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Subaward Closeout
Subaward closeout is the final phase of the subaward lifecycle. This process ensures that the subrecipient has completed all programmatic work and submitted all required deliverables, and that all financial obligations have been fulfilled. Proper and timely closeout is critical for mitigating financial risk, ensuring compliance with federal regulations and sponsor terms, and protecting the university from potential audit issues. It serves as the official verification that all aspects of the subaward agreement have been satisfied.
The Principal Investigator (PI) collaborates closely with the Office of Sponsored Projects (OSP) Award Manager to ensure a compliant and timely subaward closeout. The subaward closeout process begins as the subaward’s period of performance end date approaches and must typically be completed before the prime award can be closed.
Process
- Final Deliverable Review: The PI confirms that all technical and programmatic deliverables from the subrecipient have been received, reviewed, and approved.
- Compliance Checks: The PI should verify that all required reports—such as technical reports, invention disclosures, or property reports have been received from the subrecipient. Submission to the awarding agency or prime sponsor is typically handled by OSP, but the PI plays a key role in confirming receipt and content.
- Final Invoice Submission: The PI ensures that the subrecipient submits their final invoice within the timeframe outlined in the subaward (generally 30–60 days after the end date). The final invoice must be clearly marked “Final”.
- Risk Mitigation Review: The PI verifies that all applicable risk mitigation conditions—such as payment holdbacks, required effort certifications, or other mandatory certifications—have been satisfied prior to authorizing the final payment.
- Financial Reconciliation: The PI should work with the Research Support Team (RST) to reconcile the subaward’s financials and liquidate any remaining encumbrances. They should review all subrecipient expenditures to ensure they are correctly posted to the appropriate subaward number. If needed, they can submit Departmental Correction Forms (DCFs) to adjust misapplied expenditures.
Frequently Asked Questions
- Who is responsible for initiating subaward closeout?
The PI or department typically initiates the process by confirming deliverables and reviewing the subrecipient's final invoice. Grants and Contracts Accounting Services (GCAS) finalizes financial and administrative closeout.
- What is the deadline for the subrecipient to submit the final invoice?
The deadline is defined in the subaward agreement but is typically 30 to 60 days after the subaward’s period of performance end date.
- What happens if a subrecipient submits a final invoice late?
Invoices submitted after the contractual deadline may not be paid unless a formal extension was granted by OSP prior to the deadline. This could result in non-reimbursable costs for the subrecipient.
- Does the PI need to formally sign off on the closeout?
Yes. The PIs documented confirmation that all technical deliverables have been received and are satisfactory is mandatory before the final invoice can be paid and the subaward can be closed.
- Can the subaward be reopened after closeout?
Only under exceptional circumstances. Once closed, a subaward can only be reopened with significant justification and institutional approval.
- Why is timely closeout of a subaward so important?
Timely closeout is a federal compliance requirement and ensures the university meets its obligations to the prime sponsor. It prevents audit findings, resolves all financial obligations, and allows the prime award to be closed in a timely manner.