Financial Reporting and Closeout Policy (Policy No. 600.0)

 

Effective Date:	March 1, 2019
Revision Date:	N/A
Responsible Office(s):	Office of the Vice President for Research and Office of Sponsored Projects
Approval:	Office of the Vice President for Research

Financial Reporting and Closeout Procedures/Guidelines

Sponsored Project Reporting Guidance and Delinquent Report Notification

FAQs

 

Scope

This document sets forth the requirements for final and interim financial reporting of expenditures and closeout of all sponsored projects at the University in accordance with sponsors’ award terms and conditions.

Policy Statement

This policy ensures compliance with Office of Management and Budget Uniform Guidance (2 C.F.R., Part 200) and promotes adherence to federal, state, and other sponsor requirements related to timely reporting of sponsored projects financial expenditures as recorded in the award documentation.  2 CFR 200.343 requires that final financial, performance, and other reports be submitted within 90 calendar days after the project end date.  It is Brown’s policy that all award closeout deliverables are completed and submitted to sponsors within 90 days after sponsored projects expire.

The policy also outlines the responsibilities of the Principal Investigator (PI), Department Administrator and The Office of Sponsored Projects (OSP-POST AWARD), who together are responsible to submit reports timely and ensure:

• Reports are submitted timely within the reporting deadline set forth in the award agreement/contract;
• Financial reports accurately reflect the actual use of sponsored funds as recorded in the financial records of the University; and
• Awards are closed-out timely to avoid the risk of financial activities posting to the award general ledgers after the award performance period.

Purpose of the Policy

Final Financial Reporting (FFR)

PI and/or department administrator must certify financial rough draft reports and return to OSP-POST AWARD within the deadline specified by OSP.  PI and/or Department Administrators should reflect legitimate adjustments on the financial rough draft prior to returning certified report to OSP-POST AWARD.  In cases when the draft final financial rough draft report is not returned to OSP-POST AWARD as instructed, OSP-POST AWARD will submit to the sponsor a certified final financial report based on University’s financial records without departmental approval.

Cost overruns (overdrafts) must be removed from the project prior to submission of the certified financial rough draft to OSP.  OSP will reassign costs that overrun the award amount to the cost center associated with the award if the departments do not remove overruns prior to the submission of a certified rough draft.

Except in unusual circumstances, the University will not file final financial reports which indicate unliquidated obligations or commitments. As stated in the NIH Grants Policy Statement, “Final FFRs must indicate the exact balance of unobligated funds and may not reflect any unliquidated obligations.”  Any unique circumstance that may require a final financial report to be filed with unliquidated obligations or commitments, OSP-POST AWARD in consultation with sponsor, will report the unliquidated on the final financial report.

Revised Final Financial Reports

Revision to a financial report or final invoice should be rare and must be legitimate.  Sponsors policies will determine when a revised financial report and revised financial invoice that includes additional costs are acceptable.  However, credits to sponsors will always result in a revised report and invoice.   

Note:  Some sponsors may not require a revised final financial report under a certain threshold but rather will require a refund of funds resulting from any reduction in expenses originally reported to and paid by the sponsor.

Requests to submit a revised final financial report may require a recertification of the financial rough draft by the PI and/or department administrator, and sent to OSP-POST AWARD along with supporting documentation as may be necessary.  A revised final financial report wherein the University claims less in expenditures than what was originally reported is required regardless of timeframe.

Non-Financial Reports

Annual progress and/or technical reports

Depending on the reporting terms of an award, annual progress and/or technical reports may be required.  The progress and/or technical reports are prepared and submitted to the sponsoring agency by the Principal Investigator. The submission of required progress and/or technical reports is the responsibility of the Investigator. While some sponsors permit online submission of these reports, many do not. Copies of reports, or report transmittal letters, should be forwarded to OSP-POST AWARD. Please note that the failure to submit reports in a timely manner may jeopardize current and future funding from the sponsor.

Final Invention Reports

Many sponsors require reporting about new technologies conceived or reduced to practice during the conduct of a sponsored research project. PI’s are responsible to complete invention reports/statements and route to OSP-POST AWARD for approval and final submission to sponsors. 

Property Reports

If award terms require the submission of a property report, OSP-POST AWARD will complete report in consultation with PI and/or designee and the Manager, Capital Asset Accounting and Analyst in the Controller’s Office.  OSP-POST AWARD is also responsible for the submission of property reports.

Closing Sponsored Awards

Definitions
 

Closeout

The act of completing all internal procedures and sponsor requirements to terminate or complete a research project. Specifically, closing out a sponsored project that has ended/terminated includes:

• completion and submission of non-financial deliverables stipulated in the award document by PI and/or OSP,
• submission of final financial reports and invoices,
• final payment requests (for LOC drawdowns), and
• Inactivation of an award hierarchy in Workday (inactivation of all grant worktags associated with an award).
• Changing the award status to “Close” in Coeus

Final Financial Reports and/or Final Invoices

The accounting of expenditures and obligations incurred during the period of performance and/or at the conclusion of the sponsored project using the sponsor-mandated report format.  A financial report may also contain “cost share” expenditures and program income (reported and disbursed) for the sponsored project when applicable.

Final Letter of Credit Draw Down

Funding issued via a Letter of Credit must be drawn down within 90 days of the end of the award. These draw down requests are made by OSP-POST AWARD monthly and based on expenditures posted to the general ledger.

