See also (click for larger image):
Recommended Time Line for Closing the Award
Submit Final Progress Report
Research Affairs - Financial Management Submits Final Financial Report
Submit Equipment Report
Submit Invention Statement
Subawards / Subcontracts
Subaward Reporting Requirements
Final Requirements for the Responsible Conduct of Research (see main page)Materials and Equipment
Final Inventory Review & Report
Ownership & Title
Disposition of Equipment
Reconcile & Close the Account
Close the Account
Maintain Records & Audit
Record-keeping Roles & Responsibilities
Completion of a sponsored project period triggers sponsor and institutional requirements to reconcile all aspects of the project. Elements of the project must be brought to agreed, final positions (e.g. finances, science, intellectual property, and equipment matters). The sponsor's closeout requirements are found in the award document or contract and/or sponsor guidelines. Institutional requirements are outlined in the institutional research policy & procedure (H-20): Sponsored Project Closeout.
Unless otherwise notified, Research Affairs - Financial Management will assume that the project end date marks the close of project activity. Sixty (60) days before the project end date, Financial Management will send the PI an intent to close award notice with instructions and other closeout information.
Financial Management highly recommends that the PI schedule an appointment with his/her assigned Financial Analyst to discuss closeout procedures. If the PI needs more time to complete the project, s/he may request a period of performance extension.
Sponsored project financial accounts must be formally closed within ninety (90) days from the project end date to ensure that:
- all expenditures posted are allowable,
- all reports have been submitted to the sponsor,
- all payments have been received, and
- no additional charges will be posted to the account.
PIs are urged to follow the Recommended Time line for Closing an Award to ensure that all closeout requirements are met within these 90 days.
After a project has ended and is closed, Financial Management will store the official project file in accordance with institutional policy requirements as well as sponsor regulations.
If the PI does not receive a closeout notice, s/he should contact Research Affairs - Financial Management to confirm the project end date and verify that it is closing.
Financial Management will require a closeout document for non-federal awards. Acceptable closeout documents include:
- End of study letter from the sponsor (preferred);
- IRB closeout notice from Research Affairs - Research Protection Programs; or
- A memo from the PI.
Reporting requirements are usually outlined in the award terms and conditions. Research Affairs - Financial Management should be consulted if questions arise regarding compliance with reporting requirements.
The PI is responsible for promptly submitting a final progress report, if part of the sponsor's reporting requirements, as well as other agreed upon deliverables such as data, graphs, software, etc. The award notice or agreement should specify the required frequency of any reports and the dates that the sponsor expects them.
Inform the sponsor and Financial Management promptly of any delays. Before drafting a report, review the award terms and conditions and sponsor policies to see if a specific report form or style is required.
The PI should give a copy of the final progress report to Financial Management for the official project file.
If required by the sponsor, Financial Management will prepare a draft of the final financial report and send to the PI for corrections and approval. Once the draft report is approved and returned to Financial Management, the final report is prepared, authorized on behalf of the institution, and submitted to the sponsor.
Federal sponsors require interim or final reports using Federal Financial Report SF425 (FFR). Except for NIH awards under SNAP and awards that require more frequent reporting, the FFR is required annually and at the end of the project. The final report must be submitted to the sponsor no later than ninety (90) days after the close of the project.
All NIH financial reports must be submitted electronically through the eRA Commons.
Non-federal sponsors usually have their own financial forms which can be found in the terms and conditions in the award notice or contract.
Sometimes sponsors will request an equipment inventory report, whether or not title is retained by the institution. Sponsor policies on title to equipment and the submission of final equipment reports must be followed when closing out an award.
Research Affairs - Financial Management can assist the PI in completing the final equipment inventory report when necessary. The PI should review and approve the report and assist in resolving any issues that may arise regarding equipment or property.
If an invention statement is required (common for federal awards), PIs should contact Research Affairs - Technology Transfer. The PI must submit a Final Invention Statement within 90 days after the close of the project. The statement must include all inventions which were conceived or first actually reduced to practice during the course of work under the award.
Research Affairs - Financial Management will review the subcontract / subaward to ensure that all necessary closing actions are completed, including receipt of all appropriate closing documents. The following reports are required from the subcontract/subawardee for closeout within thirty (30) to forty-five (45) days of the project end date:
- Final technical report -- subcontractor PI submits directly to the LLU PI
- Final equipment report, if required
- Final patent report
- Final invoice -- created by the subcontractor and approved by the LLU PI, who then submits to Financial Management to initiate final payment
The PI is responsible for closing out all animal and/or human subjects protocols, submitting final reports, and fulfilling all obligations related to the Responsible Conduct of Research. See the main page for more information.
To ensure appropriate off-site handling and disposal of certain research materials, PIs should contact the following offices:
Radioactive Materials: The Office of Radiation Safety (extension 47268)
Recombinant DNA, bio-hazardous materials: Environmental Health & Safety (extension 44999)
In addition to maintaining accurate equipment records during the project, the PI should conduct a final inventory at project completion:
- Physically locate all equipment purchased with sponsor funds.
- Compare locations with the equipment tracking record. Correct the record as necessary.
- Record the condition of each piece of equipment as good, usable, usable after service, or not functional. This will aid in the development of a disposition list.
- Determine who takes title to the equipment after the project period. This will affect the disposition of equipment. Generally, title to all sponsor research equipment is vested with the institution.
- If required by the sponsor, complete and submit a final equipment report. Research Affairs - Financial Management can assist in preparing the report if necessary.
Research equipment bought with sponsored funds is owned by the institution unless otherwise stated in the award, applicable regulations, or institutional policy; or unless it is Government-Furnished Property (GFP). After project completion, title vests with the institution at the PI's school or center. The PI usually retains management responsibilities for the equipment and is encouraged to make it available to colleagues if possible.
