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Closeout Overview :. SAO-Award Closeout Training MAY 4, 2007. THE CHANGING CULTURE OF GRANT MANAGEMENT. THE CHANGING CULTURE . Grant money is becoming more competitive Sponsors are becoming less flexible about agreement requirements
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Closeout Overview: SAO-Award Closeout Training MAY 4, 2007
THE CHANGING CULTURE • Grant money is becoming more competitive • Sponsors are becoming less flexible about agreement requirements • Georgetown University culture is changing to meet the demands of the sponsors and to remain competitive
THE CHANGING CULTURE • These changes are manifesting themselves in many ways: • More collaboration between institutions • More collaboration between PI’s • Fewer grants being awarded • Monitoring quantity of No Cost Extensions • Increased oversight (and audits) by sponsors • Less flexibility at the end of the grant period
THE CHANGING CULTURE • Less flexibility means higher expectations: • The consistent expectation of SAO is that grants will be closed promptly and accurately • The administration’s expectation is that grants will be closed in a timely manner • The sponsor’s expectation is that grants will be closed in a timely manner • The result of these increased expectations is an increased pressure to perform the closeout process
Knowing the Food Chain at GU Knowing departmental hierarchy will assist in getting results faster and sometimes timely. It is crucial to the entire process that each analyst is familiar with: - Departmental food chain ladder and - Who’s responsible for what?
Key to a Timely and Efficient Closeout Process • Beginning the process 90 days prior to expiration • Constant communication with the PI/designee through out the process • Familiarity with the award terms and conditions • Review of Closeout Checklist
90 & 30 Days Award Expiration Notification Once you received your copy of the 30 days award notification letter the process begins…. keep award on your radar submit final worksheet within 30 days after expiration set timelines for final adjustments/and or response from department
THE CLOSEOUT CHECKLIST • The items on the checklist should be used as a blueprint in carrying out the closeout process at the end of a grant • The checklist can also act as a road map during the life of a grant and guide the departments in the management of the grant
THE CLOSEOUT CHECKLIST Advantages to SAO- • A good starting point • Reduces the # of communications from sponsors for Closeout documentation long after the award end date • Reduces the # of communications between SAO and external/internal auditors or # of audit findings • Ensures The University is in compliance with the financial reporting requirement as per the agreement • If the checklist is used consistently it should make the work done at closeout easier and less time consuming • Going forward, we hope to consistently use the checklist as a road map during the grant closeout process
So let’s get to it . . . . FIRST THINGS FIRST!!!!!!! STEP I Review contract/agreement -to determine required closeout documentation - to familiarize yourself with specific reporting requirements - to determine expenditures requiring pre-approval from sponsor and unallowable charges. Pre-award may also entered reporting requirement on the award profile screen, i.e. Cost Share, Program Income
STEP II Download Checklist -Checklist can be printed or downloaded from: - each item on the checklist should guide your communication with the department - the checklist serve as a reminder during the closeout process of the questionable charges to look for - the checklist should remind you to check on status of subcontract final payment and closeout documentation as per agreement. CHECKLIST
ITEM #1 ON THE CHECKLIST: Formal Time Extension/Renewal - is an extension being requested? verify information with OSR/OSP - is award being renewed? ensure new cost center has been setup by OSR/OSP - is additional funding pending? confirm availability of funds with OSR/OSP
ITEM #2 ON THE CHECKLIST: Final Technical/Progress - verify if report has been submitted and the date the report was sent to the sponsor - the name of the person to whom the report was sent to or contact information which may include: - Mailing address - Phone number - Email address -request documentation for the files
Final Technical/Progress - examples of acceptable documentation include: -a cover letter addressed to the sponsor - an email sent to an Award Officer, with header info - a fax that makes reference to the attached report • SAVE TREES . . . . The actual report does not need to be on file in SAO; just proof to show an auditor that the report was sent • Showing an auditor a final report does not show the auditor that the report was sent to the sponsor
Final Technical/Progress • If the technical report will be submitted at a future date, SAO will communicate that to the sponsor in the Closeout Transmission Letter • If the award requirements indicate a final progress report is due, but the PI states that it was not required or that the requirement was waived, then something in writing from the sponsor is needed for the closeout file
ITEM #3 ON THE CHECKLIST: Final Purchases - have all the charges hit - are there open commitments on the CSR - do the final charges fall within the award period-after end date charges
Final Purchases - After end date charges ideally should not occur, but if they do happen they should be promptly removed. Waiting for a new grant purpose code is not a valid reason from an audit standpoint - All charges hitting after the end date should be validated (JV data download is a useful tool in easily identifying and validating charges outside the award end date)
EXERCISE JV DATA DOWNLOAD/PIVOT REPORT DEMONSTRATION PP2050861
ITEM #4 ON THE CHECKLIST: SubContract -has the sub-recipient completed the project - Has final invoice been submitted and paid (verify that ‘Final’ is inserted on the final invoice) - Has sub-recipient closeout documents as per the subaward been submitted (obtain copies for file)
ITEM #5 ON THE CHECKLIST: PI effort/salary Liaise with Compliance to confirm: • PI percentage of effort/salary has been allocated to award as per agreement • If rebudgeting was done was it in compliance with sponsor rebudgeting guidelines
ITEM #6 ON THE CHECKLIST: Labor Distribution • Liaise with compliance to verify/confirm if there are outstanding labor distribution issue prior to closing out award-make sure departments change distributions at end of award if salary was charged on award.
