A closeout is the final stage of a funded project. One of the many important duties performed by principal investigators, grant administrators, and OSP is the final administrative closeout of grants and cooperative agreements. Preparation for a closeout should begin three months prior to the end date of the grant in order to accurately forecast expenses and to adjust any entries that need to be made. At this time department administrators should also consult with faculty members to determine whether or not an extension will be needed. In order for a NIH grant to be extended twelve months beyond the awarded project period, the following must apply and can be approved by OSP without NIH approval:
- No additional funds are required from the NIH awarding office
- The project's originally approved scope will not change
- Any of the following applies:
- Additional time beyond the established expiration date is required to ensure adequate completion of the originally approved project
- Continuity of NIH grant support is required while a competing continuation application is under review
- The extension is necessary to permit an orderly phase-out of a project that will not receive continued support
The fact that funds remain at the expiration of a grant is not, in itself, sufficient justification for an extension without additional funds to properly finish.
If the PI determines that a no-cost extension is not needed, then there are certain steps that must be taken in order to properly close out an award. These steps must be completed within 120 calendar days after the last day of the final budget period:
- Submission of a Final Financial Status Report
- Submission of a Final Progress Report
- Submission of a Final Invention Statement and Certification
All three of these items can be submitted via NIH Commons.
It is important to remember that unless the grants management officer of the respective awarding agency approves an extension to this 120-day reporting window in writing, VU must submit the final reports within the given timeframe. In understanding the importance of the submission of these documents, please consider and remember NIH's compliance policy regarding closeouts and the implications of being non-compliant:
Failure to submit timely and accurate final reports may adversely affect future funding to the organization and/or awards with the same principal investigator (PI). Accordingly, NIH may impose sanctions on institutions that fail to correct recurring reporting problems. Such sanctions may include restriction of facilities and administrative (F&A) costs, removal of authorities, delay or withholding of further awards to the project or program, removal from participation in NIH-funded awards under the Federal Demonstration Project, and/or designation as a high-risk grantee.
Compliance with these reporting requirements affects not only the PI but also the institution as a whole. Each Notice of Grant Award will specify the terms and conditions.
Pursuant to the new NIH policy (NOT-OD-17-022), effective January 1, 2017, Final Progress Reports will now be submitted in an eRA Commons module that mirrors the submission process of annual RPPRs. This formatting change significantly streamlines and simplifies the submission process in line with already established, regular procedures, with one notable exception: the progress report included in a Type-2 renewal application will no longer take the place of a final progress report, whether or not the application is funded. NIH will now require the submission of an "Interim-RPPR" while the Type-2 renewal application is under consideration. If the Type-2 is funded, the submitted Interim-RPPR will serve as the annual progress report for the previous competitive segment. If the application is not funded, the Interim-RPPR will be considered the institution's final progress reports.
Highlights from the Notice are copied below:
- For NIH, the Final Research Performance Progress Report (F-RPPR) will replace the Final Progress Report (FPR) for closeouts, effective January 1, 2017. [...] Generally, the format will be the same as the current interim/annual RPPR, making it easier for recipients to navigate through the F-RPPR based on familiarity with the existing format of the annual RPPR.
- However, a significant change with the implementation of the F-RPPR is, in order to maximize public transparency, NIH will not maintain the currenty Type-2 policy which, in accordance with NIHGPS Chapter 8.6.2 states that "whether funded or not" the progress report contained in the Type-2 application may serve in lieu of a separate final progress report.
- Therefore, as standard policy, NIH will request that organizations submit an "Interim-RPPR" while their renewal application (Type-2) is under consideration. In the event that the Type-2 is funded, NIH will treat the Interim-RPPR as the annual performance report for the final year of the previous competitive segment. If the Type-2 is not funded, the Interim-RPPR will be treated by NIH staff as the institution's Final-RPPR. For additional information regarding how Type-2 renewal submissions are impacted, please visit NOT-OD-17-037.
- Also, in accordance with NIH's implementation of the F-RPPR, recipients will be required to adhere to the new requirement to report on Project Outcomes. This section will be made publicly available, thus allowing recipients the opportunity to provide the general public with a concise summary of the cumulative outcome or findings of the project (analogous to the Project Summary/Abstract section of the competing application).
All final RPPRs must now be initiated by the PI and routed through the eRA Commons system to OSP for review and submission.