Closing Out Award. The PI will work with ORA in obtaining the applicable resolution. Residuals

Transcription

1 Clseut All spnsred prject awards must be frmally clsed-ut as sn as pssible after the prject end date t ensure that all expenses psted t this prject are allwable, n additinal charges are psted, all payments are received, and required reprts are submitted. Clinical trials are cnsidered ready fr clseut when n additinal patients are being enrlled r in a fllw-up perid. The PI is respnsible fr ntifying ORA, Pst Award when prjects are ready t be clsed ut. ntificatins are generated and sent t the PI 90 days prir t the prject end date as a reminder f the upcming expiratin date and as a trigger fr a n cst extensin request r cntract mdificatin, if needed t cmplete the wrk. Prir t the clseut, the PI and departmental designee are expected t review the prject, clear ut all utstanding encumbrances, and determine if all expenditures are psted. N new charges r cmmitments may be incurred t a prject after the prject end date. This includes persnnel charges. Charges that were cmmitted befre the prject end date may be prcessed after the end date but prir t the final financial reprt r invice will be prepared based n the spnsr regulatins and the award dcument. Prjects will be clsed ut in accrdance with the Clseut Plicy. The PI and/r ther persnnel will cntact ORA t determine if there are residual balances. Prjects with negative balances at the end f the prject must be subsidized frm departmental funds. The PI, in cnsultatin with his/her Divisin s Chair r Department/Center Directr will determine hw t fund the negative balance and will advise ORA by the given due date. If the PI/designee des nt respnd timely, ORA retains the right t charge the departmental prgram/gift fr the negative balance n the spnsred prject. Prjects with residual balances will be clsed ut in accrdance with the Residual Balance plicy. The award will be clsed ut by first charging any remaining indirect cst. If a reduced r waived indirect cst rate was granted at the utset f the prject, and there are funds remaining at the cmpletin f the prject, these funds cannt be designated as residual until the reduced r waived prtin f the indirect csts have been recvered. In the event that a PI leaves the university, residual fund balances will be retained by UM. New expenditures incurred after the end date will nt be allwed unless a NCE has been apprved. ORA, Pst Award will change the award life cycle status f all awards t Pending Clse within 90 days after the award end date. This will ensure n additinal charges ccur n the accunt withut review. Encumbrances existing prir t the end date will be released as the purchase rder is paid. 1

2 The PI r departmental designee is required t cmplete the fllwing: Review all prject expenditures t determine that they are allwable and apprpriate and t ensure that charges have nt psted in errr. Verify that all expenses have psted t the award and that all payments t subrecipients and suppliers have been made. Stp all recurring charges. Identify the prgram/gift t which any ver-expenditures incurred n the prject shuld be transferred. Review prject cst share expenditures t ensure that charges have nt psted in errr and that the cst share requirements have been met. Verify that all labr charges have been psted, that the ttal effrt charged t the prject is crrect, and that the cmmitted effrt has been met. Infrm ORA immediately f any errrs charged t prjects. Update all labr cst allcatins t terminate future charges t this prject. Cnfirm that all cmmitments are liquidated r inviced and paid. Cmmunicate t ORA when all intended expenditures and crrectins have psted. Submit a final reprt t IRB (if applicable) and ntify ORA f prjects ending that d nt have a cntractually specified clsing date. Verify that all utstanding reprts r deliverables are cmpleted. Review clseut issues and reslve questins. Issues may include mnitring visits by spnsrs, utstanding case reprt frms, regulatry requirements t IRB, etc. Prepare the final technical reprt and submit a cpy t the spnsr accrding t the instructins in the award dcument as applicable. Identify, dcument, and submit all Intellectual Prperty infrmatin, including the final inventin reprt, when applicable. Verify/submit all cmpliance related dcuments. Fr any study with per-patient charges: Recncile the patient care charges t ensure that all payments t patients have been made. Review patient enrllment and the per-patient reimbursement if applicable. Cmplete and sign the Clseut frm. Expenditures shuld be cut ff as fllws: Telephne: T cancel telephne service n spnsred accunts, fllw the Telecmmunicatins prcedures and frward a cpy f this request, which identifies the telephne number, service, and the effective date f the change f service t ORA. Standing Purchase Orders: T clse a standing purchase rder n a spnsred accunt, submit a PO change rder Request. N rders may be placed against a standing purchase rder after the clse f the prject perid Duplicating Charges: T cancel recurring duplicating charges n a spnsred 2

