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Frequent Questions about Closeouts

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General Questions

1. What is a closeout?

EPA policy defines a closeout as the systematic process by which EPA determines that all required technical work under a grant or cooperative agreement has been completed by the recipient and EPA, and all applicable administrative requirements are met.

2. How do I determine if my award is about to end and will require closeout?

Recipients should refer to the award’s assistance agreement to determine the award’s budget and project period expiration dates. In addition, recipients will receive a notification via email 60 days prior to the award expiration date, however, projects may be closed prior to expiration if all project requirements have been met.
 
3. What if I need more time to complete the project? Can the award be extended?

Generally, assistance agreements subject to 40 CFR Part 30, may be extended one-time up to a year without a formal amendment to the assistance agreement provided certain requirements are met and EPA is notified in writing at least 10 calendar days before the end of the performance period specified in the award document (40 CFR 30.25.f.2).  Subsequent extensions require a formal amendment after the one-time automatic extension has been exercised.  You must provide along with your notification, or request to extend the performance period, a justification or reasons and the revised expiration date.  Be sure to check the terms and conditions of your award as you may be required to submit an interim or annual Federal Financial Status Report (SF 425) as well.

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Assistance agreements subject to 40 CFR Part 31 require a formal amendment to extend the performance period.  You must submit a written request with the supporting reasons, revised timelines and milestones, and the requested period of performance.  Be sure to check the terms and conditions of your award as you may be required to submit an interim or annual Federal Financial Status Report (SF 425) as well.

For assistance agreements to which the Uniform Grant Guidance (2 CFR 200) is applicable, EPA has not exercised the waiver option to allow automatic one-time extensions for non-research grants under 2 CFR 200.308 (d)(2).  Therefore, in the event an extension is needed, the recipient must submit a written request to initiate an amendment to extend the performance period of the assistance agreement.  The request must be submitted at least 10 calendar days before the end of the project period and include  the supporting reasons, revised timelines and milestones, and the requested period of performance, (see 2 CFR 200.308).

A formal amendment to the agreement will be issued by the EPA Award Official if the extension request is approved.  If applicable, please refer to the Grant-Specific Administrative terms and conditions of your award document for specific instructions for requesting a no-cost time extension amendment.

Note:  An extension may not be granted merely for the purpose of expending unobligated balances.

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4. How do I determine which regulations apply to my award (40 CFR or 2 CFR 200)?

The regulations that apply to your assistance agreement are stated on page 2 of your award document; please refer to the award document to determine the regulations you must follow. 

As a general matter, please be aware that on December 26, 2014, the Office of Management and Budget issued Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Any new funding through an amendment (supplemental or incremental) on or after December 26, 2014, and any unobligated balances (defined at 200.98) remaining on the award at the time of the amendment, will be subject to the requirements of the Uniform Administrative Requirements, Cost Principles and Audit Requirements (2 CFR 200 and 1500).This means that awards expiring before or after that date, and that have not had a monetary amendment, are still required to adhere to the previous regulations listed on the award document (40 CFR 30 or 40 CFR 31). Links to applicable regulations are found in the Additional Guidance section below.

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Preparing and Submitting Reports

  1. When are final reports due?

Reports required for closeout must be submitted no later than 90 days after the project period end date. If applicable, final MBE/WBE Utilization Reports (EPA Form 5700-52A) are due by October 30th or 90 days after the end date of the project period, whichever comes first.

2. What if I need additional time?

If you require additional time to submit reports please contact the appropriate office or individual listed in the "How do I submit final reports to EPA" section below.  To receive additional time, you must submit a request with a justification and proposed submittal date to that office or individual.  

3. Where can I find instructions on what to include in each report?

Reference the terms and conditions of the award. Forms and instructions for specific closeout reports can be found at EPA Grantee Forms

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4. What reports are required of recipients for closeout?

