Chapter 8: Closeout

Closeout is a critical and mandatory process for sponsored projects. All obligations to sponsors must be fulfilled within the time frame specified in the award terms and conditions. Closeout requirements can vary depending on the sponsor and the type of award. Failing to meet these requirements can result in audit findings, financial penalties, administrative consequences, and impact the University’s ability to secure future awards. Closeout responsibilities are shared between OGC, PIs, and their administrative units. To ensure timely closeout, activities should begin no later than 90 days before the end of the award’s period of performance.

PIs and administrative units who do not comply with closeout requirements will be held accountable for any resulting fines, penalties, or cost disallowances.

8.1.1 OGC Responsibilities

OGC's responsibilities for closeout include:

• Assisting PIs and their administrative units throughout the closeout process
• Providing Closeout Timeline Reports (90-60-30 Day Report and 30-60-90 Day Report) to administrative units
• Completing and submitting final financial reports to sponsors
• Submitting other required deliverables to sponsors when AOR submission is necessary
• Submitting and processing final invoices and/or drawdowns
• Liquidating unobligated balances
• Closing speedtypes for sponsored projects

OGC is responsible for providing the Closeout Timeline Reports to administrative units at least 90 days before a project ends. The Closeout Timeline Reports include a checklist outlining activities and actions that the PI and their respective administrative units must complete to ensure timely closeout.

8.1.2 PI and Respective Administrative Units Responsibilities

PIs and their respective administrative units are responsible for completing all applicable requirements on the Closeout Timeline Reports, which include, but are not limited to:

• Completing a financial reconciliation for the project
• Completing and submitting all required reports and deliverables
• Ensuring and documenting subrecipient compliance with closeout activities, as applicable
• Submitting applicable cost transfers for any unallowable or improperly allocated costs
• Resolving overspending
• Updating employee funding distributions
• Submitting the Request to Close Contract or Agreement form for clinical trials to OGC

To ensure the University meets closeout responsibilities, PIs and their respective administrative units should complete all required closeout actions 30 days before the closeout period ends. PIs or their administrative units must immediately notify OGC if delays or issues arise that may prevent the University from closing the award within the prescribed timeframe.

Administrative units are responsible for meeting all closeout responsibilities, including in cases where the PI is incapacitated, no longer employed by the University, or in the event of the PI’s death.

The general requirements for federal award closeout are outlined in 2 CFR 200.344; however, each federal award may have differing closeout requirements as stipulated by the award terms and conditions, which take precedence over 2 CFR 200. It is the responsibility of PIs and their administrative units to adhere to the specific requirements of each award.

In general, closeout for federal awards requires:

• Submission of financial, performance, and other reports no later than 120 calendar days after the end date of the period of performance
• Receipt of all subrecipient reports and deliverables no later than 90 calendar days after the end of the subagreement period of performance, or another date as provided for in the subagreement (please note, the University generally requires subrecipients to provide final invoices within 60 days of the end of the subagreement’s period of performance)
• Final payment to subrecipients within 45 days of receipt of the final invoice
• Financial reconciliation and liquidation of all financial obligations no later than 120 calendar days after the end date of the period of performance
• Meeting all cost share obligations
• Complying with all post-closeout responsibilities

Please note, while the general government requirements provide for 120 calendar days after the end date of the period of performance to meet closeout responsibilities, some federal agencies may only provide 90 days.

In recent years, the federal government has increased monitoring and oversight of award closeout. To enforce compliance with closeout responsibilities, a federal agency may:

• Prevent drawdowns or reimbursements 120 calendar days after the end date of the period of performance
• Unilaterally closeout the award one year after the end date of the period of performance
• Report the University to SAM.gov for material failure to comply with closeout requirements

Under 2 CFR 200, failure to timely and accurately comply with closeout requirements may affect future funding to the University and/or awards involving the same PI

The closeout requirements for non-federal awards vary by sponsor. It is the responsibility of the PI and their respective administrative units to comply with all requirements outlined in the award terms and conditions.

When the University has entered into a subagreement with another institution, the PI and their administrative units are responsible for ensuring the subrecipient complies with the subagreement terms and conditions. The University may unilaterally close a subagreement if the subrecipient fails to comply with these terms, particularly when noncompliance hinders the University's ability to meet its closeout obligations. Unilateral closeout may include rejecting invoices submitted more than 90 calendar days after the end of the subagreement’s period of performance. PIs and their administrative units must notify OGC Subcontracts if a subrecipient fails to comply. OGC Subcontracts reserves the right to deny future subagreements with a subrecipient PI or institution for noncompliance with closeout requirements.

