Record Retention & Closeout: Compliance Essentials
Oct 28
/
Rachel Werner
Every grant has a beginning, middle, and end. But when the project itself wraps up, your responsibilities as a grantee don’t stop there. Record retention and closeout are critical steps in the grant lifecycle, and they’re also areas where many organizations face compliance challenges.
Record retention rules under 2 CFR 200.334 require you to keep financial and programmatic records for at least three years from the date of submission of the final expenditure report. That includes everything from invoices and payroll records to performance reports and correspondence with your funding agency. In some cases — such as program specific requirements per the notice of grant award terms and conditions, pending audits or legal actions — you may need to hold on to records even longer.
Record retention rules under 2 CFR 200.334 require you to keep financial and programmatic records for at least three years from the date of submission of the final expenditure report. That includes everything from invoices and payroll records to performance reports and correspondence with your funding agency. In some cases — such as program specific requirements per the notice of grant award terms and conditions, pending audits or legal actions — you may need to hold on to records even longer.
Why Closeout Matters
Closeout isn’t just about sending in a final report. It’s the process of ensuring that every obligation tied to the grant has been met. That means submitting all required financial, property, and performance reports within 120 days, reconciling cash advances with actual disbursements, and verifying how equipment or supplies were disposed of once the project ended.
Where organizations often run into trouble is with timing. Missing the 120-day deadline or failing to reconcile advances properly can create major issues. Others simply don’t have a checklist in place, which makes it easy to overlook a key step.
The best way to avoid problems is to create a closeout plan for every award as soon as you receive it. Assign responsibilities clearly, keep track of deadlines, and make sure communication lines with your funding agency are open. By doing this, you’re not just protecting your organization from findings — you’re also setting yourself up for smoother grant management in the future.
Where organizations often run into trouble is with timing. Missing the 120-day deadline or failing to reconcile advances properly can create major issues. Others simply don’t have a checklist in place, which makes it easy to overlook a key step.
The best way to avoid problems is to create a closeout plan for every award as soon as you receive it. Assign responsibilities clearly, keep track of deadlines, and make sure communication lines with your funding agency are open. By doing this, you’re not just protecting your organization from findings — you’re also setting yourself up for smoother grant management in the future.
Bottom Line
Closing out properly shows funders that you can be trusted with federal dollars. Strong record retention and closeout practices not only wrap up one grant well but also pave the way for successful awards down the road.
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Martha A Moore, MPA, DTM, CNAP, has been working in the accounting industry for over 35 years. Over that time, she has worked in the Grants Management area for 20 years. She has recently received the Certified Nonprofit Accounting Professional (CNAP) credentials. Martha’s expertise in grants management field is in the post-award/closing/audit areas, while serving as an advisor to preaward budgeting and program narrative. Thanks to her many years in the accounting/grants management industry, Martha has the ability to zoom out and holistically see the big picture and how external funding can be crafted for effective and efficient use. She believes in team approach with both finance and program team at the table to ensure a clear and comprehensive award application, with the end goal being grant awards. Martha also has extensive experience in subaward management from a university to a local nonprofit organization. Martha is a public speaker and trainer, thanks to her many years (20+) in Toastmasters International. She earned the highest designation, Distinguished Toastmaster, and puts those skills to use daily. Martha’s niche’ is the desire to see local nonprofits (BIPOC startups to mature nonprofits) succeed in securing funding to fulfill community gaps in partnership with the philanthropists, private sectors, local, state, and federal governments.
