0601 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) policies for closeout and post-closeout activities associated with Federal financial assistance for Grants Program Offices (GPOs).

Key items covered in this chapter include:

• GPOs will comply with grants management requirements for closeout as described in 2 C.F.R. § 200.344-346;
• GPOs will close Federal awards when they determine that all administrative actions and required work of the Federal award have been completed;
• GPOs will make every effort to complete all closeout actions no later than one year after the end of the period of performance; and
• GPOs will require recipients to adhere to timelines for final reports or approve extensions when justified.

0602 Revisions

Section	Revision	Office	Reason for Change	Effective Date
Various	Updated to align with the 2024 updated Uniform Grant Guidance at 2 C.F.R.  Part 200 and to incorporate references to new guidance where appropriate.	OBO- GMS (045)	The Office of Management and Budget (OMB) released revisions to Title 2 of the C.F.R. for Federal financial assistance in April 2024.	March 2026
060506	Updated name of section from GONE act to Agency Financial Report and other language	OBO- GMS (045)	Reflect expiration of GONE Act and provide information on current requirements.	March 2026

For a complete list of previous policy revisions, see Appendix A.

0603 Definitions

Closeout – the process by which the Federal agency or pass-through entity determines that all applicable administrative actions and all required work of the Federal award have been completed and takes actions as described in 2 C.F.R. § 200.344.

Disallowed costs – charges to a Federal award that the Federal agency or pass-through entity determines to be unallowable, in accordance with the applicable Federal statutes, regulations, 2 C.F.R. Part 200, or the terms and conditions of the Federal award.

Period of performance – the time interval between the start and end date of a Federal award, which may include one or more budget periods. The period of performance listed in the Federal award does not commit the Federal agency to fund the award beyond the currently approved budget period.

0604 Roles and Responsibilities

Financial Service Center (FSC) is responsible for working with specific GPOs for accounting and fund reconciliation and collecting grant information to include in the VA’s Agency Financial Report (AFR).

Office of Financial Reporting (OFR) is responsible for preparing and submitting VA’s financial statements and related financial information in accordance with the laws and regulations of the United States Government. OFR ensures proper accounting, reporting, and consolidation of data.

Grant Program Office (GPO) is responsible for programmatic administration of a particular grant program.

0605  Policies

060501 General Policies

1. In accordance with 2 C.F.R. § 200.344, GPOs will close an award when it determines that the recipient has completed all applicable administrative actions and required work.
2. In accordance with 2 C.F.R. § 200.344(c), GPOs must ensure that the recipient liquidates all financial obligations incurred under the Federal award no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must liquidate all financial obligations incurred under a subaward no later than 90 calendar days after the conclusion of the period of performance of the subaward.
3. In accordance with 2 C.F.R. § 200.344(h), GPOs must make every effort to complete all closeout actions no later than one year after the end of the period of performance, unless an authorizing statute directs otherwise.
4. GPOs will coordinate with all necessary parties to complete closeout actions. This may involve multiple VA offices (e.g., GPO, finance, property, Financial Service Center (FSC)), as well as other federal agencies (e.g., Health and Human Services (HHS)).
5. In accordance with 2 C.F.R. § 200.344(b), GPOs will require:
   1. Recipients to submit reports (financial, performance, and other reports required by the Federal award) no later than 120 calendar days after the conclusion of the period of performance.
   2. Subrecipients to submit required reports to the recipient or pass-through entity no later than 90 calendar days after the conclusion of the period of performance of the subaward.
6. In accordance with 2 C.F.R. § 200.344, GPOs may approve reporting deadline extensions when requested and justified by the recipient. GPOs may also approve extensions for liquidation but should be aware of, and stay within, VA and individual Administration timelines.
7. GPOs must ensure that recipients liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the conclusion of the period of performance.
8. GPOs will notify grant recipients that subrecipients must liquidate all financial obligations incurred under a subaward no later than 90 calendar days after the conclusion of the period of performance of the subaward.
9. In accordance with 2 C.F.R. § 200.403(h) and 2 C.F.R. § 200.472(b), GPOs must reimburse for allowable administrative costs associated with the closeout activities of a Federal award even if the costs were incurred after the period of performance end date. However, these costs must be incurred before the due date of the final report.

