Award Start, End, and Close Date Questions and Answer
Can the Start, End and Close Dates be changed?
Yes and no. The system will allow the dates to be changed to accommodate time extensions and continuations. However, remember that these dates are driven by the sponsored agreement and therefore are binding. These dates should not be changed unless properly approved by the sponsor or through the on-campus “OPAS” approval process.
What if there is a proposed time extension on the award and approval is not received prior to the original End Date?
Because FIS prevents expenditures against the award after the End Date, the End Date in the system will have to be changed to reflect the Proposed End Date in order to continue spending. This will have to be done PRIOR to the original End Date or you may have expenditures rejected. It will be very important for you to be proactive about processing Proposed Time Extensions through the PreAward Services Office PRIOR to the original End Date. END DATES WILL NOT BE CHANGED unless a Proposed Time Extension has been processed, not even for payroll purposes!
What if the Proposed Time Extension is refused, or is shorter than requested?
All spending after the original End Date but before the Proposed Time Extension is approved is at the department’s own risk. Any expenditures that are charged to the award after the date that is ultimately approved will have to be transferred off of the award.
Why is the Close Date required?
As with the Start and End Dates, Oracle designed their Grants Accounting module to incorporate controls that are needed to properly adhere to federal and other sponsor regulations. The federal OMB Circular A-110 requires that all obligations be liquidated within 90 days of the end date of an award. Other sponsors typically require the account to be finalized and reported or invoiced within less than 90 days. The Close Date functionality in FIS helps us manage these requirements more consistently and accurately than with FRS.
How were these date requirements managed in FRS since that system had no date functionality?
With FRS, we used a combination of things. The Freeze flag in FRS is similar to the Close Date that is in FIS. SPA accounts were automatically frozen within 90 days of the End Date. The Outstanding Obligations list was required to finalize and close the account and was a way to help simulate both the End Date and Close Date that is in FIS. If the END DATE and CLOSE DATE functionality in FIS is used as intended, Outstanding Obligations lists would no longer be needed.
To explain this in more detail:
In FRS any expenditures that were incurred before the End Date, but not processed through the accounting system prior to the End Date, were to be listed on an Outstanding Obligations list and incorporated into final reports and invoices. The department signature on the Outstanding Obligations list indicated that everything on that list had in fact been incurred BEFORE the End Date and therefore was allowable. SPA staff use this information to adjust final invoices to reflect all costs and get the invoices out to the sponsors even though all expenditures were not actually in the accounting system yet.
We have managed to make this approach with FRS work over the years, but it also has a number of shortcomings. One of the most serious problems that we encounter is that by the time departmental staff are able to determine and compile the Outstanding list, we have sometimes missed the sponsor’s invoicing and/or final reporting deadline. This puts the award at risk in regard to receiving final payment from the sponsor. And when the sponsor doesn’t pay, the department is responsible for the costs! Not a good situation.
If departmental personnel use the time needed to prepare the Outstanding Obligations list to instead get expenditures processed and in the accounting system by the Close Date, then we would no longer need that list to prepare final invoices.
Can the Close Date be changed if all expenditures to spend out the account are not processed in time to meet the Close Date?
The system does allow the date to be changed, however, remember that the Close Date is there because of sponsor requirements. (see #4 above). In order to adhere to sponsor requirements and eventually eliminate the Outstanding Obligations list (see #5 above), changing the Close Date should be the exception, not the rule. It is anticipated that as we progress through the first year of working in a new system the Close Date may need to be changed more frequently than we would like and Outstanding Obligations lists from the departments will most likely still be needed for SPA to prepare final invoices and reports to meet sponsor deadlines.