Sponsored Project Closeout

Policy number: 10.11

Policy section: Research

Revised Date: December 16, 2019

1. Definitions

Definitions of capitalized terms are set forth in Appendix A.

2. Policy Statement

It is the policy of the University that closeout of Sponsored Projects will be in accordance with federal, state, and local government regulations, specific Sponsor policies and requirements and the terms of the Award and within the timeframe required by the Sponsor.

3. Purpose

This policy establishes requirements for Award Closeout of Sponsored Projects in a timely and accurate manner.

4. Project Closeout

  1. Reporting requirements and the deadlines for the report submission will be met as specified in the Award and may include one or more of the following reports: technical/scientific/progress report, financial statement of expenditures, report of inventions, patent report, royalty report, inventory listing of equipment purchased under the Award, and contractor’s release form and/or final invoice or voucher.
  2. It is the Principal Investigator/Project Director's responsibility to prepare the final technical report and invention statement in a timely and accurate manner. If the Principal Investigator/Project Director is no longer with the University or is otherwise unable to meet Award Closeout obligations, the Chair of the Department is responsible for assuring required final reports are re-submitted to appropriate University offices in order to meet Sponsor requirements.
  3. All Deficit Balances must be cleared by the Principal Investigator/Project Director, School, College, Division, Department, Center or Institute within the timeframe required by the Award for the final expenditure report or invoice/voucher.
  4. Residual Balances will be returned or retained according to the terms of the Award. Transfer of retained Residual Balances will be to designated funds, available for use by the Principal Investigator/Project Director, net of full indirect costs as calculated based on the applicable rate approved by Department of Health and Human Services regardless of the rate stated in the Award. If there is a Significant Residual Balance, disposition will be determined after justification by the Principal Investigator/Project Director and approval by the Associate Vice President for Research in consultation with the Vice President for Business and Finance.

5. Roles and Responsibilities: Principal Investigator/Project Director

The Principal Investigator/Project Director is responsible for ensuring that:

  1. all appropriate expenditures are charged to the Sponsored Project;
  2. all Personnel Activity Reports (“PARs”) certifying effort charged to the Sponsored Project are signed and submitted;
  3. the final technical/progress report is submitted to the Sponsor in accordance with the Sponsor’s requirements;
  4. a copy of final technical report is provided to the Office of Research and Graduate Studies;
  5. final invention, patent and/or royalty report(s) are provided to the Office of Research and Graduate Studies;
  6. clear all deficit balances within the timeframe required by the Award for the final expenditure report or invoice/voucher; and
  7. a final inventory of government property is certified and provided to the Asset Management Department, along with recommendations for the disposition of property.

6. Roles and Responsibilities: Deans, Associate Deans, Assistant Deans, Department Chairs and Directors

The Deans, Associate Deans, Assistant Deans, Department Chairs and Directors are responsible for ensuring that:

  1. direction, resources, and oversight are provided; and
  2. final reports are submitted on behalf of the Principal Investigator/Project Director when the Principal Investigator/Project Director is unable to meet closeout obligations.

7. Roles and Responsibilities: Office of Research and Graduate Studies

It is the responsibility of the Office of Research and Graduate Studies to:

  1. finalize Subrecipient monitoring procedures, when applicable; and
  2. submit Contractor’s release and other Award Closeout forms, when applicable.

8. Roles and Responsibilities: Office of Grant and Contract Accounting

It is the responsibility of the Office of Grant and Contract Accounting to:

  1. submit the final expenditure report and final invoice/voucher as required by the terms of the Award;
  2. request a check to return any residual balances to the Sponsor, when applicable;
  3. transfer retained, Residual Balances;
  4. send regular notice of expiring awards; and
  5. deactivate the Sponsored Project in the University’s accounting system to prevent post-Award Closeout expenditures from posting.

9. Related Policies, Procedures, and Guidelines

  • University Policy 10.1 Sponsored Research and Activities
  • Research Handbook

Appendix A: Definitions

"Award" means a Grant, subgrant, Contract, subcontract, or Cooperative Agreement that provides for Funding.

“Award Closeout” is the process of documenting and assuring the fulfillment of the terms and conditions of the Award, of certifying University compliance with applicable regulations and making final disposition of all Award by-products, such as final vouchers, reports, patent disclosures, property inventory, and the collection of outstanding accounts receivable and addressing deficit or residual balances.

"Contract" means a legally enforceable agreement between the University and a Sponsor that provides Funding when a primary purpose is delivery to the Sponsor of property or services for the benefit of the Sponsor, in addition to the research, educational, or service benefit to the University.

