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Financial Reporting/No-Cost Extension

As an institution that receives sponsored funds from various public and private sponsors, the University is obligated to comply with financial reporting requirements set by federal sponsoring agencies and other entities. The University must ensure that all project expenditures are accurately and promptly reported as stipulated in the award terms and conditions.
 
The Office of Sponsored Programs collaborates with the Principal Investigator and Department Administrator to ensure timely completion of financial reporting. Our team interprets and applies fiscal regulations and guidelines to meet the financial reporting requirements of federal, state, university, and private sponsors. We prepare quarterly, semi-annual, and annual reports for required federal agencies and sponsors, which accurately reflect the expenses recorded on the project in our financial system. Timely and accurate submission of these reports is crucial for complying with sponsor requirements and reducing institutional and financial risk to the University.
 
Some agencies may choose to hold back future funding or freeze accounts if any financial or technical reports are not submitted by the deadline. The Federal Financial Report (FFR) must be prepared in accordance with the Uniform Guidance (2CFR 200). Failure to comply with these reporting requirements for a specific grant or contract may lead to the federal agency withholding new awards for the entire campus or suspending payments for costs incurred by the University on other projects funded by the same agency. Therefore, it is crucial for the institution to understand and abide by all mandatory reporting requirements.
 
Federal Financial Reports (FFRs)

A Federal Financial Report (FFR) is a statement of expenditures and obligations incurred during the period of performance and/or at the conclusion of the sponsored project.  The report reflects the University’s official accounting records.  

The Sponsored Programs-Post Award team is responsible for preparing an annual and final financial report based on institutional financial records while ensuring expenses are in accordance with the terms and conditions of the sponsored award and University policies.  Office of Sponsored Programs will sign and submit all financial reports to the sponsor on behalf of the University.  In most cases, the Sponsored Programs-Post Award team can prepare financial reports without direct involvement from the department.  

Upon completion of the financial report, a copy is sent to the department for their records.  The report reflects the unobligated remaining balance, if applicable.

Timing

The Office of Management and Budget Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal awards, 2 CFR 200.343, (Uniform Guidance) states:

  • The recipient must submit no later than 90 or 120 calendar days after the end date of the period of performance all financial, performance, and other reports as required by the terms and conditions of the federal award.
  • Most NIH grants follow the 120-day timing noted in the Uniform Guidance, but some grants require reports to be submitted within 90 days of the end of the period of performance.

Office of Sponsored Programs requires the account to be reviewed and reconciled within 60 days after the end date to ensure all allowable charges have posted and are ready for closeout procedures. This includes any affiliated subaward’s expenditures.

Public and Private Sponsors’ Financial Reporting

The financial accounting system of the University is designed to comply and report financial data based on major budget categories. However, some sponsored agreements may require the provision of additional detailed information. In such cases, it is the responsibility of the Department Administrator to prepare the requested additional detailed information and submit it to the Sponsored Programs-Post Award team.

The Office of Sponsored Programs is responsible for submitting financial reports to sponsors via their online portals. In some cases, and with the approval of Sponsored Programs, departments may collaborate with OSP to submit financial reports to private sponsors. This ensures that the receivable is properly recorded, and that payment is tracked and collected. Such instances are rare and must be approved by Sponsored Programs.

Carryover of funds

If the award allows automatic carryover, departments are permitted to continue spending against their existing project. However, if carryforward necessitates prior approval from the sponsor, the department should coordinate with Sponsored Programs (OSP) on how to proceed. In such situations, OSP should adjust the budget to match expenses to prevent any further spending. If carryover is denied, the department will be responsible for any expenses incurred. Under section 75.308 c(2)(d)(3) Carry forward unobligated balances to subsequent periods of performance. Except for funds restricted on a Notice of Award, grantee organizations are authorized to carry over unobligated grant funds up to the lesser of 25% or $250,000 of the amount awarded for that budget period remaining at the end of that budget period. If the unobligated balance is in excess of 25% of the total amount awarded, or $250,000, whichever is less, and the grantee wishes to carry the funds forward, the grantee must obtain prior approval from the Grants Management Officer.

Deficit Balance

Departments should confirm whether the correct budget is reflected and confirm that the amount agrees with the agency authorized budget.  Departments should review all expenses to ensure charges were posted to the correct project.  If a deficit exists and the charges are unallowable, the department must transfer those costs to a discretionary account by completing a cost transfer justification form. If the charges are allowable, OSP may cost share the charges to a non-federal account.