3 accunt, send a memrandum t Duplicating Services with a cpy t ORA with the fllwing infrmatin: grant number currently being charged, grant/prgram/gift number nw t be charged, and the effective date f the change. Petty Cash and Travel Reimbursements: These must be clsed cnsistent with university plicy and are t be submitted within ten wrking days f the clse f the prject perid. Equipment acquisitins within six mnths f the expiratin f the award may require justificatin f the usefulness t the prject in the clse-ut perid. Supplies are t be acquired in reasnable amunts fr the expected activity during the clse-ut perid. Stckpiling in the terminal year f a prject perid are nt allwed. All prjects are subject t a clse ut review. ORA will cnduct this review prir t clsing ut each prject in additin t the steps listed belw as fllws: Identify prjects that need t be clsed. Verify that the cmmitted effrt fr all key persnnel has been met. Prcess and review final expenditure and cst transfer requests. Determine if all cst sharing requirements have been met. Review the grant terms r cntractual agreement and determine if any unspent funds shuld be returned. Review the Clseut frm. Fr studies with patient care csts: Determine if revenue and expenditures appear reasnable and in line with the budget. Examples f final expenditures that are nt reasnable r in line with the budget: a clinical study that enrlled patients r ther research prject that has been cmpleted but with n r relatively few expenses charged; a prject with budgeted effrt, intercmpany charges, etc, with little r n actual charges psted. Review the patient care payments and determine if all payments t patients have been made. Submit the final invice r expenditure reprt if applicable. Ensure all invices are paid. Sign the award clse ut check list. This review, perfrmed by ORA des nt remve r reduce the PI s respnsibilities but is intended as a clse-ut audit. The award and all related award lines will be clsed when all required reprts have been submitted, final payment has been received by UM, and there are n utstanding issues. Financial, perfrmance, and ther reprts t Federal agencies are nrmally due within 90 calendar days after the cmpletin f the award in accrdance with the terms and cnditins f the award. ORA and the department 3

4 will wrk tgether t cmplete a recnciliatin f the accunt prir t the due date f the reprt t the agency. Once the abve criteria have been met, ORA will change the award lifecycle status t clsed pending final audit adjustments. Accunt verdrafts and Residuals Accunt Overdraft The PI is respnsible fr managing all spnsred prjects in a manner t minimize unallwable cst r verdrafts frm ccurring r t reslve these prmptly when they ccur. Althugh circumstances may create a temprary verdraft n a spnsred prject, reslutin f verdrafts must incur as sn as pssible, but by n later than by the final award recnciliatin. The reslutin can include ne r mre f the fllwing actins: btain additinal spnsred funding; Absrb the verdraft thrugh the PI s respnsible departmental prgram/gift. The PI will wrk with ORA in btaining the applicable reslutin. Residuals Once a fixed price award has been cmpleted, including any n-cst extensins that may be granted, n new bligatins r expenditures will be incurred against the award. Upn clseut f the fixed fee/fixed price agreement, any revenue in excess f expenditures incurred will be subject t the residual plicy. ORA is respnsible fr reviewing all related revenue and expenditures and determining if these seem reasnable. Once this review has been cmpleted, any remaining residuals will be clsed ut as fllws: If the ttal cst incurred n the prject is less than the amunt received, any waived indirect cst as well as any F&A budgeted but nt charged will be charged t the prject, and the remaining balance will be transferred t a departmental prgram. 4

5 Residual balances in excess f 20% f the ttal revenue recgnized are subject t a special review by ORA. If the residual is greater than 20% f the ttal revenue recgnized, the PI will submit a written justificatin describing the cause f the residual balance. This, alng with the Clseut Frm and ther supprting dcuments (if applicable) are submitted t ORA fr review. Transfer t anther institutin If a PI transfers t anther institutin, (s)he may decide t either leave his/her grant(s) r cntract(s) with UM r transfer these t the new institutin. Final dispsitin plans may require apprval frm the department Chair/Dean. If the award(s) remain at UM, the request t change the PI shuld be submitted t ORA, Pre Award fr submissin t the spnsr. If the award(s) are transferred t the PI s new institutin, the PI cnfers with ORA, Pre Award wh will advise and assist him/her in initiating the prcedures required by the spnsr and the university fr a grant/cntract transfer. ORA, Pst Award will fllw spnsr prcedures in submitting the final financial reprt, the relinquishing frm, and a refund f unexpended funds t the spnsr, if applicable, and fllw any ther guidelines prvided by the spnsr. ORA, Pst Award will ensure prper clse ut f the prject. Capital equipment purchased r prvided frm an award may be transferred t anther Institutin prviding all f the fllwing cnditins are met: The equipment is transferred t the same institutin as the award frm which it was purchased and the spnsr has apprved the transfer f the award. The principal investigatr (PI) and the department chair have determined the university will n lnger need the equipment and apprved the transfer; The institutin t which the equipment will be transferred agrees in writing t accept title and accuntability fr the equipment; and The university will nt incur any cst fr packing and shipping the equipment, unless stipulated in the award. Capital equipment purchased and prvided by the spnsr shuld typically be returned t the spnsr. Hwever, if this equipment needs t be transferred t the PI s new institutin, then apprval frm the agency is required. If the Gvernment hlds title f the equipment, the final dispsitin guidance has t cme frm the gvernment. T request a transfer: 5

6 The PI will cmplete and submit a request fr apprval t the chair f the department r dean f the schl. Upn review and apprval frm the chair/dean, this request will be frwarded t ORA. The university fficial in ORA will review the request in accrdance with the spnsr guidelines and award specific terms and cnditins. Upn review, the frm will be returned t the PI r designee if additinal infrmatin/justificatin is required, r frwarded t the spnsr fr review if there are n additinal questins. 6