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Award Closeout and Audit

Research Services understands that the closeout of a grant or other agreement is the process by which the sponsoring agency determines that all applicable administrative actions and required work of the agreement have been completed by the University and the sponsoring agency. The date of completion is the date on which all work under grants and other agreements is completed or the date on the award document, or any supplement or amendment thereto, on which sponsorship ends.

Each grant shall be closed out as promptly as is feasible after expiration or termination. In many cases, the way in which close out procedures are handled, such as timely submission of final reports and the quality of these reports, can have a direct impact on chances for future funding. As the ending date approaches, Research Services, the Research Accounting office, Research and Service Foundation, and the Principal Investigator ensure that all agency specific and university requirements have been met and all necessary records are in the file for each project.

Closeout and Audit Responsibilities

In compliance with 2 CFR 200.33 and Georgia Board of Regents, Research Services maintains records pertaining to each award for seven years after the date of submission of the final expenditure report and has a process in place to make these records available for review upon request by the funding agency, its inspector general or Comptroller General of the United States when applicable as well as the institution’s internal and state auditors for purposes of single audit.

Closeout and Audit Procedures

Closeout documentation and record keepingResearch Services ensures any specific instructions provided in the awarding agency on closeout procedures, e.g., disposition of government owned equipment, and any other documents specifically pertaining to the closeout of the grant are adhered to and included in the grant file. Research Services ensures that the official grant folder includes preward documents, post award documents i.e., executed subawards and any after-the-grant documents i.e., audit reports. 
Site VisitsResearch Services participates and/or take the lead in programmatic and business management performance reviews by the Program and/or Grants Official. 
Georgia Department of Audits and Accountshttps://www.audits.ga.gov/SGD/single_audit.html 
Single Audit Report –USG Finance and Business: Auditing (7.9)https://www.usg.edu/policymanual/section7/C474 
USG Records Retention Schedules: Category Researchhttps://www.usg.edu/records_management/schedules/932

Closeout and Audit Policy Resources

Accrued Annual Payout – Payroll Policy – FS-PR-1402-01

When an employee with accrued annual leave separates from Georgia Southern University (or transfers to a position ineligible for annual leave accrual), they are eligible to receive compensation for accrued hours, up to the maximum of 360 hours, based on their regular rate of pay at the time of separation.

VPO payments are processed in the pay period following the pay period in which the employee terminates. If the employee has outstanding obligations owed to the University, their VPO is reduced by the amount due. If VPO is not sufficient to cover the cost of outstanding obligations, the terminating employee will be invoiced. The University System of Georgia collections procedure will be implemented for any unpaid balances due.
The VPO payment is charged to the budget where the employee is permanently assigned at the time of separation with the exception of grant funded positions where accrued annual leave payout is charged to a designated alternate funding source. For grant funded positions, the Principal Investigator and Department Chair provide the funding and charge location on the termination/transfer PAF (Personnel Action From) in the comments section. Alternate funding sources may be the Departmental Educational and General (E&G) budget or the F&A (Indirect) Cost budget.
In situations where an employee is terminating from Georgia Southern University to accept employment with another State of Georgia agency which allows the transfer of accrued annual leave, the employee must notify Human Resources in writing when resignation is submitted. The terminating PAF must note in the comments section the amount of accrued annual leave to be transferred. The hours to be transferred will be deducted from the total accrual, with any remaining balance paid to the employee.
Please see the Board of Regents Policy 8.2.7.1 on transfers to other institutions.
Closeout of Sponsored Awards Policy – RSSP-501Award closeout is the final stage of a funded project. As the award recipient, the university has the responsibility and obligation to close and to submit necessary technical and final reports. Proper closeout of an award is also important for audit purposes.

