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Stage
Manage Award and Finances
Topic
Prepare for budget period or award end
Subtopic

Award closeout

Need assistance with award closeout?

IMPORTANT NOTICE: 

Please note that due to continuing developments, users should consult the following resource for the most recent guidance and directives from federal funding agencies:

Questions relating to specific awards or grants should be directed to the following contact:

When a project is approaching the end of the award period, programmatic and administrative closeout activities need to be completed in a timely manner to achieve a clean close of the award. Utilize the timeline below for activities and milestones to be completed as part of the award closeout process. The "Related Resources" on this page also include quick reference guides and other resources to provide more detailed information to proactively navigate this process.

Closeout Analysis & Action Timeline

Close period for a sponsored project begins 90 days prior to the budget or project period end date. Activities highlighted below represent actions and analysis needed throughout close period to support a compliant closeout submission. These timeframes are based on projects with standard due dates, adjustments should be made for projects with non-standard or shortened reporting deadlines. Refer to Closeout of Sponsored Project GAP 200.180 and other associated Sponsored Research GAPs.

90 days prior to Project End

Proactive management will lead to a clean and timely closeout, with minimal/no late activity.
Actions
  • Initiate tasklist & utilize the questions to identify actions needed
  • Communicate with internal & external subs on closeout expectations, responsibilities & WBSE/project balance management
  • Conduct compliance review of ledger to identify CAS items, unresolved errors, etc.
     
Analyses
  • Intention for NCE
  • Reconciliation/validations completed and reviewed for compliance issues through-out post award management
  • Options and plans for future effort distributions
  • Balance projections – parent & all subcodes
Reports, resources and instructions
Award ManagementProject

Continue discussions with PI regarding project status and future plans (based on sponsor guidelines)

  • Will NCE be requested? If so, see NCE guidance
  • Will IRB Protocol continue? If yes, discuss applicable system requirements with research staff
  • Review projected expenses with PI and update projections. If cost overrun anticipated, confirm with PI how deficit will be managed. If balance anticipated, review sponsor guidelines with PI
  • Contact internal sub(s) to communicate project ending to clarify reporting responsibilities and management of WBSE balances for project
Compliance
  • Review sponsor and award specific terms to ensure compliance with guidelines (CAS, effort requirements, cost sharing, tuition remission, etc.)
External Subrecipient
  • Begin dialogue with subrecipient, reminding them of final invoice due date and reporting requirements.
  • Confirm receipt of consecutive invoices. Research and resolve outstanding invoice issues.
Duke@WorkCONS Report
  • Identify projects that are ready for initiation of the closeout process and the required documents
  • Confirm closeout docs due dates and sponsor due dates
Projection Tool
  • Review personnel allocation with PI and discuss updates to personnel plans with Business Manager/HR
  • Review & update with additional projected expenses from PI/lab/research coordinators
CAS Compliance Report
  • Review to identify non-compliant project line items and make corrections
Closeout Tasklist Utility
SAPITD report (Z71PROJ)
  • Review expenses for accuracy and compliance, address any budget vs actual concerns
  • Plan for cost overrun or carry forward, if applicable
  • Address unresolved CAS/rebudget issues
Master Data  (CJ20N)
  • Review WBSE’s backstop code
WBSE Master Data & One Line Summary (ZF600) 
  • Review project data for closeout guidance (Federal award, due dates, LOC attribute, etc.)

60 days prior to Project End

Actions
  • Address relevant tasklist items
  • Resolve outstanding procurement obligations and invoices
  • Review revenue to address any delays in AR
  • Remove any unallowable expenses
  • Identify and resolve remaining compliance issues: CAS, IRB, and all other Duke or sponsor related guidelines
  • Process NCE submission in SPS
Analysis
  • Confirm compliance with all sponsor terms and conditions
Reports, resources and instructions
Award ManagementProject
  • Complete NCE request with Sponsor through SPS, if applicable
  • Continue conversations with PI
Compliance
  • IRB Protocol Status – continue conversation with PI and Research Staff
    • Request eIRB status update
  • Identify and resolve any CAS items
     