Refer to VA financial policy Volume XII, Chapter 9 Collection of Debts for additional details.

060502 Receipt and Review of Reports

1. GPOs will notify recipients of required deliverables ahead of their due date.
2. GPOs must collect final reports from recipients no later than 120 calendar days after the conclusion of the period of performance, unless the GPO has approved an extension request.
3. GPOs will take timely action to obtain reports not submitted within 120-day period after the conclusion of the period of performance.
4. Final reports may include but are not limited to:
   • Financial reports,
   • Performance reports, and
   • Other reports required by the terms and conditions of the Federal award or as specified by the program office.
5. GPOs will receive, read, and evaluate all required final reports. Actions with respect to outstanding annual or other periodic reports should be resolved prior to closeout as part of monitoring and enforcement, as specified in Volume X Chapter 5 – Grants Post Award.
6. Consistent with grant monitoring throughout the performance period, GPOs will reconcile recipient financial records with final reports. As part of the reconciliation process, GPOs must ensure that all payments owed to the recipient are paid, and that any unused (i.e., unobligated by the recipient) funds previously provided to the recipient are promptly returned to the VA; unless VA has authorized that the funds may be retained. For example, GPOs can ensure the amounts reported in the recipient’s SF-425 (Federal Financial Report) agree with those in VA’s accounting systems and the Payment Management System, if applicable.
7. GPOs must ensure, as part of the closeout reconciliation, that a recipient has accounted for any property acquired with Federal funds or received from the Federal government in accordance with 2 C.F.R. § 200.310 through § 200.316 and § 200.330. GPOs should provide instructions for disposition of equipment prior to closeout.
8. If a recipient does not comply with VA’s closeout requirements, including submitting all final reports, GPOs must report the recipient’s material failure to comply with terms and conditions of the Federal award in the System for Award Management (SAM.gov.) GPOs must use the Contractor Performance Assessment Reporting System (CPARS) to enter or amend information in SAM.gov. GPOs may also pursue other enforcement actions outlined in 2 C.F.R. § 200.339, as appropriate.
9. In accordance with 2 C.F.R. § 200.344(a), if the recipient fails to complete the necessary administrative actions or the required work for an award, GPOs must still proceed with closeout based on the information available.

060503 Extension Requests

1. GPOs must monitor recipient performance closely throughout the award period to minimize delays to the closeout process and limit extension requests.
2. GPOs may approve extensions for liquidation but should be aware of and stay within VA and individual administration timelines.
3. Recipients must provide adequate justification to support extension requests for final reports.
4. GPOs shall ensure that granting an extension request will not conflict with VA timelines. For example, extensions must not exceed the five-year expiration of funds limit on fixed appropriations (31 U.S.C. § 1552).

060504  Post Closeout Responsibilities

1. The closeout of a Federal award does not affect:
   1. GPOs right to recover funds from disallowed costs identified by audit or review, as long as recipients are notified within the record retention period.
   2. A recipient’s requirement to return funds or right to receive any remaining available funds as a result of refunds, corrections, final indirect cost rate adjustments, or other transactions.
   3. GPOs ability to make financial adjustments (e.g., correcting indirect cost payments or making a final payment).
   4. A recipient’s requirement to fulfill audit requirements as outlined in 2 C.F.R. 200 Subpart F.
   5. Property management and disposition requirements in 2 C.F.R. §§ 200.310 through 200.316.
   6. Records retention requirements as required in 2 C.F.R. §§ 200.334 through 200.337.
2. In accordance with 2 C.F.R. § 200.345(b), after the closeout of an award, the relationship created under the Federal award may be modified or ended in whole or in part. This can only be done with the consent of the Federal agency and the recipient.
3. GPOs will determine the nature of any continuing requirements by recipients. These may include inventory reporting, accountability for program income earned after the period of grant support, real and personal property requirements, including the use of property in which the Federal government has an interest, and receipt of audits completed subsequent to the end of grant support. GPOs will communicate continuing requirements to the recipient in writing.

