Consulting Services • Published 3/27/2023 Closeout of Grant Programs: Best Practices for Timely and Efficient Closeout

When you reach the closeout process of your grant-funded program, it signifies that you are nearing the end of your project performance period. While every part of the grant life cycle is important, the closeout phase is essential to a successful program and future opportunities for funding. Every recipient of federal funds is required to perform certain closeout activities to administratively and fiscally close out a program with the federal funding agency.

Properly closing out your program allows you to: 

• Show that your organization has been a good steward of federal funds (final programmatic reports, final administrative reports, final financial reports, and accounting for real and personal property). 
• Demonstrate compliance with OMB 2 CFR Subpart D § 200.344 and your specific federal funding agency requirements. 
• Set the stage for your organization to achieve future grant success. 

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Key project closeout principles 

Closing down a project can be complicated, but planning for closeout long before the deadline can help support a smooth and complete process for your team. Consider these five principles from pre- to post-closeout: 

1. Pre-closeout: As your program approaches closeout, review the closeout terms and conditions listed in the Notice of Award you received at the time of funding.  
2. Standardizing the process: When possible, standardize your closeout process across grant programs. Diverse programs will have different objectives and requirements, which can result in competing priorities and deadlines that strain staff and fiscal resources.  
3. Starting grant program closeout: Begin your closeout process early and plan for adequate time to collect all programmatic, administrative, and fiscal documents and data ahead of the submission due date: 120 calendar days after the end of the performance period.  
4. Subrecipients’ role in the grant program closeout process: Be sure to communicate with your subrecipients at least 90 days before the end of your performance period and continue to include them in the closeout timeline and submission process.  
5. Post-closeout record retention: After you submit your final closeout documents, you must adhere to the record retention policy and retain documents as outlined in your state and federal guidelines. 

Every recipient of federal funds is required to perform certain closeout activities.

The risks of not planning properly for closeout 

Depending on the number of federal awards your agency received, it could be easy to miss the deadline, or worse, fail to properly close out the grant and risk being reported to the Federal Awardee Integrity Information System (FAPIIS). Noncompliance could put your organization in a position to return money to the federal government or jeopardize future funding opportunities, so be sure to: 

• Liquidate all financial obligations and submit accurate final reports. 
• Account for all real and personal inventory properly. 
• Reconcile all expenditures and disbursements. 
• Communicate with your subrecipients and share expectations on their role in the grant closeout process. 

Help is available 

The grant closeout is a critical piece in the life cycle of a grant and grants management. Many federal programs funded during the pandemic, including the CARES Act and the American Rescue Plan, are coming to an end and will require resources to complete the closeout properly.

P&N has extensive experience in auditing, grants administration, reconciliation, and closeout of FEMA Public Assistance, HUD CDBG-DR, and many other sources of grant funds. Our team members have a deep understanding of the closeout process as outlined in Title 2 U.S. Code of Federal Regulations Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Contact us for assistance if you have questions about the grant closeout process.