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

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