Financial Reporting and Closeout Procedures/Guidelines

Reason for the Procedures/Guidelines

Federal agencies have become increasingly stringent about the timeliness of deliverables which is a key mechanism of financial accountability and stewardship.  The procedures/guidelines described below are intended to help ensure compliance with sponsors’ award terms and conditions and preserve Brown’s good standing, payments and future funding.

Deliverables due at a project’s end date vary by sponsor and by federal agency, but generally include the timely submission of:

  • A final financial report
  • A final invoice or a request for a final draw (for our Letter of Credit sponsors)
  • A technical/scientific/progress report
  • An invention/patent report
  • A property/equipment inventory report
  • A cost-share report, or validation of any cost-sharing on the main financial report
  • Other non-financial reports (e.g., assignment and release forms)
  • Final payment on an award may be contingent on the receipt of non-financial reports.

The financial reporting and closeout process is a shared responsibility. Principal Investigators and department staff have primary responsibility, and Office of Sponsored Projects (OSP) secondary responsibility.  The procedures/guidelines following are intended to streamline the financial reporting and closeout process of an award and ensure timely submission of deliverables. 

Exceptions to the procedural due dates will only be granted when presented in writing no later than 5 business days prior to the date that the certified rough draft report is due back to OSP Post-Award. Such exceptions will be considered only in extenuating circumstances and may require OSP to request sponsor approval for extension of the reporting deadline.

Examples of extenuating circumstances include:

  • Failure of another department to take action – e.g., on a properly submitted payroll adjustment request or service center charges.
  • Failure of a subcontractor to issue a final invoice in a timely manner, when evidence of attempts to obtain invoice(s) exists.
  • Systemic error(s) that impacts processing of adjustments to the general ledger.

If request for an extension to the due date is not communicated to OSP Post Award within 5 business in advance, the allowable expenditures reflected on the Workday ledger on the award end_date or budget end_date will be used as the official document for completing the financial report/invoice.  At this point, adjustments processed after the award performance or budget period are not permissible and will not be included on the report submitted to the sponsor.

 

Procedures/Guidelines-

A visual representation of the timelines noted below can be found in Appendix A in this document.

30-60 awards in this group are reflected on the “Awards Expiring in 90 Days” report located on the Grant Management Dashboard (a.k.a. PI Dashboard).  Best practice is to use this report to identify awards expiring within 30-60 days.  Note-if no cost extension will be requested, confirm advance notice requirements in the award document as some sponsors require more than 30 days advance before the current end date or budget period.  Example, the National Science Foundation requires that requests for a second no cost extension be submitted 45 days before the current end date.  Make sure to always check the award document, to confirm advance notice requirements.

30-60 before the award end date or budget end date (annual reports):

Department Staff

  • Submit the required paperwork/email to OSP Pre-Award Grant & Contract Administrator for no cost extension requests, if applicable.  Include the OSP Post Award Grant/Contract Accountant on the email.
  • Remind the subawardees of the due date for the final invoice.

0-30 days following an award end date or budget end date (annual reports): 

Department Staff

  • Thoroughly review the award financial record in Workday to ensure all outstanding expenses are posted in the general ledger (e.g. expense reports, service center billings, subcontract invoices, supplier invoices, etc.). 
  • Process outstanding cost transfers, if applicable.
  • Inform OSP Post Award if no cost extension will be requested, if request not previously submitted to OSP Pre-Award.
  • If applicable, work with the Manager, Capital Asset Accounting and Analysis in the Controller’s Office to make sure fabricated equipment are capitalized and tagged appropriately.
  • Journal off any over-expenditures from award prior to submitting the certified rough draft report to OSP Post Award.
  • Confirm, if applicable, actual cost share amount reflected on Sponsored Budget to Actuals Financial Record and Effort Certification Report(s) match the cost share committed amount.  Process adjustments if required/necessary.  It is essential to note that cost shared expenses must be verifiable on the Sponsored Budget to Actuals Financial Record and/or Effort Certification Report for financial reporting and/or closeout.
  • For training grants, reconcile stipend and/or tuition payments for each trainee to ensure accuracy of amounts posted to the general ledger.
  • Confirm deliverables required at the end of the project.
  • Check on status of programmatic deliverables with PI (final technical reports, etc.).
  • Notify OSP of any extenuating circumstances that may prohibit the final financial report from being submitted to sponsors (federal or non-federal) on time or prohibit cash being drawn by Letter of Credit before the sponsor deadline.

