This announcement contains important information for sponsored agreement administrators who are responsible for preparing Closing Memos. Effective immediately, the Comptroller's Office is implementing four changes to the Closing Memo processes. We expect that these changes will ease the administrative burden associated with preparing and processing Closing Memos. The changes are as follows:

1. No longer must the administrator use the AM090 for the terminating month of the sponsored agreement to prepare the Closing Memo; instead, the AM090 for a subsequent month may be used. For example, if a sponsored agreement's financial reporting period terminated 12/96, and its financial report is due 3/31/97, then you may use the AM090 for 12/96, 1/97 or 2/97 to prepare the Closing Memo.
2. No longer will Closing Memos be due 45 days after the financial reporting period termination date (budget end date). Instead, Closing Memos will now be due 15 days prior to the date that the sponsored agreement's financial report is due. Most financial reports are due 90 days after the budget end date, though some are due after 60 days. Regardless of this Closing Memo due date extension, the Comptroller's Office strongly encourages administrators to submit Closing Memos as early as possible.
3. In the past, the Comptroller's Office mailed out the requests for Closing Memos approximately 75 days before the sponsored agreements financial reporting periods' termination date; now they will be mailed out approximately 45 days before that date.
4. You may now use copies of FAS Screen 24 as supporting documentation for trailing transactions.

Given the above changes, its appropriate to remind administrators of one particular requirement that must be met in order for an expense to be considered an allowable charge against a sponsored agreement, and that is the requirement that the expense must be incurred within the sponsored agreement's period of performance or an approved pre-award period. For example, for a salary charge to be considered incurred within the period of performance, the salary must be earned during the period. A technician's salary for a month subsequent to the month in which the award terminated would not be within the performance period and, therefore, would not be an allowable expense. For a service or commodity expense to be considered incurred during the period or performance, it must have been ordered during the period of performance as evidence by the date of a purchase order or other official procurement request to the vendor. A procurement made via a Z-Order the day after the termination date of an award would not be within the period of performance; therefore, it would not be an allowable expense. Similarly, a long distance telephone call made after the termination date would not be an allowable expense. If you have any question as to whether a charge qualifies as being incurred within the period of performance, call the Post Award Administrator in the Comptroller's Office who is listed as the Comptroller Office Contact at the top of the AM090 Report for the award.