When the University is a subrecipient, the PI and their administrative units must ensure compliance with the pass-through entity's requirements. The PI and administrative units are responsible for any cost disallowances or penalties imposed by the pass-through entity.

PIs and their respective administrative units are responsible for completing a final financial reconciliation during closeout. It is considered best practice to conduct monthly reconciliations to minimize the administrative burden during closeout. The final financial reconciliation must review all costs incurred throughout the project period and should be completed once all outstanding encumbrances have been settled. This reconciliation must occur before OGC can submit the final financial report to the sponsor and should be completed no less than 30 days before the closeout period ends.

During the final financial reconciliation, PIs and their respective administrative units must:

• Ensure that all charges to the sponsor have been properly allocated and documented when costs have been charged to multiple projects or activities.
• Ensure that all ePERs have been certified.
• Remove all unallowable costs from the speedtype using a cost transfer.
• Verify that all recurring costs, such as monthly supply orders, have been canceled.
• Ensure that multi-year costs, such as warranties or service agreements, have been prorated so that charges to the sponsor do not extend past the award's period of performance.
• Confirm that cost share obligations have been met.
• Ensure indirect costs have been applied correctly.
• Verify that program income and applicable credits (such as rebates and refunds) have been appropriately applied to the sponsor.
• Address any overspending on the project.

The University must comply with all sponsor closeout requirements. OGC reserves the right to charge any unresolved expenses directly to the PI’s administrative unit if the PI or their administrative unit fails to complete a timely final financial reconciliation, potentially causing the University to miss sponsor closeout deadlines.

PIs and their respective administrative units are responsible for all overspent projects. Cost overruns must be applied to an administrative unit speedtype, in accordance with the administrative unit’s policies and procedures. A cost transfer may be required to move costs from a sponsored project speedtype to an administrative unit speedtype.

Final reporting requirements will be identified either explicitly or by reference in the award terms and conditions. Common reporting requirements include:

• Final Financial Report – OGC is responsible for submitting the final financial report.
• Final Progress or Technical Report – PIs and their respective administrative unit are responsible for writing the final progress or technical report and for determining who submits the final report. If AOR submission is required, the PI and their respective administrative unit must route the final progress report to OGC at least five business days before the deadline.
• Invention Statement – Most sponsors require the University to report any inventions, discoveries, or other novel commercial developments that were a result of an award. This is typically a requirement regardless if an invention disclosure has already been filed. PIs and their respective administrative unit are responsible for completing the invention statement and following sponsor submission requirements.
• Property Reports – Some sponsors may require final property reports to be submitted during closeout and these responsibilities may continue until the University has disposed of the property. PIs and their administrative units are responsible for submission of property reports.
• Dissemination of Clinical Trial Results – PIs and their administrative units are responsible for ensuring compliance with sponsor requirements regarding the dissemination of clinical trial results.

Under expanded authorities, federal sponsors may grant authority to unilaterally extend the project period of an award up to 12 months without prior approval. One-time extensions may not be used solely to spend any remaining funds. Under 2 CFR 200, this expanded authority is known as a “one-time extension”; however, the University and many sponsors refer to this authority as a “first no-cost extension.”

Any additional request to extend the period of performance requires sponsor prior approval. Under 2 CFR 200, this additional request is called a “no-cost extension,” while the University and many sponsors refer to it as a “second no-cost extension.”

Since January 2025, some federal sponsors, such as NIH, have removed this authority. It is the responsibility of PIs and their respective administrative units to comply with applicable sponsor requirements and deadlines to elect the one-time extension.

Additional information, including recent federal updates regarding no-cost extensions, is available on the OGC website.

Equipment purchases and large supply purchases near the end of the period of performance of an award may indicate an attempt to spend remaining funds, rather than incurring necessary costs for project completion. These costs may be seen as a misuse of sponsor funds.

For costs to be allowable near the end of the award, they must be incurred before the end of the period of performance and allocated in proportion to the benefit the award receives from the cost.

Equipment and supplies that have been charged to an award before the end of the period of performance but are received after the period ends are unallowable costs. Additionally, travel costs incurred after the period of performance cannot be charged to the sponsor and are considered unallowable.

