BMC is obliged to bring every external sponsored programs (SP) to closure in a timely manner. Internal SPs should also follow applicable steps for record-keeping and audit readiness.
Closeout is a Collaborative Effort
Closeout is the process by which the sponsor determines that all applicable administrative actions and all required program work have been completed.
The closeout process should begin well before the end date. The goal is a timely, orderly closure of administrative and financial obligations, including those involving subrecipients. Failure to meet requirements within the specified timeframe may prompt the sponsor to close the award unilaterally, resulting in loss of funds and potential loss of future collaboration.
The principal investigator/program director (PI/PD) plays a central role but may also delegate some activities to a department administrator (DA). When the SP is an award, Sponsored Programs Administration (SPA) and Sponsored Programs Finance (SPF) oversee closeout. If the award includes prospective clinical services, the Clinical Trial Office (CTO) adds relevant oversight. All negotiated industry SPs are overseen by the CTO.
Please see the flowchart for details, additional resources further below, as well as BMC's Closeout Policy.
Steps in the Closeout Process
Closeout Process Resources
Below we outline the three National Institutes of Health (NIH) award closeout reports, to be submitted within 120 days of project end date; the no-cost extension (NCE) option to extend award performance; a list of standard close-out activities; and links to the federal regulations governing BMC's SP closeout. Other sponsors' requirements vary to some degree but typically hew closely to NIH standards.
If your questions are not answered below, please contact your assigned grants and contracts administrators or financial analysts for assistance.
No-Cost Extension Requests
In the final year of multi-year awards, do consider whether additional time is needed to complete the SP. Requests for award-period extensions of up to one year are common. During the NCE period, remaining funds must be used to support the work and expenses must be reported.
Consult the eRA Online Help page for National Institutes of Health (NIH) NCE requests.
Final Research Performance Progress Reports
The NIH's Final Research Performance Progress Report (F-RPPR) requires the same information and process as its interim RPPRs, differing only in the timing of its availability for submission through and its location in eRA Commons.
Final Invention Statement
The NIH-required Final Invention Statement should include any invention that was "conceived or first reduced to practice" during the entirety of the grant or award's performance.
Final Financial Report
The NIH requires a final Federal Financial Report (FFR) upon closeout of an award and specifies three relevant contexts: termination of the award, transfer to a new awardee, or non-renewal of a new competitive segment. See SPF's final FFR and invoice guidance for more information.
Summary of Closeout Activities
Closeout activities include but may not be limited to:
- Completion of scientific and technical work and all related deliverables
- Submission and sponsor acceptance of a final progress report
- Submission of the final invention statement, when applicable
- Fulfillment of all requirements specified in the terms and conditions of the award, including regulatory compliance obligations
- Retention of SP records in accordance with sponsor requirements and the BMC record retention policy
- Project completion in:
- InfoEd, BMC’s official grant management system,
- Infor, BMC's financial system of record, and
- Applicable other systems, e.g, those used in clinical research management
- Completion of a final reconciliation that documents all costs, invoices, and receipts
- Submission of final financial reports, when required*
- Submission of final invoices or letter of credit draws (direct federal awards)*
*Please consult SPF's final FFR and invoice guidance
Federal Regulations Governing Closeout
As either federal award recipient or subrecipient, BMC must follow federal regulations governing closeout.* When BMC is the pass-through entity of a federal sponsor, it assumes a role analogous to the sponsor in closing out a subrecipient's subaward. As a subrecipient, it assumes the standard awardee role in relation to the sponsor.
Requirements are spelled out for award closeout (2 CFR 200.344) and post-closeout adjustments and responsibilities (2 CFR 200.345) in the Uniform Guidance.*
If you are new to subaward management, see Basics of Subawards for background details.
*From the Office of Management and Budget Guidance for Grants and Agreements, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 200, colloquially known as "Uniform Guidance" or "UG."