Agreement Closeout

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Pertinent Regulations


When an award expires (the performance period runs out), federal funders require certain closeout actions to formalize the completion of the agreement.

Private funders seldom require closeout documentation, but note that they may.

Federal requirements for award closeout are stated at § 200.343 Closeout.. USAID publishes its internal guidance on the topic at ADS Chapter 303.5.i.

You will generally want to begin your closeout actions at least 60 days before the project is due to end.

Typical closeout actions required by federal funders (using USAID as the example) are the following:

  • Review your organization’s closeout checklist. (Don’t have one of these? write me for a suggestion.)
  • Prepare a full inventory of tangible property obtained under the award. Review this inventory to determine what property will require disposition instructions from the AO. Make a disposition plan. You should have a property management policy that enables you to produce the required inventory; see Notes on Property Management Policy. For a discussion of some of the issues commonly encountered in disposing of residual property, see Property Management Issues.
  • If you have reportable residual property (of either kind – tangible or intangible), correspond with the AO prior to the end date of the award to communicate your property disposition plan. Obtain the AO’s approval of this plan.
  • By the end date of the award, terminate any staff employment agreements that need terminating (see Notes on HR Policies and Termination Costs (Severance)), terminate all outstanding leases and rental agreements, dispose of all property, close all bank accounts, and depart the country. (You may not actually be leaving the country. NGO’s often aim to win awards that allow them to continue operations in a given country. So not all of this paragraph necessarily applies. In any case, analyze the situation to determine just what you need to do here.)
  • Submit final narrative (programmatic) report within 90 days following the last day of the performance period, in accordance with the instructions in your award agreement. Keep records of these transmissions.
  • Submit “preliminary final” financial report within 90 days following the last day of the performance period. Note that you probably can’t produce a truly “final” financial report until your NICRA rates are finalized following completion of your of the year in which the project closes. See About the NICRA and Audit Basics.

Eventually, the AO will send your organization a letter asking you to certify that you’ve completed all the required closeout activities. Typically, the letter will ask for the following certifications:

  • that all program reporting has been submitted;
  • that your indirect cost allocation rates have been finalized with the funder;
  • that the final financial report (based on final rates for all years) has been submitted and that your organization has received all the funds that are due under the award (and returned all unliquidated advances, if any);
  • that (and how) you’ve disposed of all residual tangible personal property acquired under the award, in compliance with the terms and conditions of the award agreement; and
  • that (and how) you’ve disposed of all intangible property acquired under the award.

In addition to the above, you will also submit two certifications: Indirect Cost Rate Certification, and Audit Certification. (Examples of these certs for USAID are in ADS Chapter 303.5.i. Other federal funders will have similar certifications.)

Often, you won’t have received your final NICRA rates for the final year of the project at the time you receive the AO’s closeout letter. When that’s the case, you should do everything else that you can (from the list above) and advise the AO when you anticipate having final (audited) rates. Eventually, you will receive final rates and will then be able to complete the closeout of the award. See more on this topic at About the NICRA.

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