1. University of Pennsylvania 1 1 Non-Financial Administration of Award Closeouts December 7 th, 2011

2. University of Pennsylvania 2 What is Closeout? Closeout is the process in which the awarding agency determines that all applicable administrative actions and all required work with the award have been completed by the recipient [and the awarding agency]. Closeout is an After-the-Award activity officially ending the grant relationship. Defined in 45 CFR Part 74.71 2

3. University of Pennsylvania 3 3 All grants and contracts have end dates that require a variety of closeout procedures: Final financial report; Final invoice, Reporting of inventions and patent results; Listing of equipment purchases and equipment ownership information; and Final technical progress report providing the sponsor with the results of the research. What is Closeout?

4. University of Pennsylvania 4 What is expected? Timeliness of reporting and closing is crucial to sound grants/contracts management to assure full compliance with sponsoring agency regulations. These functions are tested as part of the annual OMB A-133 audit as well as by otherOMB A-133 sponsoring agencies when they make periodic site visits. 4

5. University of Pennsylvania 5 NIH Grantees must submit to NIH within 90 calendar days after the last day of the final budget period. –Final Progress Report –Final Financial Status Report –Final Invention Statement Submit to eRA Commons (preferred) or NIH Centralized Processing Center Requirements detailed in the NIH Grants Policy Statement (Section 8.6 Closeout) http://grants.nih.gov/grants/policy/nihgps_2011/nihgps_ch8.htm#_Toc271264983 5

6. University of Pennsylvania 6 NSF Final project report must be submitted electronically via the NSF FastLane System within 90 days following expiration of the grant; Within 90 days following expiration of the grant, a project outcomes report for the general public must be submitted electronically via Research.gov; and Federal Financial Report (FFR) must be submitted one full quarter after the expiration of the grant. http://www.nsf.gov/pubs/policydocs/pappguide/nsf11001/nsf11_1.pdf 6

7. University of Pennsylvania 7 Foundations & Other Not for Profit Organizations Final Technical/Scientific reports; Final Financial Reports; Other reports as designated; and Due dates vary by sponsor and will be specified in the the award documents. 7

8. University of Pennsylvania 8 Compliance Reminder Failure to submit timely and accurate final reports may affect future funding to the organization and/or awards with the same PD/PI(s). Accordingly NIH may impose sanctions on institutions that fail to correct recurring problems. Sanctions may include: –Corrective Actions –Removal of Authorities –Delay or withholding of future awards to the project or program 8

9. University of Pennsylvania 9 Compliance Reminder OMB Circular A-110 provides Information on Closeout Requirements* – Submit all sponsor required reports and liquidate all obligations within 90 calendar days; – Refund any balances of unobligated cash that was paid by the sponsor; and – Disclose information on any property acquired with funds or received from the sponsoring agency. *(OMB Circular A-110, Section 71) 9

10. University of Pennsylvania 10 Roles & Responsibilities PI/Department Ensure all associated projects and subprojects have been reviewed and are ready to close; Review the Terms and Conditions of the award and confirm all requirements were met; Confirm all non-financial reporting requirements are met (Final Equipment Report or a final Invention or Patent Report, Final Progress Report); and Communicate to ORS that reports have been uploaded in Era Commons/alternatively submit reports to ORS for processing, if applicable ORS Ensure PI compliance with technical reporting requirements; Verifies final invention report with Center for Technology Transfer; and Submit deliverables for PI, if applicable 10

11. University of Pennsylvania 11 Roles & Responsibilities cont. PI/BA work with Post-Award to complete Final Closeout; PI/BA uploads Final Progress report via Era Commons/NSF, sponsors website or via e-mail as required by contract/grant agreement; If final progress report needs to be signed off on or submitted by ORS, please forward to Tina Nemetz Notify Tina Nemetz tnemetz@upenn.edu once Final Invention has been completed in Era Commons, alternatively complete Final Invention form and forward to Tina for processing;tnemetz@upenn.edu Contact Tina Nemetz for clarification on non-financial closeout actions. 11

12. University of Pennsylvania 12 Recommended Practices to Improve the Closeout Process and Reduce Risk The non-financial closeout process is often treated as a separate procedure from the completion of the final financial closeout, but it should ideally be an extension of this process. Notify ORS when you are ready to begin the process. –If the project will not be completed by the end date, determine if you want to request a no-cost extension. If so, your Pre-award contact can facilitate that process. 12

13. University of Pennsylvania 13 Recommended Practices to Improve the Closeout Process and Reduce Risk Timeframe. –It is recommended that you begin the process 2-3 months prior to the end of the project. –For NIH grants, you have *90 days after the grant end date to finalize all expenses and submit all documentation. *Check with Post-Award Desk Accountant –For incoming subawards under NIH grants, you have 45-60 days after the end date to close out the project. –For other projects, refer to your contract or other sponsor guidelines. For clarity, once you have been notified by Post-Award that closeout action will begin please complete the non-financial closeout process (i.e. Final Invention and Final Progress Report). If at any point you are unclear of what is specifically required by your sponsor for non- financial closeout please feel free to contact Tina Nemetz. 13

14. University of Pennsylvania 14 Questions 14

15. University of Pennsylvania 15 Resources How to Guide for Era Commons: http://era.nih.gov/grantees/how-to_steps.cfm Reminder of NIH Requirements for Submission of Financial, Administrative, and Scientific Closeout Reports in a Timely and Accurate Fashion: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-128.html Subpart D-After-The-Award Requirements http://ecfr.gpoaccess.gov/cgi/t/text/text- idx?c=ecfr&sid=c7f392dac96e1efc24a5b821048f5243&rgn=div8&vi ew=text&node=45:1.0.1.1.35.4.11.2&idno=45 15