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Close-Outs. Presented by Stacy Tedder NOAA Grants Management Division January 31, 2013. Definition of a Close-out. The process by which DOC determines that all financial assistance award requirements and applicable administrative actions have been completed by the recipient and DOC.
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Close-Outs Presented by Stacy Tedder NOAA Grants Management Division January 31, 2013
Definition of a Close-out The process by which DOC determines that all financial assistance award requirements and applicable administrative actions have been completed by the recipient and DOC.
Financial Assistance A grant is the legal instrument reflecting a relationship between DOC and a recipient whenever: (a) the principal purpose of the relationship is to transfer money, property, services, or anything of value in order to accomplish a public purpose of support or stimulation authorized by Federal statute, and (b) no substantial involvement is anticipated between DOC and the recipient during the performance of the contemplated activity.
Financial Assistance A cooperative agreement is a legal instrument reflecting a relationship between DOC and a recipient whenever: (1) the principal purpose of the relationship is to transfer money, property, services, or anything of value toaccomplish a public purpose of support or stimulation authorized by Federal statute, and (2) substantial involvement (e.g., collaboration, participation, or intervention by DOC in the management of the project) is anticipated between DOC and the recipient during performance of the contemplated activity.
Administrative Laws The Grants Officer is responsible for the close out of all expired grant awards in accordance with the applicable OMB Circulars. • 15 CFR § 14.71 Closeout Procedures (Universities, Non-Profits, and For-Profits) • 15 CFR § 24.50 Closeout Procedures (States and Local Governments)
DOC Policies • DOC Grants and Cooperative Agreements Grants Manual (Chapter 12: Award Close-Out) • DOC Financial Assistance Standard Terms and Conditions (January 2013) • DOC Pre-Award Notification Requirements for Grants and Cooperative Agreements (December 17, 2012)
Who is Responsible for Award Close-out? • Recipient • Program Officer • Finance Officer • Grants Officer
Recipient’s Responsibilities • Completes the goals and objectives of the approved award • Submits the final Request for Advance or Reimbursement (SF-270) if applicable, or requests the final ASAP drawdown • Submits the final Federal Financial Report (SF425) and the final Progress Report within 90 days after the expiration date of the award
Recipient’s Responsibilities • Submits Statement to the FPO regarding Inventions/Patents/Royalties and/or use of I-Edison to verify submission or verification of recipient’s intent to register invention/patent if applicable • Submits Report of Federally Owned Property (SF428A-Annually or SF428B-Final) • Requests Property/Equipment Disposition (SF428C- Disposition) (purchased with grant funds)
Program Officer’s Responsibilities • The Program Officer, or assigned operating unit component, is responsible for monitoring and oversight of the work being conducted under an award, such as tracking the recipient’s progress and comparing the actual accomplishments with the goals and objectives established in the award.
Program Officer’s Responsibilities • Monitors project activities to ensure that goals are being achieved and the project is being carried out properly • Reviews financial reportsand reviews and certifies acceptance of performance or technical reports for consistency with the approved project • Notifies the Grants Officer if the recipient is not in compliance with the terms and conditions of the award
Grants Officer’s Responsibilities • GMS (Grants Management Specialist) reviews and approves the final Request for Advance or Reimbursement (SF-270) • GMS reviews and approves the final Federal Financial Report (SF425) • GO approves Financial Closeout and recommends Finance deobligate remaining funds • GO approves Administrative closeout documentation
Grants Officer’s Responsibilities • Manages disposition of Federally-owned property and property acquired with Grant funds • Ensures that the award file is held in the appropriate records holding facility for the appropriate time period before the file is destroyed
Finance Officer’s Responsibilities • Provides full accounting support and financial advice to Grants Officers, Program Officers, the operating unit, and others as needed • Records the financial transactions associated with each financial assistance award from inception to close-out of the final financial report, including obligation and deobligation of funds, and payments
Grants Online Processing • Phase I: Financial Closeout De-obligation Memo • Phase II: Administrative Closeout Administrative Closeout Checklist
Administrative Closeout Checklist • The countersigned copy of the grant award/amendments • Cost-share/match requirements/met in accordance with the award • Indirect costs consistent with the award • Suspended/disallowed costs resolved • Government property accounted • Patents/royalties/invention submitted, if applicable
Administrative Closeout Checklist 7. Advance/excess payments returned 8. Final SF-270(if applicable) received & forwarded to Finance 9. Final financial reports (SF-269/SF-272/SF-425) received forwarded to Finance 10. Final performance certification/report received & accepted (to include satisfying the terms and conditions) 11. File purged of unneeded and duplicate correspondence
Closeout Period • The Grantee has 90 days after the expiration date of the award to submit all required reports and drawdown funds to cover expenses incurred during the award period. • Grantee must notify NOAA of their intent to request an extension for report submission, payment drawdown during the close out period. • Grantee may request a one time extension to the closeout period of up to 60 days.
Top Ten Issues 1. Delinquent Financial and Progress Reports (Recipient) 2. Erroneous and incomplete Financial Reports 3. Indirect Costs: Omitted on the approved SF424A Omitted Negotiated Indirect Cost Rate Agreement (NICRA) Erroneous Calculations Utilizing Incorrect Rate
Top Ten Issues 4. Recipient failed to Countersign Documents (Awards/Amendments) 5. Delinquent Progress Report Certifications 6. Confusion surrounding Extensions to the Closeout Period versus Extensions to the Award Period 7. Recipient did not make the final drawdown prior to the expiration of the close out period
Top Ten Issues 8. Cost Share Requirements were not met by the Recipient in accordance with the approved award 9. Recipient failed to return excess funds 10. Untimely deobligation of funds
Open Discussion Thank you!