Project Completion and Closeout

The Federal government has established standardized guidance documents that provide direction for the closeout of funded research projects (OMB Circular A-110, “Grants and Agreements with Institutions of Higher Education”) as well as the State of Tennessee guidelines for contract management (TCA ¶12-4-109 (d) and Finance and Administration Rules 0620-3-8 -.03, “Contract Management and Subrecipient Monitoring”). Proper closeout of research projects is essential to protect the University in the event the project is audited.

Policy

For the closeout of any funded project, the Principal Investigator (PI) is required to fulfill all final technical reporting requirements including patent disclosure, invention statements, and equipment inventory. As during the funded period, the PI must also ensure, during closeout, that all expenses are appropriate for the project and that all obligations have been liquidated prior to the submission of the final financial report. Cost share/matching commitments must be reported to the Grant Accountant within forty-five (45) days after the project end date.

The Grant Accountant will review the account and ensure that financial reporting deadlines are met. The Grant Accountant maintains the cash flow associated with the project and ensures that the amounts of cash received match the expenditures reported. Interim and final financial reports are also the responsibility of the Grant Accountant. The Grant Accountant will act as the point of contact for audits of research projects and will manage financial record retention.

The Office of Research will provide assistance to both the PI and Grant Accountant during the closeout process to ensure that any affirmative action or A-133 audit requirements are met. Any notifications of report due dates (interim or final) received by the Office of Research will be forwarded to the PI and Grants Accountant (when applicable) for processing.

Implementation

The specific duties of those individuals responsible for monitoring an award are as follows:

The principal investigator (PI) is responsible for monitoring the project to ensure compliance with federal regulations and for the timely review of technical performance to ensure that specified deliverables are met in a timely manner.

The appropriate dean and department chair have responsibility for approving the programmatic and fiscal monitoring of its sponsored research and award recipients.

The project bookkeeper has the responsibility for assisting the PI in discharging their monitoring responsibilities, for reviewing invoices and questioning expenditures if necessary, and for maintaining documentation of monitoring efforts. The project bookkeeper should periodically review invoices and expenses-to-budget. The bookkeeper should periodically compare invoices to established award budgets, and clarify invoiced charges. The project bookkeeper will make the PI aware of current overspending or large balances due to late billing. Evidence of regular review of invoices by both the PI and the project bookkeeper should be in place and retained on file. Evidence can be in the form of PI initials or authorizing signature on invoices.

The grant accountant, in collaboration with the project bookkeeper, is responsible for reviewing invoices, submitting the invoices in a timely manner for payment as articulated in the agreement with the prime contractor, and resolving any issues that arise with respect to billing or invoicing. Two months (60 days) prior to the end date of a project, the Grant Accountant will notify the PI when awards are about to expire. The notices will include reminders of technical and financial report due dates, and reminders for the project bookkeeper and PI to begin the closeout process. The PI should communicate within thirty (30) days following the end date of the project with the Grant Accountant in order to verify that all charges to the project are accounted for and a final invoice can be submitted to the funding agency. Once the final reports are submitted to the agency (90-120 days after the project end date), a copy of the final reports along with the signed Project Monitoring Form must be submitted to the Office of Research.

The Office of Research is responsible for any changes in the terms, conditions, or amounts cited in the agreement and for the overall programmatic and fiscal monitoring of its sponsored research and award recipients.

The Office of Internal Audit will be responsible for conducting audits on contracts when requested by the Office of Research.

Once all deliverables have been completed and submitted to the funding agency, federal guidelines require the retention of the project records for three (3) years beyond the end date of the project. Real property and equipment records are retained for three (3) years after the final disposition of the property.

Last updated April 2008

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