Reporting Requirements

Sponsored activities administered under the terms and conditions of a grant or contract agreement normally requires retention of records for three (3) years from the expiration date of the agreement except as otherwise stated therein. This time period is measured from the final project ending date extended by any amendments or modification.

If the University’s period for retaining records is less than the required period of a grant or contract, it is the responsibility of the department to retain pertinent documentation on individual projects. Specific contract or grant regulations should be followed if the requirement is more than 3 years.

SP is responsible for retaining (1) the official contract files, including the original award and any amendments, required sponsor approvals, and subcontracts; and (2) the official accounting records, including financial transactions, reports, and invoices. In the event that any litigation, claim, or audit is started before the end of the specified retention period, the documentation must be retained until all issues have been resolved.

According to OMB 2 CFR 200, “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.” There are a few exceptions to this requirement, which are noted in the Circular https://www.whitehouse.gov/omb/information-for-agencies/circulars/. Retention requirements may be different for non-Federal grants. Upon a grant’s official close-out, the PI, SP, and Controller’s office should meet to examine the grant’s record retention requirements and note when the retention period ends.

At the end of the retention period, records should be purged from physical and electronic files. For further direction and guidance regarding record retention, call the SP office.