"Cooperative Agreement" means a legally enforceable agreement between the University and a Sponsor that provides Funding when substantial interaction between the Sponsor and the University is anticipated during the performance of the Sponsored Project.

“Deficit Balances” occur when cumulative expenses exceed the amount awarded by the Sponsor.

“Effort” means the time spent on Sponsored Projects and all other activities for which an individual is compensated by the University. See University Policy 10.15, Sponsored Project Effort Reporting.

“Funding” means financial support for a Sponsored Project, including money, property, services, or anything of value in lieu of money.

"Grant" means a legally enforceable agreement between the University and a Sponsor that provides Funding when:

  1. the Sponsor has no expectation of delivery of a specific product or service other than a final written report;
  2. no substantial interaction between the Sponsor and the University during performance is anticipated; and
  3. the agreement contains general terms and conditions that stipulate a period of performance and minimal reporting requirements.

"Principal Investigator/Project Director” means the individual solely responsible for technical conduct of a Sponsored Project, technical contact with the Sponsor, expenditure of Sponsored Project Funding, and fulfillment of technical performance and reporting obligations under an Award. "Principal Investigator” (PI) includes an individual designated in an Award as "Project Director" (PD), when performing the functions of a Principal Investigator, or other individuals performing the functions of a Principal Investigator. For the period of the Award, the Principal Investigator/Project Director must be a full-time employee (staff, tenured or, tenure track faculty, Research Professor, Research Associate Professor, Research Assistant Professor, or, if approved by the Provost or his or her designee, a non-tenure track, non-tenure eligible faculty member) appointed pursuant to University Policy 2.3, Faculty Ranks, Academic Titles, and Voting Rights.

“Proposal” means the document submitted to a Sponsor requesting Funding for a Sponsored Project which includes, without limitation, (i) Financial Obligations, Regulatory Obligations, Reporting Obligations or Accounting Obligations, as described under “Sponsored Projects”, (ii) a Statement of Work and (iii) a budget.

“Residual Balances” are the cash or unobligated balances remaining after Sponsored Project termination and after all appropriate expenditures have been charged against the Sponsored Project.

“Research Handbook” is a document maintained by the Office of Research and Graduate Studies specifying current procedures and requirements for the proposal, acceptance, execution, and oversight of Sponsored Projects.

“Significant Residual Balances” occur when the unexpended balance is 25% or greater than the total payments received for the Sponsored Project.

"Sponsor” means any external entity that provides Funding to the University. Sponsors may be (i) governmental agencies (for example, federal, state, or local governments or their administrative organizations); (ii) nonprofit organizations (for example, universities, nonprofit corporations, foundations, or associations); (iii) for profit organizations (for example, corporations, partnerships, sole proprietorships, and other business entities); or (iv) individuals.

"Sponsored Projects” means all projects, programs, research, training, public service and other activities that receive external Funding through Grants to the University or through Contracts or Cooperative Agreements between the University and a Sponsor, where one or more of the following obligations applies:

  1. Financial Obligation. The University is required to comply with conditions imposed when a Sponsor awards Funding for the performance of services or delivery of products described in a Statement of Work;
  2. Regulatory Obligation. The University is required to comply with Sponsor regulations.
  3. Reporting Obligation. The University is required to provide to the Sponsor technical performance reports or regulatory or administrative reports; or
  4. Accounting Obligation. The University is required to establish a separate accounting record of Sponsored Project expenditures to demonstrate allowability of costs, to maintain financial accountability, to make financial reports to the Sponsor, and to preserve appropriate records for audit.

“Statement of Work” means the component of a Proposal or an Award that describes the specific work to be undertaken and the products that will be produced by the Sponsored Project.

“Subaward” (also referred to as subgrant if the prime award is a Grant, subcontract if the prime award is a Contract or subagreement) means a formal, secondary agreement between the University and a qualified organization for the performance of a substantive portion of the program funded under an Award. The term also includes subawards made by a Subrecipient to a lower tier Subrecipient.

“Subrecipient” means the legal entity to which a Subaward is made and which is accountable to the University for the use of the Funding provided in carrying out a portion of the University’s programmatic Effort under a Sponsored Project. The term may include institutions of higher education, other non-profit organizations, for-profit organizations, and foreign or international organizations (such as agencies of the United Nations), if approved by the Sponsor.

Revised: December 16, 2019

Adopted: January 15, 2015

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