060505  Collection of Amounts Due

1. Any Federal funds paid to the recipient in excess of the amount determined to be entitled under the terms of the Federal award constitutes a debt to the Federal government.
2. In accordance with 2 C.F.R. § 200.346, VA must collect all debts arising out of its Federal awards in accordance with the Standards for the Administrative Collection of Claims (31 C.F.R. part 901).
3. GPOs will follow VA Financial Policy Volume XII, Chapter 9 – Collection of Debts as well as their administration’s process on debt collection, which may include administrative offset against other requests for reimbursements, withholding advance payments otherwise due to the recipient, or other actions permitted by the program statute or regulations.

060506  Agency Financial Reporting

1. In accordance with OMB A-136, GPOs will complete required government-wide reporting.
2. Office of Financial Reporting (OFR) compiles OMB A-136 required grant data, which includes a high-level summary of expired, but not closed, Federal grants and cooperative agreements. The summary will include:
   1. The total number of awards and balances for which closeout has not yet occurred, but for which the period of performance has elapsed by two years or more prior to September 30 of that year;
   2. A brief narrative for each award included in the summary describing the progress made over the past year compared to the previous year;
   3. An explanation of the difficulties encountered relative to closing each of the expired awards; and
   4. Future actions to be taken to close each award.

0606 Authorities and References

• United States Code (U.S.C)
  • 31 U.S.C. §1552 Procedure for Appropriation Accounts Available for Definite Periods
• Code of Federal Regulations (C.F.R.)
  • 2 C.F.R.  subpart D §§200.310-316 Property Standards
  • 2 C.F.R.  subpart D §§ 200.334-337 Record Retention and Access
  • 2 C.F.R. § 200 subpart F Audit Requirements
  • 2 C.F.R. § 200.310 Insurance Coverage
  • 2 C.F.R. § 200.316 Property Trust Relationship
  • 2 C.F.R. § 200.330 Reporting on Real Property
  • 2 C.F.R. § 200.339 Remedies for Non-Compliance
  • 2 C.F.R. § 200.344 Close out
  • 2 C.F.R. § 200.345 Post-closeout adjustments and continuing responsibilities
  • 2 C.F.R. § 200.346 Collections of amounts due
  • 2 C.F.R. § 200.403(h) Factors Affecting Allowability of Cost
  • 2 C.F.R. § 200.472(b) Termination and Standard Closeout Costs
  • 31 C.F.R. Part 901 Standards for the Administrative Collection of Claims
• Office of Management and Budget Circular A-136 for FY2023.pdf (whitehouse.gov)
• SF-425 Federal Financial Report
• Grants Oversight and New Efficiency (GONE) Act
• VA Financial Policies
  • Volume X, Chapter 5 – Grants Post Award
  • Volume XII, Chapter 9 – Collection of Debts

0607 Rescissions

OFP Volume X, Chapter 6, Grant Close-out and Post Close-out Activities, April 2021.

Appendix A: Previous Policy Revisions

Section	Revision	Office	Reason for Change	Effective Date
Various	Updated close-out requirements for grant programs.	OFP (047G)	OMB released revisions to Title 2 of the C.F.R. for Federal grants.	April 2021
Various	Reformatted to new policy format and completed five-year review	OFP (047G)	Reorganize chapter layout	June 2019
0605	Updated to address the provisions of the OMB Uniform Grant Guidance at 2 CFR Part 200, and to incorporate references to new guidance where appropriate.	OFP (047G)	Properly reflect current grant close-out requirements	June 2019
060505	Added language for GPO’s to follow guidance under the GONE Act.	OFP (047G)	Updated to address current requirements.	June 2019
0606	Added link to GONE Act legislation	OFP (047G)	Updated to address current requirements.	June 2019
0604	Updated references to GPO grants management staff to read as GPO staff	OFP (047G)	To clarify the responsible party as program office staff.	June 2019