RA-HT
RESEARCH ADMINISTRATION HOT TOPICS
University Research Administration (URA)
Sponsored Award Accounting (SAA)
TOPIC 5
OMB Uniform Guidance: Closeouts
March 16, 2015
OMB Uniform Guidance – Session Topics
• Uniform Guidance Closeout Requirements
• Financial Risks to UChicago
• Tracking of Sponsor Deliverables
• Department Actions to Take
• URA and SAA Response
• Resources
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UG Closeout Requirements
§200.16 Closeout.
• The process by which the Federal awarding agency or
pass-through entity determines that all applicable
administrative actions and all required work of
the Federal award have been completed
• Sponsor takes actions as described in §200.343
Closeout
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UG Closeout Requirements
§200.343 Closeout.
• All financial, performance, and other reports as required
by the terms and conditions of the Federal award are due
no later than 90 calendar days* after the end date of the
period of performance
• All obligations must be liquidated no later than 90
calendar* days after the end date of the period of
performance
• Any real and personal property acquired with Federal
funds or received from the Federal Government must be
accounted for at the end of the award
*Agency implementation plans are pending but NIH and NSF have indicated that a
120 closeout requirement is likely.
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Financial Risks to UChicago
• Disallowance of expenses posted after 90-day timeframe
• Late reports have resulted in delays in receiving new and
continuation funding; not just for the PI but for all
institutional awards
• Collaborators are disallowing late invoices for our sub-
awards
• Potential for funding reductions for future budget periods
due to low expenditure volume
• NIH and NSF requesting additional support for carryover
and no-cost extension requests
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Tracking Award Deliverables
• AURA and FAS have attributes and functionality to track all required
financial, performance, and any other reports
• URA and SAA staff populate these attributes at award setup
• Unit administrators should review attributes
• Check AURA View 21.0; contact URA to update View 21.0 if the
deliverables change due to “unofficial” communication
• Check FAS screen 6 for Financial Report Due Date
• Unit administrators/managers should determine what tools to use
to monitor deadlines (e.g., Business Object reports, email
notifications, sponsor system notifications, etc.)
This should be done when the award is received .
Don’t forget to check all projects when you learn that a PI is leaving the institution.
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Tracking Award Deliverables - AURA
• AURA View 21.0, Sponsor Deliverables
• Currently used in different ways:
• For awards that will have progress reports submitted
through CNs (NIH RPPRs)
• For other non-NIH awards or others that will NOT have
CNs to add additional periods, but that do have some
form of required deliverables (many not-for-profits, NSF
awards issued with all years, etc.)
Tracking Award Deliverables - NIH and Other Projects
With CNs
• The unilateral grants from NIH all require progress reports prior
to the start date of the next budget period
• General NIH RPPR dates:
• SNAPs (R01s on the 15th of the month preceding the month in
which the budget period ends
• Non-SNAPs (Ps, Ts, & Us) due on the 1st of the month preceding
the month in which the budget period ends
• Fellowships (Ts & Ks) due 2 months prior to the beginning date
of the next budget period
• AHRQ due 3 months prior
• Final reports (Financial, Final Progress, Invention, etc.) may also
be entered
Tracking Award Deliverables - NIH and Other Projects
With CNs
• When is this information entered into
AURA?
• Year 1, not entered by URA at award stage (at this time)
• Prior to the RPPR due date, the PD/PI gets an automatic
e-mail notification from NIH
• URA also sends out a list of all RPPRs that are due the
following month (usually around the 20th of the
preceding month)
Tracking Award Deliverables - NIH/CN-types at RPPR
Stage
• URA uploads the final RPPR document in View
21.0 when complete and completes the
following:
• 21.1.1 – Type = Progress Report
• 21.1.2 – Due date = the date it WAS due
• 21.1.4 – Required for closeout? Y/N
• 21.1.5 – Document (final uploaded version with date
submitted and document status “final”)
Tracking Award Deliverables - For Other (Non-CN-Type)
of Awards
• GCM enters deliverables and dates in View 21.0
prior to distribution of AWARD
• PCO should check that information for
verification
• GCM will update deliverables when we process
no-cost extensions or other modification which
affect these requirements
Tracking Award Deliverables - NIH/Other CNs for Out
Years
• When the FP is in an editable state, PCO can
add the future RPPR dates for additional
email reminders in 21.1
• Look for the “ADD” button in the main FP
• Type of deliverable (Progress, Technical, Financial,
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Other)
Due date(s)
Reminder Frequency (30, 45, 60 or 90 days)
Required for closeout Y/N
(Documents are uploaded by URA)
Tracking Award Deliverables - FAS
• SAA enters the financial report due date in FAS – Screen 6
• SAA enters the closing memo return date and financial
report file date in FAS – Screen 6
Tracking Award Deliverables - Management Reports
SAA developed a suite of Business Objects Reports as a management toolkit
for departments.
Name of Report
Description
Upcoming Closing Memos Due
Covers upcoming 2 months based
on the report run date
Late Closing Memos
List of closing memos not
submitted to SAA 15 days before
financial report file due date
These reports were emailed to many units and are available on the BSD
SharePoint. If you are interested in obtaining any of these reports, please
contact your SAA Post-Award Administrator.
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Department Actions to Take
• Effective communication to PIs on the importance and
implications of these changes
• Reduce the number retro-active expense transfers at the end of the
award
• Limit the number of large purchases at the end of the award
• Avoid “saving” budget on awards; 4 year award segments are not 5
years long
• Better coordination between pre- and post-award staff to
track reporting requirements and status of submissions
• Management review of upcoming deadlines to better
distribute department workload and prioritize tasks
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Department Actions to Take
• PI portfolio review of current and pending support;
management of portfolio not award-by-award
• Review of award during the life of the award, not just when
it’s over (SAA has suite of reports for this too!)
• Subaward budget to actuals
• Cost sharing commitments
• Overdrafts
• Unallowable costs
• Timely and accurate closing memos for financial closeout
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Top 10 Closing Memo Mistakes
SAA will only enter the closing memo return date in FAS once a complete,
actionable closing memo has been received.
Late closing memo
Incorrect ledger date
Unsigned closing memo
Includes transactions incurred after award end
date
Missing ledgers
Missing trailing transaction documents (e.g.
Purchase Order for expense not yet posted)
Incorrect IDC rate and/or base
Missing closing memo for associate account
Underspent cost share
Encumbrance issues
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URA/SAA Response
• Initiation of Closeout Working Group to review current
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policies, procedures, and systems to support timely closeouts
Develop better training and outreach to campus units and
faculty groups
Refine and consistently use View 21.0 in AURA
Forward Sponsor “reminders” and “late notices” to
Department and PIs
Follow up with Chairs/Section Chiefs when sponsor sends 2nd
notice (as needed)
Utilize Business Objects to track status of closing memos and
financial reports
Determine how best to use AURA to retain documents
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OMB Uniform Guidance – Resources
2 CFR 200: Uniform Administrative Requirements, Cost Principles,
and Audit Requirements for Federal Awards
Frequently Asked Questions:
https://cfo.gov/wp-content/uploads/2014/11/2014-11-26Frequently-Asked-Questions.pdf
Federal Regulations:
http://researchadmin.uchicago.edu/policies_compliance/federal_regu
lations.shtml
RA-HT Session Slides: http://researchadmin.uchicago.edu/
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