1301 Sponsored Projects Financial Reporting and Financial Closeout
Scope and Purpose
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, business support unit, and the Office of Sponsored Projects (OSP).
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.
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 OSP to prepare interim financial reports, final financial reports 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 OSP to sign and submit all financial reports to the sponsor on behalf of the institution. On rare occasions and with the approval of OSP, financial reports may be submitted to the sponsor by the department or business support unit in collaboration with OSP 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 department business office, or business support unit is required to prepare the required detailed information and submit to OSP.
The PI, business office, or business support unit must certify interim draft financial reports and submit them to OSP within the period specified by OSP. In cases where draft interim financial reports are not returned within the specified period, the financial report will be certified by OSP and submitted to the sponsor based on University’s financial records and without departmental or business support unit approval.
Department business offices or business support units considered to be the responsible organization and owner of an Award will review and verify a draft of the final financial report. They are responsible for communicating changes and providing additional information or documentation to OSP, and return the final draft financial report, certified by the department business office, business support unit or PI to OSP. In cases when the draft final financial report is not returned to OSP as instructed, OSP will submit to the sponsor a certified final financial report based on University’s financial records without departmental or business support unit approval.
Except in unusual circumstances, the University will not file final financial reports which indicate unliquidated obligations or commitments. As stated in the NIH Grants Policy Statement, “Final FFRs must indicate the exact balance of unobligated funds and may not reflect any unliquidated obligations.” Any unique circumstance that may require a final financial report to be filed with unliquidated obligations or commitments must be approved in advance by OSP.
Under certain and rare circumstances a revised final financial report 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 final financial report 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 final financial report must be approved by the PI and business administrator (or designee), and sent to OSP for approval. A revised final financial report 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 final financial report may call into question the veracity of the original final financial report, University’s certification of that report, internal controls and financial management of its sponsored awards.
After the final financial report is filed with the sponsor, and all financial obligations satisfied, OSP 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. OSP uploads a copy of the signed and submitted final financial report to the University’s financial accounting system.
Roles and Responsibilities
- Reviews financial reports with their department business office 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 department business office or business support unit to ensure expenditures benefit the project and permitted in accordance with the terms and conditions of the sponsored award and University policy.
Department Business Office or Business Support Unit
- Ensures timely certified draft financial reports are provided to OSP 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 OSP.
- Assists OSP 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.
Office of Sponsored Projects – Financial Management
- Notifies Department Administrator or Business Support Unit of expiring sponsored awards.
- 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 final report submission date.
- Deactivates 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.
Reviewed for Workday purposes 5/25/2017.