I think this is a fairly simple question, but I can see both sides of
the coin.

We are a subcontractor on a federal grant made to a state agency.  The
federal grant and our subcontract are subject to A-110, which requires
that records be retained for three years after expiraton of the award.
Our subcontract does not run the same period as the state agency's
award; let's say it ends one year before the prime award ends and then,
unbeknownst to us, the state agency later gets a one-year extension.

If A-110 applies to our subcontract, are we within our rights to destroy
our records at three years--which would be a full two years before the
state agency can destroy theirs?  The state agency feels that they
should have all project records--including our subcontract
records--available to them for their three-year retention period, which
means we would have to retain our records for five years.   Is this
appropriate?  If so, who is generally responsible for informing the
subcontractor that the prime's expiration date has changed.  (They want
us to contact them for permission before destroying the records.)  If
this is not appropriate, can someone give me a citation that clearly
says that it is the three-year period applies to us as a subcontractor
and that is the only period during which they can reasonably demand
copies of the record?

Thanks.
Barbara

--
Barbara H. Gray
Director of Sponsored Research
Desert Research Institute
2215 Raggio Parkway
Reno, Nevada  89512-1095
Telephone:	775-673-7381
Fax:		775-673-7459
E-mail:	xxxxxx@dri.edu
www.dri.edu

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