Award Closeout

Last Updated: April 22, 2024 3:01:43 PM PDT

Information on Award Closeout.

The majority of agencies (federal and non-federal) require the University to submit a final invoice or financial report when a project ends. These agencies may also require final technical reports, final invention reports as well as final equipment reports at the end of the project.

While federal sponsors have had policies in place to withhold funding from PIs (and/or institutions) with delinquent awards missing required closeout documentation, they have recently started increasing the level of communication around these policies, thereby making enforcement of these policies more likely. This significantly increases the risks associated with not properly closing out awards. These notices and warnings are coming from major federal sponsors such as NSF and NIH, further increasing the potential risk to UC San Diego's research portfolio.

NIH strengthens its enforcement of closeout requirements

The recent incident involving delinquent closeout reports which led the NIH, ONR, and Army to withhold awards highlights the importance of PIs being fully informed about and compliant with the policies governing their awards. While we have resolved the current issue, federal agencies are now strictly enforcing their policies.

While federal sponsors have had policies in place to withhold funding from PIs (and/or institutions) with delinquent awards missing required closeout documentation, they have recently increased their communication around these policies, thereby making enforcement of these policies more likely. This significantly increases the risks associated with not properly closing out awards. These notices and warnings are coming from major federal sponsors such as NSF and NIH, and highlight the degree to which closeout delinquencies increase the potential risk to UC San Diego's research portfolio.

To increase compliance with requirements for the timely reporting of closeout documents, NIH announced in NOT-OD-24-047 that starting in January 2024, it will send an additional closeout email notification 90 days after the project period end date. NIH previously sent reminder emails to recipients 10, 120, and 150 days after the project period end date.

Closeout documents include Final Research Performance Progress Reports (RPPRs), Final Invention Statements, and Final Financial Reports (FFRs).

On January 23, 2024, NIH issued a second notice (NOT-OD-24-055), clarifying that NIH will now strengthen closeout requirements by initiating unilateral closeouts for all awards that fail to meet closeout requirements within 120 days of the award’s end, and will record the delinquency in the System for Award Management (SAM.gov) which is monitored by all agencies. Delinquent awards will remain on this list until all closeout requirements are completed, and entities with awards on the list. are vulnerable to other awards being withheld by any federal agency.

Timely completion of required closeout reporting must be a high priority for all PIs to ensure that UC San Diego does not again have awards withheld due to closeout delinquencies.

As a reminder for the UCSD research community:

All final reports for NIH awards are due within 120 days of the project end date and become overdue the next day
Delinquent reports put UCSD at risk for corrective actions including withholding funding
The Sponsored Projects Office (SPO) will be escalating non-compliant projects to the department chair and dean level for action

Closeout Responsibility Summary

Office / Personnel Responsible	Closeout Responsibilities
Department: Principal Investigator (PI) Research Administrator (RA)	Prepares and submits required reports timely to the appropriate central office Track RPPR, Progress reports, technical reports, etc. Assist PI’s with sponsor reports Financial Closeout with SPF Submit the Financial Expense Report (FER) and all backup documents within 30 days of the project end date Cost sharing, effort reporting
SPF: SPF Accountant	Prepare/Submit final financial reports and invoice
SPO: SPO Coordinator	SPO Coordinator follows up with Departments when reports are past their due date. If no patents – PI/RA lets SPO know, SPO Coordinator will sign and submit to the agency If patents – PI/RA needs to complete a section of the form and coordinate with OIC, the SPO Coordinator will sign and submit it to the agency
SPO: SPO Officer	Coordinates with the Departments the submission of final technical project reports and other reports that may be required (e.g. Patent Certs, Property Close)
Equipment Asset Management: Financial Analyst	Final property reports are submitted to the sponsor by the Equipment Asset Management Office consulting with the PI to determine if there are any disclosures.

Final Reports

The Principal Investigator(s) (PI) and department are responsible for the submission of all technical reports required under the terms of an award in the form required by the sponsor. Sponsors may also require an annual progress report, final technical report, final property as well as a final invention statement.

PIs and department representatives should consult the Research Administration Activity Dashboard - Awards Ending or Ended Reports and/or their award terms to determine what reports are required and when the sponsor expects to receive these reports. See here to access a Quick Guide on how to use the Research Administration Activity Dashboard

The PI and department are also responsible for ensuring that each subrecipient has submitted all required reports and deliverables to UC San Diego prior to approval of final payment to the subrecipient.

It is important to know where and how the sponsor expects such reports to be submitted. For example, the National Science Foundation (NSF) now expects the PI to use Research.gov (instead of FastLane) to meet all NSF project reporting requirements, including submission of final, annual, and interim project reports and the Project Outcomes Report. Please see NSF’s closeout guidance. However, the National Institutes of Health (NIH) requires grantees to submit Research Performance Progress Reports (RPPR) and final technical reports through the eRA Commons.

In short, each sponsor has guidelines about how, when and where progress and final reports should be submitted. It is critical to read the “Reporting” requirements of an award carefully prior to submission of these reports.

When an invention is developed under a federally sponsored project, it is disclosed by the PI to the Office of Innovation and Commercialization (OIC). OIC is responsible for notifying the federal sponsor about this invention via iEdison. iEdison is an electronic system for grantees and contractors to report inventions arising out of federally funded research to the government agency that issued the funding, as required by the Bayh-Dole Act.

Failure to comply with the reporting requirements of the sponsor can have significant repercussions. For example, the PI’s future funding from the sponsor can be jeopardized. A sponsor also may hold up all new awards to UC San Diego just because of one PI’s delinquent technical report.

Important note: When submitting a progress or final technical report to a sponsor, PIs and/or Department Research Administrators are required to keep a copy of the report and documentation that the report was submitted as well as send a copy of these reports to their SPO (the SPO will upload these reports along with the submission date to the Award record). Reports can be sent to the SPO using this Service Now form or by emailing the officer directly. This step is important in case the sponsor fails to record the receipt of the report accurately.

The SPO will provide assistance with any questions, sign any reports if required by the sponsor, and submit any reports if required by the sponsor.

For additional information or questions email awardcloseout@ucsd.edu.

SPF and Department Financial Administrative Responsibilities

The Office of Sponsored Projects Finance (SPF) is responsible for preparing financial reports, submitting them, and certifying on behalf of the University that project expenditures comply with the sponsor's financial terms and conditions. If you manage sponsored projects for your department, you assist in this process visit the Preparing for a Final or Annual Reporting page.

For additional information or questions see the SPF Contacts page.

For more information or questions email researchadmin@ucsd.edu.