Grant Closeouts Robin Bunch Grants Management Officer
Topics � Definitions for this Discussion � No-Cost Extension versus Grant Closeout � Grant Closeout Procedures � Adjustments and Continuing Responsibilities � Collections, Audits, Records Retention, and Property Management � References � HHS Grants Policy Statement, 2 CFR Subpart D, and Grant Contacts
Definitions for this Discussion from 2 CFR 215.2 Subpart A � Obligation: the amount of orders placed, contracts and grants awarded, services received and similar transactions during a given period that require payment by the recipient during the same or a future period. � Unliquidated obligation: amount of obligation incurred by the recipient that have not been paid. � Unobligated balance: the portion of the funds authorized by the Federal awarding agency that has not been obligated by the recipient.
No-Cost Extensions � Normally requested to complete activities of the grant. � Requests must be in prior to the end of the Project Period. � No Cost Extensions are not permitted to merely use unobligated balances. � Are one time extensions of the expiration date up to 12 months.
No-Cost Extensions � You must provide: � a “letter of justification” providing us with the time needed for the No Cost Extension signed by the authorized official (person who signed SF- 424) � SF-425 indicating the amount of unobligated funds � May not permit any budget changes in a recipient’s award that caused any FEDERAL APPROPRIATION to be used for purposes other than those consistent with the original award/purpose of the authorization and appropriation. � Can run concurrently with “new” awards � Grantee must maintain separate accounting
Grant Closeout � A process by which the federal agency determines that all applicable administrative actions, all terms and conditions, and all required work on the grant have been completed.
When a Grant Can Not be Closed � If it is in litigation or under appeal. � Termination has been initiated and all necessary termination actions have not been accomplished. � Allowable costs under the grant have not been paid � Any unliquidated funds remain in the grant.
Closeout Procedures � Liquidate all obligations incurred within 90 days after the funding period. � Submit within 90 days � Final SF-425 reports � Final Program Progress Reports (PPR) � Property Inventory and Disposition Form (http://www.acf.hhs.gov/grants-forms) � Promptly refund any balances of unobligated cash advanced by ACF
Adjustments and Continuing Responsibilities � Closeout does not affect – � Federal agencies ability to disallow costs and recover funds on the basis of a later audit or other review. � The recipients obligation to return any funds due as a result of later refunds, corrections, or other transactions. � Audit requirements � Records Retention � Property Management
Collection of Amounts Due � Any funds paid in excess of that entitled constitute a debt to the government. � If not paid, may reduce the debt by � Administrative offset against other requests for reimbursement. � Withholding advance payments. � Take other action permitted by statute. � Interest is accrued.
Audit Requirements OMB Circular - A-133 � Non-federal entities that expend $500,000 or more in a year shall be audited. � $500,000 is from all Federal sources � Frequency of audits - Annual basis � Submission - 9 months after your audit period to Federal Audit Clearinghouse (http://harvester.census.gov/sac/) � http://georgewbush- whitehouse.archives.gov/omb/circulars/a133/a133.html
Records Retention � Three years from date of submission of final SF-425 � If litigation or audit started before expiration of 3 year period, then retain until litigation, claims, or audit findings have been resolved. � Real Property and equipment for 3 years after disposition.
Property Management � Supplies and other Expendable Property � Title to supplies and other expendable property shall vest in the recipient upon acquisition. If there is a residual inventory of unused supplies exceeding $5000 in total aggregate value upon termination or completion of the project or program and the supplies are not needed for any other federally-sponsored project or program, the recipient shall retain the supplies for use on non-Federal sponsored activities or sell them, but shall, in either case, compensate the Federal Government for its share ( 2 CFR 215.35a – Subpart C Post Award Requirements ) � Also, see OMB Circular A-110 (Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations) for guidance on Equipment and Real Property (http://www.whitehouse.gov/omb/circulars_a110/)
References � 2 CFR Subpart D � HHS Grants Policy Statement � Grants Management Contacts
2 CFR Subpart D � After-the Award Requirements � 215.71 Closeout Procedures � 215.72 Adjustments and Continuing Responsibilities � 215.73 Collection of Amounts Due � http://www.whitehouse.gov/sites/default/files/o mb/assets/omb/circulars/a110/2cfr215-0.pdf
HHS Grants Policy Statement � Public document providing information about the HHS grants process � Closeout information is found in section II � http://www.hhs.gov/asfr/ogapa/grantinform ation/hhsgps107.pdf
Grants Management Contacts The Grants Management Specialist identified on your FAA should be � called on all financial and non-programmatic aspects of the Grants. � Grants Specialist Phone Number � Roni Brooks (202) 401-5283 � Marc Hill (202) 690-5800 � Theresa Hall (202) 401-5402 � Bernard Morgan (202) 401-4896
Programmatic reporting � Semi-annual report covering April 1 – September 29, 2012 � Final report: 90 days after the end of the project period, or Dec. 31, 2012. “PPR” or Performance Progress Report (forms can be found here: http://www.acf.hhs.gov/grants-forms on the new ACF/ORR website)
Performance Progress Report � ACF Instructions for the SF-PPR Cover Sheet In completing block 10 of the SF-PPR cover sheet, grantees will be expected to attach a written narrative on their performance in the following areas for the time period for which the report is submitted: � Major activities and accomplishments � Problems encountered � Significant findings or events � Dissemination Activities � Other Activities � Activities Planned for the next reporting period
Recommend
More recommend
