Dear Principal Investigators, Chief Business Officers, research and finance team members, and award administrators,

We are writing to remind you of  significant changes made to the close out process and related final invoicing and financial reporting requirements of sponsored awards. The changes affect all sponsored awards, Principal Investigators, award administrators, Chief Business Officers, research and finance team members, and team members in Research Administration Services (RAS) and Research Grants & Contracts (RGC).

What changed?

Effective October 1^st, all awards must be fully reconciled, and final expenditures posted timely to the institutional general ledger to provide sufficient time for financial reports to be submitted and billing/draw downs to occur before the award is fully expired. For direct federal awards, timely means within 90-days of the award expiration. Additional details regarding  changes to the financial milestone deadlines can be found in the September ORA Newsletter. All final invoices and financial reports will be based on general ledger activity only; projections will not be included.

Background

In recent reviews by consultants as well as HHS, it was noted that our current close out process caused unreconciled balances on awards, which required corrections and resubmission of numerous financial reports, write offs, and return of unallowable funds.

Federal sponsors are now requiring a stricter enforcement of the award close out processes which includes requirements to submit all financial reports and draw down requests for related funds within 120-days of award expiration. Failure to meet the deadlines may result in sponsors flagging the University as noncompliant and denying payment of all drawdowns submitted. In addition, federal guidelines require that billing be processed after expenditures are incurred (e.g. paid  vendors).

What does this mean to you?

Awards are required to be properly and timely closed out once the award performance period has expired. Proper close out requires all expenditures to be fully reconciled, invoices paid, cost transfers processed, interdepartmental charges for service centers and core facilities posted to the awards, etc. Proper close out means that no projections (outstanding invoices or other expenses) can be included on final financial reports.

While this policy is already in effect, we will consider exceptions on a limited basis through December 31^st. A process to request and justify an exception will soon be released This process will allow a minimal number of exceptions each month to include projections on awards. However, projections must be fully paid and reconciled prior to the final draw down deadline for federal awards. The exceptions request will require signature from the PI or CBO and must include a justification for not posting the expenditures timely, a corrective action plan indicating action taken to prevent this from happening in the future and requires a speedtype to be used if the final expenditures are rejected or not reconciled timely.

For questions, please contact Research Grants & Contracts at https://rgc.emory.edu/.