Policies & Procedures

16.1 Sponsored Programs Closeout

Policy Statement

The University of Illinois System has a responsibility to close out completed sponsored programs in compliance with federal regulations, sponsor policy, and award terms and conditions. The Office of Management and Budget (OMB) Uniform Guidance 2 CFR 200 – Closeout requires that final financial, performance, and other reports be submitted no later than 120 calendar days after the project end date. It is the system’s policy that all required closeout deliverables be submitted to the sponsor within this stated timeframe. In the event that sponsor policy or specific award terms and conditions prescribe otherwise, such policy or terms and conditions shall prevail.

Reason for the Policy

This policy alerts the system to the urgency of timely submission of final deliverables and the prompt closeout of expired sponsored programs. Non-compliance with sponsored project closeout requirements has adverse consequences for the system including, but not limited to, forfeiture of final payment, delayed or reduced future funding, less favorable award terms and conditions, and audit finding risks. The submission of final financial, performance, and other reports to the sponsor and the closeout of completed projects within 120 days of expiration help the system mitigate risks and negative consequences.

Applicability of the Policy

In order to maintain consistency in the treatment of sponsored programs, the policy on sponsored project closeout applies to all awards regardless of the funding source. Requirements and considerations for closing out fixed price agreements are subject to the Fixed Price Agreement policy and guidance: UIC—Section 16.6.2—UIC Disposition of Unexpended Balance on Fixed Price Agreements; UIUC—Fixed Price Awards Research Topic).

Procedure

Before you Begin

Sponsored program closeout is the shared responsibility of the principal investigator (PI), unit business office or department administrator, and the applicable university sponsored programs office. Collectively, they are responsible for the closeout of expired awards by the due date indicated in the specific award terms and conditions.

Administrators of a sponsored project must be mindful of its end date and terms and conditions, and must take the necessary actions leading to a timely closeout.

Begin

To close a sponsored project, the Principal Investigator (PI) and the unit business office are expected to take actions before and after the project end date as outlined in this procedure.

What to do before Project End Date

Approximately 90 days before the expiration of a sponsored project, the applicable university sponsored programs office sends the unit business office a monthly report of its projects that will end in 90 days. Between that time and expiration date, the PI and unit business office are expected to do the following:

Inform the applicable university sponsored programs office immediately if an expiring project should be continued or extended. This will stop the closeout process.
- Process extension requests as required per sponsor guidelines, or 90 days prior to project end date.
- Request an anticipation grant/fund or use of an expired or overspent grant/fund (GC70: Request to Establish an Anticipation Grant/Fund—Request to Use Expired or Overdrafted Grant/Fund), if applicable.
Review accounting statements to date and ensure that all expenses charged to the award thus far are allowable, per the Uniform Guidance and the terms of the award.
Determine whether the project will end up with an unobligated (or unexpended) balance, and be aware of the award terms regarding treatment of such a balance: Can the unobligated balance be automatically carried forward? Or must it be returned to the sponsor? (Consult the applicable university sponsored programs office contact for assistance.)
Review status of subrecipient invoicing to date as to accuracy and timeliness.
Notify service centers with recurring billings (e.g., animal charges, printing, etc.) of the sponsored project expiration date and provide a new C-FOAP, if applicable.
Ensure that all project costs, except incidental costs related to the creation of the final report (for example, photocopying or binding), are incurred or obligated by the project end date. For information about cost transfers, consult 16.3 Sponsored Programs Cost Transfers.
Promptly remove cost overruns (overdrafts) if no additional funding is expected from the sponsor.
Notify the applicable university sponsored programs office of issues with the sponsoring agency that would prevent collection of any outstanding accounts receivable.

What to do after Project End Date

The closeout process starts with the project end date. Within the next 45 to 60 days, the PI and unit business office are expected to do the following:

Remove all costs incurred outside the performance period, except allowable pre-award costs.
- Generally, “pre-award” costs are allocable to the time period of the forthcoming new or competing continuation award and may be incurred up to 90 days prior to the beginning date of the project or budget period in accordance with the sponsor’s guidelines. Pre-award costs must be adequately justified to indicate that advanced funding is necessary for the effective and economical conduct of the project and must be allowable under the terms of the forthcoming award.
- Post-award or after-term charges that are deemed non-applicable or unallowable must be transferred to an appropriate funding source.
Remove cost overruns (overdrafts) within 45 days after the project has expired to allow for submission of the federal financial report no later than 120 days after the project end date. Overdrafts must be transferred to an unrestricted funding source.
Remove costs resulting from sponsor disallowances, or other unallowable costs per the terms of the award—as advised by the applicable university sponsored programs office contact.
Review open obligations (e.g., encumbrances, purchase orders, payroll commitments, etc.), and ensure that they are liquidated, cancelled, or moved to other appropriate funding sources.
Confirm that all subrecipients have completed their scope of work, including all required deliverables, and submitted their final billing according to the terms of their agreement. Refer to the Final Invoice section of policies and procedures on 16.5.1 Review and Pay Subrecipient Invoices.

Ensure that all project costs have been recorded. Process final expenditures per the due date of a final bill or financial report to allow for timely submission of the bill or report, as indicated in the following table.

If Sponsor Final Billing/Closeout Is Required	Then, Final Submission of Expense Transactions Is Due
30 days after project end date	15 days after project end date
60 days after project end date	30 days after project end date
90-120 days after project end date	60 days after project end date

Validate final expenditure report prior to submission of final invoice or federal financial report.
Prepare and submit the final technical report and/or deliverables to the sponsor.
Submit form listing invention disclosures, or indicate that there were none.
Submit a final inventory of federally-funded equipment, if any.
For federal projects: Submit an accounting of unused expendable supplies (including expensed equipment) with an aggregate value of $5,000 or more, as applicable.
Provide the applicable university sponsored programs office an accounting of program income or cost share commitments, as applicable, if these items are not tracked centrally.

Related Policies and Procedures

Urbana—Fixed Price Awards Research Topic

Section 16.6.2—UIC Disposition of Unexpended Balance on Fixed Price Agreements

Additional Resources

16.1.1 University Central Office Responsibilities

16.1.2 Closeout Documents and Responsibilities

16.1 Frequently Asked Questions

2 CFR 200.344 Closeout

GC70: Request to Establish an Anticipation Grant/Fund—Request to Use Expired or Overdrafted Grant/Fund

First Published: March 2021 | Last Updated: March 2024 | Last Reviewed: March 2024