1. Closeout: Sponsor requirements and UW requirements MRAM April 2014 Presented by: Office of Sponsored Programs

2. Closeout Requirements for Federal Grants  Closeout requirements for federal funding are established in OMB A-110  Agencies adopt specific requirements for closeout based on A-110:  Final technical (e.g. progress) report  Final financial report  Final invention statement  Final equipment report  Any other information they require per agency policy/award terms and conditions!

3. Current landscape for closeout requirements  OSP seeing tightening up of sponsor requirements:  Closer adherence to 90 day reporting requirement  Insistence that a report be submitted, even with absence of PI (e.g. out of country, transferred, or otherwise no longer with UW)  Increased use of wide spread impact to University due to single project non-compliance

4. Example  Sponsor notifies UW/PI that requirements due  PI has transferred  OSP contacts Sponsor to get exception  No exception granted; Chair is responsible for:  Following up with transferred PI to get final report information; or  Making formal statement and submitting to Sponsor via sponsor submission method

5. Example  Sponsor notifies UW/PI that requirements due  Due date comes and goes; final technical report not submitted  Sponsor sends multiple follow-up to UW/PI  Sponsor threatens termination of other award to this PI by date certain  OSP prepares termination Post-Award Change (PAC) per Sponsor notification  Work on other award temporarily on HOLD until this was rectified

6. Example  Sponsor notifies UW/PI that requirements due  Due date comes and goes; final technical report not submitted  Sponsor threatens to withhold future funding to the University of Washington  Sponsor sends letter to OSP that all pending funding will be on HOLD until due date met  OSP puts on fast track “escalation” path involving Chair, Dean and OSP Director  PI submits final technical report

7. Sponsors take final reporting seriously  Emphasis on final reporting is not going away  Omnicircular:  All obligations to be liquidated within 90 days past end date  Submission f final reports within 90 days as well  Steps for UW to take

8. Steps  Be familiar with GIM 39  Sets out general federal sponsor requirements  Emphasis on being aware of award terms and conditions with respect to final report requirements specific to project  Includes the notification schedule undertaken by OSP  Includes the escalation process followed by OSP

9. Steps  Establish a process within the department for handling closeout:  Know who receives closeout notifications from a Sponsor (often it is the PI only)  Know who receives OSP notifications (see GIM 39)  Have a general plan for gathering final documentation from departing PIs, if grant is not transferred with PI  Be familiar with sponsor systems involved to submit final technical reports. Often only the PI has level of user access to submit final technical reports on Sponsor systems.

10. Resources  Equipment Inventory Office – final equipment report  Grant and Contract Accounting – final fiscal report  Office of Sponsored Programs – general closeout requirements, liaise with Sponsor (other documents or requirements), notification and escalation process, and record for final submitted technical report  Center for Commercialization – signatory for final positive invention statement