The University has a responsibility to closeout completed sponsored programs in a timely and accurate manner. The award closeout process includes documenting and assuring the fulfillment of the terms and conditions of the award, of certifying GW’s compliance with applicable regulations and making final disposition of all award by-products, such as final vouchers, reports, patent disclosures and property inventory. In addition, this process includes the collection of outstanding accounts receivables and the distribution of any residual funds.
The University’s EAS/oracle system generates a notice 90-days prior to the end date of an award. Upon receipt of this notice, a first step for the Principal Investigator is to determine whether to request a “No Cost Extension” or NCE from the sponsor to allow for more time to complete the program. If such an extension is desired, it is best to advise the appropriate RSC as some sponsors have advance notification requirements for reviewing and approving NCEs.
An award can not be closed out in the University’s accounting system until the revenue, the invoicing, the cash received and the cumulative expenditures, program to date, are equal and in balance. The final financial report is prepared as soon as all details of the financial accounting for the program have been reconciled. The University has established a timeline that begins 90 days prior to the award end date and that allows for a timely progression through the closeout process as well as a basis for acceptance of financial responsibility for the outcome of all collection efforts. Due dates for final invoicing and submission of final reports vary by sponsor from the date of termination to within 90 days after termination. Each Program should be checked for the specific final date to avoid a late submission of required close out documents. Additionally, it is important that the Principal Investigator and other Program personnel respond promptly to any inquiries related to Program close out. In general, once a final financial report has been approved, any remaining funds will not be available to pay for items that were not identified in the final report.
Every effort should be made to complete programs within the grant or contract period of performance and to submit all required reports on time. If this is not possible for some reason, then with as much notice as possible, an extension of the period of performance should be discussed with the appropriate Research Service Coordinator to request additional time from the sponsor. For more information regarding Award Management and Closeout practices and procedures, please see http://my.gwu.edu/files/policies/Award%20Closeout%20PolicyFINAL.pdf.
ADDITIONAL CLOSE-OUT RESPONSIBILITIES
The Principal Investigator has additional Close-out responsibilities that generally include:
The OCRO RSC will be assisting with the process in many ways. Timely award close-outs are monitored as part of the OMB Circular A-133 audit, and compliance is very important.
The GCAS RA will be completing any final billings of the sponsor, collecting any outstanding accounts receivables, publishing the final financial report, and returning any residual funds, if appropriate.
18.1. AWARD CLOSE-OUT PROCESSThe award close-out timeline begins at 90-days prior to award end date. At this time, the Principal Investigator and the RSC receive an automatic system alert email. A second email alert is received 60 days prior to the award end date, and a third at 30 days. These alerts keep the award close-out prioritized for all parties so that any problems can be addressed and resolved prior to any final report filing deadlines. To facilitate the timely and accurate closeout of sponsored programs, the following procedure should be followed. The chart below identifies the more specific responsibilities of Principal Investigators, Research Service Coordinators, and Research Administrators in this process. Please contact the appropriate Research Service Coordinator with any questions.
90 Days Prior to Award End Date |
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Principal Investigator |
Research Service Coordinator |
Research Administrator |
Receive 90-day notice |
Receive 90-day notice |
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Run Budget Performance Detail Report (GM139) |
Run GM139 |
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Review expenditures; bring any discrepancies to RSC's attention |
Work to resolve any discrepancies identified by the Principal Investigator |
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Consider requesting a no-cost extension, if appropriate |
Suggest that Principal Investigator consider a no-cost extension, if appropriate |
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Process any outstanding orders, personnel actions, and direct payments. |
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Submit a request for a no-cost extension, if appropriate, according to sponsor time line. |
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60 Days Prior to Award End Date |
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Receive 60-day notice |
Receive 60-day notice |
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Review GM 139 to identify any additional discrepancies |
Review GM 139 to see that requested corrections were made |
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Work with RSC to assure that needed corrections are made |
Continue to work with Principal Investigator to resolve discrepancies |
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Continue to process any outstanding orders, personnel actions, and direct payments |
Clear suspense and funds check |
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Take corrective actions immediately if award is in deficit overall, by, for example, identifying any charges that caused the deficit such as erroneous salary charges or other direct charges not accounted for in the budget and initiating appropriate actions to remove these charges. |
Notify department chair of pending closeout with a current deficit |
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30 Days Prior to Award End Date |
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Receive 30-day notice |
Receive 30-day notice |
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Final review of GM 139 to identify discrepancies |
Final review of GM 139 to identify discrepancies |
