Project Closeout Policy

1. Purpose of Policy

The purpose of this policy is to set guidelines for project closeout on externally funded sponsored projects, to comply with the Code of Federal Regulations, Title 2: Grants and Agreements Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200).  It further sets forth detailed requirements with respect to the complete and timely submission of financial reports and other closeout procedures for sponsored projects. 

2. Stakeholders Most Impacted by the Policy

This policy applies to Principal Investigators engaged in research, projects, activities conducted under the auspices of Western Michigan University whether the activities are conducted on or off campus.

3. Key Definitions

3.1 Project Termination Notice – a reminder of the reporting requirements, due dates and closeout checklist items that need to be addressed prior to the project end date.

3.2 Uncollectible Costs –Costs charged to sponsored projects that cannot be collected from the sponsor for reasons of unallowability, unallocability, dispute with or bankruptcy by the sponsor, or other reasons must be paid for with University funds. 

3.3 Surplus Balances –when revenue is greater than expenditures

3.4 Deficit Balances –When cumulative expenses exceed the amount awarded by the sponsor.

3.5 Final closeout –For the purposes of record retention, it occurs upon the final payment by the sponsor.

3.6 Expanded Authority - additional authority granted by the awarding agency which allows changes that are necessary for the completion of the project within the original scope of work and budget.

4. Full Policy Details 

Principal Investigators and others involved in the management of awards should at all times assure that expenditures are allowable, allocable, reasonable, and timely.  Expenditures should be posted on a timely basis. However, at times there are reasonable delays in being able to post a transaction or to make a required adjustment.  Because of this, there is a period of time after the end date during which adjustments and final postings may be made to a sponsored project.

4.1 Project Termination Notices - Ninety days prior to the project end date, a project termination notice and a closeout checklist is sent by Grants and Contracts to the Principal Investigator.

4.2 End Date of Award - For purposes of this Policy, the end date of the award will be the end date under the sponsored agreement.  Modification of the end date may only be made with approval of the sponsor as follows:

• 4.2.1 Federal Grants – If the project falls under Expanded Authority, WMU may approve a one-time no cost extension of up to one year.
• 4.2.2 Federal Contracts – Written approval for an extension must be obtained from the sponsoring agency at least 10 days prior to the contract end date.
• 4.2.3 Other Sponsored Projects – Written approval for an extension must be obtained from the sponsoring agency by either the Principal Investigator or ORI prior to the end date of the sponsored project in accordance with agency guidelines.

4.3 Expense Close Date - The expense close date is the last day on which expenditures can be posted to the account.

4.4 Closeout Reports - At the close of a project, reports must be filed as required by the sponsor.

4.5 Surplus and Deficit Balances - Surplus and Deficit balances must first be addressed according to sponsor guidelines. If there is a cost overrun (i.e., deficit balance), the amount must be covered by the Principal Investigator and/or department. If the sponsor does not pay in full, the Principal Investigator and/or department must cover the deficit amount. Deficit balances must be cleared within 90 days of the sponsored project end date. 

4.6 Record Retention – Departments must retain copies of expenditure documentation and all supporting source documents that are charged as a direct cost on a sponsored project for at least three years following final closeout of the award and receipt of final payment.

5. Accountability 

5.1 Failure to adhere to these Federal regulations for reporting guidelines in connection with a specific sponsored project may result in the withholding of new awards.

5.2 Unallowable and unallocable expenses will be charged back to the department(s) responsible for the research.

5.3 Failure to follow this Policy and any associated procedures may subject WMU employees to disciplinary action, up to and including dismissal from employment by the University consistent with applicable procedures and Collective Bargaining Agreements. 

6. Related Procedures and Guidelines 

Project Closeout Procedures 

Code of Federal Regulations Title 2: Grants and Agreements Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200).