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Researcher's Handbook
Section 11
Records Management
Required Records and Retention Schedule
Grantees are required to keep intact and accessible all financial and programmatic records, supporting documents, statistical records and other records pertinent to an award. The records retention and custodial requirements extend not only to the records of the grantee, but to those of its subgrantees, contractors and subcontractors.
Records must be retained for a period of three years or longer as specified in each agreement. On a multi-year award, records are usually required to be kept only three years from the date of submittal of the first fiscal report for each budget period. Records under audit, involving unresolved audit findings, appeals or litigation must be held until the action is completed or the dispute resolved. (Note: Under no circumstances can a federal agency require retention of records relating to a program for more than six years. The statute of limitations, Title 28 U.S.C. 2415(b), provides that an action to recover for diversion of money paid under a grant program or an action for conversion of property of the U.S. must be brought within six years after the right of action accrues).
The starting date for the three-year retention period depends on the type of records:
| Type of Records | Retain for three years from the date of: |
|---|---|
| General records | Submission of the final or annual expenditure report. |
| Property and equipment | Final disposition of the equipment (i.e., transfer, records replacement, sale, or junking of the item). |
| Cost allocation plan and indirect cost records | Submission of plan or for plans which are prepared and retained by the grantee, with the close of the fiscal year. |
| Income records | The end of the grantee's fiscal year in which the income was used. |
| Royalties and other | The end of the grantee's fiscal year in which the program income earned income is earnedafter completion of grant. |
Property Management Standards
A grantee's property records for nonexpendable personal property (e.g., equipment) acquired under the grant must be retained for three years after the final disposition of the property. Records should include the following:
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Description of property.
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Manufacturers' serial number, model number, Federal Stock Number, National Stock Number, or other identification number.
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Source of the property, including grant or agreement number.
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Whether title rests with the grantee or the federal government.
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Acquisition date and cost.
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Percentage (at the end of the budget year) of federal participation in the project or program for which the property was acquired.
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Location, use, condition and the date the information was reported.
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Unit acquisition cost.
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Ultimate disposition data, including date of disposal, sales price or method used to determine fair market value where a grantee compensates the agency for its share.
Grantees must take a physical inventory at least every year with the results reconciled with property records. The inventory should:
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Verify the existence, current use, and continued need for the property.
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Establish a control system of adequate safeguards and maintenance to prevent loss, damage, or theft.
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Maintain property in good condition.
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Use selling procedures that provide for competition that will result in the highest possible return.
Financial Management Standards
The federal government in its OMB circular A-110 (Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals and other Non-Profit Organizations) and OMB circular A-21(Cost Principals for Education Institutions) set forth the basic grantee financial management standards which apply to all grant programs and provides, among other things, for:
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accurate, current, and complete disclosure of the financial results of each grant program;
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accounting records which identify the source and use of grant funds;
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account control for all grant funds, property, and other assets.
At the University of Florida, these requirements are met through a uniform accounting system that provides the basic controls as well as accounting reports that will assist faculty and their staff in managing contracts and grants. The University accounting system is under the jurisdiction of the Division of Finance and Accounting and the Vice President for Administrative Affairs. