3.5 Grant Closeout

3.5.1 Grant Closeout

Effective date: October 12, 2019

Background

Recipients and subrecipients of DOL grant awards are responsible for developing a closeout process that will be used to close out their sub-awards and contract agreements. In accordance with the requirements of Uniform Guidance Section 200.343, this policy addresses the steps DWD-DET will take in order to close out a grant agreement. The WIOA closeout period refers to the 60-day period after a grant agreement has reached its term end date or its funding has been fully utilized.

The purpose of the financial reconciliation/closeout is to ensure allowable reportable costs and payments are equal.

Closeout Procedures

To closeout a grant effectively and to avoid cost overruns and deficits, DWD-DET has established the following procedures:

1. A final expenditure report must be submitted in COMET within 60 calendar days of the grant end date.
2. Unless authorized by DWD-DET, subrecipients must liquidate all accruals incurred under DWD-DET's award(s) no later than 60 calendar days following the expiration of the grant term.
3. A final invoice must be submitted to DWD-DET for any cash requests within 60 calendar days of the grant end date.
4. Program income earned shall be fully expended or remitted to DWD-DET.
5. DWD-DET will review each grant during the WIOA closeout period or once funding has been fully utilized and determine:
   
   1. Total expenditures reported in COMET
   2. Percentage of Administrative funds spent in relation to Program funds where applicable
   3. Reporting and performance of memo line activities
   4. Total cash requested in STAR
   5. Purchase Order balances
   6. Any un-obligated funds
6. DWD-DET Contract Manager will initiate closeout procedures with all subrecipients by sending a closeout packet for review.
7. Subrecipients must terminate all activities and reconcile all financial activity related to the grant/award prior to closing the grant with DWD-DET.
8. Boards must review the closeout packet and reconcile with their records
   
   1. If reconciliation ties out, the subrecipient must sign the grant closeout worksheet and return it to DWD-DET Contract Manager along with the General Ledger Trial Balance report within five (5) business days of receiving the closeout packet.
   2. If a discrepancy is noted, the subrecipient must respond to DWD-DET within 10 business days providing details and supporting documentation regarding the discrepancy.
9. All refunds due to DWD-DET must be made before the closeout or submitted with the closeout packet within the five (5) business days timeframe.

Closeout Packet

The closeout packet will include:

1. Grant Closeout Worksheet
2. STAR Payment Confirmation Report
3. STAR Purchase Order Balance Report
4. COMET Expenditure Report

Post Closeout

The closeout of an award does not affect the following:

1. The right of DWD-DET to disallow costs and recover funds on the basis of a later audit or other review.
2. The obligation of the grant recipient to return any funds due as a result of later refunds, corrections, or other transactions.
3. Record retention requirements.

DWD-DET will not be liable for any costs the subrecipient failed to pay before the closeout date. Additionally, DWD-DET will not be liable for any late claims received by subrecipients. DWD-DET will not have funds available for those claims.

The subrecipient shall ensure that all program/grant liabilities are paid before the closeout date. No unpaid bill can be paid with the federal funds after closeout. Any such bills will have to be paid by the subrecipient from other non-federal funds.