Sponsored projects are required to be closed in accordance with all appropriate University of Hawaiʻi (UH) policies and award terms and conditions. Careful attention to project closeout is necessary to ensure that UH is fully reimbursed for project expenses. This also protects the reputation of UH and the principal investigator, while maintaining a positive relationship with the sponsor to provide for future collaboration and funding.
Compliance with award terms for project closeout is required. Consequences of non-compliance include termination of current awards or suspension of future awards, rejection of claims for reimbursement, possible adverse audit findings and possible enforcement actions that may be legally applicable.
Closeout roles and responsibilities are detailed in AP 12.412 Extramural Closeout Procedures, Section C, and include, but are not limited to:
Principal Investigator (PI)
- Ensure compliance with award terms (for example, adherence to approved budgets and project due dates)
- Ensure that all costs charged to the project are allowable, allocable, and reasonable. Provide fiscal administrator (FA) with necessary documentation to support allowability, allocability, and reasonableness.
- Avoid purchasing goods and/or services that will not be consumed within the award period
- Complete all required reports such as technical, invention and cost sharing reports
- Collaborate with FA to resolve fiscal matters
- Determine if a project extension is necessary
- Assist ORS with recovery of costs as necessary
Fiscal Administrator (FA)
- Assist PI in ensuring all project costs are allowable, allocable and reasonable and posted in a timely manner to the Kuali Financial System (KFS)
- Assist PI in clearing deficits and disallowances in a timely manner
- Work with PI to confirm final expenditures for project account
- Verify that encumbrances and suspense items are cleared
- Provide approval to process final invoice or report
- Provide detailed schedules or back up documentation, if required by sponsor
Dean or Director
- Ensure that PI and FA carry out their closeout duties
- Assist PI in securing alternative funding if deficits or disallowances occur
- Issue reminder notices to PI and FA (sent out via “Closeout Notice Mailbox”). These are courtesy reminders only, which may not be always be sent as anticipated due to timing, or other issues, the PI and FA are to monitor their project to ensure deadlines are met.
- Submit invoices and financial reports to the sponsor and coordinate and/or endorse other report submissions
- Inform dean/director if closeout problems arise
- Pursue accounts receivable collections, and notifies and consults with the PI and FA, as necessary
|-60 Days||-30 Days||At/After Termination|
|Determine whether an extension is necessary
If so, initiate written request for project extension
Submit to ORS for endorsement and submission to sponsor
|Initiate change to account end date in KFS||X|
|Review anticipated expenditures and address significantly over expended budget categories*||X|
|Review approved budget and actual expenditures for issues requiring resolution*||X|
|Initiate process to transfer payroll and other recurring costs to other account(s)||X|
|Verify all personnel have been transferred off of the project account as of project end date||X|
|Move transactions that may have posted to the continuation account||X|
Encumbrances and adjustments
|Monitor outstanding POs, encumbrances, subawards, and transactions posted to continuation accounts*||X|
|Verify necessary adjustments posted*||X|
|Verify committed cost sharing recorded*||X|
Other closeout requirements
|Review closeout requirements and deadlines applicable to award. May include:
Final technical report
Final invention statement
Final inventory report
Final invoice/financial report
|Submit required reports by deadlines applicable to award. May include:
Final technical report
Final invention statement
Final inventory report
Support for final invoice/financial report
|Closeout confirmation to ORS 90 day deadline – 90 days, or no later than 30 days, prior to due date, whichever is earlier
60 day deadline – no later than 20 days prior to due date Less than 60 day deadline – no later than 15 days prior to due date
* Also performed throughout the award period
In accordance with AP 12.412 Extramural Closeout Procedures, collection letter(s) are sent to sponsors for unpaid final invoices.
|1st Collection Letter||Approximately 2 months after the final invoice submitted|
|2nd Collection Letter||Approximately 2 months after 1st Collection Letter|
|Notification to Dean/Director||Approximately 2 months after 2nd Collection Letter|
|Account may be sent to a collection agency after consultation with the PI, FA, and provost, chancellor, dean or director, as applicable.|
- Any excess cash received will be returned to the sponsor in accordance with award terms.
- If the project account is in deficit and despite all collection efforts, the accounts receivable is deemed unrecoverable, ORS will work with the school/campus to obtain funds or set up a payment plan to reimburse the project account for any cash deficit. Generally, cash deficits will be charged to the school’s, college’s or research unit’s Research Training and Revolving (RTRF) account or other departmental account provided.
If payment is subsequently received from the sponsor, the account used to cover the deficit will be credited.
A fixed-price award is an agreement in which a fair price for the scope of work is agreed upon and is not subject to upward or downward adjustment based on actual costs incurred. Fixed-price awards include, but are not limited to fixed fee contracts, deliverable-based agreements, fixed-rate agreements, and other awards where there is no requirement that any remaining funds be returned to the sponsor.
Fixed-Price Residual Balance Transfer
A project account for a fixed-price award is considered to have a residual balance if there is an unobligated, unspent balance remaining on the fixed-price award at the conclusion of the project period after all project costs have been allocated to the award, all financial obligations have been met, and all deliverables have been received by the sponsor.
For fixed-price residual balances:
- Full indirect costs will be calculated based on the total award amount and the full negotiated indirect cost rate, even if a lower rate was approved for the award.
- Full indirect cost less indirect cost recovered will be recorded up to the residual balance. The remaining net residual balance will transfer to an account under the responsibility of the school, college or research unit, as applicable.
- Net residual balances are generally transferred to fixed price accounts designated by the principal investigator (PI). However, significant residual balances (more than 20% of total award amount) will be transferred to a fixed price account designated by the dean/director/provost/chancellor for further review and resolution.
To request a fixed-price residual balance transfer, submit ORS Form 2, Fixed-Price Residual Balance Closeout Form to the assigned ORS accountant.
Fixed-Price Internal Account Extensions
If an end date for the project is not specified in the award document, an extension to the end date initially established for the Kuali Financial System (KFS) project account may be requested by submitting ORS Form 3 – Fixed-Price – Internal Account Extension Request Form to the assigned ORS accountant. The new end date should reflect the PI’s best estimate of when all project activities are likely to be completed.