grants and Contracts Officer (GCO): Award Ending Date: Award Closeout Date: The above sponsored program will soon be ending. Please use this notice as an opportunity to review the necessary tasks that will bring the project to a successful completion. 1. Review the budget for funds available: a. If the amount remaining is adequate to cover completion of the project, and the project is scheduled to be completed on time, proceed as planned. b. If the amount remaining is adequate, but the time remaining is not, a no cost extension may be an available option. Please contact your GCO for guidance. c. If the amount available is not adequate or, if particular budget line items require adjustment, please contact your GCO to clarify the necessary procedures. 2. Review all charges on the project to ensure they are allowable and properly allocated. 3. Review cost share commitments to ensure that the required obligation will be met. 4. Process payroll retro forms to transfer salary appointments to alternative sources of funding. If no additional funding is available for staff employees, refer to NDUS Human Resource Policy 24 Reduction in Force. 5. Finalize purchases in order for them to be processed prior to the project fund termination date. Expenditures late in the award period may require additional documentation. 6. Review all outstanding purchase orders. If there are potential problems regarding delivery, payment, or acceptance of the items, please contact your GCO. 7. Review subagreements to ensure all deliverables have been received and approved, and that all invoices have been received and submitted for payment. 8. Contact all UND service providers that process scheduled charges to provide them with an updated funding source (i.e., Chester Fritz Library, Telecommunications, Center for Biomedical Research, Copy charges, Postal Services, etc.). 1 Page
Sponsored Program Closeouts Appendix 1 9. Assign new funding sources for other recurring expenses and inform departmental personnel. 10. Discuss equipment purchases with your GCO to address any title issues. 11. Complete all required closeout documents: property reports, IP reports, etc., in conjunction with the GCO. 12. An invention statement may need to be filed regardless of whether there is an invention. If you believe that Intellectual Property has been developed under the grant(s), and have not yet disclosed the information to the Intellectual Property Commercialization & Economic Development Office (IPCED), you should contact them for further guidance. 13. Provide a copy of all technical/progress reports to your departmental chair to satisfy the records retention policy. Please contact Grants & Contracts Administration at 777 4151 with any questions regarding this sponsored program and the timing of the closeout process. 2 Page