NIH Unilateral Closeout: In the most recent notice on closeouts, NIH Division of Grants Compliance and Oversight stated it will now “strictly enforce its closeout policies.” This includes initiating unilateral closeouts for award recipients who fail to meet the 120-day deadlines for financial and performance reporting – and reporting this noncompliance in the institution’s SAM.gov record. NIH will retroactively report on unilateral closeouts that have taken place since January 1, 2023, which includes one award received by Northwestern.
   
A unilateral closeout is a serious action with consequences to the investigator’s and University’s reputation, and invites additional audit scrutiny. This is visible to sponsors and can affect future funding from any sponsor, for any investigator.     

Best practices that help facilitate timely closeouts include adhering to a spending plan, posting charges early and regularly, and reconciling monthly. In addition, department administrators can help by resolving deficits on awards in or awaiting closeout.

Closeout Initiative: As a result of NIH’s recent memo and feedback from the research community, ASRSP staff will launch an aggressive initiative to resolve the closeout backlog going back to 2018. The duration of this initiative will span over the next 60-90 days and will require assistance from stakeholders. Requests to remove overdrafts, payroll, or provide non-sponsored chartstrings will require immediate attention to successfully complete this initiative. With your help and partnership, we are optimistic that we will be able to resolve at least 90% of the closeout backlog.  


NIH Salary Cap: The NIH released its annual notice on salary limitations for grants, which set the salary cap of $221,900 effective January 1, 2024. The NU Salary Cap Calculator and Salary Planning Templates have been updated with this figure.

Capital Equipment Inventory: A new year brings a new inventory cycle. This fiscal year, Accounting Services will be inventorying capital equipment assigned to the Chicago campus. Pre-selected representatives from Chicago campus departments will receive instructions and inventory sheets later this month. 

As the steward of capital equipment that is purchased under sponsored agreements (sponsored equipment), the University is responsible for ensuring that assets are managed (i.e. safeguarded, tracked, reported, retired, and disposed of) in compliance with University, sponsor, and federal requirements (2 CFR 200). The title for sponsored equipment may be retained by the sponsor or be vested with Northwestern but in all cases, Northwestern assumes custodian responsibilities for the asset.

Departments should plan to complete their inventory by 5/31/24. For any questions regarding the inventory process, please contact Accounting Services at [log in to unmask]. 

Single Audit: The FY23 Single Audit is on track to be submitted ahead of schedule. Looking ahead, the FY24 Single Audit is expected to focus on research and development (R&D). That means sponsored research activity will be reviewed with a primary focus on evidence of internal controls; adherence to policies, procedures, and terms and conditions of the sponsored award; cost allowability; and proper documentation. Each transaction should be considered auditable. The following best practices support compliance in the areas examined in audit:

Effort Reporting: The first semi-annual reporting period is coming soon. Below are a few reminders:

Closeout: Closeout is the process by which the sponsor determines that all applicable administrative actions and all required work of the award have been completed. Specific requirements include the submission of final performance and financial reports, processing of final payments and refunds, and any other activities included in the award terms and conditions.