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Verify that submitted corrections have been processed |
Follow up on submitted corrections that remain unprocessed |
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Take further corrective actions immediately if award is in deficit overall |
Notify department chair and dean of pending closeout with a current deficit |
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Award End Date |
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Receive "award ended today" via e-mail |
Receive "award ended today" via e-mail |
Determine which awards are ending this month and discuss closeouts with RSC at regularly scheduled meetings |
Final verification that GM 139 is correct |
Notify Research Administrator of any outstanding issues which must be resolved prior to the preparation of draft final financial report |
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Identify to RSC any remaining discrepancies that need to be corrected |
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Review outstanding encumbrances and liquidate as needed |
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30 Days After Award End Date |
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This is the data that will be the basis for the final financial report |
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Deficits remaining at this point (other than pending corrections) become the responsibility of the Principal Investigator's department. Remove salary deficits via CIS forms, if needed |
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Deficits other than salary remaining after the award close date will be moved to the Principal Investigator's department by GCAS. |
60 Days After Award End Date |
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Review draft final financial report prepared by the Research Administrator and sign or return with issues within five working days |
Review draft final financial report and follow up with Principal Investigator to assure timely signature |
Prepare draft final financial report based on data as of 30 days after award end |
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If required, indicate alias that will cover overdrafts |
Submit draft financial report to Principal Investigator and RSC via e-mail |
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Confirm which reports need to be prepared |
For fixed-price awards with residual funds, sign the certification and forward to OCRO. |
Obtain signature of Managing Director, Research Support and Analysis on certification form and send to GCAS. |
Transfer residual funds. |
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Log outstanding issues, if any, for follow up |
Confirm with RSC that there are no outstanding issues; if there are, RSC logs for follow up prior to close date. |
Award Close Date |
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Receive and retain file copy of final financial report |
Receive and retain file copy of final financial report |
Submit final financial report to the sponsor, with copies to the Principal Investigator and RSC. (If a no-cost extension approval is pending, Research Administrator will submit report with a note to that effect to the sponsor.) |
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GCAS will not perform final financial report revisions unless the following criteria are met: |
18.1.1. Residual Funds on Fixed Price Awards
For awards negotiated under fixed price agreements, if the final revenue exceeds the expenditures under the agreement, the residual funds are due to the school or the department in which the program was conducted. Such funds are distributed without adjustment if the award was negotiated with the sponsor at GW’s full indirect cost rates. If the award was negotiated at less than the full indirect cost rates, then such funds will be adjusted to reflect a full recovery prior to distribution.
19.1. COOPERATING WITH AUDITORS
Auditors are individuals who request to review and/or audit University records. Auditors include University employees or agents such as PriceWaterhouseCooper and Beers and Cutler, as well as auditors that are not University employees or agents such as District of Columbia auditors, sales tax auditors or federal agencies.
To verify protection of confidential information entrusted to the University and to protect the privacy of individuals as well as the integrity and reputation of the University, all auditors are verified before any information is released to them.
The Compliance and Privacy Office identifies all internal and external auditors who request to review information and verifies the propriety and scope of the proposed audit. Auditors who have not previously established a working relationship are introduced to the manager(s) of the department(s) to be audited. The Compliance and Privacy office must be notified when any auditor (whether internal or external) arrives unannounced.
Once the propriety of the audit is confirmed, the department should make every effort to provide the requested information.
For further information, please see Audit Notification Policy, http://my.gwu.edu/files/policies/AuditNotificationPolicy.pdf.
Section 19: Audits and Reviews
19.1. COOPERATING WITH AUDITORS
Auditors are individuals who request to review and/or audit University records. Auditors include University employees or agents such as PriceWaterhouseCooper and Beers and Cutler, as well as auditors that are not University employees or agents such as District of Columbia auditors, sales tax auditors or federal agencies.
To verify protection of confidential information entrusted to the University and to protect the privacy of individuals as well as the integrity and reputation of the University, all auditors are verified before any information is released to them.
The Compliance and Privacy Office identifies all internal and external auditors who request to review information and verifies the propriety and scope of the proposed audit. Auditors who have not previously established a working relationship are introduced to the manager(s) of the department(s) to be audited. The Compliance and Privacy office must be notified when any auditor (whether internal or external) arrives unannounced.
Once the propriety of the audit is confirmed, the department should make every effort to provide the requested information.
For further information, please see Audit Notification Policy, http://my.gwu.edu/files/policies/AuditNotificationPolicy.pdf.