Shuttered Venue Operators Grant: SBA’s Closeout Process

The Small Business Administration (SBA) is nearly finished evaluating requests for supplemental award and Reconsideration 2.0, an option that allows grantees to correct mistakes made during their Shuttered Venue Operators Grant (SVOG) application process. That means most grantees should start thinking about how to make the next steps of the process efficient, easy, and compliant. Consider some key aspects of SBA post-application guidance.

Respond to Finalize Budget Action Item

After your SVOG application has been considered for all possible awards, you will receive an email to respond to a Finalize Budget Action Item, which marks the transition into the active grantee phase. For most, this will be the final budget revision before reporting expenditures and initiating closeout. Grantees must complete the action item within 14 days of it becoming available in their portal.

The final budget is what the SBA terms a “point-in-time projection” of how SVOG award funds will be spent within the allowable cost categories.

After approval of the Finalize Budget Action Item, the Begin Closeout – Expense Report Action Item will be sent to grantees.

Understand the closeout phases

The SVOG award closeout process has three phases:

1. Begin Closeout – Expense Report Action Item
2. Complete Closeout – SF-425 Action Item
3. SBA’s notification that the award has been closed

Phase 1 “Begin Close-out-Expense Report” steps are as follows:

• Assemble supporting documentation.
• Organize expenditures by budget category.
• If applicable, prepare property inventory and create request for property disposition instructions.
• Respond to any follow-up questions from the SBA.

Phase 1 is complete when the SBA approves the Begin Closeout – Expense Report Action Item.

Phase 2 “Complete Closeout – SF-425” steps are as follows:

• Complete and confirm SF-425 has the correct data.
• If applicable, upload supporting documents for property disposition.
• If applicable, complete and document repayment of unused SVOG award money. If your total sum of expenditures is less than the total SVOG award disbursed, SBA will issue repayment instructions to collect the unspent funds.
• Respond to any follow-up questions from the SBA.

Phase 2 is complete when the SBA approves the Complete Closeout – SF-425 Action Item.

Phase 3 is when you will receive your grant award closure notification. It is considered complete when the notification is received and (if necessary) any final responses to SBA inquiries are completed.

Note the closeout timeline

Grantees must respond to the Begin Closeout — Expense Report Action Item and initiate the closeout process no later than 120 days after the end of their budget period (“Through” date in Form 1222 Box 5). However, responding to the action item soon after expending all grant award funds — when the award work and financial recordkeeping will be fresh — can help make the closeout easier.

Review responsibilities after closeout

After all three phases of the closeout process have been completed, grantees must:

• Maintain employment records for four years and all other records documenting compliance and eligibility for the SVOG program for three years following the award date (“From” date in Form 1222 Box 5).
• Complete and submit any audit requirement documentation.
• Be responsive to SBA follow-up inquiries.

Prepare for SBA monitoring

The SBA will select certain grantees, using a risk-based monitoring system, to determine whether award funds were used for eligible and allowable purposes. SVOG staff will complete most reviews remotely, but some grantees may receive on-site monitoring.

If you are selected, you will receive a notification in the portal and an email from the SBA stating that an action item is pending response. The action item will provide the monitoring scope and the information you must provide. The process, including review and responses, will be managed through the SVOG portal, and an SBA-assigned SVOG program staffer (who will serve as the primary reviewer and point of contact) will follow up directly by email or phone as needed.

Most monitoring events will start during the active award phase, so you are encouraged to continue spending award funds even if you receive a notification of monitoring, unless otherwise notified by the SBA. The SBA can begin a monitoring review once the closeout phase has been initiated or after a grant award has been closed out.

How we can help

We have a team of experienced grant compliance professionals who can help you navigate the complexities of your SVOG award. Whether you are looking for help understanding how to properly spend and manage your SVOG award, need an audit of your SVOG award, are interested in outsourcing your bookkeeping, or are seeking tax-related services, we can provide insight and assistance at each stage of the process.