During the management of research awards, interim and final are often required by sponsors, and reporting frequency would generally be prescribed in the award document.
Below are examples of deliverables sponsors require at the end of a project. This guidance focuses on final financial deliverables and closeout procedures.
- A financial report
- A final invoice or a request for a last draw (for our Letter of Credit sponsors)
- A technical/scientific/progress report
- An invention/patent report
- A property/equipment inventory report
- A cost-share report or validation of any cost-sharing on the main financial report
- Other non-financial reports (e.g., assignment and release forms)
- Final payment on an award may be contingent on receiving non-financial information.
Financial Status Reports are submitted in compliance with all Federal regulations, sponsor guidelines, and award terms and conditions. Submitting these reports is a shared responsibility of the Principal Investigator, department staff, and the Office of Sponsored Programs (OSP) Post award Team. The procedures/guidelines described below are intended to help ensure compliance with sponsors' award terms and timely submission of financial deliverables and closeout. The timelines are generally based on most federal agencies' 120 days financial reporting requirements. These timelines will be adjusted to ensure the timely submission of the financial report/final invoice for awards with due dates less than 120 days.
Exceptions to the due dates outlined below will only be granted when presented in writing by 7 business days before the draft report is due back to OSP Post-Award Officer. Such exceptions will be considered only in extenuating circumstances and may require OSP to request sponsor approval to extend the reporting deadline.
Examples of extenuating circumstances include:
- Failure of another administrative department to take action – e.g., Prior Period Adjustment (PPA) not processed timely by the responsible office, even though the PPA was submitted before the OSP deadline.
- A subcontractor's failure to issue a final invoice on time when evidence of attempts to obtain final invoice(s) exists.
- Spectrum systemic error(s) that impact the processing of adjustments to the general ledger.
OSP Post-Award Officer will use the draft financial report submitted to the PI as the supporting documentation for completing the financial report/final invoice if the draft financial report is NOT approved/completed timely and there is no request from the department to extend the draft financial report's due date. In this case, Adjustments processed by the department after the award performance period and not included on the draft financial report/final invoice may not be permissible.
Commitments and encumbrances will only be reported in exceptional circumstances and require Associate Director/Post Award Director approval.
Georgia State University discourages the revision of previously submitted financial reports. Modifications or amendments are made on an exception basis and approved by OSP Post Award Director. If expenditures are reduced on the award, resulting in a balance owed to the sponsor, OSP will revise the financial report once the adjustments are posted to the ledger. A refund will be processed and remitted to the sponsor as appropriate.
The National Institute of Health (NIH) Revised Expenditure Reports Guidelines- NIH requires all financial expenditure reports (domestic and foreign) to be submitted using the Payment Management System. This includes the initial FFR & any FFR revisions being submitted or re-submitted to NIH. Sometimes the recipient may have to revise or amend a previously submitted FFR. When the revision results in a balance due to NIH, the recipient must submit a revised report whenever the overcharge is discovered, no matter how long the lapse of time since the original due date of the information. Revised expenditure reports representing additional expenditures by the recipient that were not reported to NIH within the 90-day time frame may be submitted electronically with an explanation for the revision. The resolution also should indicate why the correction is necessary & describe what action is being taken by the recipient to preclude similar situations in the future. This should be done as promptly as possible but not later than one year from the due date of the original report for annual FFRs and no later than 60 calendar days from the due date of the original description for final FFRs (i.e., 180 days from the project end date). If an adjustment is to be made, the NIH Awarding IC will advise the recipient of actions it will take to reflect the adjustment. (T****aken from NIH Grants Policy Statement)
Overall:
Awards Expiring Notification- 90 Days & 180 Days:
Automatic notifications are sent to Principal Investigators, Grant & Contract Officers (GCO), and OSP Post Award Officers for awards or budget periods ending within 90 & 180 days. The best practice is to use these reports to identify awards expiring within these days. Note-if no-cost extension (NCE) will be requested, confirm advance notice requirements in the award document as some sponsors require advance notice before the current award or budget period end date. For example, the National Science Foundation (NSF) requires that requests for a second no-cost extension be submitted 45 days before the end date. Make sure always to check the award document to confirm advance notice requirements.
