This is to identify the key award closeout procedures and requirements as prescribed by the Office of Accounting Services & Controls at the University of California, Santa Barbara.
The University’s external auditors require the Accounting Office to certify that financial reports submitted to agencies for all contract and grants are filed on a timely basis and are supported by the general ledger.
OMB Circular A-110 requires that a final financial report be submitted within 90 days* from the end date of a contract or grant. The University’s status with funding agencies may be jeopardized when financial reports are submitted after the required filing deadlines. In addition, audit findings for failure to submit financial reports within the specified time frame can put the University at risk of the imposition of remedial action. Such actions can include the withholding of award(s) to an investigator or the entire University, the withholding of payments on outstanding invoices, and/or the revocation of the Expanded Authorities Agreement. For example, included but not limited to, the ability for grantee to approve pre-award costs, approve first no-cost extensions, and carry-forward unobligated balances unless specifically required by a federal agency.
Compliance with Federal and Local requirements is critical to the University’s continued participation in contract and grant programs. Any questions regarding this procedure or the award closeout process should be directed to the Extramural Fund Accounting Manager.
*Certain awards may have different reporting requirements.
1. Close Memo: The close memo must be signed by the principal investigator and submitted two weeks prior to the deadline required to submit the final financial report (e.g., if the award end date is 3/31/07, then the close memo should be submitted no later than 6/15/07).
2. Certification Clause: The principal investigator must sign a certification clause certifying that all costs are appropriate and allowable. Extramural Fund Accounting (EMF) has created a standard “Closing Memo” template. Departments can create their own close memo with the following certification included:
“I have reviewed the grant/contract and certify all expenditures are appropriate and allowable.”
Close memos will only be accepted if the certification clause contains the exact wording as provided above.
3. Overdrafts: Copies of cost transfers must be attached for all contract and grant overdrafts (costs that exceed the budget).
4. Outstanding Charges: Departments must indicate outstanding charges to be included in the close memo. All outstanding charges in the close memo must have supporting documentation attached. Supporting documentation may include: vouchers, invoices, payroll, non-payroll transfers, and financial journals, etc.
5. F&A Costs: F&A costs can only be charged as a direct expense to a sponsored project when there is an unusual or unique circumstance, and the amount of the charge is significant. Most F&A charges are covered by the campus overhead allocation and should therefore not be charged to a sponsored project. A written and signed justification from the principal investigator must be included with the close memo if F&A costs are to be charged to a sponsored project. General statements do not satisfy this requirement.
If there is no written justification, EMF will move these charges as a lump sum, by object code, to an existing research account number linked to unrestricted funds. The cost transfer will include reference to the principal investigator and the target research account/fund will need to be funded by the department. The amount transferred to the research account will only be the direct cost portion. This process will be a coordinated effort between EMF and the department.
6. Project Contribution: Departments must submit a Project Contribution Report with the close memo if the project contribution commitment has not been reported.
7. No Cost Extensions/Additional Funds: Documentation must be provided to EMF when No Cost Extensions, Supplemental funds, or Continuation funds have been requested or is expected. The closeout process for the award will be placed on hold until the synopsis from Office of Research is received indicating the changes or additions. The principal investigator will continue to receive email closing notifications until the synopsis is received from Office of Research.
The financial reports will be submitted late if the No Cost Extension or Additional Funding is not approved within the required agency closeout deadline. This may create a financial liability to the department.
8. Revised Financial Reports: The department will be required to request prior written approval (email or memo) from the agency to submit a revised financial report that would include additional costs.
Exceptions to the 90 Day Deadline
- Non-federal Awards – Close 60 days from the end date.
- Federal-flow Through Awards - Close 30 days from the end date.
- Intercampus Awards – Close 60 days from the end date unless the Multiple Campus Agreement (MCA) indicates 30 day
- Other: Awards may specify a different close period (e.g., award closeout required within 45 days of end date)