Close Out Responsibilities
Principal Investigator (PI)             
Informs the RA about any problems related to expenses, management, or budget before the project’s end date;
Submits all documentation for expenditures to the RA by the deadline;
Ensures that the project does not incur a deficit, defined as total expenditures and outstanding commitments exceeding the total amount budgeted;
Ensures that cost-shared resources have been allocated to the project;
Submits the necessary technical reports and meets any other technical or programmatic requirements of the award or agreement; and
Submits all programmatic reports to the sponsor in accordance with the terms and conditions of the award.
Research Accountant (RA) – Office of Research Accounting (ORA)
Contacts the PI or department administrator to determine whether any expenditures have not been processed;
Notifies the PI at 90, 60 and 30 days prior to the end date to determine the necessity of no-cost extensions, supplemental funding requests, or other updates per the PI and funding agency.
Ensures that expenditures are reasonable, allowable, and allocable;
Assists the PI in resolving any outstanding items;
Works with the PI and/or department administrator to minimize last-minute adjustments before the final report/invoice is due to the Research and Service Foundation (RSF);
Coordinates adjustments or transfers with the PI and/or department;
Prepares adjustment/transfer forms for the deficit and coordinates with the RSF;
Runs a closeout report to ensure expenditures match revenue;
Reviews the Accounts Receivable Aging report with the RSF;
Deactivates the project in the PFS after confirming all receivables have zero (0) balance;
Notifies the RSF of any unusual university financial reports or invoicing problems and/or deadlines (e.g., year-end invoicing delays);
Posts all expenses to the project before the final invoice or financial report is submitted to the sponsor.
College/Academic Department or Responsible Unit
Assumes responsibility for budgetary over-expenditures on the part of the PI;
Assumes responsibility for disallowed costs incurred by the PI; and
Approves adjustments/transfer by the signature of the PI or a department official.
Research and Service Foundation (RSF)
Prepares and submits all invoices and financial reports to the sponsor by the deadline;
Contacts the RA before submitting the final report/invoice to confirm that all transactions are posted in the PFS;
Ensures that all cash is collected on the final invoice and the financial report has been submitted; and
Submits financial reports to the sponsor in accordance with the terms and conditions of the award.

See more details on closeout procedures here.
Federally Sponsored Effort Documentation Policy – FS-RA-2103-01The purpose of this policy is to establish guidelines and procedures for documenting personnel (faculty, staff, and students) charged to federally sponsored grants and contracts.

Procedures
The OMB Uniform Guidance, 2 C.F.R. Part 200.430, paragraph (i) states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. This code sets forth standards for documentation of personnel expenses charged to Federal awards.
Research Accounting prepares and distributes effort certification reports via email to the PI for salaries and wages charged to federally sponsored grants and contracts either as a direct charge or as a cost shared commitment. These reports are based on payroll records and are distributed within forty-five (45) days following the end of the Spring and Fall semesters and within sixty (60) days following the end of the Summer semester. The reporting periods are as follows:
●  Fall Semester – August 1 through December 31
●  Spring Semester – January 1 through May 31
●  Summer Semester – June 1 through August 31

Other reporting time frames will be taken into account if required by sponsoring agencies.

Included in this process are salaries paid to faculty, administrative professionals, bi-weekly paid staff, graduate assistants (GAs, RAs, TAs), and bi-weekly or monthly-paid temporary staff. Also included in this process is any overload salary paid or extra compensation paid for University commitments. Extra compensation paid for incidental work that is in excess of base salary is included in the effort calculation to ensure consistency in reporting.

Effort reports reasonably reflect the percent distribution of efforts expended by these groups on federally funded grants, contracts, and cooperative agreements and account for 100% of an employee’s actual effort for the given time period. Any deviation in reported effort of greater/less than 5% should be reported to the Office of Research Accounting for review and correction.

The recipient of an effort report should certify his/her own effort report unless the employee is no longer available to certify. In this event, the Principal Investigator, or a person with direct knowledge of the employee’s workload, must certify the report. Effort reports should be returned to Research Accounting within thirty (30) days of receipt. Research Accounting accepts original signatures returned via campus mail, approved and scanned reports via email, or in the instance that the faculty and staff are away from campus, an emailed approval from the faculty or staff will be accepted and attached to the effort report.

Reminder emails are sent to the PI by Research Accounting staff when reports are not received within thirty (30) days. If effort reports are not received within forty-five (45) days, the delinquent reports are referred to the Department Chair and College Dean of the respective employee’s department.
Any effort reports that remain uncertified upon distribution of reports for the next reporting period are subject to additional scrutiny, and the salary portion that was charged to any federal source will be reallocated to alternate funding.

The alternate funding will be applied in the following order of availability:
(1)  Principal Investigator F&A account
(2)  Departmental F&A Account
(3)  College’s F&A Account
(4)  Other Departmental Budgets
Labeling File Containers Policy – FS-RM-4102-01The purpose of labeling file containers with exact series title and disposition instructions is to reduce the problem of identification of files and implementation of disposition instructions. A file folder, cabinet or other container properly labeled reduces the chances of making a mistake several years later and prematurely or accidentally disposing of important records.

Procedures
File Folder:
File folder labels will bear the appropriate file title and should be typed or written on the file to prevent lost and/or misfiled files due to lost labels.

