To: Deans, Directors, Chairs, Principal Investigators and Business Managers
From: Bruce C. Fehn
University Controller
Andrew B. Rudczynski
Associate Vice President for Research Policy and Administration
Subject: Close Out Procedures
The close out process for sponsored programs requires coordination and cooperation between principal investigators, departmental business officers and post award administrators. An effective and efficient process is necessary to ensure that sponsoring agencies receive the required final technical and fiscal reports within the due dates established under the terms and conditions of the awards. If the University fails to file these reports on, a timely basis, it may be unable to receive final payments for the work performed and/or obtain continuation awards, renewal awards or entirely new awards from the affected sponsors. Therefore, the timely submission of required technical and fiscal reports is an important goal for the University.
In order to achieve this goal, it is appropriate and necessary to periodically review the university's policies and procedures governing the close out process. Accordingly, we have summarized these requirements for your information and benefit as follows:
A. Reporting Responsibilities
Principal Investigators (PIs) are responsible for preparing and submitting all technical reports and disclosure statements associated with their sponsored projects.
Departmental Business Offices (DBOs), working in conjunction with their PIs and post award administrators, are responsible for finalizing the costs associated with their sponsored projects.
Post award administrators are responsible for preparing and submitting final financial status reports required by sponsoring agencies. Post award administration on the New Brunswick and Camden Campuses is provided by the Division of Grant end Contract Accounting (DGCA). Post award administration on the Newark Campus is provided by the Grant & Contract Accounting -Newark (GCN).
B. Final Costs
All program costs (including payroll) need to be finalized and recorded in the appropriate 4-2 account on the general ledger thirty (30) days prior to the due date of the final fiscal report. Since most agencies require the final reports within ninety (90) days of the-project end date, this requirement will generally give DBOs sixty (60) days to finalize charges and the DGCA/GCN thirty (30) days to prepare and submit the fiscal reports.
The PI and DBO should monitor the award activity to insure all project costs are incurred prior to the award termination date and recorded thirty (30) days prior to the reporting date. During the sixty (60) day finalization period, the PI, DPO and DGCA/GCN should review program expenditures for any unallowable costs and agree on the appropriate adjustments. If at the conclusion of this process any unexpended project funds remain, they will be returned to the sponsor by the DGCA/GCN with the final fiscal report.
C. Cost Sharing Information
When cost sharing documentation is required, it must be submitted to the DGCA/GCN thirty (30) days prior to the final fiscal report due date. The final fiscal reports can not be filed without this information.
Please be advised that Federal and State agencies are applying more rigorous standards to amounts claimed as cost sharing. In particular, certain sponsoring agencies are beginning to expect that institutions maintain contemporaneous time keeping records to support the amount of effort claimed as cost sharing. As a consequence, the University will be implementing a new cost sharing documentation procedure in the near future.
D. Technical Reports
Technical reports must be filed with the sponsor within the due dates established under the terms of the award. In order to effectively respond to inquiries received from sponsoring agencies concerning outstanding technical reports, the PI is required to copy the DGCA/GCN on the cover letter transmitting the report to the sponsor and if necessary any letter requesting an extension to file the report. The PI must also retain a copy of the technical report on file in his/her department for examination upon audit and as a backup in the event the report is lost in transit or misplaced by the sponsoring agency.
E. Unallowable Charges
If any unallowable charges remain on an account after the final fiscal report is filed, they must be cleared by the PI/DBO within six months after the award termination date. If the unallowable charges are not cleared, the DGCA/GCN is authorized to transfer the charges to any related Facilities and Administrative cost return account of the PI, Department Chair or Dean.
F. Delinquent Reporting
If and when delinquent reporting becomes a chronic problem with a particular PI, the Office of Research and Sponsored Programs, the Newark Office of Sponsored Programs and DGCA/GCN are authorized to suspend processing of new proposals and new account requests for the PI until the delinquent reports are submitted and accepted.
Thank you for your attention and cooperation in this regard. If you have any questions concerning these procedures, please call the DGCA at extension 2-0165 or the GCN at extension 1335.
cc: Walter K. Gordon
James L Flanagan
Norman Samuels
Joseph J. Seneca
Joseph P. Whiteside
revised 6/14/99