Santa Clara University

Sponsored Projects

Final Reports & Audit

Most sponsors require a fiscal and/or technical reporting of the project. The detail of those reports varies from sponsor to sponsor, but generally the reports are due within 90 days from the expiration date shown on the award document. Failure to submit reports in a timely and acceptable form can block favorable consideration and award of pending proposals and cause final payment to be withheld.

1. Technical Reports

Technical reports are the responsibility of the principal investigator. Many award documents either include the report information or incorporate, by reference, the document that contains the information. Copies of the final technical report usually are forwarded directly to the technical/project monitor (named on the award document). However, SPO should be provided with a copy of the letter transmitting the final technical report to the sponsor. This will assist SPO in closing out the account and is helpful in tracking down reports allegedly not submitted. Some sponsors require the submission of the final technical report along with the final fiscal report. Questions regarding technical report requirements can be answered by the project monitor.

2. Fiscal Reports

Fiscal reports are prepared and submitted by SPO in accordance with the requirements of the award. For final fiscal reports, the principal investigator is requested to review project expenses and final costs. Once it is confirmed that all costs and adjustments have been completed, SPO reports to the sponsor in the format required by the award.

3. Invention Statements

Annual and final invention or patent certifications, if required, are prepared by SPO and sent to the principal investigator for verification that either: 1) there were no inventions or 2) it details any final Invention Disclosures and lists all inventions previously disclosed under the agreement.

4. Equipment Inventory Reports

Equipment inventory reports, if required, are submitted to the sponsor by SPO. However, the principal investigator and his or her department should assist in the preparation of the report to determine the final disposition of property acquired under the agreement. See the document entitled Capital Equipment Management System (CEMS) for Sponsored Projects (see Appendix A) for more information on equipment inventory reporting.

5. Federal Audits

Direct cost audits are done either on a random sampling basis or at the request of the sponsoring agency. The aims of the audit are to test the effectiveness of the University's internal system for monitoring expenses, and to confirm that expenses were incurred as required by government wide regulations on the allowability of costs and by the specific provisions of the award. The audit also ensures that the government was charged for the proper portion of the total project costs on projects for which there is a University cost-sharing contribution or those that are partially supported by other sources.

A common audit inquiry concerns costs incurred in the latter stages or processed after the termination of an agreement. This includes purchases made from outside vendors as well as transactions within the University. The contention of the auditors is that late purchases do not significantly benefit the project. Large volume purchases or single purchases of a significant amount at the end of a project are usually not allowable since it appears that the intent is to expend remaining funds. Copies of all records should be attached to the initiating documents and also maintained on file in the department until the final audit is completed, even though this may take several years.

A useful method of supporting appropriate late purchases on a project is to obtain a no-cost extension from the sponsor through SPO. Timeliness or dating problems are then not relevant to the auditors for the extension period.

Closing audits normally are completed within one year of the termination of the agreement (although the period may extend to four or five years). The audit agency obtains information on the project available within SPO and other administrative offices. If these offices are unable to provide the necessary information, the principal investigator is contacted for further clarifications.

The auditors submit their report to the sponsor, usually with a copy of the draft report to the Director of Sponsored Projects. The sponsor then determines the allowability of items questioned in the auditor's report. If the audit uncovers questionable charges on the agreement, the sponsor submits a letter to the University reiterating the findings and requesting a reply. SPO reviews results of the audit against available records and determines the nature of the University's response to the sponsor. If SPO does not have sufficient information, it contacts the principal investigator and the department for additional explanations to support the charges. After these explanations have been provided for the questioned and/or disallowed costs, SPO presents the University's position and supporting documentation to the sponsor. The contract or grant officer reviews the initial audit with the University's response and determines the total amount allowable on the agreement