4.1. Federal Award Closeout
According to Uniform Guidance (2 CFR 200), the university is expected to submit final financial, programmatic, and property reports no later than 90 to 120 days per the award after the end of the period of performance for federal awards although some sponsors stipulate different closeout deadlines. Sponsors determine the reporting requirements based on where title to property acquired with award funds vests. On federal awards, title may vest with the university or with the Government. The property closeout process for federal awards is described below:
University Titled Property:
A federal sponsor may vest title to the university under the award terms as unconditional and exempt from further obligation or as conditional. When title is vested unconditionally to the university, the federal sponsor may still require a final property report, which will be completed by OCG.
When the university has conditional title, OCG completes and submits a final listing of all reportable property acquired with award funds. To complete the final property report, OCG reviews the Department Closeout Property Report (DCPR), property management systems, and the award record. After the university submits a final property report, the federal sponsor has up to 120 days to request a return of the conditionally titled property. During this period the university generally requests title to the property. If the university no longer needs conditionally titled property for other federal awards, the university may be required to reimburse the federal sponsor, depending on the current value of the property. If the sponsor does not respond within the 120-day time limit, title to the property transfers fully to the university without further obligations to the Government.
Government Titled Equipment:
A federal sponsor may retain title to property acquired with award funds and at closeout the university is required to complete a final property report and request disposition instructions. To complete the final property report, OCG reviews the Department Closeout Property Report (DCPR), the award record, and the Government property records. OCG reconciles with the award financials and discusses with the department preferences for disposition. Government titled property cannot be disposed or used on another sponsored award without authorization from the sponsor.
A closeout inventory is conducted to ensure all items associated with that award are accounted for. This inventory is conducted 30 days before the project end date to ensure the final report is submitted timely.
After receiving the final property report and disposition request, the sponsor and the ACO will provide one of the following disposition instructions to the university:
- Title to property is transferred to the university.
- Title to property remains with the Government, accountability for the property is transferred to another federal award, and the Government property remains under university control.
- Title to property remains with the Government and the university must return the property according to the sponsor’s instructions.
National laboratories are not considered federal agencies and do not have authorization to donate Government titled property to the university. When Government titled property is accountable on an award sponsored by a national laboratory, the university must either return all Government property to the national laboratory or request that the Government property be transferred to another active award.