Common Reporting Questions
Sponsors expect that reports will be submitted on or before the due date. Failure to provide reports on time may result in consequences such as sponsors not providing future funding increments. In some cases, the sponsor will also not process any new awards to a PI with a delinquent report. Any technical and/or progress reports considered overdue by the sponsor require immediate attention to avoid sponsor penalties.
In addition to sponsor actions, OCG may implement corrective actions as outlined in the Sponsored Projects Progress and/or Technical Reports procedural statement.
No, the PI should not sign any documents (including research performance reports) that require signature from an authorized University official or contain certifications or representations on behalf of the University. If this type of signature is required on a project report, the PI should provide the report either through the sponsor’s online system, if applicable, or via email to firstname.lastname@example.org. If the report is for financials, the appropriate Grant Accountant will be able to assist with the submission of these reports.
Sponsors may or may not authorize the submission of a late report, but the request must be made before the report becomes late. If for some reason the report cannot be submitted on time, please contact OCG Compliance by sending an email to email@example.com with your request and justification for why you would like to request an extension to the reporting timeframe, but please keep in mind that this request will not always be approved.
All required reports, including technical and final reports, should be retained in infoEd. When reports are stored in infoEd responsibility transitions from the PI to OCG to produce a copy of the report in the event the sponsor questions CU’s fulfillment of the award. If OCG does not receive a copy of a report, then the PI and that PI’s department assume this responsibility, and will need to retain the document for six years past the inactivation date of all financial accounts of that award, in accordance with CU Boulder’s Records Retention and Management policies.
All reporting requirements for a specific award may be found in infoEd within the Deliverables folder in the Proposal Tracking (PT) record. The due date and submission date are both indicated on this screen.
In addition, a Deliverables report may be pulled using CU-Data. The report may be accessed through Team content>eRA>CU Boulder>Proposal and Award Tracking>OCG/SPA>Deliverables Report. For assistance in pulling a deliverables report or to verify any reporting requirements, contact firstname.lastname@example.org.
Federal agencies have been given the mandate by Congress and the Office of Management and Budget to close awards per Federal requirements. In addition, both NIH and NSF have been audited since 2013 with recommendations to take appropriate actions to ensure performance reports are submitted on time. Consequently, many agencies are continually improving their capability to track outstanding obligations and are making warnings or taking steps of disciplinary action against individual PIs and the University because of unfulfilled obligations. Prior to 2014, OCG had seen this type of sponsor response only in rare and extreme situations. It is now common practice.
Completion and submission of performance reports within the sponsor deadlines are the primary responsibility of the lead Principal Investigator (PI) because these reports capture the achievements of the research and progress according to the scope of work. OCG helps ensure compliance with the reporting requirements by tracking the submissions of the reports, not by submitting the reports on behalf of the PI. In some cases, OCG does assist with the report submission (see the "How To" Guide for Reporting Requirements tool). However, it is understood by most sponsors that the PI will complete and submit the required performance reports. Those sponsors have designed their submission systems with the understanding that PIs, not the central administrative offices, would complete and submit the performance reports.
Property purchased with sponsored projects funds is managed by the OCG Compliance Property Officer, and that person will submit any required property reports to the sponsor. If you have questions, contact OCGProperty@colorado.edu or call Thao Tsuda at 303-735-8963.
Extending the end date of a project will generally change the due date of the final report. Whether an additional annual report is required is dependent on the sponsor and/or the award terms.
NSF requires an annual progress report for the prior year if a no-cost extension is approved. NSF allows you to submit an extension request in as little as 10 days before the period of performance ends, which means there can be very little time between the no-cost extension approval and the previous year’s annual report due date. The day the extension is approved is when the reporting requirement is made available in Research.gov. There is no leniency to the due date once the extension is approved because the system adjusts the dates based on the period of performance and terms of the award. To avoid this potential issue, submit NSF no-cost extension requests as soon as the need is known to reduce the risk of last minute reporting needs.
For other organizations, updated reporting due dates may be identified in the award modification. If you have questions regarding reporting requirements, email email@example.com.
OCG tracks the due dates and submissions of award deliverables for all sponsored awards on the Boulder campus to help ensure campus compliance with sponsor reporting requirements. Past due reports place the University's future funding at risk. OCG has received notices from Federal sponsors saying they have blocked particular awards and have also delayed processing certain requests because of non-compliance due to delinquent reporting.