180, 90 & 30 days before the award end date or budget end date (final/annual reports):
Department Responsibilities
- Confirm with PI if a no-cost extension(NCE) will be requested for the project listed on the notifications.
- Submit a no-cost extension request in the Research Portal and include the required paperwork/email if applicable. Include the OSP Post Award Officer on the NCE request in the Portal (the NCE routes to OSP Pre-Award. Will check with Sarah if the OSP Post Award Officer can be notified when the request is submitted to OSP Pre-Award).
- Remind the sub-awardees of the due date for the final invoice.
- Follow-up on allowable charges or prior period adjustments submitted for processing have been posted correctly to the project (e.g., Fisher Scientific, PPAs, service center billings, subcontract final invoices, supplier final invoices, imprest funds, animal per diem, etc.)
- Process Payroll Manager Self Service (MSS) transactions needed to remove employees from the award for closeout.
- Review the encumbrance balance; if applicable, work with Purchasing and vendor to clear the outstanding balance.
OSP Post-Award Responsibilities
- Confirm if NCE has been submitted in the Research Portal for any awards on the 30 & 90 days notifications.
- If NCE is not submitted, contact PI/GCO to confirm if NCE will be requested for any of their awards reflected on the 90 & 180 days notifications.
- Review cost share obligation and cost share budget setup in Spectrum.
- Review open Accounts Receivable for cost reimbursable, schedule payments, and fixed price awards.
- Reconcile IDC and notify GCO/PI of any adjustments affecting the remaining award budget.
- Confirm award budget reflected in the award document matches the budget loaded in SPECTRUM for the reporting period.
0-60 days following an award end date or budget period end date (final/annual reports)****: Note: The table below helps to define the beginning of the financial reporting process. The days noted below may be adjusted based on the financial reporting due date specified in the award document.
FFR Due 120 days after the end date | 0-60 days |
FFR/Invoice Due 90 days after the end date | 0-45 days |
FFR/Invoice Due 60 days after the end date | 0-30 days |
FFR/Invoice Due 45 days after the end date | 0-20 days |
FFR/Invoice Due 30 days after the end date | 0-10 days |
Department Responsibilities
- Thoroughly review the award financial record in the system and confirm that all outstanding expenses have been posted to the general ledger (e.g., Fisher Scientific, PPAs, service center billings, subcontract final invoices, supplier final invoices, etc.). Follow up with the relevant administrative department if charges have not been posted to the ledger.
- Process outstanding PPAs/cost transfers, if applicable.
- Inform OSP Post Award Officer if a no-cost extension will be requested if a request has not previously been submitted to OSP Pre-Award Officer.
- Journal any over-expenditures from the award before submitting the draft report to OSP Post Award Officer.
- Confirm, if applicable, actual cost share amount on the cost share account matches the cost share committed amount. Process adjustments if required/necessary. It is essential to note that cost-shared expenses must be verifiable in the system and or/Effort Certification report for financial reporting and closeout.
- Confirm deliverables required at the end of the project.
- Confirm effort reports certified for PI and all personnel who worked on the project.
- Check the status of programmatic deliverables with PI (final technical reports, etc.).
- Notify OSP of any extenuating circumstances that may prohibit the financial report from being submitted to sponsors (federal or non-federal) on time or prohibit cash from being drawn by Letter of Credit before the sponsor deadline.
Examples of extenuating circumstances include:
- Systemic error(s) that impact the processing of adjustments to the general ledger. • Failure of another department to take action (– e.g., on a correctly submitted payroll adjustment request or service center charges.)
