NIH Grants Administration Manual Part 4304-205 supersedes NIH Manual Chapter 55805 entitled, “Closeout of NIH Grants.” This chapter states the basic requirements for the closeout of assistance awards following expiration of support from the National Institutes of Health (NIH).

This policy applies to all NIH grants and cooperative agreements. 

This policy is implemented to align with requirements outlined in 2 CFR Part 200.344. This policy describes NIH’s administrative and financial internal closeout requirements for Institutes, Centers, and Offices (ICOs) that also impact recipients. 
NIH Grants Policy Statement (NIHGPS) Section 8.6 outlines the administrative requirements for closeout of most NIH awards for recipients. The policy below notes when any award type or activity code deviates from these requirements.   
 

1. Closeout Requirements
   Closing out an award is the process by which NIH determines that all applicable administrative and financial actions have been completed by the recipient (see NIHGPS Section 8.6). NIH frequently refers to the processes of closeout as administrative closeout, financial closeout, and unilateral closeout. Specific actions taken by NIH staff during the closeout process are detailed in staff guidance. (Add hyperlink to guidance once available).
   
   Timeframe for Institute, Center, or Office Closeout
   
   An award ends on the last day of the period of performance noted in the latest Notice of Award (NoA), including any no-cost extensions.  
   
   NIH is responsible for closing all awards within 270 days of the period of performance, but no later than one year after the completion date of the period of performance unless otherwise directed by authorizing statutes.  
   
   OPERA will approve extensions beyond 270 days in rare instances under the following circumstances:

   • a presidentially declared disaster under the Stafford Act, which is a public health emergency declared by the Secretary, HHS, or other local, regional or national disaster,
   • a natural disaster or other act of God, or
   • an urgent event that disrupts the recipient organization’s normal operations and prevents the recipient from liquidating funds within the 120-day timeframe.

   Closeout may extend beyond one year only under the following circumstances:

   • There is a pending decision in an HHS appeal (including appeals to NIH and the Departmental Appeals Board);
   • There is one or more unresolved monetary finding(s) related to that award in an audit; or
   • NIH is party to open legal action.

   NIH staff may permit closeout costs in the final budget period of the award, where appropriate.
   
   Recipients receive an initial closeout reminder letter 10 business days following the period of performance end date for grants that have been opened for closeout in the Electronic Research Administration (eRA) Grants Closeout Module (GCM). The eRA system then automatically sends a letter to recipients reminding them of required final reports on 90 business days, 120 business days, and 150 business days following the period of performance end date. If a recipient has not provided these reports or responded to ICO requests to reconcile discrepancies in grant records within the 120-calendar day period, the ICO must close the award in a timely manner. 
   
   The Chief Grants Management Officer (CGMO) or designated grants management official will initiate unilateral closeout by the 270th day after the end of the period of performance. An OPERA approved template must be used to prepare the unilateral closeout letter (refer to the Closeout policy webpage). 
   
   Administrative Closeout
   
   Administrative closeout is the process by which NIH determines that all applicable administrative actions and all research-related award activities have been completed through receipt and acceptance of the Final Research Performance Progress Report (F-RPPR), the Final Invention Statement (FIS) (HHS 568) and the Final Federal Financial Report (FFR).  Awards must be administratively closed in the eRA GCM. The specific actions that occur during the closeout process are detailed in the “Procedures for Closeout of NIH Grant and Cooperative Agreement Awards” document. (add hyperlink to guidance once available).
   
   If final required reports are not received and accepted within 180 days beyond the project period, the award automatically moves into “In Unilateral Closeout” status in the GCM on the 181st day. While in “In Unilateral Closeout” status in GCM, only the administering ICO CGMO or designated official may complete administrative closeout actions in GCM.
   
   In rare cases, if a recipient is unable to submit one of the required reports in the system, the ICO may still administratively close the award. NIH will not report these administratively closed awards into SAM.gov Responsibility and Qualifications.
   
