Record Retention Policies for Contracts and Grants Tam Tran Assistant Director, Sponsored Projects


Record Retention Policies for

Contracts and Grants

Tam Tran

Assistant Director, Sponsored Projects

September 12, 2012


How long are we supposed to keep Contracts and Grants financial records such as back up/supporting documentation for expenses allocated to the award?

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Federal Requirement

• OMB Circular A-110 (Section C53)

• Financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of three years from the date of submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, as authorized by the Federal awarding agency.

• If any litigation, claim, or audit is started before the expiration of the 3year period, the records shall be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken.

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UC Requirement

Contract and Grant Manual

(Section 17-300)

• Financial records and supporting documents pertinent to an award (Federal, State and Private)

• Records Copy must be kept the longer of 6 years after expiration/termination; resolution of any litigation, claim or audit; or period stated in award document.


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• What is the Records Copy?

original copy of record that is maintained and retained by the Office of Records

• What is the Office of Records?

Unit or department that is responsible for retaining the

Records Copy


 C&G Accounting-general ledger

 Sponsored Projects- awards, proposals and institutional communications with sponsors

 Departments/units/schools- supporting documentation for the charges and credits on general ledger

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• Why UC requires 6 years when OMB A-110 states 3 years?

administratively burdensome for Accounting to notify all Offices of Records when final expenditure report is submitted

- presume a period of 6 years after project end date is enough to accommodate the 3 years req’t imposed by sponsors

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• Example 1-NIH Grant

 Period of Performance April 1, 2008-March 30, 2013

 Record copies must be retained 6 years after the project end date (i.e. March 30, 2019)

• Example 2-DOE Grant

 Same award number- last continuation award before renewal marks end of the prior competitive segment

• Example 3- Contract

 end date of the contract= end date of the award

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Take Away Message

• Follow the more restrictive requirement- UC retention requirement

• Records remain subject to possible future requests under statute or legal proceedings

(e.g., California Public Records Act) if not disposed timely

• Check with SPA before destroying records if there is any doubt!!!

Quality Research Administration Meeting


Quality Research Administration Meeting