The presentation by James Luther of Duke University, delivered in June 2015, addresses the evolving requirements and operational implications of grant closeout, particularly in relation to NIH subaccounting and the federal Payment Management System (PMS). Luther outlines key regulatory mandates, including those stemming from the Uniform Guidance and specific agency requirements, such as the expectation of final financial, programmatic, and invention reports within strict 90- or 120-day post-award deadlines. He emphasizes the trend toward stricter enforcement by federal agencies, with possible unilateral closeouts if deadlines are not met, and highlights the significant administrative and IT challenges institutions face in adapting to these timelines—ranging from increased workload for departments to the need for new project codes, revised internal processes, and substantial IT investments.
The transition to subaccounting, particularly for NIH awards, is presented as a catalyst for increased complexity in financial management and reporting, requiring careful coordination between central offices, departments, and IT resources. Luther identifies several outstanding issues, such as the harmonization of reporting timelines, management of carryforwards, retroactive changes, and subaward modifications, underscoring uncertainties that institutions must navigate. The presentation further discusses the PMS's enforcement mechanisms, such as the activation of “expired grant” status after the deadline, which restricts further drawdowns without sponsor approval. Throughout, the need for proactive communication, ongoing advocacy (through organizations like COGR), and sustained readiness is stressed, as institutions that fail to adapt risk losing access to critical federal funds.
