As a recipient of federal sponsored project funding, Notre Dame de Namur University is responsible for accurate and timely submission of all reports required by the terms and conditions of the sponsoring agency grant award agreement. Interim, annual, and final performance and financial reports are common reporting requirements of federal grants; however, additional technical reports, endowment reports, programmatic reports, progress reports, and special analysis may also be required.
Project Directors shall ensure that all reporting requirements are fulfilled and that reports are submitted on time and in accord with the terms of the award agreement. It is important that Project Directors read and understand the grant application package, grant award notification and agreement, and all attachments and enclosures provided by the sponsor to ensure that all reporting requirements are accounted for. It is recommended that Project Directors develop and maintain a calendar of all reporting requirements and due dates throughout the life-cycle of their grant(s). If there is any uncertainty as to the specific reporting requirements of a federal grant, the Project Director should contact their Program Officer at the sponsoring agency for assistance.
Failure to comply with all reporting requirements of a federal award may result in restricted access to awarded funds, withholding of payments, termination of federal funding, and/or suspension and debarment, and may raise “red flags” that could trigger federal audit activity.
Financial Reporting: Federal awarding agencies typically require grantees to submit the Standard Form 425, Federal Financial Report, on a quarterly, semi-annual, or annual basis. The SF-425 is a government wide form designed for grant award financial reporting. Certain federal awards do not require the SF-425 to be submitted. For example, the United States Department of Education’s Developing Hispanic-Serving Institutions (HSI) Program as awarded to NDNU does not require the SF-425, relying instead on the drawdown of funds by the University. In this case, the drawdown of funds by grant award serves as a record of expenditures by the University.
Special financial reporting requirements may exist for awards which allow for the establishing or improving of an endowment fund and/or for grants with endowment matching requirements. The HSI Title V, Part A and HSI STEM Grants as awarded to NDNU are such grants. These grants each require an annual Financial Report for the Endowment Activities under the Title III Parts A & B and Title V Programs, due September 30th of each year for the duration of twenty years. It is the responsibility of the NDNU Office of Finance and Administration to submit this report in a timely manner.
Performance Reporting: Performance reports are not required more frequently than quarterly or less frequently than annually. Performance reports for multi-year grants are typically due annually, within 90 calendar days of the end of each grant budget year. For example, a performance report for a grant with a budget year ending September 30th would be due by December 29th of the same year. Certain grants require more frequent quarterly or semi-annual performance reports and/or an additional one-time interim performance report. If required, and unless otherwise specified in the Grant Award Agreement, quarterly or semi-annual performance reports and interim performance reports are due within 45 days after the reporting period. Performance reports generally include a comparison of actual accomplishments with the goals and objectives established for the period, reasons why established goals were not met, if appropriate, and other pertinent information including, when appropriate, analysis and explanation of cost overruns or high unit costs.
Final Reporting and Grant Closeout: Project closeouts typically require a series of final reports be submitted to the awarding agency. Depending on the type of grant and the nature of the activities of the grant, these final reports may include performance reports, technical or programmatic reports, financial reports, endowment reports, inventory reports, etc. Unless otherwise specified in the Grant Award Agreement, final financial and performance reports are due 90 calendar days after the expiration or termination of the award. Project Directors should pay close attention to all final reporting requirements and due dates. Failure to submit timely and accurate closeout reports may affect future funding to the University.
Special Analysis: Dependent upon the activities and objectives of the program/project being funded, the University may be subject to special analysis requested by the sponsoring agency. For example, under the United States Department of Education’s HSI Program, the University is required to report data on student enrollment, retention, graduation rates and other data fields in efforts of monitoring and improving or adjusting grant-funded activities to maximize results.
While not encouraged by NDNU, and only to be used in the case of unforeseen or extraordinary circumstances, extensions of reporting due dates may be approved by the funding agency upon request of the University.
Links to Commonly Used Grant Reporting Forms
Department of Education:
ED 524-B, Grant Performance Report Part 1 – Cover Sheet and Summary
ED 524-B, Grant Performance Report Part 2 – Project Status
ED 524-B, Grant Performance Report Part 3 – Instructions
Financial Reporting System - Financial Report for the Endowment Activities under the Title III Parts A & B and Title V Programs
Office of Management and Budget:
SF 270, Request for Advance or Reimbursement
SF 425, Federal Financial Report – Instructions for Federal Financial Report
SF 425A, Federal Financial Report Attachment – Instructions for Federal Financial Report Attachment
SF LLL Form, Disclosure of Lobbying Activities
OMB Circular A-133 Single Audit
The Single Audit Act requires that grantees obtain a non-federal audit of their expenditures under their federal grant(s) in accordance with OMB Circular A-133 if the grantee expends more than $500,000 in federal funds in one fiscal year. The University has an annual A-133 Single Audit conducted in review of both financial and compliance components. A sample of federal awards, and related direct cost transactions, is examined to determine if expenditures and procedures were appropriate and in accordance with federal policies, and in compliance with sponsoring agency terms and conditions and University policies. As such, requests for information or documentation should receive immediate attention.
Areas of A-133 compliance testing include:
- Activities Allowed or Unallowed
- Allowable Costs/Cost Principals
- Cash Management
- Equipment and Real Property Management
- Matching, Level of Effort, Earmarking
- Period of Availability of Federal Funds
- Procurement and Suspension and Debarment
- Program Income
- Real Property Acquisition and Relocation Assistance
Federal Sponsoring Agency Audits
The Office of the Inspector General (OIG) of the federal awarding agency reserves the right to audit their awards in review of financial operations, program/project effectiveness, economy and efficiency of operations, internal control, compliance, and other measures relevant to the objectives of the audit. Under the Inspector General Act of 1978, the Inspector General shall have “…access to all records, reports, audits, reviews, documents, papers, recommendations, or other material available to the applicable establishment which relate to programs and operations with respect to which that Inspector General has responsibilities…” While the OIG will typically notify a grantee in advance of an audit, they may also show up unannounced. As such, the University shall maintain an “audit ready” position at all times. In the case of an OIG audit, all University personnel shall cooperate with auditors and representatives of OIG and should make available all documents and information deemed necessary for the conduct of the audit.