Post Award Compliance Changes
Overdrafts and Accelerated Spending Procedures
Overdraft Reports
Procedures regarding Closeout/Financial Reporting Delays
Other Closeout/Interim Financial Reporting Issues
Download Postaward Compliance Procedure memo 
(07/26/2001)
Post Award Compliance Changes
Effective July 2001, the School of Medicine through the Research Management Group (RMG) established
the Quarterly Post Award Reporting Policy and Procedure for the review and
monitoring of sponsored project accounts. The University required
the School to develop additional controls to ensure timely management of these
accounts consistent with University policy as well as any sponsor requirements
and governmental regulations. The following two issues were addressed:
-
Accounts that appear to have an accelerated spending pattern or have gone into overdraft
-
Timely submission of interim and final financial reports to the sponsors. This document addresses specific responsibilities of the Department, the Research Management Group and the Office of Sponsored Research in the management of these two areas.
1. Overdrafts and accelerated spending
A report of potential overexpenditures above a threshold of $50,000 on federal
awards and non-federal grants will be sent to each department with their
copy of the Quarterly Report. The department must give a detailed explanation
and, if applicable, an action plan to resolve the problem. Identified overdrafts
must be cleared within 30 days of the quarterly report due date. If
not cleared within 30 days, Medical School Finance will provide a department
account to OSR and OSR will prepare the journal with a copy to the department. Overdraft and accelerated spending procedures .
2. Closeout and Interim Financial Reporting
Most sponsors require final financial reports within 90 days (sometimes
less) from the project end date. Interim reports are generally required 90 days
from the end of the reporting period.
RMG will send a reminder 90 days
prior to the end date that an award will be ending. The department should
be ready to close out the award 30 days after the end of the award.
To
initiate closeout, OSR will contact the department by email not less than 30
days after the end date of the award to verify if the award is ready to be closed. In
most cases, the email will also question any possible unallowable charges on
the account. The department has 30 days from the date of the email to respond
to OSR.
After 21 days, if they have not heard back from the department,
OSR will call the department as a reminder of the upcoming 30-day deadline. Lack
of a response from the department will indicate to OSR that they may proceed
with closeout. If possible unallowable charges were included in the email,
they will be then be considered unallowable and moved off of the award. Medical
School Finance will provide OSR with a department account and OSR will prepare
journals with a copy to the department.
In addition, OSR is currently working to eliminate a backlog of grants and
contracts that are already more than 90 days past the end date and, therefore,
the financial closeout is past due. For these awards, OSR will notify
the department when they initiate closeout, allowing 5 business days for a
response.
Closeout and Interim Financial Reporting procedures
Office of Sponsored Research staff contact information: ORA website.
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New Procedures Regarding Overdrafts and Accelerated Spending
| Issue | Action | Further Action |
|---|---|---|
Overdrafts Identified by OSR and RMG |
The Overdraft Report will consist of apparent overdrafts of greater than $50,000. The report will be sent to the department with the Quarterly Reports. Department must comment on each account and return comments with Quarterlies by the due date. Identified overdrafts must be removed within 30 days of the due date listed on the cover memo. If not removed within 30 days, OSR/Med School Finance will move the overdraft to a department account identified by Med School Finance. Also, all overdrafts identified during financial reporting must be removed within 30 days of notification by OSR. If not removed within 30 days, OSR/Med School Finance will move the overdraft to a department account identified by Med School Finance. |
The department may work with Med School Finance to determine an alternate account for the overdraft from the one provided by Med School Finance, if necessary. |
Accelerated Spending |
Most will be identified, and commented upon, as part of the Overdraft
Report mentioned above. Accounts identified as having accelerated spending will be dealt
with on a case-by-case |
|
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Overdraft Reports (RMG)
- Departments must give a detailed explanation and, if applicable, an action plan to resolve the issue for each account that is listed on the Overdraft Report.
- Journals prepared by OSR or Med School Finance to move overdrafts will have the Department/Division Chair cc:'d on the journal.
- A report listing Questionable and Administrative charges on sponsored projects will also be sent with the Quarterly Reports for your review.
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New Procedures Regarding Closeout/Financial Reporting Delays
| Issue | Action | Further Action |
|---|---|---|
No answer from department on "Okay to Close" request |
Once contacted by OSR, Department has 30 days to respond to RMG/OSR whether or not the award is ready to close. After 21 days, OSR will call the department as a reminder if they have not had a response. Lack of a response within those 30 days indicates that the award is ready to close and OSR will proceed with closeout. In the event a final invoice for a contract is due within 45 days or less, the department will respond promptly so that the deadline can be met. |
If expenses post to the award after the closeout is complete and final report has been sent, the charges will be moved to an appropriate department account (given to OSR by department or Med School Finance).* |
Possible Unallowable Charge(s) |
Once contacted by OSR, Department has 30 days to respond to request for information/justification or to remove the charge. After 21 days, OSR will call the department as a reminder if they have not had a response. If no response from department in 30 days, OSR/Med School Finance will move the charge to a department account identified by Med School Finance. |
Even if the charge is later determined to be allowable, it may not be transferred back onto the award (since OSR would have to revise the report). |
Award ended more than 120 days ago (and there is no NCX in process) |
OSR will proceed with closeout without department approval. However, OSR will notify the department that the final financial report is being prepared and sent to the sponsor. |
Any further charges must be charged to an appropriate department account. |
* OSR will not revise reports once the financial report has been sent
to the sponsor (unless a credit is posted to the account).
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Other Closeout/Interim Financial Reporting Issues (OSR)
- Initial contact will be via email to department by OSR accountant. Emails
will be sent to two departmental contacts, both of which can make decisions. A response from either contact is
will be considered final.
- OSR will not contact department any sooner than 30 days after the end date
of the award.
- "Okay to Close" and Possible Unallowable Charges requests will in most
cases be sent in the same email.
- The response must be an answer; time extensions will not be granted.
- Exceptions to these procedures will be made on a case by case basis.
Other resources:
Office of Sponsored Research Closeout Strategy
Cardinal Curriculum training: Closeout and Record Retention
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