Overdue Reporting Escalation

Purpose

The following outlines the additional involvement that may be required to ensure the timely submission of required reports.

Late reporting is a significant issue, as the University is responsible for overseeing sponsored project operations. Reports must be submitted at the intervals required by sponsors. Failure to submit timely reports can negatively impact a PI's reputation, and all late reports create unnecessary and costly work for University faculty and staff.

Remedies and Detrimental Impacts

Per §200.339 Remedies for noncompliance, federal regulations allow corrective actions that have a negative impact on PI's and the University. For example, sponsors may:

Withhold payments to the University;
Disallow all or part of the costs of a project;
Suspend or terminate an award;
Initiate suspension or debarment proceedings against the University (which could make us ineligible for Federal Funding); and/or
Withhold any additional awards and incremental funding for existing awards.

For example, if a PI has a late technical report on an award, a sponsor like NSF can withhold the issuance of continuation funds for: (i) the award with the late report; (ii) the PI's other NSF awards; and (iii) NSF awards on which the individual with the late report is a Co-PI (impacting relationships with other colleagues).

Additionally, Office of Management and Budget (OMB) Uniform Guidance (§200.344) requires projects to be closed out within one year of their end date. Notably, "if awardees do not submit reports within one year, the awarding agency must report to OMB (currently FAPIIS) a material failure to comply with the award terms and conditions." This includes financial and non-financial reports.

Applicability

Principal Investigators (PIs) are required to understand and comply with the technical/programmatic reporting requirements of their awards, which involves becoming familiar with reporting formats, templates, and any online submission portals.

PI's who demonstrate a pattern of late reports and/or are unresponsive to requests and notifications may become ineligible to be a PI because they have demonstrated an inability to fulfill the responsibilities of a PI.

Notification and Escalation

1st Notice

When reports are coming due or recently overdue, including initial close-out requests, OSP will forward the request to the PI, department administrator/post-award contacts, and an OSP contract administrator. OSP will provide guidance, as applicable, for completing the request and any relevant information provided by the sponsor.

2nd Notice

At the first follow-up request from the sponsor (or when reports are delinquent), OSP will forward the request as usual and copy the department chair/division chief.

3rd Notice

With further follow-up requests (or when the University is being warned of corrective actions), OSP will forward the request as outlined in 2nd Notice and copy the Associate Vice President for Research Integrity & Compliance.

At this stage, the University may exercise its own remedies and corrective actions.

Frequently Asked Questions

OSP provides guidance on no-cost extensions and how to request them. Departments can also initiate preliminary no-costs extensions via e-Award.

OSP recognizes that reporting due dates may change during the course of a sponsored project. If you receive a due date change notification, PI's are responsible for tracking the dates and providing documentation should you receive an overdue notice.

Certain sponsors (e.g., U.S. Department of Education) do not list technical report due dates in the award document. They may instead provide the due dates to you at a later time. If you do not have the due dates, you should contact your Program Manager/Technical Contact for more information.

If you cannot meet report deadlines, you should first contact your Program Manager/Technical Contact to see if it's possible to obtain a deadline extension.

Yes. Unless you have written confirmation from your Program Manager/Technical Contact that your report is not due, you must submit your report by the existing deadline.

For example, NSF has advised: "A 'no cost extension' adds time to an award, but does not relieve the awardee of reporting requirements. Annual reports are still due every 12 months. When the award finally does expire, the final report and project outcomes report are both due within 120 days."

Yes, OSP has developed sponsor specific guidance to assist you:

If you can't find what you need, please reach out to your Sponsored Projects Officer.

OSP is happy to help you understand the terms and conditions of your award, including report due dates and processes, but it's the PI's responsibility to: (i) prepare and submit report (including how to submit your reports via online portals); and (ii) obtain written due date extensions from your Program Manager/Technical Contact. If you still have questions or concerns after researching how to prepare and submit your reports, please contact your Sponsored Projects Officer. OSP will seek additional resources to assist you.

Typically, sponsors should receive technical reports from PI's and financial reports from Grants and Contracts Accounting (GCA). Some sponsors require periodic reports to contain both technical and financial information. In these limited situations, PI's and/or department admins should coordinate with GCA to obtain updated financial information before submitting the combined report.

Related Policies and Procedures

Grant Life Cycle > Manage Your Award > Report
Grant Life Cycle > Manage Your Award > No-Cost Extensions
Grant Life Cycle > Manage Your Award > Closeout
Grant Life Cycle > Manage Your Award > Subrecipient Closeout
Procedure Library > Subaward Closeout

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Overdue Reporting Escalation