Project Closeout and Property Management and Disposal

  1. Reporting Requirements
    1. Technical
    2. Financial
    3. Inventions
    4. Property
  2. Federal Closeout Procedure
  3. Situations where Closeout Procedures are Appropriate
  4. Procedures for Equipment Disposal, Transfer

a. Reporting Requirements

At the conclusion of a sponsored project, the terms of the award generally require written reports, including a final technical or progress report and a report of expenditures, which must be submitted to the sponsor within a specified period of time. These reports are generally viewed as the University's fundamental obligation to the sponsor, and are generally required whether the sponsor is a private organization or a public agency.

Federal awards, according to federal Circular A-110, are subject to the following requirements:

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i. Technical

Unless otherwise indicated, final performance reports are due 90 calendar days after the expiration or termination of the award. When required, performance reports shall generally contain, for each award, brief information to address the following requirements.

  • A comparison of actual accomplishments in relation to the goals and objectives established for the period, the findings of the investigator, or both.
  • Whenever appropriate and when the output of programs or projects can be readily quantified, such quantitative data should be related to cost data for computation of unit costs.
  • Reasons established goals were not met, if appropriate.
  • Other pertinent information, including, when appropriate, analysis and explanation of cost overruns or high unit costs.
    The PI is responsible for preparing and submitting this report. A dated copy of the report or letter of transmittal should be sent to the Division of Sponsored Programs, serving as audit verification that the report was filed.

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ii. Financial

Most sponsors generally require a final accounting to document how the funding was spent. Federal awards require a standard Financial Status Report (Form 269), which is prepared by the Grant Accounting Office, sent to the PI for approval, then submitted to the federal awarding agency.

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iii. Inventions

Many private sponsors and most federal funding agencies require some sort of reporting to indicate whether inventions have resulted from the sponsored project. While private sponsors collect this information in various ways, federal agencies require the grantee (University) to submit a Final Invention Report or Statement and Certification, whether an invention has resulted from work under the funded project or not. The Final Invention Report or Statement/Certification must list all inventions that were conceived of or first actually reduced to practice during the course of work under the funded project, between the original effective date of support through the date of expiration or termination of the project, whether previously reported or not. If there were no inventions, the statement should simply indicate None. Depending on the sponsor involved the report may be prepared and signed by the principal investigator or by the Division of Sponsored Programs.

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iv. Property

While private sponsors establish their own, individual policies and requirements for any accounting and disposition of property acquired with their funds, federal agencies always require the University to account for any real or personal property acquired with federal funds. A report is prepared using agency-specific forms, identifying the equipment purchased, acquisition cost, make, model number, serial number, UI inventory number, and condition. If the terms of the award do not automatically give title to the University, a letter is sent to the agency requesting transfer of title to the University.

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b. Federal Closeout Procedure

Federal Circular A-110 requires federally funded projects to complete the following closeout steps:

  1. Recipients (i.e., the University) shall submit, within 90 calendar days after the date of completion of the award, all financial, performance, and other reports as required by the terms and conditions of the award. The Federal awarding agency may approve extensions when requested by the recipient.  
  2. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
  3. The Federal awarding agency shall make prompt payments to a recipient for allowable reimbursable costs under the award being closed out.
  4. The recipient shall promptly refund any balances of unobligated cash that the Federal awarding agency has advanced or paid and that is not authorized to be retained by the recipient for use in other projects.
  5. When authorized by the terms and conditions of the award, the Federal awarding agency shall make a settlement for any upward or downward adjustments to the Federal share of costs after closeout reports are received.  
  6. The recipient shall account for any real and personal property acquired with Federal funds or received from the Federal Government in accordance with the A-110 Property Standards Sections .31 through .37, addressing Insurance Coverage; Real Property; Federally Owned and Exempt Property; Equipment; Supplies and Other Expendable Property; Intangible Property; and Property Trust Relationship.
  7. In the event a final audit has not been performed prior to the closeout of an award, the Federal awarding agency shall retain the right to recover an appropriate amount after fully considering the recommendations on disallowed costs resulting from the final audit.

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c. Situations where Closeout Procedures are Appropriate

Closeout procedures and requirements are sponsor- and award-specific, and generally outlined in the sponsor policies and/or award terms and conditions. The University's fundamental obligation for every sponsored agreement is a final written report. Some agreements, such as fixed-price agreements, may not require expenditure reports, while cost-reimbursement agreements with fixed end dates generally require some closeout procedures.

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d. Procedures for Equipment Disposal, Transfer

Unless otherwise stated in the award terms and conditions, the title to equipment acquired under a sponsored agreement belongs to the University. The University is obligated to track and account for all equipment acquired with federal funds. If a principal investigator terminates his or her position at UI and wishes to transfer project-related equipment to another institution, he or she must follow the policies outlined in the UI Operations Manual/Title Transfer of University Equipment for Departing Faculty section. The UI Property Management Office provides advice on procedures and forms for initiating requests for equipment disposal or transfer.

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