Best Practices for Efficient Grant Program Closeout

Reaching the closeout process of your grant-funded program signifies nearing the end of your project’s period of performance. While each phase of the grant life cycle is important, a good closeout indicates proper grant management, which is essential for a successful program and access to future funding opportunities. Effective closeout creates accountability, facilitates smooth transitions, and sets a positive stage for future funding opportunities.  

The Importance of Grant Program Closeout 

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.  

By implementing best practices, grant recipients can streamline the closeout process, minimize potential issues, and maintain a positive relationship with the funding agency. 

Properly closing out your grant program allows you to: 

• Demonstrate good stewardship: Show that your organization is a good steward of federal funds by submitting final programmatic reports, final administrative reports, final financial reports, and accounting for real and personal property. 

• Strengthen compliance: Demonstrate overall compliance with Uniform Guidance 2 CFR 200 and Subpart D § 200.344, and specific requirements from your federal funding agency. 

• Prepare for future success: Set the stage for future grant success by demonstrating diligence and accountability. 

Understanding the Closeout Process and Key Principles   

Proactive planning is essential for a smooth and complete closeout process. To aid in your organization’s planning process, utilize these principles from pre- to post-closeout: 

1. Pre-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 have different objectives and requirements, resulting in competing priorities and deadlines that may 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, typically 120 calendar days after the end of the performance period.  
4. Include closeout costs: Recent updates to the Uniform Guidance will now allow for the inclusion of closeout costs incurred after the period of performance for all awards received after October 1, 2024. Plan and budget for these costs to better guarantee compliance and completeness in the closeout process.  
5. Subrecipients’ role in the grant program closeout process: Communicate with subrecipients at least 90 days before the end of your performance period and continue to include them in the closeout timeline and submission process. 
6. Post-closeout record retention: After submitting final closeout documents, you must adhere to the grant reporting requirements as outlined in your state and federal guidelines. You and your subrecipients must maintain adequate documentation processes to satisfy this requirement.  
7. Conduct a Closeout Evaluation: Assess the overall effectiveness of the grant program and identify lessons learned for future projects. 
8. Disseminate findings: Share the project(s) outcomes and best practices with relevant stakeholders, including granting agency, partners and the public.  

Avoiding Common Pitfalls in Grant Program Closeout 

With the increased number of new federal grantees and the complexity of new federal grant programs, especially those initiated during the COVID-19 pandemic, such as the CARES Act and the American Rescue Plan, organizations must be more diligent than ever. Some new challenges and considerations include: 

• Enhanced Compliance Requirements: With more stringent regulations, maintaining compliance with Uniform Guidance 2 CFR 200 and specific agency guidelines is critical. 

• Technological Integration: Leveraging grant management software to track and report on grant activities can streamline the closeout process and improve accuracy. 

• Staff Training: Continuous training for staff on the latest regulations and best practices in grant management is essential. 

• Data Security & Retention: Prioritizing the security and retention of sensitive financial and programmatic data during the closeout process is paramount. 

Complying with Federal Requirements   

Depending on the number of federal awards your organization receives, it can be easy to miss deadlines, or worse, fail to properly closeout a grant. In fact, if your organization receives over $10M in federal funds, your organization is at risk of 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. 

Resources and Support for Grant Closeout 

Effectively closing out a federal grant program requires careful planning, attention to detail, and adherence to specific guidelines. Closeout is a critical phase in the grants management lifecycle. 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.  

EisnerAmper has extensive experience in auditing and grants administration. Our team has a proven track record navigating complex federal regulations and assisting clients in executing their program. Contact us below for assistance if you have questions about the grant closeout process.