Project Close-out in Grants Management System

Policy No: 
3.11
Type of Policy: 
Administrative
Effective Date: 
October 2015
Last Revised: 
October 2015
Review Date: 
October 2018
Policy Owner: 
Office of Grants and Contracts Accounting
Contact Name: 
Sandra Mason
Contact Title: 
Senior Director
Contact Email: 
sandy.mason@business.gatech.edu
Reason for Policy: 

This procedure explains the method of review to financially close sponsored projects in the accounting records of the Georgia Institute of Technology in accordance with close-out requirements mandated by Federal regulations, including the Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200), sponsor requirements, and award terms and conditions. Timing of the financial close is often included in contractual clauses and efforts should be made to meet deadlines and limit the risk of loss.

Policy Statement: 

The Office of Grants and Contracts Accounting is charged with the financial close-out of Sponsored projects in the accounting records of the Georgia Institute of Technology for sponsored activity in Resident Instruction (RI), Georgia Tech Professional Education (GTPE), and the Enterprise Innovation Institute (EII).

Scope: 
All employees engaging in sponsored research activity.
Policy Terms: 

Matching/Cost Sharing Funds
Funds contractually obligated by awards accepted by the Office of Sponsored Programs (OSP) in the name of Georgia Institute of Technology or the Georgia Tech Research Corporation.

Procedures: 

The Office of Grants and Contracts Accounting is responsible for the financial close-out of sponsored awards in the accounting records of the Georgia Institute of Technology for both externally funded awards and internally funded projects (i.e., Georgia Tech Foundation, managed by the Controller’s Office, and the Georgia Tech Research Corporation). Steps taken to complete the financial close-out process are as follows:

  1. Accountants in the Office of Grants and Contracts Accounting review expenditures and encumbrances allocated to sponsored projects throughout the life of the award. These checks may include, but are not limited to, line item transaction review and verification that transactions occurred within the performance period. This process is designed to ensure expenditures are within sponsor guidelines established in the award document and in compliance with applicable laws and institutional policies, including the Federal Government’s Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200). In accordance with 2 CFR 200.343, the non-Federal entity must submit, no later than 90 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award.
  2. An administrative report entitled "90 Days to Expiration" is available to Project Directors/Principal Investigators, unit financial officers and other appropriate Grants Management (GM) system users as notice of initiation of the financial close-out process.
  3. Upon project expiration, the G&C Accountant responsible for financial review of the expiring project contacts the administrative unit responsible for expenditure allocation. The purpose of the contact is to verify that all appropriate expenditures and/or encumbrances have been recorded properly in the accounting records. Any unrecorded activity must be verified by the Accountant as allowable in order to include those costs and/or unliquidated obligations in the financial reporting to the sponsoring entity.
  4. Upon confirmation that all expenditures and/or obligations have been verified, the G&C Accountant reviews transactions for propriety, and reconciles indirect charges. Charges are verified to be allowable and within contractual budgets and terms of the award. The accounting review includes the same checks with respect to contractually obligated matching/cost sharing funds as it does to sponsored funds.
  5. Final invoices, vouchers, or cash requests are prepared according to instructions included in the award document or standard procedures for specific sponsoring entities.
  6. Final financial reports, if required, are prepared and submitted to the sponsoring entity in compliance with external reporting requirements.
  7. Accountants in the Office of Grants and Contracts Accounting are responsible for monitoring projects which have been financially closed with the sponsor but have outstanding action required by campus units. Until all internal adjustments are complete, the sponsored project cannot be inactivated in the accounting records.
  8. At the time final payment from the sponsoring entity is received and all internal actions have been processed in the accounting records, the Office of Grants and Contracts Accounting inactivates the fund and project(s) in the Institute's records.

Fixed-price Sponsored Projects
Fixed-price sponsored projects will be closed in accordance with the terms and conditions of the sponsored award agreement and in the same manner as standard cost-reimbursable projects. In accordance with 200.201 (b)(3) of the OMB Uniform Requirements (2 CFR 200), written certification that the project or activity was completed or the level of effort expended must be obtained. If the required level of effort or activity was not carried out, the amount of the award must be adjusted.

Residual funds (if any) remaining on fixed price projects, after certification, will be transferred to a departmental GTRC allocation fund, net of applicable F&A expenses, to be managed by the Chair/Director of the department.

Frequently Asked Questions
Additional information, including Web GM access requirements and training materials, are available on the Grants and Contracts Accounting web site www.grants.gatech.edu

Contact the Office of Grants and Contracts Accounting at gc.ask@business.gatech.edu for specific guidance related to managing sponsored projects at Georgia Tech.

Responsibilities: 

Principal Investigators, assigned delegates, and unit financial officers are responsible for providing proper oversight and management of sponsored projects during the performance and close-out periods.

Valuation and disposition of equipment and supplies, including computing devices, must be managed in accordance with 200.313 “Equipment” and 200.314 “Supplies” of the OMB Uniform Requirements (2 CFR 200).

Enforcement: 

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History: 
Revision Date Author Description
10-01-2015 Office of Grants & Contracts Accounting Revise close-out process for Firm Fixed Price awards
11-05-2014 Office of Grants & Contracts Accounting Align with requirements of 2 CFR 200
04-01-2014 Office of Grants & Contracts Accounting Administrative review

 

 

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