Sponsored Research Grant Close Out Requirements
Effective Date: October 01, 2017
Responsible Party: Office of Sponsored Programs
Administrative Category: Sponsored Research
Applies To: Faculty, Staff, Students
Keywords: Closeout, Grants, Research, OSP, Sponsored Research, Federal Grants
Please review NIH's guidance on grant final closeout as well as the final invention statement form.
Abstract
This policy details the UAB research grant closeout process for extramurally funded research. As a recipient of sponsored funding from federal and non-federal sources, UAB is required to provide accurate, timely, and complete disclosure of technical, programmatic and financial results of sponsored awards and programs.
This policy provides the UAB research community with specific timelines for institutional requirements for efficient and final closeout of sponsored research conducted at UAB. This policy also ensures that UAB is compliant with 2 CFR 200 Uniform Administrative Requirements, Cost Principals, and Audit Requirements (Uniform Guidance) for federal awards. The policy applies to all sponsored projects at UAB, whether or not they are subject to Uniform Guidance.
Roles and Responsibilities
UAB has a responsibility to effectively and efficiently close out extramurally-sponsored projects and collect on all outstanding account receivables in a timely and accurate manner. This can only be accomplished when Principal Investigator’s, award managers, research administrators, and contract/grant administrators and accountants work together.
It is the responsibility of the PI and Award Manager to responsibly perform all required tasks/deliverables and appropriately allocate costs to an award over the life of the grant/contract consistent with the approved budget of the sponsor and the initial grant/contract awarding documents including any mutually agreed to amendments or modifications.
The Office of Sponsored Programs (OSP) is responsible for the administration of all aspects of the grant/contract proposal review, electronic submission, grant/contract awards management, and contract negotiation with sponsors on behalf of UAB.
Grants & Contracts Accounting (GCA) is responsible for managing the post-award accounting, fiscal compliance, and reporting for UAB's sponsored grants and contracts.
Sponsored Research Grant Close Out Requirements
Research grant closeout is the process by which sponsors of extramurally funded projects determine that all applicable administrative actions of an award have been completed by the grantee. Uniform Guidance §200.343 states, “The non-Federal entity must submit, no later than 90 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by or the terms and conditions of the Federal award.” Therefore, consistent with Uniform Guidance requirements, all research grants conducted at UAB should be closed at least 90 days after the completion date of the research award. If the sponsor requirements are less than 90 days, the sponsored required closeout period will supersede.
Failure to submit timely and accurate closeout documents may affect UAB’s future funding opportunities, resulting in sponsors taken one or more actions that may include, but are not limited to, corrective actions, withholding or further awards, suspension or termination of the award.
Closeout Deliverables
Deliverables due at a project’s end date vary by sponsor and by federal agency, but generally include the timely submission of:
- Final Financial Report (NIH - FFR)
- Final Cost-Share Report (if applicable)
- Final Invoice or Draw Request
- Final Technical/Scientific/Progress Report (NIH - Final RPPR)
- Final Invention Report (NIH - Final Invention Statement)
- Final Inventory Report (if applicable)
- Other Non-financial Reports (if applicable)
- Termination Notice (required for NIH Fellowship and Training grants)
Federal Grant Closeout Communications
Principal Investigators and departmental contacts of federally funded grants will receive e-mail notifications of grant close out requirements from the Office of Sponsored Programs as follows;
- 30 days prior to award end date
- 30 days after award end date
- 90 days after award end date
Grants and Contracts Accounting will notify Principal Investigators and Award Managers as follows;
- 125 days prior to award end date
- 95 days prior to award end date
- 65 days prior to award end date
- 35 days prior to award end date
Final Financial Reports
Final financial reports for sponsored research grants is a shared responsibility between the Principal Investigator, departmental financial/research administration, and UAB’s Grants and Contracts Accounting department. Principal Investigators should report any outstanding expenditures (including subrecipient payments) no later than 30 days prior to the Final Financial Report due date. For additional information concerning Final Financial Closeout, refer to the GCA Sponsored Project Closeout/Payment Collection Guideline.
Final Progress/Technical Reports
Final Progress/Technical Reports are a shared responsibility of the Principal Investigator, departmental financial/research administration, and UAB’s Office of Sponsored Programs. Principal Investigators should follow the sponsor’s award guidelines for submission of final progress/technical reports. Most federal grant sponsors require final reporting to be submitted through the University’s Authorized Signing Official. For these projects, submission to the UAB Office of Sponsored Programs is required. Final Progress Reports in eRA Commons should be routed to the appropriate Federal Senior Grants and Contracts Specialist for review. If the sponsor does not require Signing Official review, the Principal Investigator and departmental financial/research administration should submit a copy of the final progress/technical report to the Office of Sponsored Programs.
Final Invention Report
Final Invention Statements are a shared responsibility of the Principal Investigator, departmental financial/research administration, and UAB’s Office of Sponsored Programs. If required, the Principal Investigator must submit a Final Invention Statement within 90 days following the termination of a grant award. The statement should include all inventions that were conceived, or first reduced to practice during the course of work under the award, from the original effective date of support through the date of completion or termination. Form HHS 568 should be completed for all NIH federal grants, and should be submitted to OSP through eRA Commons.
Other Closeout Documentation
Sponsors may require other closeout documentation such as Final Property Reports, Animal Disposition Statements, etc. When additional reporting requirements exist, the Principal Investigator should forward all required closeout reports to the Office of Sponsored Programs for timely submission to the sponsoring agency.
Inform OSP
The UAB Expedited Checklist must be submitted to the Office of Sponsored Programs (