Barbara, is DRI under state regulations?  If so, their requirements
for longer retention take precedence.

Even if they are not, I suggest acquiescing to their retention
requests when they are your prime, as a courtesy.

Chuck

At 03:33 PM 3/9/2006, you wrote:
>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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Herbert "Chuck" Chermside, CRA
Director Emeritus, VCU Sponsored Programs
Executive Director, Research Administrators Certification Council
1915 Robindale Rd.
Richmond, VA 23235-3931
804-320-5502
xxxxxx@verizon.net

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