Office of Acquisitions Grants and Risk Management This Is Us Objectives Learning Activities Closeout Policy Sources Uniform Guidance CFR Part 200 EDGAR Grant Award Notice GAN 2 CFR Part 200 ID: 1028893
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1. Grant CloseoutGrants Management Policy DivisionOffice of Acquisitions, Grants, and Risk Management
2. This Is Us
3. Objectives
4. Learning Activities
5.
6. Closeout Policy SourcesUniform Guidance: CFR Part 200 EDGARGrant Award Notice (GAN)
7. 2 CFR Part 200Commonly referred to as the Uniform Guidance, 2 CFR Part 200 addresses the administrative requirements, cost principles, and audit requirements for federal awards and provides consistency across agencies. Note despite the name it is the regulations governing grants and not simply guidance.2 CFR 200.344 specifically addresses closeout:The Federal awarding agency or pass-through entity will close out the Federal award when it determines that all applicable administrative actions and all required work of the Federal award have been completed by the non-Federal entity. If the non-Federal entity fails to complete the requirements, the Federal awarding agency or pass-through entity will proceed to close out the Federal award with the information available. This section specifies the actions the non-Federal entity and Federal awarding agency or pass-through entity must take to complete this process at the end of the period of performance.
8. 2 CFR Part 200 continued200.344 Closeout.(a) The recipient must submit, no later than 120 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award. A subrecipient must submit to the pass-through entity, no later than 90 calendar days (or an earlier date as agreed upon by the pass-through entity and subrecipient) after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award. The Federal awarding agency or pass-through entity may approve extensions when requested and justified by the non-Federal entity, as applicable. (b) Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.
9. 2 CFR Part 200 continued200.344 Closeout.(c) The Federal awarding agency or pass-through entity must make prompt payments to the non-Federal entity for costs meeting the requirements in Subpart E of this part under the Federal award being closed out. (d) The non-Federal entity must promptly refund any balances of unobligated cash that the Federal awarding agency or pass-through entity paid in advance or paid and that are not authorized to be retained by the non-Federal entity for use in other projects. See OMB Circular A-129 and see § 200.346, for requirements regarding unreturned amounts that become delinquent debts.(e) Consistent with the terms and conditions of the Federal award, the Federal awarding agency or pass-through entity must make a settlement for any upward or downward adjustments to the Federal share of costs after closeout reports are received. (f) The non-Federal entity must account for any real and personal property acquired with Federal funds or received from the Federal Government in accordance with §§ 200.310 through 200.316 and 200.330.
10. 2 CFR Part 200 continued200.344 Closeout.(g) When a recipient or subrecipient completes all closeout requirements, the Federal awarding agency or pass-through entity must promptly complete all closeout actions for Federal awards. The Federal awarding agency must make every effort to complete closeout actions no later than one year after the end of the period of performance unless otherwise directed by authorizing statutes. Closeout actions include Federal awarding agency actions in the grants management and payment systems. (h) If the non-Federal entity does not submit all reports in accordance with this section and the terms and conditions of the Federal Award, the Federal awarding agency must proceed to close out with the information available within one year of the period of performance end date. (i) If the non-Federal entity does not submit all reports in accordance with this section within one year of the period of performance end date, the Federal awarding agency must report the non-Federal entity's material failure to comply with the terms and conditions of the award with the OMB-designated integrity and performance system (currently FAPIIS). Federal awarding agencies may also pursue other enforcement actions per § 200.339.
11. General Timeframe for Closeout
12. Education Department General Administrative Regulations (EDGAR)The regulations specific to the department of education and its particular programs. Unlike 2 CFR 200 which applies to all grant making agencies.Education Department General Administrative Regulations (EDGAR) and Other Applicable Grant Regulations
13. EDGAR continued Specific 34 CFR Parts dedicated to closeout prior to 2014. After 2014, were replaced with 2 CFR 200.344. Part 74—ADMINISTRATION OF GRANTS AND AGREEMENTS WITH INSTITUTIONS OF HIGHER EDUCATION, HOSPITALS, AND OTHER NON-PROFIT ORGANIZATIONS § 74.71 Closeout procedures. PART 80—UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS AND COOPERATIVE AGREEMENTS TO STATE AND LOCAL GOVERNMENTS §80.50 Closeout Procedures
14. GANIt is the official document and notification to a grantee that states an amount and terms and conditions of award. This can include any grant specific closeout requirements, so be sure to read carefully.
