Closeout phase

The closeout phase is the sponsor-facing wind-down of a grant once its period of performance has ended: submitting the required final reports, reconciling final expenditure against the approved budget, resolving any unliquidated obligations, and disposing of equipment according to the sponsor’s rules. It is a defined process with statutory deadlines, not simply “the project being over.”

What has to happen, and by when

Under 2 CFR 200.344, a recipient must submit all required reports and liquidate all financial obligations no later than 120 calendar days after the period of performance ends; a subrecipient faces a shorter 90-calendar-day deadline to report to its pass-through entity, giving that entity time to compile subrecipient data before its own 120-day deadline. The federal awarding agency, in turn, must make every effort to complete its own closeout actions within one year of the period of performance ending. The 120-day recipient figure applies to federal awards issued on or after October 1, 2024 (raised from 90 days by an OMB Uniform Guidance revision); older awards may still carry a 90-day closeout term written into their own award documents.

Three related terms, one process

Closeout is easy to conflate with two related but distinct terms. The final report is one specific deliverable produced during closeout — not the whole process. Project closure documentation is the complete auditable record closeout produces as its output — the process’s paper trail, not the process itself. Offboarding is a different axis entirely: it is about people and system access, can happen mid-project whenever an individual leaves, and runs alongside closeout at project end without being part of the sponsor-facing administrative wind-down itself.

What can go wrong

A missed closeout deadline, including a late final report, must be reported by the federal awarding agency as a material failure to comply with the award’s terms. Unresolved unliquidated obligations at closeout are one of the most common items an auditor flags, and if an institution’s indirect cost rate is not yet finalized by the reporting deadline, the final financial report must still be submitted on schedule using the best available rate, with a revised report filed once the rate is set.

When this last changed, and how you find out next time

The 120-day recipient deadline above is current as of OMB’s most recent revision to the Uniform Guidance. OMB revised 2 CFR 200 on April 22, 2024, published in the Federal Register at 89 FR 30046, effective for awards issued on or after October 1, 2024.

OMB publishes every change to the Uniform Guidance in the Federal Register, and the Federal Register is one of the sources Regulatory Radar checks every day — so 2 CFR 200 is one of the few subjects where CASRAI reads the primary publication venue itself rather than waiting for somebody’s summary. It does not watch the NIH Guide, and it does not watch private accreditors.

Ask CASRAI what 2 CFR 200 currently requires for the reporting and property-disposition deadlines that make up the closeout phase under 2 CFR 200.344 — it answers with its sources linked, so you can open each one and check it. Two questions a day are free while you are signed out, no account and no card. Regulatory Radar is $29 a month for 150 a day, a subscriber dashboard, API keys and MCP access. Everything CASRAI publishes, including this page, stays free to read.

Frequently asked questions

Is the closeout phase the same as submitting the final report?

No — the final report is one specific deliverable produced during closeout, not the whole process; closeout also includes liquidating obligations, resolving unliquidated obligations, and disposing of any federally funded equipment.

How long does closeout take?

Recipients generally have 120 calendar days after the period of performance ends to submit required reports and liquidate obligations (90 days for a subrecipient reporting to its pass-through entity); the federal awarding agency then has up to a year to complete its own closeout actions.

What happens if closeout is late?

A missed closeout deadline, including a late final report, must be reported by the federal awarding agency as a material failure to comply with the award’s terms.

Does closeout end an institution’s obligations under the award?

Not entirely — federally funded equipment can carry continuing disposition obligations, and records generally must be retained for a further period after closeout, so closeout ends the award’s active reporting cycle without erasing every downstream compliance duty.