The problem isn't storage, it's that if you still have the records, they are
auditable, regardless of whether you're past your records retention period.
Since A-133 requires pass through entities to require that subrecipients
permit them to "have access to the records and financial statements as
necessary for the pass-through entity to comply with" A-133, I would say the
state has the right to extend your records retention period to be the same
as theirs.
-----Original Message-----
From: Kristen Wolff [mailto:xxxxxx@ASU.EDU]
Sent: Thursday, March 09, 2006 4:09 PM
To: xxxxxx@HRINET.ORG
Subject: Re: [RESADM-L] Records Retention Period for Subawardees
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
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