Records Retention
There are several official retention schedules governing University records. Reconciling the requirements can be challenging. Not all information created or received by an organization rises to the level of being an official business record – this important subset requires deliberate management because these records provide evidence of business transactions, decisions and satisfaction of legal obligations. Record retention periods for sponsored research records vary depending on the type of sponsor (Federal, State, other) and the type of record. Individual sponsors can deviate from these norms and specify retention periods unique to a sponsor, program, award or record type.
All project-related records, (financial, supporting documentation, statistical, and all other non-federal entity records pertinent to a federal award) must be maintained for a period of five years after the submission of the final financial and/or audit report. The only exceptions are the following:
- If any litigation, claim, or audit is started before the expiration of the 5-year period, the records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken.
- When the non-federal entity is notified in writing by the federal awarding agency, cognizant agency for indirect costs, or pass-through entity to extend the retention period.
- Records for real property and equipment acquired with federal funds must be retained for 3 years after final disposition.
- Sponsors who require a different retention period per the award agreement.
- Certain records in which a central administrative office is the official office of record, such as export control and PO invoices and vouchers.
Principal Investigators, Project Directors and Business Managers should retain complete grant/contract files (financial and technical: including technical reports, lab notes, and all institutional committee approvals such as human subject, animal care, radiation, etc.) for a minimum of five years AFTER award closeout. After that date, check with the Office of Contracts and Grants to ascertain whether longer retention is necessary.
Record Retention Reference Guide
Record Type |
Policy |
Business Transaction Records Not Contract or Grant Related |
|
Direct Charges and Revenues - Sponsored Projects |
|
Documents included in F&A Rates |
|
Environmental Health and Safety Training |
|
Employee Payroll Information |
|
Equipment/Property Records |
|
Other Depreciable Assets |
|
Personnel Files |
|
Petty Cash Receipts - Contracts |
|
Program Income |
|
Research Data Including Lab Notebooks |
|
Student Records |
|
Taxable Income (UBI) |