Change UG to Allow 120 Days for all Final Reporting (Financial and Programmatic) for all agencies
Currently the Uniform Guidance (UG) requires that all financial & programmatic reports are submitted to the sponsor within 90 days after end date. Several agencies, through coordination with the FDP (Federal Demonstration Partnership) and COGR, are adjusting their deadlines to 120 days after end-date. These agencies, most prominently NIH, NSF, & DoD, have been great partners in understanding that many institutions have limited issues with reporting within 90 days for some projects; but many projects, including international projects, projects with multiple sub-agreements, complex program project grants, etc. require more time. Allowing 120 days as a consistent timeframe will ease the burden related to training and communication, technology solutions, management of peers subawards, etc. It will allow institutions and agencies to smooth the workload as often closeout deadlines compete with proposal submission deadlines, academic calendars, and other institutional responsibilities.
A consistent 120 days, will allow parties to work in a bi-lateral fashion to ensure an award is closed in the most timely, efficient, and accurate manner possible. Further, it will reduce the likelihood of unintended impacts on research outcomes – i.e., reduction of performance periods in order to process timely invoices, the selection of subrecipients based on their administrative abilities for timely payments rather than the quality of science, and other practices that inappropriately put administration ahead of science.
Institutions are very sensitive to previous late reporting issues and are dedicating resources and technology to reduce the compliance and financial risk inherent in late reporting. But a consistent policy for all agencies will support this objective.