Close-out Requirements for Extramurally Sponsored Awards
Extramurally sponsored projects or programs often have specific close-out requirements which are listed in the terms and conditions of the notice of award. By accepting the sponsored funding, the Medical University of South Carolina (MUSC) has an obligation to comply with all of the final close-out requirements. Failure to adhere to these requirements can cause delays in, or even loss of, future funding for the individual and the institution; a non-compliant principal investigator/project director (PI/PD) places the entire University at risk for the suspension of all current and future funding. Principal investigators, departmental staff, and central administration units must work together in their respective roles to ensure all final close-out requirements of a sponsored award are met and in full compliance with the terms and conditions listed in the sponsor’s award notice.
Federal Award Final Close-out Requirements
The close-out of a federally sponsored award requires the timely submission of applicable reports (e.g. a final technical report, a final invention/patent report, and a final financial report). Additional close-out reports (e.g. property report) may be required depending upon the federal agency involved. Section 200.343 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance or UG) states all required final reports must be submitted within 90 days after the end date of the official period of performance. Per the UG some federal agencies, such as the National Institutes of Health, have exercised agency specific discretion and extended the final reports deadline to 120 days after the end date of the official period of performance; but this extension should not be presumed by the investigator. Questions about the required final reports and the due dates should be directed to MUSC’s Office of Research and Sponsored Programs (ORSP).
- Final Technical Reports - The lead PI/PD is responsible for the timely submission of the final technical report. The PI/PD must meet all of the sponsor’s specified requirements when preparing the final technical report and must provide MUSC’s ORSP a copy of the final technical report along with a time-stamped proof of submission if the sponsor does not have an ORSP accessible report tracking and retrieval system.
- Final Invention Reports - The lead PI/PD is responsible for the timely submission of any required invention or patent report. The PI/PD must comply with the sponsor’s invention reporting requirements and deadlines. Final invention reports typically require the PI/PD to indicate whether or not an invention occurred during the course of the study/project. Once the PI/PD has completed the final invention report, ORSP will review and certify on behalf of MUSC.
- Final Financial Reports - MUSC’s Office of Grants and Contracts Accounting (GCA) is responsible for completing and submitting any required final financial report. The PI/PD and the departmental staff must work with GCA to ensure all financials are in order prior to the end date of the grant award so there is adequate time for GCA to compile, review, and submit the final financial report prior to the sponsor's deadline. MUSC’s GCA published guidance about roles and responsibilities when preparing and submitting the final financial report. (see FAQ #7)
Questions about the final financial reports should be directed to MUSC’s GCA, the office responsible for completing and submitting all final financial reports on behalf of MUSC.
Non-federal Award Final Close-out Requirements
Non-federal awards; awards that are funded by corporations, foundations, or other governmental agencies (state or local); may have final close-out requirements. These close-out or reporting requirements will vary by sponsor, so it is required that the PI/PD review the terms and conditions of each award to comply with the specific requirements and deadlines. Questions about the close-out reporting requirements and due dates of a non-federal award should be directed to MUSC’s ORSP.
- Final Technical Reports - The PI/PD is solely responsible for the on-time submission of any technical reports required by the non-federal sponsor. When applicable, specific formatting requirements of the sponsor must be followed to ensure final report compliance.
- Final Financial Reports - MUSC’s Office of Grants and Contracts Accounting (GCA) is responsible for completing and submitting any required final financial report. The PI and the departmental staff must work with GCA to ensure all financials are in order prior to the end date of the grant award so there is adequate time for GCA to compile, review, and submit the final financial report prior to the sponsor's deadline. GCA published guidance about roles and responsibilities when preparing and submitting the final financial report. (see FAQ #7)
Questions about the final financial reports should be directed to MUSC’s GCA.
Documenting Final Reporting Requirements Have Been Met
To document compliance with a sponsor’s final reporting requirements, the PI/PD must provide a copy of all required non-financial reports along with proof of submission to ORSP by the sponsor’s deadline. ORSP will maintain these materials in the official file for reference as needed (e.g. audit). For those sponsors that have an ORSP accessible report tracking and retrieval system (e.g. NIH’s eRA Commons), the PI/PD will not be required to provide a copy of the final reports since ORSP can retrieve this information from the sponsor’s systems.
Documentation of the required final financial report completion and submission is maintained by MUSC’s GCA.
Delinquent Non-Financial Reports
Given the risks posed by late or non-compliant final close-out reports, MUSC’s ORSP will notify via e-mail a non-compliant PI/PD, the chair of the PI/PD, and MUSC’s Vice President for Research about any non-compliance in the area of final close-out reports. If for any reason the PI/PD cannot produce the required final reports, ORSP will contact the PI/PD’s department chair for a final resolution. As the PI/PD’s supervisor, the chair has the responsibility to ensure the PI/PD completes the final close-out report(s).
Award Close-out and Final Reporting Requirements: Role and Responsibilities
Principal Investigators/Project Directors must:
- Prepare and submit all non-financial final reports required by the sponsor’s award terms and conditions
- Meet all non-financial final report submission deadlines of the sponsor
- Comply with the sponsor’s final report formatting specifications
- Work with the departmental business managers to ensure all financials are accurate and correct allowing for a timely close-out of the financial records by GCA
- Address any questions about the close-out process with ORSP
Office of Research and Sponsored Programs (ORSP) must:
- Serve as an information resource for the final close-out requirements/procedures
- Assist Principal Investigator/departmental staff with final report submissions as needed
- Administratively review, approve, and sign the non-financial final reports as needed
- Track and maintain the records for the submitted non-financial final reports along with proof of submission
Departmental/Study/Unit Staff must:
- Assist the PI/PD so that they can submit the required final reports by the sponsor's deadline
- Help ensure financials are in order and up-to-date (accurate), so GCA can submit the final financial report by the sponsor's deadline
- Take an active role in assisting and supporting the PI/PD to meet all final report deadlines
Grants and Contracts Accounting (GCA) must:
- Serve as an information resource for the final financial report as needed
- Complete and submit the final financial report by the sponsor’s deadline
- Maintain the close-out records for final financial reports along with proof of submission
Here are some examples of sponsors’ final close-out report processes, however questions about close-out or final reporting requirements should be directed to ORSP at email@example.com.