CGMS 100%

Study grouping: Grant Award

Lesson 8: Closeout

Finishing a grant properly, on the deadlines that actually apply · 14 practice questions

0:00 / --:--

Reading

Closeout is the formal end of a grant, the point at which the recipient (or subrecipient) has finished the work, submitted its final paperwork, and settled every financial obligation tied to the award. 2 CFR 200.344 governs closeout, and its deadlines are specific, and specific numbers are exactly the kind of detail a rushed grants manager gets wrong under pressure at the end of a project.

The closeout deadlines: 120 days, 90 days

Under 200.344, a recipient must submit all required closeout reports, and settle all outstanding financial obligations, no later than 120 calendar days after the conclusion of the period of performance. A subrecipient reporting to a pass-through entity works on a shorter clock, 90 calendar days after the subaward's period of performance ends (or an earlier date agreed with the pass-through entity), which in practice leaves the pass-through entity time to roll subrecipient information into its own 120-day closeout package. When justified, the federal agency or pass-through entity may approve extensions, but neither is automatic; an organization that expects to need more time should ask for an extension before the deadline passes, not after.

What "settling financial obligations" covers

Closeout is not only paperwork, it requires liquidating (paying off and finalizing) every financial obligation tied to the award within the same 120-day (or 90-day, for a subrecipient) window. That includes paying final invoices, resolving any outstanding cost questions, and making sure the accounting records reconcile to what was actually drawn down and spent. Costs of administrative closeout can be incurred until the due date of the final reports, but they must be liquidated before that date (200.403(h)).

Unobligated funds must be returned

Any federal funds that were paid to the recipient or subrecipient but never obligated, and that the organization is not authorized to keep, must be promptly refunded to the federal agency or pass-through entity that paid them. Sitting on unspent, unobligated federal money past closeout is not a minor administrative lapse, it is federal funds the organization has no authority to hold.

Property still has to be accounted for

If the award funded the purchase of property or equipment, or the organization received government property to carry out the work, closeout requires that property to be accounted for consistent with the property management rules elsewhere in 2 CFR 200 (Subpart D's property standards, sections 200.310 through 200.316, and 200.330, which covers reporting on real property). Closeout does not erase the property recordkeeping requirement: 200.344(g) expressly requires property acquired with federal funds, or received from the federal government, to be accounted for under those sections.

The one-year outer boundary for the federal agency

200.344 also puts a target on the federal agency's own side of closeout: the federal awarding agency is expected to make every effort to complete all closeout actions no later than one year after the end of the period of performance. This is framed as an expectation for the agency to complete its own closeout review and sign-off, not a deadline the recipient itself is racing against, the recipient's own deadlines are the 120- and 90-day figures above.

Why closeout connects back to everything already covered

Closeout is where every earlier domain converges. The final performance report due at closeout is built on the same reporting discipline from lesson 4 (financial data connected to program accomplishments). Any indirect costs charged in the award's final months have to meet the same 200.403 allowability factors from lesson 2. Property purchased mid-award has to be accounted for using the same rules referenced here. And a pass-through entity closing out its own award to a federal agency has to have already collected clean closeout information from every subrecipient it oversees, tying back to lesson 6's monitoring duties. A grants manager who treats closeout as a separate, late-stage task disconnected from everything that came before will find the 120-day window is not nearly long enough to fix problems that should have been caught earlier.

Closeout deadlines under 2 CFR 200.344 A timeline from the end of the period of performance: subrecipients have 90 days to submit final reports and settle obligations to their pass-through entity; recipients have 120 days to submit final reports and settle obligations to the federal agency; unobligated funds must be promptly refunded; property must be accounted for; and the federal agency targets completing all closeout actions within one year. Period ends 90 days Subrecipient deadline 120 days Recipient deadline 1 year Agency closeouttarget Reports submitted, obligations settled, unobligated funds refunded, property accounted for, all within the deadline that applies
Subrecipients close out to their pass-through entity in 90 days; the pass-through entity (or a direct recipient) closes out to the federal agency in 120 days, giving the shorter subrecipient window time to roll up into the longer one.

Practice questions

1. Under 2 CFR 200.344, how many calendar days does a direct recipient have to submit all closeout reports and settle financial obligations after the period of performance ends?

  1. 30 days
  2. 90 days
  3. 120 days
  4. 365 days

2. How many calendar days does a subrecipient have to complete the same closeout steps, reporting to its pass-through entity?

  1. 120 days
  2. 90 days
  3. 30 days
  4. 180 days

3. Are the 120-day and 90-day closeout deadlines ever extendable?

  1. Yes, when justified and approved, so an extension should be requested before the deadline passes
  2. No, both deadlines are absolute and the agency has no authority to approve an extension for any reason
  3. Only the 90-day subrecipient deadline can be extended, never the 120-day recipient deadline, under any circumstances
  4. Yes, extensions are granted automatically to every organization that simply asks for more time in writing

4. What must happen to federal funds that were paid out but never obligated, and that the organization has no authority to keep?