Final Number

Cumulative expenditures reported to the sponsor.  Final numbers are logged on the award line record in Workday.  Entering the final figure into Workday confirms that payments expenditures in the general ledger agree to the final number reported to the sponsor. 

Financial Rough Draft Report

A draft of the financial report certified by the PI and/or department manager.  Changes and/or adjustments are also included on this document.

Interim/Annual Financial Reports

Many sponsors require the submission of annual and/or interim financial reports or invoices at the end of a budget period.  The expenditures reported on interim/annual reports represents expenditures that incurred within the specific budget period. 

No Cost Extension

A mechanism to extend the performance period of an award without adding additional funding. NCE’s typically must be requested before the award period ends.

Progress and/or Technical Report

Programmatic report of the project- includes the science/technical aspect of the project. This report is the responsibility of the Principal Investigator.

Unliquidated Obligations

The amount of obligations incurred by the recipient that have not been paid. For reports prepared on an accrued expenditure basis, these represent obligation amount incurred by the recipient that has not been settled or paid.

Unobligated Balance

The portion of the funds authorized by the sponsor for expenditure under a Notice of Award (NoA) that has not been obligated by the end of a budget period.

Unreconciled Accounts

These are expired/terminated awards having Coeus Status other than “Close” because there is a difference between what was reported to the sponsor and what is reflected on the general ledger.  Or, in some cases, there may be outstanding non-financial reports.  These present obvious risks and must be managed and fully closed out/disabled to limit their financial risk.

Note:  Most awards have strict deadlines for completion of closeout activities. Failure to complete closeout within the deadline can result in non-payment of the final amount due or may affect the ability to obtain another award from the sponsor. 

• Ensures all expenses are allowable, reasonable and allocable to the project and that any required adjustments to expenses are posted in compliance with accounting, reporting and close-out policies and procedures.
• Certify final/interim financial rough draft report by the due date set by OSP-POST AWARD during the reporting period.
• Ensures final invoice from subawardees is received and all payments have been processed prior to confirming final expenditures.
• Determine whether the project will end up with an unobligated (unexpended) balance, and be aware of the award terms regarding treatment of such a balance: Can the unobligated balance be automatically carried forward? Or must it be returned to the sponsor?  
• Principal Investigators (PIs) are required to understand and comply with the technical/programmatic reporting requirements of their awards, which involves becoming familiar with reporting formats, templates, and any online submission portals.  OSP is available to help you understand the terms and conditions of your award, including report due dates and processes. 

Department Manager/Financial Coordinator

• May certify final/interim financial rough draft report on behalf of PI and submit by the due date set by OSP-POST AWARD.
• Determine whether the project will end up with an unobligated (unexpended) balance, and be aware of the award terms regarding treatment of such a balance: Can the unobligated balance be automatically carried forward? Or must it be returned to the sponsor?  Contact your Pre-Award Grant/Contract Administrator if you require assistance.
• Reviews Workday general ledger reports regularly (e.g., no less frequently than monthly and more frequently for high dollar awards) to ensure costs are properly and completely recorded.
• Provides OSP-POST AWARD with any requested documentation to support questioned charges by due date set forth by OSP-POST AWARD during the reporting period.
• Submits to OSP-POST AWARD all adjustments after the performance period along with adequate documentation.  Process adjustments immediately, once approved by OSP-POST AWARD and provide operational transaction number on report (example, journal number, supplier invoice number, etc).
• As may be required per sponsor award documentation, prepares interim/final report and submit to OSP-POST AWARD for review and approval before submitting report to sponsor.
• Remove all over- expenditures of an expired award within pre-defined deadline set by OSP-POST AWARD.
• Remove unallowable costs or sponsor disallowances from the general ledger.
• Notify service centers with recurring billings (example, animal charges, printing, laboratories, etc) of the sponsored project expiration date and provide a new grant number, if applicable.
• Ensures all open commitments are closed and costing allocations have ended by the due date set forth by OSP-POST AWARD during the reporting period.

Office of Sponsored Projects - Post Award

• Performs desk review of expenditures to ensure compliance and selects cost items for allowability, and notifies PI and/or department manager of appropriate action to take, if necessary.
• Confirms with PI and/or Department Manager that all expenses are final.
• Reviews and approves all adjustments after the performance period that are included in the certified rough draft package submitted by department.
• Signs and submits financial report to sponsors based on total expenditures confirmed by PI and /or department manager.
• Submits final invoice to sponsor or processes final cash draw, if applicable.
• Reconciles payments against cumulative expenditures reported and ensures all payment received.
• Refund or transfer unexpended cash balance per the award terms and conditions.
• Process final project budget adjustment and general ledger closing entries as may be necessary.
• Obtains confirmation from PI and/or department manager that all required non-financial deliverables have been submitted to sponsor.
• Closeout award in COEUS and request the inactivation award hierarchy in Workday.
• Marks award file with discard date.
• Remits unspent funds back to sponsor, as required.

Office of Sponsored Projects - Pre Award

• Certifies and submits final progress reports or technical reports when institutional signature is required.
• Submits carryforward and no-cost extension requests to sponsor when applicable.
• Submits relinquishment statement when applicable.

FAQs

Subject	Contact	Phone
Financial Reporting & Closeout Policy	Grants/Contracts Accountant	401-863-2777