Type of Policy
Administrative
Policy No
3.11
Effective Date
Last Revised
Review Date
Policy Owner
Office of Grants and Contracts Accounting
Contact Name
Josh Rosenberg
Contact Title
Senior Director, Grants and Contracts Accounting
Contact Email
josh.rosenberg@business.gatech.edu
Reason for Policy

This policy summarizes the review process to financially close sponsored awards in the accounting records of the Georgia Institute of Technology in accordance with close-out requirements mandated by Federal regulations, including the Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200), sponsor requirements, and award terms and conditions.

Policy Statement

The Office of Grants and Contracts Accounting is charged with the financial close-out of sponsored awards in the accounting records of the Georgia Institute of Technology for sponsored activity in Resident Instruction (RI), Georgia Tech Professional Education (GTPE), and the Enterprise Innovation Institute (EII).

 

Scope

All employees engaging in sponsored research activity.

Policy Terms

Matching/Cost Sharing Funds
The Institute's contribution to an externally funded sponsored award when contractually obligated for awards accepted by the Office of Sponsored Programs (OSP) in the name of Georgia Institute of Technology or the Georgia Tech Research Corporation.

Procedures

The Office of Grants and Contracts Accounting, in collaboration with financial representative in the campus units, is responsible for the financial close-out of sponsored awards in the Institute's accounting records for both external sponsored awards and restricted gift allocations funded by the Georgia Tech Research Corporation. Steps taken to complete the financial close-out process are as follows:

  1. Personnel in the Office of Grants and Contracts Accounting may review expenditures and obligations allocated to sponsored awards period of performance. The review may include, but is not limited to, review of transactions to ensure expenditures are within sponsor guidelines established in the award document and in compliance with applicable laws and institutional policies, including the Federal Government’s Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200).
  2. G&C personnel responsible for award close-out will work collaboratively with the campus unit financially responsible for the prime award. Any unrecorded activity must be verified by the G&C personnel as allowable in order to include those costs and/or unliquidated obligations in a financial report or final billing to the sponsor.
  3. In accordance with 2 CFR 200.344, the non-Federal entity 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. This deadline may be extended based on requirements for specific sponsors or contract terms and conditions that indicate a due date other than 120 days after the performance end date.
  4. Grants and Contracts Accounting personnel are responsible for monitoring awards which have been financially closed with the sponsor but have outstanding action required by campus units. Until all internal adjustments are complete, the sponsored award will not be inactivated in the accounting records.
  5. At the time final payment from the sponsor is received and all internal actions have been processed (i.e., transfer of overrun costs to a discretionary funding source) in the accounting records, the Office of Grants and Contracts Accounting inactivates the award in the Institute's accounting records.

Fixed-price Sponsored Projects
Fixed-price sponsored awards will be closed in same manner as standard cost-reimbursable awards. In accordance with 200.201 (b)(3) of the OMB Uniform Requirements (2 CFR 200), written certification that the project or activity was completed or the level of effort expended must be obtained. If the required level of effort or activity was not carried out, the amount of the award must be adjusted.

The PI Fixed Price Close-out Certification must be completed and submitted to Grants & Contracts Accounting for review. After certification, immaterial residual balances (if any) remaining on fixed price awards will be transferred to a departmental GTRC allocation, net of applicable F&A expenses, to be managed by the Chair/Director of the department.

Frequently Asked Questions

Please refer to the Grants and Contracts Accounting web site at www.grants.gatech.edu for additional information

Responsibilities

Principal Investigators, assigned delegates, and unit financial officers are responsible for providing proper oversight and management of sponsored awards during the performance and close-out periods.

Valuation and disposition of equipment and supplies, including computing devices, must be managed in accordance with 200.313 “Equipment” and 200.314 “Supplies” of the OMB Uniform Requirements (2 CFR 200).

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
09-09-2021 Office of Grants & Contracts Accounting Updated to align with 2 CFR 200, editorial updates to align with new financial system
10-01-2015 Office of Grants & Contracts Accounting Revise close-out process for Firm Fixed Price awards
11-05-2014 Office of Grants & Contracts Accounting Align with requirements of 2 CFR 200
04-01-2014 Office of Grants & Contracts Accounting Administrative review