File Drawers:
Color-coded folders may be used to identify specific file series.
When an entire file drawer consists of a single series of records the drawer will be labeled with the file title, inclusive dates of the records in the drawer and instructions for their disposition. Additional file drawers consisting of the same file series need only a brief identification of the material in the drawer and the inclusive dates of the records contained therein.

The label will be affixed to the front top center of the drawer.

File Cabinets:
When an entire file cabinet consists of a single series of records the cabinet will be labeled with the file title, inclusive dates of the records in the cabinet and the instructions for their disposition. Additional file cabinets consisting of the same file series will be labeled in the same manner.

The labels will be affixed to the front top center of the cabinet.

Other Containers:
Containers such as boxes, shelving or transfer files will be labeled in the same manner as file cabinets.
The label will be affixed in a conspicuous position on the front or side of the container.
Records Retention Policy – FS-RM-4101-01The University has established a University Records Center (URC) for the storage of official University records. The purpose of this policy is to address the responsibilities of records management and specifically the destruction of records.

O.C.G.A. 50-18-90 through 50-18-121 “the Georgia Records Act” establishes guidelines for the establishment of retention schedules, the duties of agencies with regards to records management and access to records.
The University shall follow the records retention schedule set forth by the Board of Regents. Once records have met all required retention in accordance to the BOR retention schedule, destruction procedures are implemented.

The University Records Management Officer (URMO) shall establish and coordinate a University Records Management Program. This individual shall be responsible for the following:
Managing the overall operation of the URC.
Working with University departments to ensure that records are handled in a manner which follows
established State and Board of Regents guidelines.
Maintaining a file of Record Control Cards for materials stored at the URC.
Maintaining a file of Records Destruction.
Ensuring that the URC web page contains current information regarding procedures for records handling
and links to the most current retention schedules.
Destruction of records stored in the URC once the BOR records retention schedule has been met.
Departments will be notified in advance of said destruction.
Updating and reviewing applicable standards and policies.

Each Department Head or Budget Unit Director shall be responsible for the following:
Working with the URMO to ensure an orderly and detailed transfer of records to the URC.
Maintain departmental copies of all records transfer documentation.
Ensure that only legitimate University records are transferred to the URC.

Records covered under these schedules and other records as may be approved by the University will be maintained either in each department or transferred to the University Records Center for safekeeping during the remainder of time specified in the retention schedules.
Departments and the URMO in consultation with the Dean of Libraries will jointly determine if any records have archival value. These documents will be transferred to the University Library.
Reports and Deliverables for Sponsored Projects – RSSP-404-02This policy defines the responsibilities of the principal investigator (PI), Research Services (RS), and the Georgia Southern University Research & Service Foundation (GSURSF) with respect to reports and deliverables required by the funding agency.

Procedures
For technical reports and deliverables, the PI will provide the Research Services with one copy of the following (as applicable) for the official project file:
all progress reports;
deliverable confirmations;
final technical report; and
the submittal letter or email to the funding agency.
The GSURSF will place a copy of each financial or other nontechnical report in the official project file.
Residual Balance Policy – RSSP-502This policy establishes an institutional procedure for residual revenue earned on restricted fixed-price or fee-for-service contracts: (1) timely and appropriate use; (2) compliance with sponsor policy and restrictions; and (3) approval and documentation of further expenditures.

Procedures
Upon full closeout, the GSURSF will transfer residual balances over $500 earned on a fixed-price/fee-for-service contract to a departmental or center sponsored program residual balance account. The Vice Provost for Research must approve residual balances over $10,000, or 20% of the approved project cost whichever is greater.
The PI/PD must complete the Residual Balance Transfer Form and provide written justification.
The form must be signed by the PI/PD and the dean and forwarded to Research Accounting for approval.
After Research Accounting approves, the form will be submitted to the VPR or final review/approval,
if required.
Before residual funds are transferred to the department, center, or fiscal unit, the F&A rate is calculated on
the total award amount and deducted from the residual funds.
• In the case of multiple PI/PDs or Co-PI/PDs, the residual balance is distributed to the department,
center, or fiscal unit involved in the project in the same proportion as their aggregate F&A recoveries
were distributed for the fixed-price/fee-for-service contract.
• Before the account is extended or funds transferred, the residual balance will be used to cover any cost
overruns (deficits) accrued by the same fiscal unit director on other internal or external restricted accounts.

Last updated: 7/28/2020