3/8 Good (?) news for "terminees":
✅ NSF publicly intends to follow through with final closeout payments.
INCLUDING "closeout costs required to submit the final/annual report", as required by fed 2 CFR 200.472: https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-E/subject-group-ECFRed1f39f9b3d4e72/section-200.472
There was some question if that fed reg would be followed
✅ NSF publicly intends to follow through with final closeout payments.
INCLUDING "closeout costs required to submit the final/annual report", as required by fed 2 CFR 200.472: https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-E/subject-group-ECFRed1f39f9b3d4e72/section-200.472
There was some question if that fed reg would be followed
Comments
✅ The 30-day report is ONLY for financial accounting.
It's NOT the final annual report (which is due in 120 days).
It's NOT an interim project report which has same structure as an annual report (there was prior mixed intel about that).
"Project Outcomes Reports are waived for terminated awards"
These appear publicly on the NSF award pages (normally).
✅ Minimizes reporting burden.
❌ Grantees can't say in their own words how the project ended (e.g., "was illegally terminated...").
"The traditional final financial reporting and adjustment periods will not apply for these terminated awards."
Not sure what that means...
NSF is **required** to follow 2 CFR 200.472 (link in next post), which supersedes NSF's own policy statements.
https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-E/subject-group-ECFRed1f39f9b3d4e72/section-200.472
So, I'm not really sure what NSF is getting at by just stating, "the traditional..periods will not apply."
But from a practical perspective...
It's most practical to do so in one fell swoop, aligning with the steps/actions noted below.
(Even if the fed regs might require NSF to go further; this is about maximizing the % chance of a positive outcome for grantees)