Closeout: Sponsor requirements and UW requirements

1. Closeout: Sponsor requirements and UW requirements MRAM April 2014 Presented by: Office of Sponsored Programs

2. Closeout Requirements for Federal Grants • Closeout requirements for federal funding are established in OMB A-110 • Agencies adopt specific requirements for closeout based on A-110: • Final technical (e.g. progress) report • Final financial report • Final invention statement • Final equipment report • Any other information they require per agency policy/award terms and conditions!

3. Current landscape for closeout requirements • OSP seeing tightening up of sponsor requirements: • Closer adherence to 90 day reporting requirement • Insistence that a report be submitted, even with absence of PI (e.g. out of country, transferred, or otherwise no longer with UW) • Increased use of wide spread impact to University due to single project non-compliance

4. Example • Sponsor notifies UW/PI that requirements due • PI has transferred • OSP contacts Sponsor to get exception • No exception granted; Chair is responsible for: • Following up with transferred PI to get final report information; or • Making formal statement and submitting to Sponsor via sponsor submission method

5. Example Sponsor notifies UW/PI that requirements due Due date comes and goes; final technical report not submitted Sponsor sends multiple follow-up to UW/PI Sponsor threatens termination of other award to this PI by date certain OSP prepares termination Post-Award Change (PAC) per Sponsor notification Work on other award temporarily on HOLD until this was rectified

6. Example Sponsor notifies UW/PI that requirements due Due date comes and goes; final technical report not submitted Sponsor threatens to withhold future funding to the University of Washington Sponsor sends letter to OSP that all pending funding will be on HOLD until due date met OSP puts on fast track “escalation” path involving Chair, Dean and OSP Director PI submits final technical report

7. Sponsors take final reporting seriously • Emphasis on final reporting is not going away • Omnicircular: • All obligations to be liquidated within 90 days past end date • Submission f final reports within 90 days as well • Steps for UW to take

8. Steps • Be familiar with GIM 39 • Sets out general federal sponsor requirements • Emphasis on being aware of award terms and conditions with respect to final report requirements specific to project • Includes the notification schedule undertaken by OSP • Includes the escalation process followed by OSP

9. Steps • Establish a process within the department for handling closeout: • Know who receives closeout notifications from a Sponsor (often it is the PI only) • Know who receives OSP notifications (see GIM 39) • Have a general plan for gathering final documentation from departing PIs, if grant is not transferred with PI • Be familiar with sponsor systems involved to submit final technical reports. Often only the PI has level of user access to submit final technical reports on Sponsor systems.

10. Resources Equipment Inventory Office – final equipment report Grant and Contract Accounting – final fiscal report Office of Sponsored Programs – general closeout requirements, liaise with Sponsor (other documents or requirements), notification and escalation process, and record for final submitted technical report Center for Commercialization – signatory for final positive invention statement