  • Final Federal Financial Report (FFR) (SF-425)
    • FFR Instructions
  • Final Technical Report
    • Criteria for report content is found in the terms & conditions of the original award document.
  • Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) Utilization Under Federal Grants, Cooperative Agreements and Interagency Agreements Report (EPA Form 5700-52A), if applicable (Please refer to the grant-specific “Administrative Terms and Conditions” in your award document to determine whether this report is required)
    • A final MBE/WBE report is required for assistance agreements where there are funds budgeted for procuring construction, equipment, services and supplies, including funds budgeted for direct procurement by the recipient or procurement under subawards or loans in the “Other” category, exceeding the threshold amount of $150,000, including amendments and/or modifications.
  • Property Report (SF-428), if applicable
    • 2 CFR 220.310 through 2 CFR 220.316 discuss property standards and reporting requirements.
    • Only submit an SF428 and SF428-B for equipment with an acquisition cost of $5,000 or more and the EPA has reserved the right to transfer title. The EPA right to transfer title will be explicitly stated in the assistance agreement terms and conditions. In such instances, the non-Federal entity must submit annually to the Federal awarding agency an inventory listing Federally-owned property in its custody using the SF-428-A.  2 CFR 200.313; 40 CFR 30.34 Exit; or 40 CFR 31.32  Exit(as applicable)
    • Additionally, residual unused supplies with total aggregate fair market value exceeding $5,000 not needed for any other federally sponsored programs or projects must be reported and the value reimbursed to the EPA in accordance with the applicable regulation.  2 CFR 200.314; 40 CFR 30.35; or 40 CFR 31.33 Exit(as applicable)
    • For Superfund awards made under 40 CFR Part 35, Subpart O, refer to 40 CFR 35.6340 and 35.6660 for property reporting requirements. Typically these awards begin with the program code V or VC.
    • When submitting a final inventory report to the EPA Project Officer, utilize the SF-428 and SF-428S forms.
  • IDC Rate agreement(s), if applicable
    • Final, Fixed, Predetermined or Provisional Indirect Cost Rate Agreement(s) covering the life of the agreement must be on file with the EPA unless your organization has been approved to use a 10% de minimus rate. Please note, unless supported otherwise in the federal regulations, if indirect costs are included in the award budget it is the recipient’s responsibility to maintain an approved indirect cost rate agreement during the life of the award. Recipients with differences between their provisional rate and established rate are not entitled to more than the amount identified in the award for indirect costs without EPA approval.

      Please note, if indirect costs are included in the award budget, it is the recipient’s responsibility to maintain an approved indirect cost rate agreement during the life of the award. At the time of closeout the recipient must ensure that funds have not been drawn above the approved or provisional rate during the period established in the rate agreement. This means if your rate has gone down from year 1 to year 2, you are obligated to adjust your allocation accordingly. Any funds drawn above the established rate will be deemed unallowable and result in repayment of funds to the US EPA.

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5. How do I submit final reports to EPA?

As a general rule, all required reports should be submitted electronically.  However, if that is not a valid option please contact the appropriate individual listed below for available options.

  • Federal Financial Report (FFR) SF-425
    All EPA awarding offices require the Final FFRs to be submitted to the Las Vegas Finance Center at LVFC-Grants@epa.gov. If you are unable to email the form, please mail the report to:

    USEPA LVFC
    4220 S. Maryland Pkwy
    Bldg C, Suite 503
    Las Vegas, NV 89119
     
  • Final Technical Report
    All EPA awarding offices require the Final Technical Report (along with the property report and notification of iEdison invention reporting, as applicable) to be submitted to the EPA Project Officer identified on the first page of the award agreement.

For all other reports, please follow the instructions below of the award office that issued your award:

Headquarters

Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) reports should be signed and emailed to MBE.WBE@epa.gov.  All additional closeout reports should be sent to the EPA Grants Specialist identified on the first page of the award agreement.

Region 1

All additional closeout reports (i.e. Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) forms, etc.) should be sent to the EPA Grants Specialist identified on the first page of the award agreement.

Region 2

All additional closeout reports (i.e. Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) forms, indirect cost rates, copies of Federal Financial Report, etc.) should be sent to Region2_GrantApplicationBox@epa.gov  

As a reminder EPA Region 2’s dedicated email in-box may also be used for receiving original pdf copies of grant applications, amendment requests and other grant documents.  Region 2 will only accept signed pdf copies (documents submitted in other file formats will not be accepted).

Region 3

Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) reports, if applicable, should be signed and emailed to R3_MBE-WBE_Reports@epa.gov  as a pdf file, or by postal mail to the attention of Diversity/EEO Manager (3DA10), U.S. EPA - Region III, 1650 Arch Street, Philadelphia, PA  19103-2029 with a courtesy copy to the EPA Grant Specialist.  In addition, final indirect cost rates should be sent to the EPA Grants Specialist identified on the first page of the award.

Region 4

All additional closeout reports (i.e. Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) forms, indirect cost rates, etc.) should be sent to the EPA Grants Specialist identified on the first page of the award agreement.

Region 5

All additional closeout reports (i.e. Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) forms, indirect cost rates, etc.) should be sent to Region5Closeouts@epa.gov with the name of the Grants Specialist identified on the first page of the award agreement in the subject line.

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Region 6

All additional closeout reports (i.e. Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) forms, indirect cost rates, etc.) should be sent to R6_EPA_Grants_Programs@epa.gov with the name of the Grants Specialist identified on the first page of the award agreement in the subject line

Region 7

All additional closeout reports (i.e. Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) forms, indirect cost rates, etc.) should be sent to R7GRANTS@EPA.GOV.

Region 8

All additional closeout reports (i.e. Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) forms, indirect cost rates, etc.) should be sent to the EPA Grants Specialist identified on the first page of the award agreement.

Region 9

All additional closeout reports (i.e. Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) forms, indirect cost rates, etc.) should be sent to grantsregion9@epa.gov

Region 10

Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) reports should be emailed to Andrea Bennett, our Minority Business Enterprise/Woman Business Enterprise (MBE/WBE) Coordinator, at Bennett.Andrea@epa.gov. All additional closeout reports (i.e. indirect cost rates, etc.) should be sent to the EPA Grants Specialist identified on the first page of the award agreement

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6. How do I notify EPA of an invention or patent? How is this reported?