The only allowable cost during the closeout period that may be charged to federal awards is for publication and printing costs, if incurred during the closeout timeframe and if award terms and conditions do not prohibit such costs. Further information on publication and printing costs is available in 2 CFR 200.461.

For non-federal awards, PIs and administrative units must comply with the award terms and conditions for allowable costs.

Although 2 CFR 200.472 allows for administrative costs related to closeout to be charged to federal awards, the University prohibits these costs unless prior approval is granted by OGC.

Federal sponsors typically classify property as either “exempt” or “non-exempt.” Exempt property means that the University has title to the property purchased under a sponsored award and has no further obligations to the sponsor. Non-exempt property means the University has conditional title to the property purchased under a sponsored award and has continuing responsibilities to the sponsor.

For exempt property, PIs and their respective administrative units must request disposition requirements for capital equipment from the Finance Office. PIs and their respective administrative units may dispose of non-capital equipment and supplies in accordance with the policies and procedures of the administrative unit.

For non-exempt property, PIs and their respective administrative units must comply with all sponsor requirements, including property reports and disposition requirements. General federal government requirements for non-exempt equipment are found at 2 CFR 200.313.

Federal awards generally vest title of supplies to the University upon acquisition of the property. If there is a residual supply inventory exceeding $10,000 in aggregate fair market value at the end of the period of performance, the University may either retain the supplies for use on other federally sponsored projects or sell the supplies. The federal sponsor, or pass-through entity, must be compensated for the current market value or proceeds from the sale. Additional information regarding supplies is found at 2 CFR 200.314.

Property disposition requirements for non-federal awards vary by sponsor, and PIs and their administrative units must comply with all sponsor requirements.

When terminating an award, the sponsor must provide, in writing, the reason for the termination and the effective date for termination. No new costs may be charged to an award on or after the termination date, and PIs are responsible for complying with all closeout requirements on a terminated award. All costs incurred prior to the award termination date must comply with the cost principles, award terms and conditions, and University policies. Attempts to exhaust remaining funds are unallowable.

All subawards under a terminated award must also be terminated, and PIs and their respective administrative units must work with OGC Subcontracts to properly terminate subawards. The date of termination for subawards will be the same date as the prime award’s termination. Subrecipients must also complete all closeout activities and may not incur costs to the award on or after the date of the prime award’s termination.

Since January 2025, federal agencies have terminated awards for "failure to comply with current administration policies." PIs who have received a termination letter, stop work order, rescission, or any other grant status update must submit this information to the campus federal transition team via this form. The PI should indicate if they would like to explore appealing the decision. OGC will work with PIs during the appeals process.

Unless allowed by the award terms and conditions, a residual balance on a sponsored project is returned to a sponsor. Any residual funds are University funds and must be expended on allowable University activities – these funds are not personal funds of the PI. 

The following table identifies the required actions PIs and their administrative units need to complete when a residual balance exists at the end of an award and the sponsor allows the University to retain the residual balance.

 

Scenario	Required Action
Residual balance is under 5% for a federal award and under 50% for a non-federal award.	Complete the University's closeout process and sign the closeout certification form indicating the Fund 26 speedtype the residual balance will be distributed.
Residual balance is 5% or greater for a federal award  and 50% or greater for a non-federal award.	Complete the High Cash Balance form. OGC and/or the Office of Vice Chancellor of Research will review the situation.

Most sponsors impose additional responsibilities after closeout. General federal requirements for post-closeout responsibilities are identified at 2 CFR 200.345. Specific sponsor requirements may also be included in the award terms and conditions.

Common post-closeout responsibilities include:

• Record Retention – All University employees are required to comply with the University’s Record Retention Matrix. Information Information for sponsored project records begins on page 22 of the Matrix. Please note, since the University’s policy is more restrictive than federal requirements, the University’s Record Retention Matrix supersedes requirements under 2 CFR 200.
• Repayment of Costs – Any cost disallowance or financial adjustments requiring repayment to a sponsor is the responsibility of PIs and their respective administrative unit.
• Subrecipient Audit Verification and Resolution – For federal subagreements, 2 CFR 200 requires the University to verify each subrecipient complies with audit requirements under 2 CFR 200, Subpart F, and for audit resolution for audit findings for three years after subagreement closeout. Fiscal Compliance is responsible for reviewing the Federal Audit Clearinghouse to verify federal subrecipients are in compliance and working with PIs and their administrative units during audit resolution.