External Subrecipient
  • Follow up with subrecipient if concerned with ability to meet final invoice or technical report deadlines
Duke@WorkProject Obligation Report
  • Discuss plans for new effort distribution(s) with PI or Business Manager
  • Initiate communications with collaborating departments to plan for cross departmental effort changes
  • Resolve outstanding purchase order obligations and existing standing purchase orders
CONS Report
  • Monitor progress of Tasklist sections
Payroll Tools
  • Confirm project effort requirements have been met (Weighted Average Report)
Closeout Tasklist Utility
  • Update questions and sections as progress is made
SAPITD report (Z71PROJ)
  • Review expenses for accuracy and compliance
  • Resolve outstanding CAS items and ensure documentation is in place for reviewable G/Ls

30 days prior to Project End

Remove unallowable charges.
Resolve outstanding items that could delay closeout or impact clean close.
Actions
  • Address relevant tasklist items
  • Submit iForms for all cost distribution changes
Analyses
  • Confirm compliance with all Duke and Sponsor guidelines (CAS, IRB, etc.)
  • Assess projected balances for parent & all subcodes to identify adjustments that may not be accommodated by project netting process
  • Communication end date with relevant staff, departments, etc
Reports, resources and instructions
Award ManagementProject
  • Notify PI, lab manager, staff, etc. that WBSE will be ending soon and should not be used for procurement or with any internal billing entities (DLAR, IRs, etc.) after the project end date
  • Communicate approaching project end with CorporateCard/Concur Rep to expedite pending transactions
  • Review programmatic reporting requirements and balance projections with PI
Compliance
  • IRB Protocol Status – continue conversation with PI and research staff
    • Request eIRB status update
    • Update status with Maestro Care, submit request 1 week prior to project end (if applicable)
  • Address all outstanding CAS concerns and rebudgets
     
External Subrecipient
  • Follow up with subrecipient regarding reporting and invoicing deadlines
Duke@WorkProject Obligation Report
  • Remove effort distributions that occur after the project end date
  • Resolve outstanding purchase order obligations
Workflow Status Reports
  • Identify and expedite the processing of pending workflow items, including iForms transactions
CONS Report
  • Monitor progress of Tasklist sections
Payroll Tools
  • Initiate cost distribution changes to reallocate effort (Employee Data Search)
  • Follow up on cost distribution changes submitted but are still pending approval in workflow
Closeout Tasklist Utility
  • Complete questions in applicable sections
SAPITD report (Z71PROJ)
  • Review expenses for accuracy and compliance
  • Ensure appropriate budget amounts are in place for any CAS items

At and after Project End date

Finalize closeout actions and ensure all pending obligations/workflows have been resolved.
Advise appropriate individuals/groups funding has ended and provide new WBSE if applicable.
Actions
  • Confirm completion of cost distributions
  • Address outstanding tasklist items
  • Resolve outstanding obligations
  • Review programmatic reporting requirements & deadlines with PI
  • Resolve items in workflow (iForm & non-payroll)
  • Confirm backstop code
  • IRB status confirmation – Maestro updates
  • Obtain final invoice estimate from external sub(s)
  • Prepare for/submit PI Attestation
Analysis
  • Monitor WBSE balance
Reports, resources and instructions
Award ManagementProject
  • Reinforce expectations with Internal Subs (closeout responsibility roles, reporting needs, balance mgmt)
  • Advise lab & departmental staff that WBSE is no longer available for use
  • Notify CorporateCard/ Concur Rep that no new charges should be posted
  • Update CoreResearch & notify internal service centers that WBSE is closed.  Provide new code if needed
  • Complete Obligations Worksheet if applicable (Training Grants only)
Compliance
  • IRB Protocol Status – Confirm eIRB status update
    • Submit Maestro changes 1 week prior to project end date (if applicable)
    • Confirm requested changes have been made in Maestro Care (if applicable)
  • Resolve remaining CAS concerns and confirm completion of all rebudgets
External Subrecipient
  • Confirm final invoice amount and remaining budget balance
  • Obtain final invoice & reports as needed
  • Follow appropriate business unit process when approving final invoice payment via eCR
Duke@WorkProject Obligation Report
  • Confirm all payroll obligations have been removed
  • Resolve outstanding procurement obligations
Workflow Status Reports
  • Confirm all workflow items have been resolved, including workflow for iForms transactions
Closeout Tasklist
  • Complete remaining questions and resolve items previously indicated as “In-Progress”
PI Attestation
SAPITD (Z71PROJ)and/or Line Item (CJI3) reports
  • Review for accuracy and compliance
  • Ensure consistency between expense categories and completed Closeout Tasklist sections
  • Confirm no unallowable expenses remains
Master Data (CJ20N)
  • Verify WBSE backstop code is accurate
  • Confirm GM1/GM2 fields are entered and align with business unit process for Modified iForms Workflow and Transfer Off Tool

