45.12 - Sponsored Project Closeout and Recordkeeping Responsibilities
Owner:
- Position: Office of Sponsored Programs Director
- Email: osp@uidaho.edu
Last updated: February 13, 2024
A. Purpose. To identify the responsibilities and processes for completing sponsored project closeouts.
B. Scope. This policy applies to all sponsored projects.
C. Definition of closeout. Closeout is the process by which all required invoicing and financial accounting and reporting; all technical reporting; and all non-financial/non-technical reporting required by the award is completed.
D. Policy. It is the policy of the University to prepare and submit all required closeout documents within the time frame specified by the terms and conditions of the award document.
To ensure proper award termination procedures, the Office of Sponsored Programs (OSP), the unit, and the principal investigator (PI) have each been designated specific responsibilities. Typical regulatory or contractual requirements for sponsored research projects include final technical reports, invoices, financial reports, patent reports, and property reports. These reports are usually required to be submitted within 30 to 120 days of the project end date. Because of the requirements are contractual in nature and delinquent reporting can affect the ability of the University to receive future funding, it is important that closeout activities are finalized in a timely manner.
E. Procedure. Beginning approximately three months prior to the award termination, OSP will provide units with notifications that serve as reminders of required actions and responsibilities for timely award closeout. Non-compliance with University required actions may result in disallowed expenses.
Departmental grant administrators (DGAs) and PIs should work together to review and verify the following to OSP in written form:
- That all accrued expenses have posted to Banner;
- That no expenses incurred after the end date have posted to the award; and
- That all expenses are applicable to the project.
Failure to respond to requests for confirmation of expense review will result in the submission by OSP to the sponsor of a final invoice based on what has posted to the Banner accounting system, net of any disallowed expenses.
E-1. Revised circumstances. If there are extensions of time anticipated (i.e. for multi-year projects) the unit shall notify OSP immediately. If extensions of time are being requested from the sponsor, appropriate prior approval processes must be followed. (See APM 45.14).
E-2. Expense changes. Information on known project expenses that have not yet posted to Banner and that are requested to be included on the final invoice, must be submitted to the OSP Financial Unit by the due date specified in the “notice to final invoice” emailed near award termination. This due date is usually a minimum of 15-30 days prior to the due date for final invoicing or financial reporting to allow for sufficient processing time.
E-3. No changes required. If there are no corrections, the final invoice and financial report (when required) will be prepared from the information available in Banner. The DGA must verify the accuracy of the Banner numbers to the OSP Financial Unit by the due date specified in the “notice to final invoice” that is emailed near award termination. If there is no response, the invoice and report will be submitted to the granting agency based on the allowable expenses posted into Banner.
E-4. Limited revised final invoices and reports. If revisions are needed after the final invoice has been submitted to the sponsor, the Director of OSP or Assistant Director of Sponsored Accounting will evaluate whether to resubmit the final invoice or financial report on a case-by-case basis.
E-5. Recordkeeping responsibilities. For audit purposes, documents relating to the award must be kept for three (3) years, or longer if specified by the award terms.
The audit files maintained by OSP consist at a minimum of the following items:
- Original proposal and any additional supplemental proposals.
- Award notices and any amendments.
- Invoices and financial reports.
- Cost sharing records.
- Compensation confirmation (effort reports or other mechanism) and labor redistribution records.
- Property/equipment reports and patent reports.
- Subaward documentation.
In addition, the PI/Unit is required to maintain the following audit information:
- Technical reports (progress and final).
- Supporting documentation for cost transfers, inventory, and all expenditures.
- Miscellaneous correspondence regarding the project(s).
F. Contact information. Any questions regarding closeout procedures for sponsored projects should be addressed to the Office of Sponsored Programs at 208-885-6651 or osp@uidaho.edu.
Version History
Updated Feb. 13, 2024