1. Quality Research Administration Meeting Record Retention Policies for Contracts and Grants Tam Tran Assistant Director, Sponsored Projects September 12, 2012

2. Quality Research Administration Meeting Question How long are we supposed to keep Contracts and Grants financial records such as back up/supporting documentation for expenses allocated to the award?

3. Quality Research Administration Meeting 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 3- year period, the records shall be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken.

4. Quality Research Administration Meeting 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. http://www.ucop.edu/raohome/cgmanual/chap17.pdf

5. Quality Research Administration Meeting 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 Examples:  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

6. Quality Research Administration Meeting 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

7. Quality Research Administration Meeting Grants/Contracts 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

8. Quality Research Administration Meeting 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!!!

9. Quality Research Administration Meeting Questions????