The “Sponsored Financial Reporting and Closeout Policy” has been updated and renamed as the “Closeout and Reporting Policy for Sponsored Awards” as of May 6, 2021. Recent updates to the Uniform Guidance, specifically Subpart D, §200.344 (i), outline new requirements for closeout and consequences for not meeting these requirements:
If the non-Federal entity does not submit all reports in accordance with this section within one year of the period of performance end date, the Federal awarding agency must report the non-Federal entity's material failure to comply with the terms and conditions of the award with the OMB-designated integrity and performance system (currently FAPIIS). Federal awarding agencies may also pursue other enforcement actions per §200.339.
The updates to the Closeout and Reporting Policy for Sponsored Awards include the following:
- Emphasis on the timely submission of all reports, both financial and non-financial reports (See Note 1)
- Roles and responsibilities reformatted into bullets for readability
- Formal escalation procedure that documents the process for escalating outstanding financial deliverables; following the pre-existing process employed by OSP
In the coming months, additional guidance will be published to supplement the policy and provide further details for navigating the various processes around post-award and closeout. In the meantime, the existing procedures and guidance will remain posted as reference while the new guidance is being developed.
Please see the Closeout and Reporting Policy for Sponsored Awards for school related contacts.
Note 1: The processes for managing and escalating non-financial reports is still being discussed, and once these processes are developed and implemented, they will be updated in the policy and guidance.