- A subcontractor's failure to issue a final invoice promptly when evidence of attempts to obtain final invoice(s) exists.
OSP Post-Award Responsibilities
- Review award notice, terms, and conditions in preparation for financial reporting and confirm cost-sharing requirements, carryover restrictions, financial reporting requirements, allowable expenditures, and other restrictions.
- Run Drilldown report (General Ledger) as of the end date of the reporting period and review expenditures to ensure they are allowable/allocable by award allowability/allocability. Specially review expenditures for the following compliance items:
- Equipment- is equipment in the budget, and are any restrictions prohibiting equipment purchase?
- Domestic travel- is there evidence of the traveler working on the project (-i.e.-salary paid against the project)
- Foreign travel- is there evidence of the traveler working on the project and Fly America/Open Sky requirements being adhered to?
- Participant cost vs. human subject, confirm charges are correctly identified/coded.
- Food/entertainment charges-confirm allowable
- PI effort-confirm PI met the effort requirement
- Verify indirect cost and fringe benefit and prepare/process journal adjustments if necessary. Note:-Indirect cost and fringe benefit adjusting entries are the responsibility of the OSP Post Award Officer.
- Confirm effort reports certified for PI and all personnel who worked on the project.
- Review prior financial reports, if applicable, to determine what was reported previously.
- Prepare a draft financial report, and highlight/include potential compliance items identified and questions for follow-up with the department.
- Prepare the relevant FFR template spreadsheet (including individual tabs for each project for all multi-project awards) and the overall summary tab. The calculations on the spreadsheet determine the cumulative expenditures to be reported to the sponsor, with all recommended adjustments documented and any remaining surplus or deficit.
- Submit draft Financial Report and reconciliation worksheet to PI for review and approval through the Portal process within 60 days after the award's end date or budget period (annual report). OSP prioritizes the completion of draft financial reports to departments in the order of earliest due date to sponsor (e.g., 30/60/90/120 days). If the report is due to the sponsor within 30-60 days after the award end date or budget period, OSP Officer will send the report 15 – 30 days after the award end date or budget period.
- Include the due date when the approved draft financial report should be submitted to OSP on the draft financial report before submitting it to PI.
61-89 days following an award end date or budget period end date (final/annual reports), d_ays following an award end date or budget end date (annual reports), there is ongoing communication between OSP Post-Award Officer and PI/GCO on, example, the recommended adjustment(s) noted by OSP, compliance items identified, due dates, deliverables, etc._ Note: The table below helps to define the beginning of the financial reporting process. The days noted below may be adjusted based on the financial reporting due date specified in the award document.
FFR Due 120 days after the end date | 61-89 days |
FFR/Invoice Due 90 days after the end date | 46-65 days |
FFR/Invoice Due 60 days after the end date | 31-45 days |
FFR/Invoice Due 45 days after the end date | 21- 30 days |
FFR/Invoice Due 30 days after the end date | 11-15 days |
Department Responsibilities
- Review encumbrance and open commitments to determine if any additional expenditures are outstanding and are likely to post that need to be included in the FFR. Expenditures could include final invoices for supplies, recharges, or subcontract final invoices.
- Confirm that all encumbrances/purchase orders processed on the award have been zeroed out and closed.
- Ensure speed type (s) are removed/deleted from active speed type maintained by other service departments/HR/laboratories, etc.
- Confirm submission of the final invoice from the subawardee —complete sub-award closeout certification.
- Remove over expenditures (overdraft) from the award before the approved financial report routes back to the OSP Post Award Officer.
- Thoroughly review Please review the award financial record in the system to make sure e award financial record in the system to ensure all outstanding expenses are posted in the general ledger (e.g., Fisher Scientific, PPAs, journal entries, service center billings, subcontract final invoices, supplier final invoices, etc.).
- Submit supporting documentation and justification for questionable charges (compliance items) highlighted by OSP Post-Award on the draft financial report.