Examples of extenuating circumstances include:

  • Failure of another department to take action – e.g., on a properly submitted payroll adjustment request or service center charges.
  • Failure of a subcontractor to issue a final invoice in a timely manner, when evidence of attempts to obtain invoice(s) exists.
  • Systemic error(s) that impact processing of adjustments to the general ledger.

OSP Post-Award

  • Review award notice, terms and conditions and general ledger expenditures in preparation for financial reporting. 
  • Prepare financial rough draft and review financial activities for potential compliance items and questions for follow up with the department. 
  • Verify overhead posting and prepare/process overhead journal adjustments if necessary.
  • Submit initial rough draft final financial report to PI and/or department within 30 days after end date of award or budget period (annual report) to begin the process of confirming final expenditures.  OSP prioritizes the completion of rough draft financial reports to departments in the order of earliest due date to sponsor (30/60/90 days).

31-75 days following an award end date or budget end date (annual reports), there is ongoing communication between OSP Post-Award and Departments on the due dates, deliverables, drafts, etc. between an award’s end date and a sponsor’s deadline.  During this period:

Department Staff

  • Complete and submit certified rough draft financial report to OSP Post-Award along with supporting documentation of adjustments processed after the performance period and/or the operational transaction number (e.g. SFxxxxxxxx, ER-xxxxxx, INV-xxxxx, PAA’s, etc).
  • Submit supporting documentation and justification for questionable charges highlighted by OSP Post-Award on the rough draft financial report.
  • Confirm that all encumbrances/purchases orders and payroll costing allocations processes against an award have been zeroed out, closed, or ended.
  • Ensure grant worktags are removed/deleted from active grant listings maintained by other service departments and/or laboratories.
  • Confirm submission of final invoice from subawardee. Complete subaward closeout certification.
  • Remove overruns (overdraft) from award.

75-85 days following an award end date or budget end date (annual reports), approximately 10 business days prior to report due date to sponsor:

Department Staff

  • Ensure non-financial deliverables/reports are completed and/or submitted to sponsors (e.g. annual progress and technical reports).
  • Forward confirmation of submission of non-financial reports to OSP Post Award.

OSP Post-Award

  • If the certified rough draft financial report is NOT submitted timely, OSP Post-Award uses the Sponsored Award Budget to Actuals report as the supporting documentation for completing financial reports.  Adjustments processed by department after the award performance period are not permissible at this point and will not be included on the report submitted to the sponsor.
  • Review certified rough draft financial reports and supporting documentation submitted by department.  Reach out to department for additional information or clarification, as applicable.
  • Ensure all allowable and legitimate adjustments reflected on the rough draft financial report are posted to the ledger.
  • Complete the financial report/final invoice along with other deliverables, as applicable.
  • Submit reports for review and approval by signing officials.

86-90 days following an award end date or budget end date (annual reports), approximately 5 days prior to report due date to sponsor:

OSP Post-Award

  • Submit a final financial report to sponsor and/or final invoice (according to sponsor terms of award).
  • Submit other non-financial reports, as applicable.
  • Requests a final draw, if applicable.
  • Prepare award for inactivation in Workday.
  • Transfer any remaining outstanding overruns (overdraft) to cost center associated with grant.
  • Verify that PI has submitted programmatic/technical reports to sponsor.
  • Invention report completed and submitted to sponsor, as applicable.

After final report is submitted to sponsor:

OSP Post-Award

  • Within 1-30 days after report has been submitted to sponsor, OSP updates the COEUS award record status from Active to a closeout status as applicable (e.g. “Closed”, “Final Report Pending” “Final Payment Pending”, etc.)
  • Request the inactivation of the grant and award hierarchy in Workday.
  • Prepare award folder for transfer to off campus storage facility.

 

Appendix A- Visual Guideline References

Financial Reports Due by 90 Days After Award End Date

Financial Reports Due by 90 Days After Award End Date.png

 

Financial Reports Due by 60 Days After Award End Date

Financial Reports Due by 60 Days After Award End Date.png