We received a little more information on the SF-425 – direct from the grants management team at ACL/ILA – that may be useful for financial personnel who complete these things. TImelines, reconciliation, indirect costs and project periods are addressed.
Annual vs Final SF-425:
Annual reports are due 30 days after the end of the budget period or by October 31 for Subchapter C grants.
Final reports are due 90 days after the end of the budget period or by December 31 for Subchapter C grants.
Annual reports can include unliquidated obligations but final reports cannot as all liquidations are made prior to submission and the report reflects final expenditures.
Reconciliation between PMS and ACL submitted financial report:
As a term and condition of award, ACL grantees must submit quarterly Federal Cash Transaction Reports through Payment Management System (PMS). As ACL requires the submission of an annual SF-425 and a final SF-425, PMS and the final SF-425 should reconcile by reflecting the same expenditure total.
Line 11 on the SF-425 should only be completed when grant recipients have used awarded funds for indirect costs that are approved by a federal agency through an indirect cost rate agreement OR the use of the de minimis rate which is 10% of modified total direct costs, if the grantee has never received an approved indirect cost rate agreement.
ACL awards Subchapter C grants on a September 30 to September 29 period of performance. This probably is not the same as your October 1 to September 30 fiscal year. Therefore, allowed obligations are only for this defined period. Any obligations made on September 30, should be made to the applicable grant. Therefore, all grantees should adjust their accounting procedures to align with the approved project/budget period dates.