   Financial Closeout
   
   Financial closeout involves the financial closure of awards that satisfy financial reporting requirements. The OPERA FFR Reconciliation and Financial Closeout Center (FFR-C) is responsible for 1) accepting, reviewing, and reconciling all NIH FFRs, and 2) reconciling transactions between the NIH Business System (NBS) and the HHS Payment Management System (PMS) to ensure compliance with the financial reporting aspects for grants as specified in the Terms and Conditions of Award.  Financial closeout is executed within the eRA FFR module by the OPERA FFR-C, and the financial closeout transaction is transmitted to the HHS Payment Management System (PMS). The FFR-C may act to financially close an account in PMS if a final and acceptable FFR is not submitted by the recipient within 270 days beyond the project period. 
   
   Unilateral Closeout
   
   Unilateral closeout involves the closure of awards by the ICO for recipients that do not comply with closeout reporting requirements within 180 days beyond the period of performance. An award will enter a status of “In Unilateral Closeout” within eRA GCM on the 181st day. In this status, the OPERA Grants Closeout Center cannot take further action, and the administering ICO CGMO or designated official must act in the GCM (accessed via the eRA Grants Management Module) to close the award. The administering ICO must use an OPERA approved template to notify the recipient in writing of NIH’s intent to unilaterally close the award for noncompliance due to failure to submit the required final reports (refer to the Closeout policy webpage for templates).
   
   CGMOs (or their designated official) will report all unilateral closeout activities to the OPERA Division of Grant Compliance and Oversight (DGCO). Unilaterally closed awards are reported into the SAM.gov Responsibility and Qualifications section by DGCO and documented with OPERA leadership.

2. Requirements for Liquidation of Funds 
   Recipients may draw funds up to the date the Final FFR is submitted or up to the 120-day liquidation period on PMS documents in ‘Open’ or ‘Pending Closed’ status, whichever date comes first.  The ICO cannot reopen a closed award to allow the recipient to drawdown funds once the PMS documents are in closed status.  
   Under rare circumstances, NIH may allow a recipient to draw down funds after the 120-day liquidation period. OPERA has the authority to approve late draw requests on open PMS documents if recipient is unable to drawdown available funds due to 1) a public health emergency, 2) a natural disaster, or 3) an urgent event that disrupts the recipient organization’s normal operations and prevents the recipient from liquidating funds within the 120-day timeframe. ICOs must submit requests to the OPERA FFR-C for review and approval.
3. Required closeout documents 
   
   The Final Federal Financial Report (Final FFR) - (Standard Form 425)
   
   The Final FFR must cover the entire competitive segment (or as much of the competitive segment as has been funded before termination), indicate the exact balance of unobligated funds, and may not reflect any unliquidated obligations. Unobligated funds must be returned to NIH or must be reflected by an appropriate accounting adjustment in accordance with instructions from the ICO Grants Management Officer (GMO) or from the payment office. Final FFRs are reviewed and reconciled by the OPERA FFR-C. 
   
   The Final Research Performance Progress Report (FRPPR)
   
   A FRPPR is required for any grant that is terminated or will not be extended through award of a new competitive segment. ICO POs must review and accept FRPPRs within 14 days of receipt and are responsible for requesting any additional information needed from the recipient.  If the PO requires additional time for review, the ICO CGMO must submit a deviation request to OPERA for approval for each FRPPR review.  Additional information on this process is provided in the Staff Guidance. 
   
   The Final Invention Statement & Certification (FIS) (HHS 568)
   
   A Final Invention Statement and Certification (FIS) is required for most (but not all) programs whether the funded project resulted in any subject inventions, and whether inventions were previously reported. All inventions conceived or first actually reduced to practice during the course of work under the project from the original effective date of support through the completion date or termination of the award must be reported. OPERA Closeout Specialists are responsible for reviewing the FIS to ensure that it is submitted, and the Division of Compliance for Foreign Interference, Research Misconduct and Harassment (FIRMH) subject matter experts review that inventions are reported and documented appropriately.  The Final Invention Statement & Certification might be waived when the recipient has consistently reported "no inventions" in all applications and staff has confirmed that no inventions have been reported to FIRMH/Extramural Inventions, OPERA, OER, NIH. In such cases, the ICO may administratively close the award. Additional guidance on this process is provided in the Closeout Staff Guidance. 
    
