The National Institutes of Health (NIH), Department of Defense (DoD), and other Federal agencies may delay awarding recipients that:
- Do not provide timely, accurate closeout reports, or
- Do not respond to requests to reconcile discrepancies in grant records
Failure to correct recurring reporting problems may result in Federal awarding agencies initiating one or more remedies for noncompliance, e.g., delaying or denying awards to individuals or the entire institution.
2 CFR Part 200.344, Closeout, requires Federal awarding agencies or pass-through entities (PTE) to complete closeout actions no later than one year after the end of the period of performance.
Award recipients must submit all financial, performance/technical, and other reports per the terms and conditions of award, no later than 120 calendar days after the period of performance end date. Subrecipients must submit their reports to the PTE no later than 90 calendar after the period of performance end date.
If the award recipient does not submit all required reports per the terms and conditions of award, the Federal awarding agency must proceed to close out with the information available within one year of the period of performance end date.
If the award recipient does not submit all reports within one year of the period of performance end date, the Federal awarding agency must report the recipient’s material failure to comply with the terms and conditions of award as a Responsibility/Qualification record in the institution’s information in SAM.gov. Federal awarding agencies may take other enforcement actions (§ 200.339).
Prior to making funding decisions, Federal awarding agencies will check the institution’s Responsibility/Qualification record, formerly the Federal Awardee Performance and Integrity Information System (FAPIIS), which is a federal database that serves as a government-wide source of information on the prior performance of Federal procurement contractors, grantees, and cooperative agreement holders since 2010. Each report of non-compliance remains on the institution’s record for five years.
Timely submission of accurate closeout reports will keep the University’s record in good standing as a responsible recipient of Federal funds.