1301 Sponsored Projects Financial Reporting and Financial Closeout

Policy Sections

1301.1 Financial Reporting – Sponsored Projects Financial Administration (“SPFA”)

1301.2 Financial Reporting – Special Reporting

1301.3 Interim Financial Reporting – Principal Investigator, Business Offices, and Business Support Units

1301.4 Final Financial Reporting

1301.5 Revised Final Financial Reports

1301.6 Closing Sponsored Awards

This policy applies to all sponsored awards received by Yale University and informs the Yale community of its compliance obligations to sponsors regarding its reporting requirements for both interim and final financial reporting.

Yale University shall submit financial reports to its sponsors supporting research and other scholarly activities that:

• Accurately reflect the use of sponsored funds as recorded in the financial records of the University; and
• Are in compliance with the sponsor’s terms and conditions.

Achieving compliance with this policy is a shared responsibility involving the Principal Investigator’s (“PI”), Departmental Business Office (“DBO”), Business Support Unit, and Sponsored Project Financial Administration (“SPFA”).

Financial Report

A financial report (e.g., Federal Financial Report (“FFR”), invoice, etc.) is an accounting of expenditures and obligations incurred during the period of performance and/or at the conclusion of the sponsored project.  The financial report reflects the University’s official accounting records.

Financial Closeout

The process at the end of a sponsored award by which the University completes any required accounting to the sponsor and prevents any further expenses from being incurred on the sponsored award.

It is the responsibility of Sponsored Project Financial Administration (“SPFA”) to prepare interim financial reports, FFRs, and invoices based on institutional financial records, while ensuring expenses are in accordance with the terms and conditions of the sponsored award and University policies.  Additionally, it is the responsibility of SPFA to sign and submit all financial reports to the sponsor on behalf of the institution.  On rare occasions, and with the approval of SPFA, financial reports may be submitted to the sponsor by the department or business support unit in collaboration with SPFA to ensure the receivable is properly recorded and payment is tracked and collected.

The University’s financial accounting system compiles and reports financial data based on major budget categories.  Certain sponsored agreements, however, may require additional detailed information.  In such cases, the responsible DBO, or business support unit is required to prepare the additional detailed information requested and submit to SPFA.  

The PI, DBO, or business support unit must certify interim draft financial reports and submit them to SPFA within the period specified by SPFA.  In cases where draft interim financial reports are not returned within the specified period, the financial report will be certified by SPFA and submitted to the sponsor based on the University’s financial records and without departmental or business support unit approval.

DBOs or business support units considered to be the responsible organization and owner of an Award will review and verify a draft of the final Federal Financial report (“FFR”).  They are responsible for communicating changes and providing additional information or documentation to SPFA, and for returning the final draft FFR, certified by the DBO, business support unit or PI to SPFA by the Institutional Due Date (“IDD”).  In cases when the draft FFR is not returned to SPFA as instructed, SPFA will submit to the sponsor a certified final financial report based on the University’s financial records without departmental or business support unit approval.

Except in unusual circumstances, the University will not file FFRs which indicate unliquidated obligations or commitments.  Any unique circumstance that may require a final financial report to be filed with unliquidated obligations or commitments must be approved in advance by SPFA.

Under certain and rare circumstances, a revised final FFR may be necessary to submit to the sponsor.  Such cases may include a credit to expenditures thereby benefitting the sponsor or the inclusion of a legitimate expenditure appropriate for the sponsored award.

Note: Some sponsors may not require a revised FFR under a certain threshold but rather will require a refund of funds resulting from any reduction in expenses originally reported to and paid by the sponsor.

Requests to submit a revised FFR must be approved by the PI and business administrator (or designee), before sending the FFR to SPFA for approval.  A revised FFR wherein the University claims less in expenditures than what was originally reported is required regardless of timeframe. 

It should be noted that the submission of a revised FFR may call into question the veracity of the original FFR, the University’s certification of that report, internal controls, and financial management of its sponsored awards.

After the FFR is filed with the sponsor, and all financial obligations satisfied, SPFA is responsible for changing the status of the sponsored award in the University’s financial accounting system to “Closed”.  Once the status is changed to “Closed” no further financial activity can occur.  SPFA uploads a copy of the signed and submitted FFR to the University’s financial accounting system. 

Principal Investigator (PI)

• Reviews financial reports with their DBO or business support unit in a timely fashion (preferably monthly) to determine that financial records accurately reflect the use of sponsor funds.
• Collaborates with the DBO or business support unit to ensure expenditures benefit the project and are permitted in accordance with the terms and conditions of the sponsored award and University policy.

Departmental Business Office (“DBO”) or Business Support Unit

• Runs the Sponsored Report Tracking (Award Tasks) – Yale report at least monthly, if not more frequently, in order to identify reports that are coming due.
• Ensures timely certified draft financial reports are provided to SPFA as instructed.
• Runs appropriate reports for sponsored project financial review and closeout. Ensures any required reconciliations or sponsor required forms are completed.
• In collaboration with the PI, prepares request for no-cost-extension or carry forward request to sponsor and submits to the Office of Sponsored Projects (“OSP”).
• Assists SPFA in resolving collection issues.
• Clears all custom commitments in accordance with instructions.
• Clears all overdrafts.
• Retains financial records in accordance with the University’s Records Retention policy.

Sponsored Projects Financial Administration (“SPFA”)

• Monitors the timely closeout of all sponsored awards.
• Ensures all closeout processes are conducted in accordance with sponsor’s terms and conditions.
• Conducts periodic reviews of Facilities and Administrative type costs charged to federal awards.
• Submits reports to sponsor.
• Notifies departments of the FFR submission date.
• Closes an Award once all financial obligations have been satisfied.
• Ensures Yale’s financial accounting system agrees with final reported costs.
• Coordinates financial audits of sponsored projects by federal or other external auditors.
• Facilitates collection disputes.
• Maintains the central post-award financial records in accordance with the University’s records retention policy.