As you know, most of our federal agencies have required us to issue a financial report and draw by letter of credit or invoice within 90 days of an award’s termination date.  Up until now, this has not been enforced consistently – we have had some leverage to re-file reports, and draw additional expenditures after 90 days. 

However, strict close-out enforcement is part of the OMB Uniform Guidance (effective 12/26/14), whereby all federal financial reports must be submitted and drawdowns requested, by day 90 after a project’s end date.  Agencies are transitioning to an approach where they immediately shut off the draw, permanently, at day 90.  NSF initiated this practice in November and we expect HHS and others to follow suit.  Some sponsors, such as the Department of Education, have operated this way for years.

New OSP Closeout Policy and Reconciliation & Reporting Timeline

To ensure that we meet all sponsor terms on federal and non-federal awards, OSP is working with SALC to finalize a new closeout policy, schedule to take effect January 1, 2014.  As part of the new policy a reporting and closeout timeline will be included to help departments and OSP proactively manage awards as they come to a close.  Most notably within the timeline:

• Awards should be reconciled by 60 days after award end (GL expenditures much match the final reportable amount), with an extra 10 days (day 70) to reconcile awards with outgoing subcontracts
• Departments should confirm the final reportable amount by day 70
• OSP will ensure all final draws are requested if the reportable amount is confirmed by day 70 (note: any confirmations after day 70 present risks to OSP not being able to draw)

Reconciling and reporting early will ensure that we draw down funds accurately and on a timely basis. 

Communications and Training

We plan on communication threads this month via the OSP blog and the OSP web-site and encourage departments to register for the upcoming UG Info Sessions.  We also plan to hold info sessions in January and February to communicate an updated close-out policy along with tools to help facilitate the close-out process and meet the federal deadline.