4. Closeout of Fellowships and Institutional Training Grants
   
   Closeout of Fellowships – At the end of the period of support, ICOs are required to confirm the recipient submitted a Termination Notice (Form PHS 416-7) through the eRA Commons xTrain application within 30 days of the termination date (even if the fellow is not available for signature). The Termination Notice is the basis for validating the total period of Kirschstein-NRSA support and establishing the amount of payback obligation, if any, and is required in lieu of a final progress report for NRSA fellowship recipients. The final Federal Financial Report (SF 425) and the Final Invention Statement & Certification (HHS 568) are also not required for NRSA fellowship awards. The ICO must confirm the recipient fulfilled all payback requirements prior to closing the file. (See NIH Manual 54810 for specific details on payback.)
   
   The FFR-C will provide CGMOs with a report of all fellowship award documents that are open in PMS with performance period end dates of 270 days or greater. After reviewing the report, CGMOs should notify the FFR-C if any of the listed fellowship documents are in the process of being terminated and should be removed from the report. After ICO review has been completed, FFR-C will send the report to eRA with a request to close all of the fellowship award documents with 05925 transactions in the amount of the remaining balance.
   
   Closeout of Institutional Training Grants – Institutional training grants do not require a Final Invention Statement & Certification (HHS 568), but all other reporting requirements apply. Termination Notices (Form PHS 416-7) for all appointed trainees are required upon completion of a National Research Service Award (NRSA) institutional training award. At the end of the period of support, ICOs are required to confirm the recipient submitted a Termination Notice (Form PHS 416-7) through the eRA Commons xTrain application within 30 days of the termination date.  
5. Requirements for Annual Review of Award Unobligated Balances and Certification 
   
   No later than September 30th of each fiscal year, ICOs must complete a review of all awards with an expired period of performance to determine the validity of any remaining unobligated balances and provide a certification to the OPERA FFR-C.
6. Retention of Records
   
   All federal records pertaining to this manual chapter must be retained and disposed of under the authority of NIH Manual 1743, “Managing Federal Records,” Appendix 4, Records Management Resources. These records must be maintained in accordance with current NIH Records Management and federal guidelines.  
   
   NIH email messages, including attachments created on NIH information systems or transmitted over NIH networks, are evidence of the agency's activities with informational value and are considered federal records. All federal records must be maintained in accordance with current HHS / NIH Records Management guidelines. 
   
   Records, including but not limited to email, social media, and voice mail messages, are considered federal government property and, if requested for a legitimate government purpose, i.e., Litigation, Freedom of Information Act (FOIA) requests, etc., must be provided to the requester, employees' supervisor, NIH personnel conducting official reviews or investigations, and the Office of Inspector General (OIG) who may request access to or copies of records.  
   
   Regardless of the media, records must be provided to Congressional oversight committees if requested and are subject to Freedom of Information Act (FOIA) requests. All copies, including backup files, are subject to the exact information requests as original messages and documents. 
   
   All relevant record schedule descriptions and instructions are located in the NIH Record Schedule System (RSS), an online repository that is the authoritative source for all NIH Record Schedules. The RSS incorporates the National Archives and Records Administration (NARA) General Records Schedule (GRS). Each GRS schedule item has been cross-walked to associate with a current NIH Records Schedule. The NIH RSS can be located at the following link: https://records.nih.gov/home. Please note that authenticated identity via a VPN connection is required to access the system. 
   
   Contact the appropriate NIH Institute, Center, Office (ICO) Records Liaison, or the NIH Records Officer for additional information.
    

