Closeout Toolkit for Title X Clinics
Welcome to the Toolkit
Closeout is a complex, sensitive process that requires coordination across administrative, clinical, and fiscal functions. Whether driven by infrastructure issues, programmatic shifts, or the end of a grant, closing a clinic can be disruptive to staff, clients, and community partners. The goal of this toolkit is to help Title X grantees, subrecipients, and service sites navigate clinic closeout in a way that is timely, compassionate, and compliant with all requirements.
Note: This toolkit does not cover closeout of a Title X project. If you are a grantee facing a project closeout, please reach out to your Project Officer (PO) for guidance and to ensure compliance with all Office of Population Affairs (OPA) and Grants and Acquisitions Management (GAM) requirements.
This toolkit is organized into seven sections aligned with key aspects of closeout:
- Closeout management to establish a strong, coordinated work plan
- Internal communications to manage communication with staff and board members
- External communications to manage communication with funders, partners, and the public
- Vendor management to effectively handle vendor agreements
- Client communications to ensure confidential, compassionate, and clear communication with clients
- Documentation and records to ensure seamless and secure access to client records
- Fiscal to closeout all financial activities in compliance with funder and regulatory requirements
This toolkit is designed for any Title X grantee, subrecipient, or service site that is facing clinic closure. It is intended for use by cross-functional teams directly involved in planning and executing closeout. Not all sections or action steps will apply to every situation—use what fits your specific closeout scenario.
The first step will be to establish a strong management structure—including administrative, clinical, and fiscal leaders—and clearly define roles and responsibilities. This will help ensure that all activities are well-coordinated, timely, and align with the expectations outlined in the project’s notice of award (NOA).
The details of your plan will vary, depending on the closeout circumstances and staff involved. Reasons to engage in a closeout process include: end of a Title X grant, end of a subrecipient agreement, organization or site closure, or clinic move.
Become familiar with the closeout process and identify which parts of the process are relevant for your situation, including reviewing your project NOA.
Closeout Overview for Title X Clinics
Develop and distribute a closeout timeline:
- Identify target dates to complete each task.
- Identify a manager for each component of the timeline who will delegate tasks and monitor progress.
Closeout Work Plan for Title X Clinic
Develop a communication plan, including:
- Talking points for clients
- Talking points for staff
- Talking points for partners
- Talking points for media
Create a physical property plan.
Timely and transparent communication with internal stakeholders, particularly staff and board members, will be critical during closeout. Internal procedures within an agency or clinic will dictate whether staff or board members are notified first of the decision to close.
When developing an approach to internal communications, involve agency leadership, supervisors, human resources representatives, and the board, if appropriate. Leadership should determine whether staff will be reassigned within the organization or if positions will be eliminated. This will likely be a tough transition; make sure that all messaging is compassionate, consistent, and compliant with legal standards.
Engage board members in accordance with bylaws, policies, and procedures. If called for, write a board notification letter.
Notify staff as soon as possible, meeting with those directly affected first, and face-to-face, if possible.
Determine whether staff should be reassigned or terminated. Consider severance agreements if jobs are eliminated.
Remind staff of the employee assistance program if available.
Once board members and staff have been notified of the closure, staff leading the closeout should develop an external communications plan. This plan should address all communications, including press releases and notifications, that must be sent to funders, referral providers, community partners, professional organizations, and licensure boards. To ensure all regulatory obligations are met and messaging is clear, involve the clinic director, compliance officer, communications or public relations staff, legal counsel, and pharmacy/program administrators in crafting these messages.
Write press release/media statement for newspaper.
Compile a list of external partners you want to notify.
Notify local, state, and federal funders of closure, if applicable and in accordance with your project NOA and/or other award agreements.
Notify referral providers, community partners/organizations, professional organizations (NFPRHA, AASCP, etc.), Drug Enforcement Agency (DEA), and licensure boards.
Notify state’s controlled substance registry of closure, requesting guidance on how to handle controlled substances and updating the work plan to reflect these new tasks.
Notify the Health Resources and Services Administration’s HRSA Office of Pharmacy Affairs:
- Complete termination request in 340B OPAIS.
- Request to transfer 340B drugs to another 340B site, if appropriate.
- Receive guidance on handling 340B drugs if transfer is not applicable or approved.
- Update the work plan to reflect any new tasks.
Remove site from CLIA certificate.
Another critical step will be to review and manage all existing vendor contracts with the aim of avoiding any financial or legal complications. Involve a finance team member, contract manager, administrative lead, and legal counsel, if available, to ensure that the clinic fulfills its obligations and concludes vendor relationships appropriately.
Review project records, including accounts payable, to compile a list of vendor contracts.
Review vendor contracts for required notice.
Consider buy-out requirements.
Provide notice per terms of agreement.
Clear, compassionate, and proactive communication with clients at closeout helps ensure continuity of care and maintain trust in the organization. Involve communications staff, clinical leadership, front office or client services staff, and compliance or medical records personnel to ensure messaging is accurate, sensitive, and consistent across all platforms.
Develop a list of clients to notify. Take care to honor confidentiality.
Notify clients according to funder and state clinical oversight requirements, including those outlined in your project NOA.
Notify by posting signage.
Notify clients individually:
- During appointment scheduling communication
- At check-in
- During the appointment
Another important step will be the proper handling of documentation and records. Involve the clinic compliance officer, health information management and IT staff, administrative lead, and legal advisor to ensure compliance, protect client privacy, and support future record requests.
Transfer records, maintaining appropriate documentation.
Maintain auditable 340B records, as appropriate.
Follow your record retention policy after reviewing to ensure compliance with current auditing standards and your project NOA.
Determine how records will be stored and accessed for future client records requests in accordance with your project NOA.
Ensure all client information has been secured.
Keep phone number active and play informational outgoing message for 1–2 months, along with checking and responding to incoming messages promptly.
All financial activities must be properly reconciled and reported in accordance with regulatory and funder requirements. Involve finance and accounting personnel, grant managers, and administrative leads to ensure compliance, accuracy, and timely submission of all fiscal documentation, as well as compliant records retention.
Collect, review, and reconcile all final invoices and financial reports from closing clinics.
Finalize vendor payments.
Retain records in accordance with federal retention schedule (3 years post-closeout).
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