*This letter is shared on behalf of Research Grants & Contracts*
Dear Colleagues,
Recent federal directives have introduced significant changes to the processes for drawing down funds and closing out awards. These updates affect all federally funded awards and require immediate attention to ensure compliance.
Drawdown of Federal Funds
Historically, drawdowns were processed based on allowable expenditures incurred. However, federal agencies now require pre-approval for each drawdown and are mandating additional documentation. These requirements vary by agency and continue to evolve, resulting in a more time-intensive process that restricts our ability to draw funds on a weekly basis.
New requirements include:
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Detailed breakdown of expenditures by expense category and date incurred.
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For terminated NIH awards, expenses must be categorized pre- and post-termination, with post-termination costs limited to human subjects and animal welfare-related expenses.
To comply, we need your active support in identifying the necessary details for drawdown submissions. The Grants AR team will reach out as needed and is available to assist with any questions.
Financial Reporting and Invoicing
To meet sponsor expectations and deadlines—especially those set by NIH—expenditures reported in final Federal Financial Reports (FFRs) must match drawdown amounts. Drawdowns and invoices can only be submitted after all expenditures are fully posted and vendor payments are issued. Timely reconciliations are critical.
We are now enforcing the following internal deadlines for award closeouts:
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For 120-day federal deadlines: All expenditures and payments must be posted within 90 days of the budget period or award end date. Reconciliations are also due within 90 days.
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For shorter deadlines (<120 days): Expenditures must be posted and reconciliations submitted by half the sponsor’s deadline (e.g., 30 days for a 60-day sponsor deadline).
Expenditures and sub-recipient invoices submitted after these internal deadlines will not be accepted.
We appreciate your partnership in adapting to these changes. Please contact the Grants AR team at ar.rgc.help@emory.edu with any questions or for further clarification related to federal drawdowns or the Award Close Out Team at rgcac@emory.edu for questions related to award closeouts.