Surplus Balance

Departments must verify that all allowable expenses have posted to the project. In cases where the award requires a return of funds to the sponsor, OSP will submit a check request form. If the award permits the balance to be retained, OSP will calculate the Direct and FA cost of the residual and transfer the direct cost to the department's discretionary account.

Cash Management

The Office of Sponsored Programs-Post Award team manages all cash-related activities of externally funded projects.  The goal is to maintain appropriate levels of cash flow and timely submission of all payments on sponsored projects while at the same time ensuring financial compliance with federal regulations, sponsored requirements, and University policies. The essential responsibilities include:
  • Processing Letter of Credit (LOC) drawdowns for federal awards
  • Process installment or cost reimbursement invoices for Non-federal or federal pass-through grants and contracts and act as the point of contact for invoicing inquiries
  • Completing remittance information requests for sponsor payments
  • Identifying sponsor payments via check, wire, and ACH
  • Process receipts of sponsor payments and ensure they are credited to the correct award and outstanding receivables.
Sponsor Payment Methods
 
Every award outline terms and conditions for reimbursement requests. Sponsors use three mechanisms to disburse funding.
 
Letter of credit (LOC)
Federal agencies generally allow the University to access funds via a letter of credit based on cost reimbursement. The University can withdraw funds up to 90 days (in some cases up to 120 days) beyond the award end date. However, the withdrawal requests are rejected after this time.
Electronic fund transfer (EFT)
Sponsors can send funds electronically, either through an ACH or wire.  An electronic fund transfer requires additional information to identify the award to which it applies.
Check
Sponsors can also send checks directly to the Office of Sponsored Programs.  If a check is received by the Principal Investigator or Department Administrator, please forward it immediately to the Office of Sponsored Programs.

No-Cost Extension

Many sponsors will allow No-Cost extensions (NCE) for sponsored programs. A no-cost extension is a request to extend the project period beyond the original award end date allowing the original scope of work funded by the sponsor to be completed without requesting additional funding. The PI should work with their Department Administrator to understand the no-cost extension procedure and requirements of the sponsor.
 
Non-Federal Awards
Extending the budget period for non-federal awards with no additional cost usually needs approval from the sponsor. The Department will send an official request to the Office of Sponsored Programs (OSP) to submit to the sponsor on behalf of the Principal Investigator if the terms and conditions of the award do not include guidelines for the extension.
Federal Awards
Federal regulations provide a set of criteria for approving a one-time extension of the expiration date of a federal award for up to twelve months.  Most federal agencies will allow the University to submit a one-time 12-month no cost extension (under Federal Demonstration Partnership).  The extension may be issued unless one or more of the following conditions/restrictions apply:
  • The terms and conditions of the award prohibit the extension.
  • The extension requires additional federal funds.
  • The extension involves any change in the approved objectives or scope of the project.
Agency approval for extensions longer than twelve months must be requested.  If the University approves a request for an extension of less than twelve months and the Principal Investigator subsequently wishes to lengthen that time period to a total of twelve months or longer, agency approval must be obtained.
No-Cost Extension Request
The Principal Investigator must submit an official request describing the need for an additional period of time to complete the project objectives.  The request must address programmatic issues and may describe justifiable delays.  The request must also state the extension is:
  • not being exercised for the purpose of using the unobligated balance
  • not prohibited by the terms and conditions of the federal award
  • not to request additional federal funds
  • it does not involve any change in the approved objectives or scope of the project.
If the sponsor approval must be obtained, the letter should be addressed to the sponsor’s grant management specialist but sent to Office of Sponsored Programs for review and authorizing signature.  If the University has been given the authority to approve the no-cost extension, the request should be addressed to the Associate Vice Chancellor for Research.
The Timing of the Request
If sponsor approval must be obtained, and if the sponsor is a federal agency, request to extend a project period must be received by the OSP at least 45 days before the expiration date of the grant, unless otherwise specified.  The Principal Investigator will need to send the request to OSP for review and authorization before any contact with the sponsor is made (if necessary).  If the sponsor is a non-federal agency, the award document should be consulted for requirements regarding the timing of the request.
 
Money remaining in the project’s account is not sufficient reason for an extension. 
Effort During NCE
Sponsors expect that the original award terms and conditions, including commitments of the PI and all key personnel, extend throughout the award period, including a no-cost extension (NCE) period.  However, federal agencies recognize that effort likely will be reduced during the extension period.  Any changes or granter than 25% for the PI and other named key personnel requires prior approval and should be included in the NCE request.  Upon approval of the extension, the Department is responsible for updating all commitments according to the NCE justification.
Jan 17, 2024