Finding Text
Item No. 2025-003 – Period of Performance Compliance Applicable to: Research & Development (ALN 47.076) Criteria In accordance with the White House Compliance Supplement, allowable costs must be incurred within the established period of performance unless otherwise authorized. Costs incurred outside the grant period must be explicitly permitted under the terms of the award. Condition Testing identified four instances in which disbursements were made after the award’s estimated end date. Cause The University did not process or draw down funds in a timely manner upon completion of project activities. Effect Delayed disbursement of funds results in noncompliance with federal requirements governing the period of performance. Questioned Costs None.Recommendation Management should strengthen controls to ensure timely processing and drawdown of funds within the applicable grant period. Ongoing monitoring procedures should be implemented to ensure compliance with federal requirements. Views of Responsible Officials Management concurs with the finding. Management acknowledges the instances identified in which disbursements were processed after the award's period of performance. While no questioned costs were noted, the University recognizes that timely processing of expenditures and drawdowns is critical to ensuring compliance with federal requirements governing grant periods. To Strengthening Grant Closeout Procedures management will establish a formal grant closeout timeline to begin 90 days prior to the award end date, require principal investigators (PIs) and grant administrators to review all outstanding obligations and ensure timely submission of final expenses and implement a standardized closeout checklist to confirm all costs are recorded within the allowable period To Enhanced Monitoring of Grant Periods management will develop and maintain a centralized tracking system for all federal awards, including start and end dates, generate monthly reports identifying grants nearing expiration (within 90,60, and 30 days) and distribute reports to PIs, Grants Accounting, and Finance leadership for proactive management. For timely processing and drawdown controls management will require all invoices and expenditures to be submitted within a defined timeframe (e.g., within 30 days of service or project completion), establish internal deadlines for processing disbursements and drawdowns prior to the grant end date and implement a review step within Grants Accounting to verify that expenses fall within the period of performance before payment is released. The grants department will conduct mandatory training for PIs, grant managers, and finance staff on period of performance requirements and federal compliance expectations and reinforce accountability for timely submission and processing of expenditures Management will also put in place for any costs identified outside the period of performance will require, documented justification, review and approval by the Director of Grants Accounting and CFO, and verification of allowability under award terms or sponsor approval, if applicable.