Linda, The determining factor in this discussion is a law will always trump a regulation. 28 USC 1732 takes precedence over agency regulation and, therefore, in the regular course of business, the original may be replaced by any photographic or electronically imaged copy unless preservation of the original is required by law. Most States have laws that are similar to this. DHHS issued OGAM Action Transmittal of August 9, 1999 (OGAM AT 99-1), although the action transmittal specifically referred to organizations that receive the majority of their Federal funding from HHS, it was the intent of the Department that the action transmittal would apply where HHS is the cognizant Federal agency. We received this, from DHHS, in March 2004 concerning an audit finding concerning this very matter. The response was from the Office of Grants Management and Policy Resolution and Cost Policy. David O. Schmidt, CPA, CRA Assistant Vice President for Research and Economic Development, Grants & Contracts Management University of North Dakota 264 Centennial Drive Twamley Hall - Room 100 Stop 7306 Grand Forks, ND 58202-7306 Telephone - 701-777-2505 Fax - 701-777-2504 e-mail - xxxxxx@mail.und.nodak.edu >>> Linda Ward <xxxxxx@CHILDRENSMN.ORG> 6/2/2009 9:39 AM >>> The Dept of Justice requires original receipts, but our Accounts Payable dept scans the originals and discards them, using the scan as our institutional record. The result is that have to maintain a separate file (in our case a binder) for our DOJ grant's original receipts. Does anybody know NIH's position? "Children's Grant Accounting office provides quality service backed by over 20 years experience in federal and non federal grant and contract accounting, reporting, and compliance." Linda Ward, MBA Grant Accounting Manager Grant Accounting 35-123A Children's Hospitals and Clinics of Minnesota 2910 Centre Pointe Dr. Roseville, MN 55113 651-855-2603 651-855-2690 Fax email: xxxxxx@childrensmn.org >>> Marie Smith <xxxxxx@CARYINSTITUTE.ORG> 6/2/2009 9:22 AM >>> Check out: PARTS 200-214 [RESERVED] PART 215-UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS AND AGREEMENTS WITH INSTITUTIONS OF HIGHER EDUCATION, HOSPITALS, AND OTHER NON-PROFIT ORGANIZATIONS (OMB CIRCULAR A-110) * 215.53 Retention and access requirements for records. (c) Copies of original records may be substituted for the original records if authorized by the Federal awarding agency We checked with NSF, our cognizant agency, and the ruling was original receipts. *-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-* Marie F. Smith, CRA Certified Research Administrator Grants Administrator/Compliance Officer Cary Institute of Ecosystem Studies PO Box AB (2801 Sharon Turnpike) Millbrook, NY 12545 Phone: 845-677-7600 x202 Fax: 845-677-5976 E-mail: xxxxxx@caryinstitute.org<mailto:xxxxxx@caryinstitute.org> Internet: http://www.caryinstitute.org<http://www.ecostudies.org/> P Please consider the environment before printing this email From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Schier-Happell, Suzanne E Sent: Tuesday, June 02, 2009 9:41 AM To: xxxxxx@hrinet.org Subject: [RESADM-L] Original Receipts? I'm just curious about how strict everyone here is about receipts being turned in for reimbursement. My questions are: 1. Do you accept copies of receipts, or do they have to be the original receipts? 2. Do you accept bank statements or credit card statements as proof of purchase for reimbursement, or do you always require the original purchase receipt? It seems like we've had a lot of "misplaced" receipts lately, so people end up submitting copies of their statements along with reimbursement requests. I hate doing this because then there is no way to prove what was actually purchased, plus there's no way to know if sales tax was included in the purchase. But I'm unsure whether my hesitance should grow into flat-out refusal to pay. Anyone have some clear guidance for me on this? Thanks! Suzanne ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Suzanne Happell Assistant Director of Sponsored Programs Otterbein College xxxxxx@otterbein.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") ====================================================================== _______________________________________________________________ Confidentiality Statement: This email/fax, including attachments, may include confidential and/or proprietary information and may be used only by the person or entity to which it is addressed. If the reader of this email/fax is not the intended recipient or his or her agent, the reader is hereby notified that any dissemination, distribution or copying of this email/fax is prohibited. If you have received this email/fax in error, please notify the sender by replying to this message and deleting this email or destroying this facsimile immediately. ====================================================================== 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") ======================================================================