  1. They can be kept as a reserve for the organization's next federal award, if it is in the same program
  2. They can be transferred to a different federal program the organization already administers, without approval
  3. They can be held for one more year and refunded with the next annual report, as long as they are tracked
  4. They must be promptly refunded to the federal agency or pass-through entity that paid them

5. Does closeout eliminate the requirement to account for property purchased with federal funds?

  1. Yes, property records can be discarded once the closeout reports are filed and accepted
  2. No, 200.344(g) still requires property acquired with federal funds to be accounted for under the property standards
  3. Property accounting only applies to construction awards and real property acquisitions
  4. Property accounting is optional at the recipient's discretion once the period of performance ends

6. What is the federal awarding agency's own target for completing all closeout actions on its side?

  1. No later than one year after the end of the period of performance
  2. Within 30 days of the recipient's submission of its final reports, whichever date is earlier
  3. Within 120 days, identical to the recipient's own deadline, so both close out together
  4. There is no target; agencies may take as long as they wish, with no stated expectation

7. What is the practical effect of a subrecipient's closeout deadline falling 30 days before a direct recipient's deadline?

  1. It has no functional effect; the pass-through entity's own closeout is unaffected by when its subrecipients report
  2. Subrecipients are penalized with a shorter window because they are presumed less trustworthy than direct recipients
  3. It leaves the pass-through entity time to roll subrecipient closeout information into its own 120-day submission
  4. Subrecipients always have smaller awards, which close out faster than larger awards do under the closeout rule

8. Which of the following is part of "settling financial obligations" at closeout?

  1. Only submitting a final narrative report, with no financial reconciliation required
  2. Paying final invoices, resolving outstanding cost questions, and reconciling accounting records to actual drawdowns and spending
  3. Only refunding 10 percent of unspent funds
  4. Financial obligations are settled automatically once the period of performance ends, with no action needed

9. Which section of 2 CFR 200 governs closeout?

  1. 200.318
  2. 200.403
  3. 200.512
  4. 200.344

10. A grants manager waits until the 118th day of the 120-day closeout window to discover unresolved cost questions on the award. What does this scenario illustrate?

  1. Closeout problems usually trace back to issues that should have been caught earlier, not left to the deadline
  2. This is a normal and expected way to run closeout, since the full 120 days is meant to be used for discovery of problems
  3. The 120-day window exists specifically to allow last-minute discoveries like this to be fixed at the very end of the award
  4. Nothing; the deadline is only advisory and can be moved by the grants manager without any agency approval

11. GCHS is closing out a subgrant it made to a partner nonprofit. Whose closeout deadline governs when GCHS needs the subrecipient's final numbers in hand?

  1. The subrecipient has no deadline of its own; only GCHS's 120-day deadline to the federal agency applies to the subaward
  2. The subrecipient's 90-day deadline to GCHS, which leaves GCHS time before its own 120-day deadline
  3. Both deadlines are 120 days, identical, because the subaward and the prime award share one closeout date
  4. The subrecipient has one year, matching the federal agency's own target for completing closeout actions

12. How does this course group closeout among NGMA's four exam domains?

  1. Grant Guidance only, since closeout is a pre-award planning topic covered in the notice of funding opportunity
  2. Mainly Grant Award, as the last stage of the award lifecycle, drawing on the other domains too
  3. Fiscal Management only, since closeout consists entirely of financial reconciliation and refunds
  4. None of the four domains address closeout, so the course leaves it ungrouped and unassigned

13. If final closeout reporting deadlines mirror the reporting deadlines discussed in lesson 4, what should a grants manager expect the final performance report deadline to be for a direct recipient?

  1. 120 days after the period of performance ends, per 200.329(c) and 200.344(b)
  2. 30 days, unrelated to the closeout deadline, so it can be filed well before financial reports
  3. One year, matching the federal agency's own target for finishing its closeout actions
  4. There is no deadline for a final performance report as long as financial reports are on time

14. What is the practical risk of treating closeout as an isolated, late-stage task disconnected from how the award was managed throughout its life?

  1. There is no risk; closeout is entirely independent of earlier award management
  2. Closeout automatically corrects any earlier compliance problems
  3. The 120- (or 90-) day window is rarely long enough to fix problems, unresolved cost questions, missing documentation, incomplete monitoring records, that should have been caught earlier
  4. Closeout has no deadlines, so there is no real risk either way

Glossary

Closeout
The formal end of a grant: final reports submitted, financial obligations settled, unobligated funds refunded, and property accounted for.
2 CFR 200.344
The Uniform Guidance section governing closeout, including its 120-day (recipient) and 90-day (subrecipient) deadlines.
Unobligated funds
Federal funds paid out but never committed to an allowable purpose; must be promptly refunded if the organization has no authority to keep them.
Period of performance
The window of dates during which costs may be incurred under an award; closeout deadlines are measured from its end.
Previous lesson Back to course Mark lesson complete Next lesson