Principal Investigator (PI) Responsibilities
- Confirm all allowable/appropriate charges have been posted correctly to the project.
- Confirm all Effort reports have been certified.
- Complete/approve the draft financial report in the Research Portal by the due date.
- Confirm/approve carryforward amounts, as applicable.
90-100 days following an award end date or budget period end date (final/annual reports), approximately 20 business days before the statement due date to the sponsor: Note: The table below helps to define the beginning of the financial reporting process. The days noted below may be adjusted based on the financial reporting due date specified in the award document.
FFR Due 120 days after the end date | 90-100 days |
FFR/Invoice Due 90 days after the end date | 66-75 days |
FFR/Invoice Due 60 days after the end date | 46-55 days |
FFR/Invoice Due 45 days after the end date | 31-40 days |
FFR/Invoice Due 30 days after the end date | 16-20 days |
Department Staff Responsibilities
- Confirm
- Request a copy of the confirmation of report submission to the sponsor or a copy of the report
- Monitor outstanding non-financial reports periodically
OSP Post-Award Responsibilities
- If the draft financial report is NOT approved/completed timely, and there is no request from the department to extend the draft financial report's due date, OSP Post-Award Officer uses the draft financial report submitted to the PI as the supporting documentation for completing the financial report/final invoice. Adjustments processed by the department after the award performance period and not included on the draft financial report/final invoice are not permissible. They will not be included in the final report/invoice submitted to the sponsor.
- Review certified/approved draft financial report/final invoice and supporting documentation submitted by the department. Reach out to the department for additional information or clarification, as applicable.
- Ensure all allowable and legitimate adjustments reflected on the draft financial report/final invoice are posted to the ledger.
- Confirm total expenditures and total revenue and reconcile
- In case of awards under a letter of credit draw, request a final draw, at least by the 100th day after the award end date or budget period, if applicable.
- Complete the financial report/final invoice, and other deliverables, as applicable.
- Submit reports for review and approval by the supervisor. In case of awards under a letter of credit draw, ensure expenditures, revenue, and payment received reconcile and no variance before submitting to the supervisor.
101-120 days following an award end date or budget period end date (final/annual reports), approximately 5 days before the report due date to the sponsor. Note: The table below helps to define the beginning of the financial reporting process. The days noted below may be adjusted based on the financial reporting due date specified in the award document.
FFR Due 120 days after the end date | 101-120 days |
FFR/Invoice Due 90 days after the end date | 76-90 days |
FFR/Invoice Due 60 days after the end date | 56-60 days |
FFR/Invoice Due 45 days after the end date | 41-45 days |
FFR/Invoice Due 30 days after the end date | 21-30 days |
OSP Post-Award Responsibilities
- Submit approved financial report/final invoice to sponsor (according to sponsor terms of award).
- Submit other non-financial reports, as applicable.
- Ensure the invention report is completed and submitted to the sponsor.
- Upload the financial/final invoice, reconciliation documents, and drill-down reports into (OSPA shared folder) or Research Portal.
- Update milestone with completion dates to relieve this milestone in Spectrum.
- Initiate the Carryforward request in the research portal for awards that carryforward is not automatic. Carryforward guidance can be found here.
Note: All adjustments must be submitted and approved before the Financial Report submission. Exceptions will require detailed documentation and OSP Director approval.
After the final report is submitted to the sponsor:
OSP Post-Award Responsibilities
- Within 1-30 days after submitting the report to the sponsor, OSP Post Award Officer should prepare the award/project record in Spectrum for closeout.
- Complete the closeout checklist and update the award/project status.
- If the award/project cannot be inactivated,
- Complete the final close process in Spectrum.
- Prepare an electronic award folder and include the award discard date as an extension in the folder's name.
- Delete electronic award folders as their discard dates mature.
Summary Responsibilities Matrix- we will complete this once all responsibilities for each area have been agreed upon.