ITEM #7 ON THE CHECKLIST: Prior Approval - Verify budget line items requiring prior approval from sponsor - Obtains copy of prior approval documentation from sponsor where applicable Examples of budget line items requiring prior approval: Equipment, travel, subawards, rebudgeting, change of primary PI
ITEM #8 ON THE CHECKLIST: Cost Share/Match Cost share is the institutional contribution to the cost of completing a project Also referred to as “in-kind”
COST SHARE/Match - Obtain documentation from department certifying committed/required cost share/match was met - Verify total cost share commitment in award documentation N/B: Sometimes cost share is specifically required by the sponsor: - This may be stated in the program guidelines - It may also be a standing requirement specific to a particular sponsor, as in the case of NSF (1% match on unsolicited most projects)
BREAK & EXERCISE TIME 10 MINUTES You Be The Judge-20 Question Exercise
ITEM #9 ON THE CHECKLIST: Expenditure Type for Equipment Purchases: - Are items costing less than $5,000 acquired after 8/31/03 coded correctly as non-capital purchases - Are items from $2,500 to $4,999 recorded in the proper account
Expenditure Type for Equipment Purchases: - If an equipment/property inventory is required by the sponsor or terms of the agreement, obtain copy of property report from Property Department. - Prepare property/equipment report as per sponsor’s requirement/standardize format - Submit report to sponsor when forwarding final closeout documentation N/B: Verify in the agreement/award documentation who has title to equipment at the end of project
ITEM #10 ON THE CHECKLIST: Procard Clearing Account - Make sure there are no balances in the procard clearing account. - All balances in the procard clearing account should be reclassified prior to closing out DEMONSTRATION: Procard
ITEM #11 ON THE CHECKLIST: Advances - Reviewadvance balances verify advance has been cleared to expense accounts center should not be closed if outstanding advances have not been cleared Acct Code-02818 & 02820
ITEM #12 ON THE CHECKLIST: Major Project or Activity - review agreement to ascertain if award is a major project or activity - administrative or clerical costs should not be allowed on project or activity that are not major - administrative or clerical costs charged to major project or activity should be limited to those listed in the budget
ITEM #13 ON THE CHECKLIST: Tuition Allowance - make sure statement of appointment is on file for student working on project (especially NIH T32 training grants) - student time spend on the grant should not exceed five years for predoc and 3 years for postdoc - Make sure there are not more than 3 predocs and 2 postdocs working on an award at the same time - make sure stipend level falls within NIH approved stipend level for the grant period - confirm that all stipend/tuition has been rightly charged to the grant
ITEM #13 ON THE CHECKLIST: Have all appropriate expenses been posted to the Cost Center - confirm with PI/designee that all legitimate charges have been posted (the final worksheet could be used to confirm total expenditures)
ITEM #14 ON THE CHECKLIST: Unallowable Expenses Sources for determining unallowable charges:- - award document/agreement/program guide - review and become familiar with the OMB circular-A-21 This is the guiding principal for all federal money and is also used by many non-fed sponsors - request PI/designee to remove charges N/B:There are unusual occasions when expenses that are typically unallowable will be allowed. If this is the case, attach adequate documentation to the closeout report and put in the folder.
ITEM #14 ON THE CHECKLIST: Unallowable/Unallocable Expenses When in doubt…..verify in A-21, Section-J or on SAO Website - A-21 SECTION J Quick Check
ITEM #15 ON THE CHECKLIST: Overdraft (OD) - contact PI/designee to remove overrun from cost center - transfer overrun to approved department ‘GX’ center using account code 78440 if no response is received within a reasonable timeframe
Final FR CLOSE PROCESS • Reconciliation- - once it is certain all legitimate expenditures have hit the account prepare final financial report if one is required - total expenditure amount reflected on final report should equal total budgeted amount and total cash receipt in the financial system - if budgeted amount reflected in system is greater or less than amount reported on the final report, request budget adjustment from SAO Reporting or pre-award
FINAL FR CLOSE PROCESS - if cash received is greater or less than total reported expenditure- - remit excess cash to sponsor or department specified cost center (if firm fixed) - if cash is less than reported amount but expenditure and budget balance reflected in the system are the same, complete the FR Close milestone (verify cash receipt/AR with SAO Accounting. SAO Accounting will ensure that the cash received balances with the budgeted amount and final expenditures reported)
CLOSEOUT-CLINICAL TRIALS Once end date expires: • Confirm with PI/designee that trial is completed- • If completed, begin the closeout process • If not, analyst should recommend that PI/designee liaise with pre-award in filing a no cost extension • Reconcile balances (expenditures, budgeted amount and cash receipts) - If budgeted amount is less/ or greater than cash receipt verify with PI/designee if budget needs to be adjusted or cash was misapplied. If budget requires adjustment ensure ORS adjusts the budget accordingly - If surplus or overrun, transfer balance to medical center holding account-GD4007601.
CLOSEOUT-CLINICAL TRIALS • Inform Medical Center Finance Office (MCF)-Venishea Butler, of transfer • MCF at the end of each quarter, is responsible to transfer to department discretionary account • If charges are applied after a clinical trial has been closed, alert MCF who is responsible to get charges applied against department discretionary account N/B do not transfer surplus or overrun balances to department discretionary account. It’s MCF responsibility
FILING • Closeout Documents to include in folder • Copies of closeout reports submitted to sponsor • E.g final financial and technical reports, property/invention reports (if required), releases, etc • Closeout Report & Closeout Checklist • Sign and date and submit to manager for signature. Attached to other closeout documentation, put in folder and put folder back on shelf