Dear Colleagues,
As announced at RAF, November 12th, financial closeout requirements in UG changed effective November 12, 2020. For everyone’s easy reference, the revised guidelines are included in this email and more information can be found in Uniform Guidance §200.344 Closeout. This announcement explains how ORA will implement this change to the due date of the final financial deliverables in PAMS.
Revised guidelines are applicable to all federal awards; however, this does not mean that the financial closeout due date of all existing federal awards will be retroactively changed. For the new federal awards made on or after November 12, 2020, ORA will set up the final financial deliverable applying new 120 days requirement instead of 90 days unless the award is received with a more restrictive closeout deadline. For the federal awards made prior to November 12, 2020, the federal agency may consider funding increments as an opportunity to modify the terms and conditions applying the new 120 days requirement. As UCLA receives the change to the financial closeout deadline, the due date of the final financial deliverable in PAMS will be updated. For NIH and NSF that granted 120 days prior to the revised Uniform Guidance, the due date of final financial deliverable at the end of the project will be automatically updated soon to be 120 days in PAMS for all awards subject to Uniform Guidance.
If you have any questions about the final financial deliverable due dates, please reach out to your EFM accountant.
Uniform Guidance §200.344 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.
(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.
(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.
(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.
Sincerely,
Yoon Lee
Director, UCLA Extramural Fund Management