Step 6 - Closeout of Agreements
To comply with federal regulations, a formal project closeout consists of the following steps:
In order to explain the closeout process, the Office of Research will contact the Principal Investigator 60 days prior to the end of the project.
The Principal Investigator is responsible for initiating requests for extensions by the funding agency via the Office of Research using the Administrative Action Request Form. Prior to requesting the extension, an assessment of the budget status and the timeframe in which to complete the expenditures should be addressed with the Office of Research. This will help assure that all fiscal matters, including matching, are appropriately considered in the request for an extension.
Accounts will be made inactive after the project termination date. The principal investigator will work with the Office of Research to ensure that all transactions are completed and charged to the accounts prior to the prescribed sponsor deadline.
Programmatic reports due to the funding agency at the close of the grant are the responsibility of the project director.
All contract and grant funds awarded to the University are subject to audit. Audits may be performed at multiple levels including the:
- University Internal Auditor
- Office of the State Auditor
- Federal Auditors
- Public Auditors
Focal Point for Audit Matters
The Office of Research is responsible for coordinating all audit matters related to sponsored research of the University. Federal, state, and public firm auditors must make their initial contact with the Office of Research. Subsequent contacts by auditors with other University departments will be preceded by advance notice from the Office of Research. The purpose of the advance contact is to identify the auditors, outline the general purpose of the visit, and facilitate the audit. Questions concerning the official status of an auditor should be referred to the Office of Research.
Grants Accounting Administration Representation
Depending upon the nature of the audit or subject matter, the Office of Research may elect to be represented in audit discussions at the departmental level. Should departmental personnel require guidance at any time, the Office of Research must be contacted without hesitation. The Office of Research participates in and coordinates audit exit briefing as deemed necessary by the significance and nature of the audit findings and recommendations.
Right of Access
Under the legal terms of grants and contracts awards, auditors have the right of access to all official University records associated with an award. The University is obligated to make such records readily available for examination.
At the conclusion of an audit and prior to the issuance of the formal report, auditors normally conduct an exit conference. The purpose of this meeting is to review audit findings and tentative conclusions, exceptions, and recommendations. At this meeting, the University has an opportunity to comment on the audit findings and to provide additional information where appropriate.
The Office of Research is responsible for coordinating the University’s response to audits of contracts and grants. This responsibility in no way relieves the Principal Investigator or department concerned from providing necessary input in a timely manner or from resolving financial liability, which may ultimately be assessed as a result of audit exceptions. The University’s response must be coordinated through established channels. Under no circumstances may a department or individual initiate a direct response to an audit.
Financial responsibility for audit disallowances rests with the Principal Investigator, department, and college having primary responsibility for the project on which costs are questioned. Disallowances cannot be charged to any federal or state-funded accounts. Personal liability may be considered and assessed when an audit disallowance stemmed from gross negligence or malfeasance on the part of an employee or staff member.
The preparation, sharing, and retention of appropriate records are essential components of any research endeavor at Kennesaw State University. The University, its faculty, and its trainees have a common interest and a shared responsibility to assure that research is appropriately recorded, shared, and retained. Furthermore, the USG Board of Regents records retention policy requires that records related to “funded research grant proposals, and research activity associated with grant-funded projects” be archived.
Original records may be required to:
- protect the University’s intellectual property rights,
- answer ongoing questions regarding the management of a research program,
- address possible questions that may arise regarding the propriety of research conduct,
- comply with the data sharing requirements of many sponsors (e.g., NIH).
Most importantly, it is essential that original research records be mutually available to all the collaborators on a research project.
Research records include, by way of example but not limitation, material contained in research notes, in laboratory notebooks, and in other media, such as computer disks and instrument printouts. Significant research materials or products generated by any research are also part of the record and should be retained and available. Research records must be available to collaborators (co-investigators, supervisors, and their trainees). In collaborative projects, all investigators should know the status of all contributing research records and have access to them consistent with confidentiality restrictions. Investigators also should be aware if their research records are subject to specific data sharing requirements of a sponsor.
Faculty members, or the responsible investigators, have the obligation to ensure that, for all aspects of their research programs, sufficient records are kept to document the experimental methods and accuracy of data collection as well as the methods and accuracy of data interpretation. This policy does not create an obligation to retain the research records of an unfunded project unless it results in publication or involves the use of animals or human subjects. The original research records should be archived for a minimum of seven years after final reporting or publication of a project (or longer if required by an external sponsor, law, rule, or regulation). In addition, the records should be kept for as long as may be required to protect any patents resulting from the work. If questions regarding the research are raised during the required retention period, the records must be retained until all the questions are fully resolved. In the event an investigator leaves Kennesaw State University for any reason, the original research records must be retained at the University and the investigator’s department and collaborators notified as to their location.
Kennesaw State University is the primary owner of research records. The University has the right of access to the supporting records for all research carried out through the University with the understanding that information or data that would violate the confidentiality of sources or subjects involved in the research should not be disclosed. In addition, extramural sponsors providing support for research at the University may have the right to review any data and records resulting from that extramural support.