Document Retention and Access

  • Details

    Grant information must be organized and accessible. Through the course of a project, the grant manager should consistently maintain documentation of activities and compliance. Ideally the program should be ready at any time for a monitoring visit, a desk review, or a full scale audit.

    Many grant-based records are required to be kept, on-site and accessible, following the end of the project or grant. This ensures records are available in the event of an audit or legal concern. Because the Office of the Inspector General (OIG) can reclaim funds five years past the end date, SPPS retains records for a minimum of five years.

    If a project creates records on, of, or about students, that information is protected in the same fashion as the student record.


    Record Retention - Records Involved

    • Funder and legal documents
    • Budget records
    • Personnel records
    • Programmatic records

     See Grant Document Retention Quick Guide for a complete detailed list.


    Record Retention - Process Details

    Records may be retained in any format that protects against alteration and retains integrity. The location of SPPS records must be recorded with the grants management coordinator (GMC) and the grants accountant. Records may be turned over to the GMC for retention.

    Records must be kept for five years from the date the final expenditure report is submitted (or the date the report would have been due if this has been waived). If litigation, audit or other action involving the records starts during the retention period, the records must be kept until issues are resolved or the retention period expires, whichever is later.

    Awarding agencies may make arrangements for retention of records needing joint access. The awarding agency may request custody of records if it determines the records possess long-term value. If records are maintained by a federal agency, the retention requirement no longer applies.


    Record Access

    The awarding agency, Inspector General, Comptroller General, or any of their authorized representatives, have the right to access any SPPS records pertinent to the grant, in order to make audits, examinations, excerpts, and transcripts. The rights of access in this section last as long as the records are retained.

    The Federal Freedom of Information Act (5 USC 552) does not apply to records unless required by federal, state, or local law. SPPS is not required to permit public access to their records.

Why This Is Important

    • It’s the law (see 2 CFR Part 200.333-336)
    • Ensures records are accessible in the event of an audit
    • Ensures records and protected data are protected from unauthorized use
Last Modified on October 31, 2018