OMB has made it clear for years that this apples to all records, technical
as well as financial.

VCU interprets this conservatively.  We consider that the start of the
three year clock is after the last submission of the last financial report
required for the total project; we do not consider budget period reports
other than the last budget period as starting the clock.  Of course we have
a state requirement to retain such records for a five year period, so we
live with that.  Does Florida have something similar?  Also, numerous of
our records are actually kept for much longer in back-up files
electronically recorded and stored, so they could be available if needed,
but for all practical purposes  those are just "dead files".

We have no good system for measuring the start of the clock from the last
technical report if that is submitted after the last financial report.  I
do not know if an external authority could interpret such a later date as
the start of the clock; I think that argument can be ignored unless there
are clear precedents for it from administrative or judicial courts.

Our current draft policy on data retention recognizes the five year holding
period for "Research Data", with the clock starting from the last
"Report".  "Report", broadly, means a report to a sponsor or a journal
article or other publication of the data.  "Research Data" is carefully
defined to be original observations and statements of methodology,
essentially records that would have to be examined in a case of scientific
misconduct or follow up on compliance matters, with emphasis on human or
animal subjects.  This is not driven by the A-110 requirement, but by other
regulations.  That retention should be looked at, but with an awareness
that it is from different regulations.

Chuck

At 05:12 PM 7/8/2004, you wrote:
>
>Hello All:
>
>I have a question concerning the retention of records for Federal awards.
>The following is an excerpt of OMB Circular A-110.  How do you interpret
>and do you apply the highlighted portion below when retaining records at
>your University ?
>
>___.53
><http://www.whitehouse.gov/omb/circulars/a110/a110.html#reports#reports>Retention
>and access requirements for records.
>(a) This section sets forth requirements for record retention and access
>to records for awards to recipients. Federal awarding agencies shall not
>impose any other record retention or access requirements upon recipients.
>(b) Financial records, supporting documents, statistical records, and all
>other records pertinent to an award shall be retained for a period of
>three years from the date of submission of the final expenditure report
>or, for awards that are renewed quarterly or annually, from the date of
>the submission of the quarterly or annual financial report, as authorized
>by the Federal awarding agency. The only exceptions are the following.
>(1) If any litigation, claim, or audit is started before the expiration of
>the 3-year period, the records shall be retained until all litigation,
>claims or audit findings involving the records have been resolved and
>final action taken.
>(2) Records for real property and equipment acquired with Federal funds
>shall be retained for 3 years after final disposition.
>(3) When records are transferred to or maintained by the Federal awarding
>agency, the 3-year retention requirement is not applicable to the recipient.
>(4) Indirect cost rate proposals, cost allocations plans, etc. as
>specified in paragraph ___.53(g).
>
>
>Thanks for your input.
>Sue
>
>Sue Logan, CPA, CRA
>Assistant Director, Contracts and Grants
>Division of Research and Graduate Studies
>Florida Atlantic University
>3731 FAU Boulevard, RD7
>Boca Raton, FL  33431
>(561) 297-2606  phone
>(561) 297-2319  fax
><mailto:xxxxxx@fau.edu>xxxxxx@fau.edu
>www.fau.edu/research/ocg/index.html
>
>
>
>
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Herbert B. Chermside, CRA
Special Asst. to VP-Research
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Voice:  804-827-6036
Fax     804-828-2051
e-mail xxxxxx@vcu.edu

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