What to do if you receive a grant termination or stop-work order


Immediate actions

  • Upon receipt of a termination or stop work order, the Sponsored Programs Administration (SPA) will notify the principal investigator (PI), departmental research administrator (DRA) and department chair. 
  • In cases where the termination or stop-work order is issued directly to the PI, the PI shall immediately notify SPA, their DRA, dean and chair/director.
  • Potentially, a termination or stop-work order may have been issued but was NOT received by the PI or SPA. If the PIs who believe their project may be affected or think there is reason for concern shall notify SPA to inquire further with the sponsor.
  • The PI, DRA, and SPA should carefully read the termination notification to understand specific reasons, requirements, and deadlines.
  • The PI should inform any Co-PIs/Co-Is/collaborators of the change.  
     

Project and personnel review

  • The PI should assess project implications, especially for progress-to-completion, payroll, compliance and safety requirements. If these implications apply, the PI should contact the appropriate department.
     
  • If graduate students were paid on this project, please take the following steps:
    • Collect information about the student’s current appointment from their current offer letter. 
      • Contact your director of graduate studies, department chair, director, or department HR and fiscal support to discuss the student’s current contract/assistantship offer letter. 
    • You will need to know whether it was a nine-month or 12-month contract and the start date.
    • You will need to know if the contract and offer letter state a defined end date for the student's current appointment. (The contract may include multiple years of funding, often contingent on satisfactory academic progress.) 
      • If you are unsure about how to proceed, contact the dean of the Graduate School and vice provost for graduate studies at mugraddean@missouri.edu and include the offer letters/contracts in question. 
    • Assess the availability of alternative financial support (if the contract has not expired).
      • You will need to determine the availability of your individual resources (RIF, gifts, start-up, etc.)
      • You will need to discuss the availability of department, division, or center resources with your department chair or director.
      • You will need to discuss the availability of school or college resources with your dean or associate dean.
      • If, after assessing the availability of these resources, you cannot identify enough resources to honor the student’s contract, please contact the dean of the Graduate School and vice provost of graduate studies at mugraddean@missouri.edu.  
         
  • During the stop-work-order period, the PI and dean should determine if:
    • Affected employees can be appropriately reassigned to a new project.
    • The FTE can be reduced (in case of multiple accounts, only use the ones where there is no stop-work order).
    • The employee will need to be terminated.
       
  • If personnel termination becomes necessary, the PI and/or employee supervisor should contact their Human Resources business partner for further consultation, other employment opportunities within the UM System, and information on benefits.
     
  • SPA will immediately notify all subrecipients of the termination or stop-work order, and appropriate steps may be needed to terminate or stop work on the subaward.
     
  • All fiscal transactions must cease and/or be cancelled in compliance with the terms of the termination or stop-work order.
     

Compliance assessment

  • Inventory all compliance protocols (such as IRB, ACUC, Biosafety, etc.) that may be impacted by a stop-work order or termination notice.
  • Work with the relevant review board on protocol-specific requirements for project closeout, as these will vary depending on the nature of the work and regulated activities. Any proposed changes to a protocol, including early closeout, must receive prior approval by the appropriate board (i.e., IRB, IACUC, IBC) before they are implemented.
  • If a protocol is ending early due to funding changes, provide a final report to the relevant board/committee with the revised end date. Include a description of how the work was terminated in a safe and compliant manner.
  • Patient/animal safety should be addressed for an orderly closeout.
  • Document all costs of termination, as recovery may be available depending on the contract or grant.
  • Securely store and archive all research data and documentation associated with the grant according to institutional policies and sponsor data retention guidelines.
  • If the termination involves sponsor-funded equipment or supplies, inventory these items and manage them in accordance with sponsor and institutional policies. 
     

Final reporting and closeout

  • Identify and record all allowable costs incurred prior to the termination date (§200.343) and any costs that would not have occurred had the award not been terminated (§200.472).
  • Review all outstanding obligations. All reasonable efforts should be made to discontinue or cancel such obligations, and written documentation should be maintained. If certain costs cannot be discontinued or cancelled immediately after the effective termination date, such obligations may be considered an allowable termination cost under §200.472. Other costs that may qualify under §200.472 include:
    • Loss of value of special tooling, machinery, and equipment
    • Rental costs under unexpired leases
    • Settlement expenses including termination and settlement of subaward
    • Indirect cost allocable to such settlement expenses
    • Administrative costs associated with any closeout activities
  • Costs incurred after the termination date that have not been approved by the sponsor shall be transferred off the grant.
  • SPA will submit a final invoice to the sponsor by the deadline. 
  • PI will work with SPA to submit the final financial reports and final performance reports.
  • Confirm closeout as soon as possible.
     

Communication

  • Keep open communication with your program officer and grants management specialist regarding the closeout process.
  • Any direct communication to the PI from the sponsor should be shared with SPA.
  • Promptly respond to any sponsor inquiries or requests for additional information.
     

Appeals

  • PIs who would like to appeal a termination should contact SPA to determine if there is a viable option to pursue an appeal. 
     

Other fiscal considerations

  • Continue to exercise fiscal constraint on federally-funded projects, especially those that may be at high risk of being terminated. Difficult decisions may need to be seriously considered, such as delaying/pausing the hiring of new employees, travel, making large expenditures, and the issuance of new/continuation subawards and vendor subcontracts.
  • Ensure that all project costs are being charged directly to project accounts in a timely manner to reduce the need for after-the-fact transfers. Projects may not be able to move expenses after a termination or stop-work order is received. The PI and DRA should coordinate with SPA accounting to ensure all project costs charged up to the termination or stop-work-date order are included in the final invoice.
    • Identify allowable costs incurred up to the termination date. Any unspent funds must typically be returned to the sponsor.
       

Assess impact and future funding opportunities

  • Evaluate the impact of grant termination on your ongoing research.
  • Explore alternative funding sources, including submitting revised or new grant applications, if applicable.
     

Please contact grantsdc@missouri.edu with questions.