First Notice

When reports are coming due or recently overdue, including initial closeout requests, Sponsored Projects will forward the request to the PI and department administrator. Sponsored Projects will provide guidance, as applicable, for completing the request and any relevant information provided by the sponsor. 

Second Notice

At the first follow-up request from the sponsor or when reports are delinquent, Sponsored Projects will forward the request to the PI and department administrator and copy the department chair or center/institute director. In cases in which a PI departs Brown University without completing final deliverables, the department or center/institute remains responsible for submitting all reports and for responding to audit questions should they arise.  

Third Notice

With further follow-up requests or when the University is being warned of punitive/corrective agency actions, Sponsored Projects will forward the request as outlined under Second Notice and copy the Vice President for Research and Associate Vice President for Research.  Seriously delinquent report requests and potential adverse sponsor actions may also be shared with deans and the Provost. 

At this stage, the University may exercise its own remedies and corrective actions.

Exceptions to procedural due dates will only be granted when presented in writing no later than five business days prior to the date that the certified rough draft report is due back to Sponsored Projects. Such exceptions will be considered only in extenuating circumstances and may require Sponsored Projects staff to request sponsor approval for extension of the reporting deadline.

Examples of extenuating circumstances include:

• Failure of another department to take action (e.g., on a properly submitted payroll adjustment request or service center charges)
• Failure of a subcontractor to issue a final invoice in a timely manner, when evidence of attempts to obtain the invoice exists
• Systemic errors that impact processing of adjustments to the general ledger

If a request for an extension to the due date is not communicated to Sponsored Projects’ Post-Award team within five business days, the allowable expenditures reflected on the Workday ledger on the award end date or budget end date will be used as the official document for completing the financial report/invoice. At this point, adjustments processed after the award performance or budget period are not permissible and will not be included on the report submitted to the sponsor.

To identify awards expiring within 30 to 60 days, refer to the “Awards Expiring in 90 Days” report located on the Grant Management Dashboard (i.e., PI Dashboard) in Workday.

Department Staff Actions

Thirty to 60 days before the award end date or budget end date (for annual reports), department staff should submit the required paperwork for a no-cost extension, if applicable, via email to their Pre-Award grant and contract administrator in Sponsored Projects. Department staff also should remind any subawardees of the due date for the final invoice.

If a no-cost extension will be requested to extend the performance period of an award without adding additional funding, the PI or department administrator should confirm the advance notice requirements in the award document, as some sponsors require more than 30 days notice before the current end date or budget period (for example, the National Science Foundation (NSF) requires that requests for a second no-cost extension be submitted 45 days before the current end date).

Post-Award Team Actions

Within 30 to 60 days of the award end date, the Post-Award team in Sponsored Projects will review the award notice, terms and conditions and general ledger expenditures in preparation for financial reporting. The Post-Award team will prepare a financial rough draft and review financial activities for potential compliance items and questions for follow-up with the department. They also will verify overhead posting and prepare and process overhead journal adjustments if necessary.

Department Staff Actions

Up to 30 days after an award end date or budget end date (for annual reports), department staff should complete the following steps, as applicable.

1. Thoroughly review the award financial record in Workday to ensure all outstanding expenses are posted in the general ledger (e.g., expense reports, service center billings, subcontract invoices, supplier invoices). 
2. Process any outstanding cost transfers.
3. Inform your Post-Award contact if a no-cost extension will be requested, if a request was not previously submitted to the Pre-Award team.
4. Work with the Controller’s Office to make sure fabricated equipment is capitalized and tagged appropriately.
5. Journal off any over-expenditures from the award prior to submitting the certified rough draft report to your Post-Award contact.
6. Confirm that the actual cost share amount reflected on the Sponsored Budget to Actuals Financial Record and/or Effort Certification Report match the cost share committed amount. Process adjustments if necessary. Cost-shared expenses must be verifiable on these records for financial reporting or closeout.
7. For training grants, reconcile stipend and/or tuition payments for each trainee to ensure accurate amounts are posted to the general ledger.
8. Confirm any deliverables required at the end of the project, including the status of programmatic deliverables with the PI (e.g., final technical reports).
9. Notify Sponsored Projects of any extenuating circumstances that may prohibit the final financial report from being submitted to sponsors (federal or nonfederal) on time or that may prohibit cash being drawn by letter of credit before the sponsor deadline.

Post-Award Team Actions

The Post-Award team in Sponsored Projects will submit an initial rough draft of the final financial report to the PI and/or department within 30 days after the end date of an award or budget period (for an annual report) to begin the process of confirming final expenditures. Sponsored Projects prioritizes the completion of rough draft financial reports to departments in the order of earliest due date to sponsor (30, 60 or 90 days).

Thirty-one to 75 days after an award end date or budget end date (for annual reports) — between an award’s end date and the sponsor’s deadline — department staff should expect ongoing communication with the Post Award team in Sponsored Projects about due dates, deliverables, drafts and other items related to final financial reporting. 

Department Staff Actions

Within this time period (31-75 days after award or budget end date) department staff should complete the following steps, as applicable.

1. Complete and submit a certified rough draft financial report to Post-Award along with supporting documentation of adjustments processed after the performance period and/or the operational transaction number.
2. Submit supporting documentation and justification for questionable charges highlighted by Post-Award on the rough draft financial report.
3. Confirm that all encumbrances, purchase orders and payroll costing allocations processed against an award have been zeroed out, closed or ended.
4. Ensure grant worktags are removed from active grant listings maintained by other service departments and laboratories.
5. Confirm submission of the final invoice from any subawardees and complete subaward closeout certification.
6. Remove overruns (overdraft) from the award.

Department Staff Actions

Seventy-five to 85 days after an award end date or budget end date (for annual reports), or approximately 10 business days before the report is due to the sponsor, department staff should ensure nonfinancial deliverables and reports (e.g., annual progress and technical reports) are completed and submitted to sponsors and forward confirmation to the Post-Award team.

Post-Award Team Actions

Within this time period (75 to 85 days after award or budget end date) the Post-Award team will review certified rough draft financial reports and supporting documentation submitted by the department and reach out to department staff for additional information or clarification as needed. 

The Post-Award team will ensure all allowable and legitimate adjustments reflected on the rough draft financial report are posted to the ledger and complete the financial report/final invoice along with other deliverables, as applicable before submitting the report for review and approval by the signing officials.

Late Submissions

If department staff do not submit a certified rough draft financial report in a timely manner, Post-Award staff will use the Sponsored Award Budget to Actuals report as the supporting documentation for completing financial reports. Adjustments processed by the department after the award performance period are not permissible at this point and will not be included on the report submitted to the sponsor.

Eighty-six to 90 days after an award end date or budget end date (for annual reports), or approximately five days before the final report is due to the sponsor, the Post-Award team will submit a final financial report or final invoice to the sponsor, according to the terms of the award. 

The Post-Award team will also take the following actions, as applicable:

• Submit nonfinancial reports
• Request a final draw
• Prepare the award for inactivation in Workday
• Transfer any remaining outstanding overruns (overdraft) to the cost center associated with the grant
• Verify that the PI has submitted programmatic/technical reports to the sponsor
• Complete and submit an invention report to the sponsor

Within 30 days after the report has been submitted to the sponsor, Sponsored Projects will update the award record status in Brown’s grants management system from Active to a closeout status, as applicable (e.g., Closed, Final Report Pending, Final Payment Pending). 

Sponsored Projects also will request the inactivation of the grant and award hierarchy in Workday and prepare the award folder for transfer to an off-campus storage facility.