That is the whole point in having retention schedules – and using them.  As long as you have a policy and follow it, you are pretty much protected from criticism for not being able to produce a record.  It is when you arbitrarily choose to retain or dispose of records that you can have problems.  Questions will come up as to why you chose to destroy a certain record.

The challenge we find is managing the record retention process – getting staff to purge those records according to the schedule.  No one has time to do it, and some people like to keep the records “just in case.”  They don’t realize that the “just in case” could lead to big headaches! 

As to the original question of how long to retain grant-related records, we defer to the agency guidelines, or more general federal circular guidance for retention.  Those 3-year, or 7-year or whatever requirements are built into our retention schedule.

I, too, have gotten requests for final information that was sent more than 3 years ago.  As long as they only want financial information that we can report off of our accounting systems (e.g. a copy of the FFR) we provide it.  However, if they ask for final reports, etc. we indicate that the records were kept for the required amount of time and then destroyed.  There has never been any problem from the sponsor(s).

Heather

Great question.

Is the recipient still liable for retaining records if the funding agency hasn’t yet closed out their records?  Though my experience is that agencies have very much gotten their “act together” regarding their own closeout of awards in recent years, I do have memories of being contacted by funding agencies well after the 3 year mark. 

Thank you,

John

Our institution is reviewing our records retention policy regarding effort reports.  A-110 says (roughly) to retain financial records for three years from the date of submission of the final expenditure report or until three years after all litigation, claims, or audit findings are resolved.

I’d love to get feedback from other institutions on how this is handled.  Do you consider the audit period of each award when determining whether an individual effort report can be purged?  Do you purge based only on the period covered by the report?  Do you have another method?  Are you using paper reports or do you have a computer system?

Thanks for your assistance,

Debra

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Debra Henn, CRA

Compliance & Training Coordinator

Extramural Funds Accounting

Accounting & Financial Services, UC Davis

(530) 757-8681

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P Be green - please print only when necessary!

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