Prior to closeout docs submission

Timeliness of required documents ensures preparation and submission of final reports/invoices by the sponsor due dates. The PI Attestation, and Obligation Worksheet (if applicable), must be routed for approval before the Closeout Tasklist can be submitted into workflow.
Actions
  • Execute Project Obligations Report – confirm no entries exist
  • Execute Workflow Status Report by Cost Object – confirm no entries exist
  • Execute iForm Workflow Status Report by Cost Object – confirm no entries exist
  • Execute CAS Compliance Report – confirm no entries exist
  • Submit Closeout Tasklist and PI Attestation, Obligations Worksheet if applicable – all required documents should be approved by department prior to closeout docs due date
Reports, resources and instructions
Award ManagementProject
Compliance
  • IRB Protocol Status – Request eIRB status update
    • Confirm status with Maestro Care (if applicable)
External Subrecipient
  • Verify current status of final invoice
  • Provide amount of expected outstanding invoice(s) and status on Closeout Tasklist if final invoice not yet posted in SAP- estimated external subcontract invoice can be entered into closeout tasklist and submitted prior to receipt of final invoice 
Duke@WorkProject Obligation Report
  • Ensure there are no future effort allocations
  • Confirm all obligations have been removed prior to submission of Tasklist
Workflow Status Reports
  • Verify no workflow items exist, including iForms transactions
CAS Compliance Report
  • Ensure no CAS items remain unresolved
Closeout Tasklist Utility
  • All sections should be 100% complete or N/A; if any barriers are identified, contact your Implementation Team for guidance prior to submission
PI Attestation
  • Must be submitted to PI for approval prior to submission of Closeout Tasklist- both tasklist and PI attestation can be in workflow at the same time
  • PI must approve prior to completion of the final financial reports by PAFM
CONS Report
  • Manage the progress of required closeout documents
  • Monitor the status of closeout documents (includes parent and sub status)
Subaward Invoice Report
  • Obtain status of final invoice from external subrecipient(s)
SAPITD (Z71PROJ)and/or Line Item (CJI3) reports
  • Confirm all unallowable expenses have been removed and confirm correct GLs are being used prior to routing of closeout tasklist
  • Verify all cost sharing requirements have been met
  • Review balance is as expected/projected – ledger should be reportable at time of tasklist submission
ZH333
  • Verify that PI effort is on WBSE if applicable (includes trainees and fellows as well)
  • Be sure to make sure there is no payroll after the project end date still on the WBSE especially if there are codes in outside departments

After Closeout Tasklist submission

Ensure the progress of submitted forms throughout the approval process.
Monitor project for activity until closed in SAP. If late activity occurs, immediate analysis is necessary to determine required actions.
Actions
  • Analyze late activity if it occurs, action may or may not be necessary
  • Reach out to ORA or CAMT for guidance
Reports, resources and instructions
Award ManagementLate Activity Notifications
  • Manage late activity as it occurs. Contact the Award Management Team for guidance
Duke@WorkManagement Form Overview
  • Monitor the status of user-submitted forms to ensure timely review/approvals in workflow
    • ETL = Electronic Closeout Tasklist
    • PIA = PI Attestation
    • POW/OWS = Obligation Worksheet
CONS Report
  • Monitor timely processing and approval of all forms required for closeout (list by WBSE)
  • Monitor PI approval of the Attestation which must approve prior to completion of the final sponsor reports
Timeliness of Closeout Docs Report
  • Monitor timely processing and approval of all forms required for closeout (list by WBSE & form type)
SAPITD (Z71PROJ)and/or Line Item (CJI3) reports

Managing Costs on Terminated Awards

In cases of early termination, Duke may have non-cancellable commitments (financial obligations) that need to be managed and evaluated separately from the standard award closeout process.  The following guidance must be followed in order for Duke to request payment from the sponsor for these allowable costs.

Purpose

These procedures are applicable when a sponsor terminates an award early (before the project period end date that is listed in the previous award document).