1. OPERA
   1. Director of OPERA or designee
      1. Approve deviations, as required.
      2. Issue notifications to ICOs when unilateral closeout actions are not completed timely.
   2. Division of Grants Compliance and Oversight (DGCO)
      1. Monitor ICOs actions to comply with unilateral closeout requirements and generate letters to ICOs that are noncompliant with those requirements.
      2. Provide compliance guidance to ICOs.
      3. Maintain template letters for unilateral closeout actions.
      4. Report on the recipient's failure to comply with the terms and conditions of award in the SAM.gov Responsibility/Qualification section.
   3. FFR Reconciliation and Financial Closeout Center (FFR-C)
      1. Perform the financial closeout of an award no later than one year after the end date of the period of performance, if the grant will not be extended or after termination, as provided in 2 CFR Part 200.339 through 200.343.  The FFR-C will close the award in the Payment Management System (PMS) (i.e., generate a closed code [TC-059] as indicated under “Document Status”).  The FFR-C performs the following closeout tasks:
         • Receive, review and reconcile Annual and Final FFRs.
         • Submit closing transactions (059) to PMS as part of Final FFR reconciliation and processing.
         • Review Fellowship awards (FFR not required) after termination notice received and will submit closing transactions (059) to PMS.
         • Send standardized follow-up letters to recipients through the GCM, as needed, to obtain delinquent required FFRs.
         • Reconcile transactions between the NIH Business System and the HHS Payment Management System to ensure compliance with financial reporting requirements.
         • Generate and provide report to CGMOs containing open fellowship award documents and documents where the final FFR has either not been received or has been rejected and not re-submitted by the recipient within 30 days for awards open in PMS with performance period end dates of 270 days or greater.
         • Review and approve late drawdown requests (in coordination with the ICOs and the OPERA Director).
   4. OPERA Closeout Center
      1. The OPERA Closeout Center is the central hub for Administrative Closeout requirements across NIH. As such, the staff monitor submission of final reports (i.e., FRPPR, FFR, FIS, Termination Notice for fellowships and training grants).
      2. Send standardized follow-up letters to recipients through the GCM, as needed, to obtain delinquent final reports and monitor responses.
      3. Generate and send reports to ICOs provided updates regarding closeout status and grants entering unilateral closeout.
      4. Monitor grant activities and engage ICO grants management staff, ICO program staff, and recipients to make every attempt to receive final reports from recipients and administratively close grants in the eRA systems through the GCM.
      5. Manually add awards to the GCM for closeout as needed.
2. ICO Staff
   1. Grants Management Official
      1. Document all closeout decisions and save supporting documentation of review, correspondence, and any corrective actions related to the closeout process in the official grant folder.
      2. Retain and dispose of all grant-related records in accordance with the NARA approved Records Retention Schedules as outlined in the NIH Records Schedule System (RSS).
      3. Execute administrative or unilateral closeout actions as appropriate for grants that exceed 180-days beyond the period of performance end date.
      4. Initiate unilateral closeout if a recipient does not provide timely accurate closeout reports or does not respond timely to NIH requests to reconcile discrepancies in grant records.
      5. Determine and document appropriate actions for the awarding ICO to take when a recipient fails to submit timely and accurate closeout documents or fails to correct recurring reporting problems.
      6. Monitor ICO compliance with all closeout requirements.
      7. Instruct recipients on the appropriate accounting adjustment of unobligated balances, when applicable.
      8. Complete a review of all awards with an expired period of performance to determine the validity of any remaining unobligated balances by September 30th of each fiscal year and subsequently certify these details to OPERA FFRC.
   2. NIH Program Official
      1. Review the FRPPR within 14 days of receipt and document whether sufficient progress has been made during the reporting period, requesting additional information from the recipient, as needed.
          

1. 2 CFR Part 200.344- Closeout
2. NIH Grants Policy Statement Section 8.6: Closeout
3. NIH intranet webpage on Closeout policies
4. 2 CFR Part 200.339 through 200.343- Remedies for Noncompliance
5. OER Policy Announcement 1997-02, " Single-Case Deviation from PHS/NIH Grants Policy"
6. NIH Grants Policy Statement Section 8.4.2: Record Retention and Access
7. NOT-OD-23-086: Updated Process for Requesting Drawdowns Outside of the Liquidation Period
8. NIH Manual Chapter 54810, “National Research Service Awards”
9. NIH Manual Chapter 1743, “Managing Federal Records”
10. HHS Financial Management Directives & Guidance Volume II, Chapter 12: Undelivered Orders