NCPRO details closeout steps, deadlines and documentation for SFRF grants

Officials from the North Carolina Pandemic Recovery Office (NCPRO) walked grant administrators through the agency’s required closeout steps for State Fiscal Recovery Funds (SFRF) projects during a virtual training session.

NCPRO presenters said the closeout process verifies that administrative and programmatic grant obligations are complete, that final financial and performance reports are submitted, and that any unused or unallowable funds are returned. The office reiterated that projects should be prepared to close when funds are fully expended or when the performance period ends on Dec. 31, 2026.

The session framed closeout as the final phase in the grants management life cycle. NCPRO staff described roles and responsibilities: the U.S. Treasury is the federal awarding agency for SFRF; NCPRO acts as the pass‑through and administering agency for the state; administering agencies handle direct state spending and subawards; and subrecipients carry out program activities while beneficiaries receive services or benefits.

Laura Garmon, co‑facilitator, said agencies should “keep preparation for closeout top of mind throughout the award life cycle,” review their grant agreements for specific requirements and follow applicable state and federal guidance. She emphasized that timely reconciliation and organized record retention are central to audit readiness.

Presenters described the documents NCPRO expects to be uploaded to the Pangram system to complete closeout: a final expense report that reconciles to the entity’s general ledger, a closeout balance sheet, a signed closeout financial certification, and final performance measurement documentation (KPIs). NCPRO staff said those documents must support allowable expenditures and be retained in accordance with the retention policy.

The office gave practical guidance on financial reconciliations and expense reporting. John Whittle, co‑facilitator, said reconciling the general ledger to claimed expenses and keeping clear line descriptions helps identify ineligible costs early and reduces the risk of future clawbacks. Staff recommended regular (monthly or quarterly) financial reporting and a “close as we go” reconciliation approach so errors can be corrected before final reporting.

On expense documentation, presenters explained proof of payment must be third‑party evidence such as a canceled check, bank statement, or electronic funds transfer record. For payroll or personnel costs, grant administrators may supply system‑generated payroll reports tied to a three‑way reconciliation, the presenters said.

Procurement rules were highlighted. Ramon (presenter) outlined North Carolina procurement thresholds described in the session: small purchases for goods or services with a cumulative value of $25,000 or less (competitive bidding not required but multiple quotes encouraged); informal procurements for cumulative values above $25,000 up to an agency’s general delegation (methods include informal quotes); and formal procurements above an agency’s delegation where competition should be solicited. NCPRO’s guidance: follow the most stringent applicable procurement policy (federal, state, local, or internal). Agencies should document emergency procurement justifications and retain supporting records.

NCPRO specified the procedural closeout steps: the grant manager notifies NCPRO of project completion; the grant manager shares a closeout checklist and validates all required documentation in Pangram; finance staff initiate refunds for unspent funds and grant managers record negative payments in Pangram to document returns; finally, NCPRO schedules a closeout meeting to confirm the checklist, verify no remaining transactions, and save the completed packet in Pangram as the official closeout record. Agencies and subrecipients remain responsible for retaining records for five years after the grant expiration date (i.e., through Dec. 31, 2031).

Presenters also discussed common causes of delayed closeout: ongoing audits, a recipient ceasing to exist, unavailability of key personnel, and missing procurement documentation—for example, difficulty obtaining records from paid contractors. NCPRO staff urged grantees to build expectations for collection of contractor documentation into procurement and contract language.

During a Q&A, participants asked about required KPI and final performance reporting for subrecipients. Joe Gorsuch (chat/staff) and other NCPRO speakers said performance reporting requirements are set by the grant agreement and that NCPRO aggregates financial and performance data for required federal SFRF reporting and state reporting to the General Assembly. NCPRO staff advised collecting and preserving performance measures now, especially where subrecipients may close operations before closeout is complete.

Presenters concluded by recommending best practices: assemble a digitized closeout packet (procurement documents and supporting evidence), implement clear standard operating procedures and segregation of duties, maintain strong internal controls, and retain monitoring and audit follow‑up records. NCPRO announced a separate future session focused specifically on procurement.

Ending details, next steps and resources: grant managers will serve as primary post‑award contacts, will provide the closeout checklist and will coordinate the final closeout meeting. Participants were encouraged to contact their grant manager with case‑specific questions and to use Pangram as the system of record for closed projects.