As we approach the end of another fiscal year the Office of Research: Grants and Contracts (RGC) wanted to remind the research community of our sponsored award closeout timeline. Our office has seen an increase in the number of projected and unreconciled awards being submitted for final invoicing/financial reporting.
In keeping with 45 CFR 75.381 “a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.” While Uniform Guidance 200.344 mentions some awarding agencies may provide up to 120 days to complete final reports (NSF and NIH for example) these additional 30 days should not be considered additional time to allow further expense activity.
To prevent potential financial losses strict adherence to our existing closeout policies and timely posting of all final expenditures to Emory’s general ledger are critical. NIH will proceed with unilateral award closeout at 180 days from award end. In those instances where our submitted Federal Financial Report (FFR) does not match Payment Management System (PMS) drawdowns the sponsor is required to closeout at the lowest amount indicated.
As a reminder back in September 2021, ORA launched four policies related to Sponsored award closeouts. These polices were developed in collaboration with RAS leaders, CBOs, and ORA leaders.
- Policy 7.35 Small Balance Write-Off Policy – this policy provides the authority for RGC to clear small cash balances between (-$500 and +$500) to a central Compass project.
- Policy 7.36 Residual Balance Transfer Policy – this policy documents requirements to process a Residual Balance Transfers which will eliminate delays in the process.
- Policy 7.27 Sponsored Award Overrun Policy -this policy requires timely attention to clearing of deficits and describes processes when deficits are not cleared within 60-days after the award end date, to facilitate timely award closeout.
- Policy 7.37 Sponsored Award Close Out Policy – this policy clarifies the requirements necessary to closeout awards in Compass.
The policies are available on the Emory policy website https://policies.emory.edu/
To allow bilateral closeout with our awarding agencies we ask that regular award reconciliations occur and pre-planning for closeout are allowing sufficient time for all final expenses to fully post to our general ledger in time to meet reporting deadlines. Expense projections should be avoided whenever possible. Please communicate with your assigned RAS and RGC analysts as early as possible if complying with any of these closeout deadlines presents any difficultly.
Please contact us via email or phone if you have any questions or concerns.
The RGC Operations Team
Brian Miller
Interim Executive Director
Phone: 404-727-5230
Email: brian.miller@emory.edu