15. Sample GAN
16. Sample GAN
17. Sample Department of Education Closeout Checklist
18. Closeout LetterThis letter is to inform you that the U.S. Department of Education (ED) has completed its review of your XXXX final performance report for PR/Award No. XXXX to determine compliance with 2 CFR 200.344 as applicable. According to our records in the Grant Administration and Payment System, you have $XXXX remaining in your account. Before we can officially close your grant, we need a letter from you confirming that the unused funds are not needed and that all of your financial obligations under this grant have been met. This letter needs to be signed by your Authorized Representative.
19. Closeout Letter continued.....If you have outstanding obligations for which you have not drawn down funds, we will need a written request and justification explaining the reason for using these remaining funds on this grant and the total dollar amount of the expenditure(s). Your request may only be for expenditures incurred during the project period and may not be for any new obligations made outside this period. You will also need to submit an SF 425 Financial Final Report with this written request that must be signed by either your Authorized Representative or finance officer. We will review this request to determine compliance with 2 CFR 200, EDGAR and program regulations.
20. General Forms Required for CloseoutFinal Performance Report after project activities have completedFinal Financial Report (i.e. SF 425)Property Reports (SF428, if applicable)Data and Patent Reports (if applicable)
21. Federal Financial Report (SF-425) Section 10
22. Federal Financial Report (SF-425) Section 10
23. Federal Financial Report (SF-425) Section 10
24. Federal Financial Report (SF-425) Section 11
25. SF 428B requirementsRequirements for final reporting are based on individual award provisions and the type of property. Generally, at the end of a Federal assistance award, recipients are required to: a. submit a report of Federally-owned property. b. provide a listing of equipment items, with an acquisition cost of $5,000 or more, when the awarding agency has reserved the right to transfer title to the equipment to the Federal Government or a third party. c. compensate the awarding agency for residual unused supplies with a total aggregate fair market value greater than $5,000 that are not needed for any other Federally sponsored programs or projects
26. Is the formula grant ready for closeout?
27. Grantee Closeout Action Items Stage:OpenLiquidationSuspensionManual CloseoutClosedAction Item:Create, monitor and reconcile obligationsComplete/submit final reports and final drawdownsMake final adjustments to reports and drawdown with ED approvalMust work with ED staff to amend reports and drawdownCelebrateThis Photo by Unknown Author is licensed under CC BY-NC
28. Who Pays? 2 CFR 200.344
29. Closing a Grant in NoncomplianceA Noncompliance Letter signed by the program official will be issued explaining the basis for the noncompliance and whether the grantee materially failed to meet the requirements of the grant; A copy of the letter will be saved in the official grant file along with the documentation of the program’s efforts to resolve any noncompliance issues, and the documentation of the consultation between the program and the program official concerning the close out of the grant in noncompliance.
30. Closeout Show-Stoppers
31. After CloseoutGrantees are required to maintain grant records for three years after the submission of all required reports. This time period is extended if audit or legal matters take longer than three years to resolve.Including: Records regarding the use of grant funds, compliance with program requirements, and the data used to demonstrate the project’s effectiveness in meeting the project objectives. Your copy of the approved application. Financial records showing the amounts and sources of all funds spent on the grant, including any cost-sharing or matching funds that were required or volunteered as part of the approved project. These records must also document how all federal and matching funds were used.
32. After Closeout Continued...Records that document other types of information you provided in your annual or final reports, such as records of program participants and the source data used to report on performance measures.Maintain inventory records, if you purchase equipment with grant funds, until you dispose of the equipment or transfer it to another federal project for use.Copies of all correspondence with ED regarding the project.
33. Questions?
34. Thank you!Grants Management Policy DivisionGiving you what you need to succeed!