For detailed information on research equipment, refer to LLUAHSC policy and procedure: (H-32) Research Equipment. Guidelines regarding the disposition of research equipment are usually outlined in the award notice or agreement. Disposing of research equipment should be considered when it is no longer:
- under the control and responsibility of the institution;
- a functional or identifiable piece of equipment; or
- part of the inventory of functional items and is not cost effective to repair.
Before transferring, selling, re-assigning, or disposing of equipment within or outside the institution:
- The PI submits a written request describing the intended action, along with an Equipment Release Authorization form, to the Director of Research Affairs - Financial Management.
- For federal awards: The institution must notify the sponsoring agency of its intent to dispose research equipment and request disposition instructions.
- The Financial Management Director, upon receipt of sponsor-authorized disposition instructions, will notify the PI of the approval and sends the Equipment Release Authorization form to University Accounting for processing.
- After University Accounting has processed the form, the equipment may be transferred, re-assigned, sold, or disposed.
Thirty (30) days before the project end date, PIs must send a Labor Requisition / Rate Slip to Research Affairs - Financial Management to move all sponsored project funded personnel to other accounts effective the day after the project end date. Rate slips can be downloaded from the Human Resource Management page on VIP.
The PI should ensure that Personnel Activity Reports (PARs) are completed correctly and returned in a timely manner. For more information, see Effort Reporting.
Thirty (30) days after the project end date, the PI (assisted by Financial Management) should review the account for any charges that have not yet posted and work to ensure that all charges are found, get posted, and that all charges were properly recorded.
Recurring charges will continue to post if required paperwork is not processed. Examples include demurrage, library, animal care, and communication network services. Thirty (30) days before the project end date, the PI should inform institutional service departments that the account cannot accept further charges after this date and provide an alternate account number.
The PI should start reviewing his/her account for charges processed against the project long before it ends. In fact, all sponsored project expenditures should be reconciled on a monthly basis. Detecting and correcting errors early is a good business practice that may minimize audit risks and prevent problems for future funding.
Encumbrances are an indication of purchases that have not yet been paid. The account cannot be closed until the encumbrances are paid or cleared. Thirty (30) days after the project end date, encumbrances and any open purchase orders should either be canceled or transferred to the appropriate account. If the materials and/or services shown as encumbrances have been received before the project end date, the PI should notify Research Affairs - Financial Management. Please consult with Financial Management as additional documents may be needed to clear the encumbrance(s).
As Research Affairs - Financial Management begins to analyze the sponsored project account, the PI's assigned Financial Analyst will alert the PI if an overdraft on the account exists. At this point, the PI and the Financial Analyst are responsible for identifying and removing the over-expenditures. Please see LLUAHSC policy and procedure: (H-05) Cost Transfers on Sponsored Projects for more information. All overdrafts should be removed at least sixty (60) days after the project end date and before the final reports are submitted to the sponsor.
The sponsor's terms and conditions usually include instructions on handling residual funds.
Federal sponsors rarely allow the institution to retain residual funds after award closeout.
Non-federal sponsors occasionally allow the institution to retain residual funds, which will be distributed according to the LLUAHSC policy and procedure: (H-07) Distribution of Residual Income on Sponsored Projects.
- After the institution collects indirect costs (as permitted by the sponsor), the residual income will be distributed to the PI's performing department/group, into one or more residual income accounts.
- Residual income accounts will be directed by the PI's academic department and administered by Research Affairs - Financial Management. Research enhancement requests identifying a research function support improvement will be sent to Financial Management for review, approval and release.
- Funding these accounts will be used to enhance the research activity and capabilities of the department.
- If the PI leaves the institution, the residual income will remain in the institution's residual income accounts.
- Large residual fund balances (exceeding 10% of the award revenue) will:
- be reviewed by Financial Management to ensure that all costs have been charged to the award.
- require a written statement by the PI explaining the amount which is to be submitted to and kept by Financial Management in the official project file.
- require appropriate documentation that the objectives of the award have been satisfied.
Once a sponsored project account has a zero balance and all other closeout requirements are completed, Research Affairs - Financial Management will deactivate the account. Once the account is deactivated, charges will no longer be allowed to post to the account. Financial Management will store the official project file according to applicable regulations. Please see the LLUAHSC policy and procedure: (H-20) Sponsored Project Closeout for more information.
Financial, administrative, and research personnel all share the responsibility of retaining sponsored project records (including paper or electronic records, statistical records, and supporting documents):
The PI must retain:
- financial and administrative records;
- scientific records and data, including documentation of the methods used to conduct research, and progress/performance reports; and
- animal and human subjects documentation.
The department must retain:
- financial and personnel records
Research Affairs - Financial Management (RAFM) must retain:
- the official project file
Federal awards: Three (3) years from the submission of the final financial report, or as specified in the award terms and conditions.
Non-federal awards (including clinical trials): As indicated in the award document.
Audits are essential to successful institutional operations. Common audits include:
This audit is required by the federal government and is coordinated by Research Affairs - Financial Management. It examines the financial systems and expenditures of federal sponsored projects according to OMB Circular A-133.
The sponsor can also request that an individual award be audited. Sponsor audits are generally financial or programmatic. The institution will cooperate, to the maximum extent possible, with authorized auditors, investigators, and other agency representatives who are conducting a fiscal or programmatic review of externally funded projects.
PIs should understand that auditors have the right of access to all official institutional records for a sponsored project and that the institution is obligated to make such records available for examination. Therefore it is important that the PI, department, and central administrators all understand and comply with the applicable record-keeping requirements.