Final Reporting, Final Invoicing and Closeout of Federal Awards

Uniform Guidance Requirements

  • All federal financial reports must be received within 120 days of the project period end date
  • Refiles and revisions to financial reports will no longer be allowed, requiring the financial report to accurately account for all expenditures
  • Institutions must liquidate all obligations incurred under the federal awards within 120 days of the project end date
  • All federal awards must be closed out in the institution's financial system within 120 days of the project end date

Establishing the Award Trail Out Period

At award set-up, CGA establishes the award’s Trail Out Period by populating the People Soft Research Administration System (RAS) field Processing End Date to prevent the posting of expenditures 65 days after the budget/project end date.

  • For non-LOC awards where the deliverable due date is 60 days or less after the budget/project end date, the Processing End Date will be set to the 8th business day after the next GL month close (e.g., Final Invoice is due 45 days after the award end date of 4/15/16, Processing End Date will be set to day 6/8/16)
  • Subawardees have 60 days to close and invoice UCSF per the contracts; therefore, the last invoice will be received after the Processing End Date
    • Accounts Payable (AP) will notify CGA when the invoice, approved by the PI, is received. CGA will modify the Processing End Date to allow the invoice to be paid as long as the invoice is received prior to CGA filing the final deliverable

Final Reporting/Invoicing Certification and Closeout Process

The Final Reporting Certification process is initiated by Contracts & Grants Accounting (CGA). CGA will notify the RAS Award RSA and Principal Investigator (PI) by email 45 days prior to the end date indicating the reporting and closeout process will begin and take necessary steps to ensure expenditures are posted prior to the Processing End Date. The email contains details on the award, and a link to the RAS. Use the details on the award to complete the Final Reporting Certification form within PeopleSoft RAS and submit online to CGA for review and approval. The form will route to the correct CGA analyst based on the award number.

The RSA or his/her delegate must complete and submit the Final Reporting Certification form with associated attachments 15 days prior to the deliverable due date.

If the Department believes additional expenses not yet posted to the General Ledger are allowable and belong on the award, the department should draft the non-payroll accrual journals/Payroll Expense Transfers (PETs) using either PeopleSoft or the PET process with adequate supporting documentation, and then list and justify the transactions on the Final Reporting Certification Form noting the associated journal ID/PET ID.

Before submitting the Final Reporting Certification Form, all submitted journals/PETs should be reviewed and have the informal approval of the Department Approver (notify the approver outside of system workflow). If approved, the Journal will be in error status. If denied, the approver should request that the Journal be deleted.

The RAS Award RSA should submit the Final Reporting Certification Form to the CGA Accountant via the submit button in RAS 15 days prior to the deliverable due date. If not received by the deadline, CGA will escalate to the Award MSO and a response must be received within 5 days. If no response is received, CGA Accountant will proceed with preparing the financial report based on the General Ledger and the department will be liable for variance between the final report and pending expenses.

CGA Accountant reviews and validates the information provided in the Form. If all information is accurate and the justification to support accruals is acceptable, CGA will modify the Processing End Date and inform the Department to process the journals/PETs within two business days. Certain expenses, though allowable, may be denied if they meet CGA’s Small Balance Write-off Threshold.

CGA Accountant may request additional clarification or information in order to adequately verify the allowability and reasonableness of the expenses, prior to accepting or denying charges.

The financial report/invoice will be submitted to the sponsor by the due date.

  • Most Federal Prime and State awards – 90 days
  • Most subawards – 60 days
  • Intercampus (IRR) awards – 45 days

Any expense adjustment requests after this period will be evaluated per the exception process (See following section).

CGA is responsible for reversing accrual journals once the actual expense posts.

The award will be closed by CGA in RAS by day 120.

Exception Process for all Refiles and Revisions

The Financial report/invoice is submitted by the sponsor due date, typically 90 days for Prime awards and 60 for subawards. The following process is used if a department identifies expenses they believe should have been reported to the sponsor after the end date of the award.

If the Department believes additional expenses not yet posted to the General Ledger are allowable and belong on the award, they must file a revised Final Reporting Certification Form for the award. The department should draft the journals/PETs using PeopleSoft or PET process with adequate supporting documentation, and justify them on the Final Reporting Certification Form noting the associated journal ID/PET ID.

Before submitting the Final Reporting Certification Form, all submitted journals/PETs should be reviewed and have the informal approval of the Department Approver (notify the approver outside of system workflow). If approved, the Journal will be in error status. If denied, the approver should request that the Journal be deleted.

If approved, CGA Accountant will modify the Processing End Date and inform the Department to process the transfer within two business days. Certain expenses, though allowable, may be denied, if they meet CGA’s Small Balance Write-off Threshold.

The CGA Accountant will inform the department of the final treatment of the expense(s) and the structure for the journal.

Instances when a refile/revision will be allowed:

  • All Refunds to Sponsor
    • CGA will determine if the refund is processed against the individual award or the clearing house
    • If processed against individual award, refile report
      • If after liquidation, refile requires sponsor/PMS permission this will be obtained by CGA
  • Expense against Award Unexpended Balance
    • CGA will not consider any amount under $5,000
      • If processed against individual award, refile report if the actual expense comes in during the closeout and is greater than the accrual,CGA will process the difference in accordance with the Exception Process for Refiles/Revisions. In this case there is no need to file a revised report.
      • If after liquidation, refile requires sponsor/PMS permission this will be obtained by CGA

No-Cost Extension during the Financial Reporting and Closeout Process

CGA can implement a No-Cost Extension (NCE) and adjust the end date of an award only when notified of the approved NCE via the appropriate pre-award office via normal procedures (i.e., CACTAS). Therefore, if there is the possibility of a NCE, it should be identified and executed as early as possible to avoid the necessity of the Final Reporting and Closeout Process. If the NCE is executed after the fact, all transactions will be reversed as appropriate.

Clinical Study and Non-Federal Reporting/Invoicing and Closeout

For clinical trials and private awards, see Financial Reporting and Closeout of Clinical Trials and Private Awards.

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