Federal agencies are increasing their attention to requirements for timely grant and contract closeout documentation, including increased notification, enforcement and by imposing delays on new awards for principal investigators (PIs) and/or institutions.
Federal sponsors have long had policies in place to withhold funding from PIs (and/or institutions) with delinquent closeout documentation, so these requirements themselves are not new. NIH, for example, has issued two new notices indicating their increased attention to award closeout documentation.
- In December, NIH announced (NOT-OD-24-047) that starting January 2024, it will send a closeout email notification to PIs 90 days after their project period end date. This is in addition to the reminder emails NIH sends to recipients 10, 120 and 150 days after the project period end date.
- NIH issued a second notice (NOT-OD-24-055) on January 23, clarifying that NIH will now strengthen closeout requirements by initiating unilateral closeouts for all awards that remain delinquent 120 days after the award’s end, and will record the delinquency in the System for Award Management (SAM.gov) which is public and monitored by all agencies. Delinquent awards will remain on this list until all closeout requirements are completed, and entities with awards on the list are vulnerable to other awards being withheld by other federal agencies.
Closeout documents can include Final Research Performance Progress Reports, Final Invention Statements and Final Financial Reports.
All federal agencies, as well as the general public, have access to the SAM delinquency report, and agencies may delay awards to institutions if any delinquencies are noted (not just from their agency).
Timely completion of required closeout reporting must be a high priority for all PIs in order to ensure that UC San Diego does not have awards withheld due to closeout delinquencies.
As a reminder for the UC San Diego research community:
- All final reports for NIH awards are due within 120 days of the project end date and become overdue the next day.
- Sponsors primarily communicate about closeout requirements with PIs; central offices are inconsistently copied on these communications, and may not be aware of outstanding closeout reports.
- Delinquent reports put UC San Diego at risk for corrective actions including withholding of funding. For this reason, we strongly encourage you to be proactive in managing your award closeout requirements.
