Re: Records Retention Period for Subawardees Kristen Wolff 09 Mar 2006 16:08 EST
I have worked for two institutions now that saved their records for 7 years, using the 3-year rule as a minimum time only. Usually they kept the records on file for 3 years and then archived them elsewhere for the remaining 4 before destroying them. If you don't have much room for archiving, though, this might not be a good solution for you. -----Original Message----- From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf Of Barbara Gray Sent: Thursday, March 09, 2006 1:33 PM To: xxxxxx@HRINET.ORG Subject: [RESADM-L] Records Retention Period for Subawardees 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 ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================