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Close-out and Record Retention

Close-out

The final stage in the grant lifecycle is grant closeout.  This phase begins when either the grant award period has expired, or when the Chicago State University draws down its entire grant award.  Federal awarding agencies will notify Chicago State University as it nears the end of its grant term to request final reports.  If Chicago State University is nearing the end of its grant term but has not yet expended its entire grant award, it may be able to seek an extension from the federal awarding agency.

2 CFR Part 200 Sections 200.343 thru 200.345 give detailed guidance on grant closeout activities.  Generally, the federal awarding agency will request and review the following items within 90 days after the expiration of the grant award:

  • Work plan and progress reports
  • SF-269 Financial Status Reports
  • Requests for payments
  • Compliance with matching requirements
  • Federally-owned property records

As the federal awarding agency conducts its review, it can still discover and collect payments for disallowed costs and other deficits in the administration of the grant. Please see grant close-out form sample here 

GRANT CLOSE-OUT Procedure 20.6 – Grant Close-Out, Page 118  https://www.csu.edu/financialaffairs/documents/Admin_Finance_Policies_Procedures_Manual.pdf

Please note that all subrecipient records and documentations including risk assessments/evidences  are all kept in the department (OGRA) shared  R drive.

 

Why should we retain financial records?

  • It provides those responsible for managing cost objects with the means to monitor transactions and resolve problems.
  • It enables the Institute to comply with various requirements—Federal Acquisition Regulation (FAR), A-110, Uniform Guidance, IRS and other federal, state, and local regulations—which govern the auditing and retaining of records. Retention requirements are typically defined by the type of award (grant, contract, cooperative agreement) and the sponsor (federal, non-federal, foundation).
  • For older federal grants and cooperative agreements, A-110 states that financial records, supporting documents, statistical records, and all other records pertinent to an award should be retained for three years from the date of submission of the final expenditure report; for awards that are renewed quarterly or annually, the records should be retained from the date of submission of the quarterly or annual financial report, as authorized by the federal awarding agency.
  • For federal contracts, FAR dictates that records must be retained for three years after the final payment. This includes books, documents, accounting procedures and practices, and other data—regardless of whether such items are written, computerized, or in any other form—and other supporting evidence to satisfy the contract negotiation, administration, and audit requirements of the contracting agencies and the Comptroller General. For financial and cost account, pay administration and acquisition, and supply records, the required retention requirement is two to four years. 

Time of Retention

Generally, legal and audit requirements dictate how long financial and project records should be retained.

  • When requirements for long-term retention of records overlap, the responsible office should retain records for the maximum period needed to meet legal and audit requirements. A-110 specifies the following:
    • Direct charges to contracts and grants: Three years following the date CSU OGRA considers the project to have been formally closed by the sponsor, unless an audit or litigation is under way.
    • All cost objects included in the F&A cost rate: Three years following the final sign-off for that year by the federal government. For further information, contact the Office of Grants and Research Administration (OGRA).

Longer retention times apply to certain documents see Retention of Copies for Department Files.

Scientific Data/Technical Records Retention

The Principal Investigator is responsible for retaining scientific and technical data as well as for related compliance documentation.