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Termination

Termination means the ending of an award or subaward, in whole or in part, at any time before the planned end of the period of performance.

  • Termination of a Federal grant, fellowship, or cooperative agreement is addressed in 2 CFR 200.340 and the more specific agency regulations or policy incorporated in the terms of the award.
  • Termination of a Federal contract is addressed in the Federal Acquisition Regulation, Part 49, and any more specific termination clause incorporated in the contract.

An awarded project that is prematurely terminated will be subject to the same requirements regarding audit, recordkeeping, and submission of reports as an awarded project that runs for the duration of the project period.

I received a termination notice - what should I do?

Send the notice or directive to Laura Scarantino and Jill Frankenfield. They will review the notice, determine UMB's obligations, and advise you on next steps.

Immediately stop all project work, including any pending deliverables required by the award.

Notify subrecipients. UMB will issue stop work orders to its subrecipients, if any. If UMB does not issue orders to its subrecipients, UMB will be liable for their expenditures, but will not be reimbursed by the sponsor for any of those costs incurred by the subawardee after the date specified in the sponsor's termination notice. 

Inform the IRB and/or IACUC. 

  • Notify the Institutional Review Board (IRB) by utilizing the Reportable New Information pathway in CICERO. When UMB is the IRB of Record, select option 9 (Suspension or termination of the research by the sponsor or the investigator). When an external IRB is the IRB of Record, select option 14 (Determination...Suspension or termination at UMB (External IRB studies ONLY)).
  • If the terminated award includes Animal Subject Research, immediately notify the IACUC by email (for paper protocols) or use the “Contact IACUC Staff” button in CICERO.

Confirmation (when required):  No action required by PI/Department. For certain termination notices, SPA (Jill Frankenfield, AVP) will provide confirmation to the Contract/Agreement Officer, and also copy the sender of the Termination Notice if that person was not the Contract/Agreement Officer assigned to the award. The acknowledgement is an important communication that may have value down the road, should a claim or objection be filed during termination negotiations. Notably, it is important to simply “acknowledge receipt” and not “accept” the Notice.

Project activities and costs:

Cancel or divert applicable commitments covering personal services that extend beyond the effective date of stoppage, and abstain from placing any orders.

After stopping the work, document any cost and schedule impacts resulting from the termination. This documentation should include details such as incurred costs up to the termination date, potential costs related to winding down activities, as well as any schedule disruptions. Otherwise, allowable costs incurred to close out an award may be recoverable. However, all costs incurred after the termination effective date are incurred at the risk and responsibility of the department, with no guarantee of payment by the government. When appropriate, SPAC will set up separate PIDs to manage unavoidable closure costs. 

2 CFR 200.472 Termination and standard closeout costs provides information about the allowability of costs for grants and cooperative agreements under federal funding (federal sponsors or prime sponsors).

Response and appeals:

The SPA and SPAC (through their AVPs) will work with University Counsel to review the communication(s) and award to determine whether the termination notice was issued in accordance with the terms of the award and the law, whether the notice is a full termination or allows for partial continuation or re-scoping, and if an opportunity for appeal exists.

Navigating Federal Orders and Guidance

SWO Terms Appeals Presentation to RAC 04/10/2025

UPDATED Sponsored Stop Work Order or Termination Procedures April 2025

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