When inventions or patents are an expected result of the federal funding, the recipient must utilize the Interagency Edison extramural invention reporting system at iEdison. Annual utilization reports must be submitted through the system. The recipient is required to notify the Project Officer identified on the award document when an invention report, patent report, or utilization report is filed at iEdison.  Pursuant to the Bayh-Dole Act (set forth in 35 USC 200-212), EPA retains the right to a worldwide, nonexclusive, nontransferable, irrevocable, paid-up license to practice the invention owned by the assistance agreement holder, as defined in the Act.

Federal Financial Report (425)

1. What should be considered when submitting the Final FFR?

Maintaining sound financial records and transaction documentation is key in ensuring the correct information is reported back to the EPA. These include reconciling indirect costs to ensure they weren’t charged above the approved final, fixed, predetermined, provisional, or de minimus rate agreement(s) for the approved time period(s) and assistance agreement budget, all cost-share requirements established at the time of award have been met and documented, all expenditures have been incurred within the budget period, and program income has been accounted for and used appropriately.

2. What are some potential reporting problems my organization should check before submitting the Final FFR?

Final FFRs must indicate the exact balance of expenditures.  That means, if operating on an accrual basis, all expenditures need to be recorded in your financial system. If on a cash basis, all obligations should be paid.  Unliquidated obligations are bills that have not been paid.  Final FFR should not show any unliquidated obligations.

Please note, unless supported otherwise in the federal regulations, if indirect costs are included in the award budget it is the recipient’s responsibility to maintain an approved indirect cost rate agreement during the life of the award. At the time of closeout the recipient must ensure that funds have not been drawn above the approved final, fixed, predetermined, provisional, or de minimus rate and amount approved in the award budget during the period established in the rate agreement. Any funds drawn above the allowable amount may be deemed unallowable and result in repayment of funds to the US EPA.

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3. If the award included federal in-kind contribution where is it reported?

Similar to the instructions provided for the recipients reporting of third party in-kind contribution, federal in-kind contributions should be reported in section 10.E titled federal share of expenditures and 10.G titled total federal share.  The total in-kind awarded in the grant should be included in Black 10.D total federal funds authorized.  Remarks can be made to clarify as needed in section 12.

4. Do I need to report the Program Income generated by the project?

Yes, all program income should be accounted for on the FFR (section 10.L-O) and used in accordance with the terms and conditions of the award instructions provided.  The EPA’s standard practice is, in accordance with 2 CFR part 200.307(e)(2), for program income to be added to funds committed to the project by the EPA and used to further eligible project or program objectives.  However, please check with the respective project officer or grants specialist to verify.

5. What will happen if there is a discrepancy between the amount of total expenditures and the amount reported on the final FFR?

It is the recipient’s responsibility to reconcile expenditure reports submitted to EPA. If any discrepancies are identified during EPA review of the final FFR, the recipient will be notified and instructed to submit a corrected revised final FFR.

6. What should I do if I think it’s necessary to revise the final FFR I submitted based on audit findings or discovery of a reporting error?

Contact the grants specialist named on the award to explain the situation and receive further instructions since this will impact closing the award. Please note, regardless of whether EPA has already closed the award, the recipient remains obligated to return funds due as a result of later refunds, corrections, or other transactions; and the federal government may recover amounts based on the results of an audit covering any part of the project period (see 2 CFR 200.345).

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Compliance-Related Questions

1. What will happen if I do not submit a final Federal Financial Report (Final FFR) on time?

If an FFR cannot be submitted within the 90 days after the budget period expires, immediately contact the EPA Grant Specialist and EPA Project Officer to request an FFR extension.  Justification for the extension will need to be provided.  The LVFC does not have the authority to grant extensions.

Several attempts will be made to secure the required FFR. On the 91st day after award expiration, funds for the applicable grant will be suspended on Automated Standard Application for Payments (ASAP) or declined if requesting via manual method.  A final FFR will need to be submitted prior to funds being released.

2. What will happen if I do not submit other final reports on time?

The Las Vegas Finance Center, EPA Grants Specialist and EPA Project Officer will make several attempts to contact you for final reports. If the problem persists, the EPA Grants Specialist can refer your organization to EPA’s Office of Suspension and Debarment for further follow up and action. Referrals to the EPA’s Office of Suspension and Debarment could affect the organization’s scoring and receipt of future awards from the EPA.  Additionally, EPA, in accordance with applicable regulations, may take enforcement action, including potential recovery of funds reimbursed to your organization.

3. How long am I required to retain my files after the award is closed?

Depending on the regulations applicable to your award [see "How do I determine which regulations apply to my award (40 CFR or 2 CFR 200)?"] the guidance can be found at 40 CFR 30.53, 40 CFR 31.42, and 2 CFR 200.333.  Generally, the requirement is to retain the file for a period of 3 years after the submission of the final expenditure report.  However, please review the applicable regulation to ensure no exceptions apply to your award.

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Additional guidance

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