Definitions/Terms

Non-cancellable commitments (NCCs) refer to financial obligations incurred prior to the suspension/termination date that extend beyond the suspension/termination date provided by the sponsor but that cannot be terminated without incurring costs or penalties. Examples include:

  • Graduate assistant tuition, stipends and fees (as applicable) for the remainder of the academic term.
  • Notice period, terminal benefits and/or severance for university staff on the award (as applicable, based on institutional policy, practice, or guidance).
  • Executed purchase orders, leases or service agreements that cannot be cancelled; or any cancellation fees or penalties associated with those that can be cancelled.
  • Travel or conference costs that cannot be cancelled; or any cancellation fees or penalties associated with those that can be cancelled.
Partnering Offices
  • Pre-Award (ORA/ORS)
  • Award Management Teams (AMTs)
  • Post-Award (TBS/PAFM/OPAA)
  • OR&I
  • Local owning org unit (PI/GM/DA)
Procedures
  1. Notification and Documentation
    • The PI and local administration (grant manager, department administrator, business manager, etc.) must identify, assess and document all NCCs related to the impacted award as soon as possible.  The assessment should consider the individual terms of each commitment, including any penalties or fees associated with cancellation; the documentation should include an estimate of the financial impact of each NCC.
  2. Review/Approval of Financial Obligations
    • The AMTs will review the NCC documentation prepared by the project owners.
    • PAFM will confirm the documentation package upon receipt from the AMTs and incorporate as applicable into the final payment request to the sponsor.
    • Note that NCCs will not be funded beyond the current obligated value of the award.
  3. Responsibility to Mitigate Damages
    • The calculated total value of the NCCs should be regarded as the maximum cancellation cost, acknowledging that Duke has an obligation to minimize and mitigate these costs to the greatest extent possible.  Duke must be able to document a good faith effort to cancel commitments and stop incurring new costs; Federal and other external sponsors may require detailed supporting documentation for any/all NCCs.
    • Supplies/equipment that had been ordered but not delivered prior to the termination date should be returned to the vendor; return/restocking fees are allocable to the terminated award.
      • “The cost of items reasonably usable on […] other work is unallowable” per 2 CFR 200.472(a)(1) of the Federal Uniform Guidance regulations.
  4. Sponsor Approval
    • An award’s/sponsor’s existing prior approval requirements remain in effect on these terminated awards; if required, Pre-Award and Post-Award will coordinate to obtain sponsor approval of any NCC costs.
  5. Compliance and Monitoring
    • An award’s managing unit (PI, GM, BM, etc.) is primarily responsible for the determination and submission of NCCs for reimbursement, and for ensuring compliance with all applicable laws, regulations, and institutional policies related to NCCs.  The terminated award’s grant manager is also responsible for monitoring the status of NCCs posting to the award until it is closed in SAP.
  6. Resumption or Close Out (for SWOs/suspensions only)
    • Should a stop work order or a suspension proceed to a termination, the total obligation of allowable NCCs (according to these procedures) will be billed to the sponsor in accordance with the award terms, and the award will enter the close out process.
    • Should a stop work order or a suspension be rescinded by the sponsor, Post-Award will return the award date to the original value (or any modifications thereto) and the project will proceed in accordance with its plan.
    • Note that new costs incurred during the period the stop work order or suspension was in effect are unallowable unless separately agreed upon with the sponsor.
  7. Pending Costs
    • The department will complete the required “Pending Ledger Activity at Closeout" document. This document will account for all NCCs that should be included in the award’s final payment request that have not yet posted to the ledger, at the time the closeout tasklist is routed for approval.
    • If there is pending ledger activity, the department will notify their SOM or Campus AMT team prior to routing the tasklist into workflow. It is important that the department understands that the AMTs do not have the ability to prevent transfer off activity, unless they are alerted as soon as the tasklist is routed.
    • The AMTs will review the Pending Ledger Activity at Closeout document as part of their normal closeout review, and ensure that all activity included falls under the non-cancellable commitment definition.
    • Once the AMTs approve the closeout, they will alert PAFM via email and include the Pending Ledger Activity document.
    • PLEASE NOTE: This step to capture pending costs only applies to awards which have received terminations with a shortened closeout period, requiring Duke to expedite the closeout process in order to ensure the final payment request includes all allowable expenses. This process does not apply to closeouts with normal closeout period deadlines, even those terminated early.
  8. Review and Amendments
    • This procedure will be reviewed periodically to ensure its effectiveness and relevance.
    • Amendments to the procedure may be made as necessary to address changing circumstances or regulatory requirements.
References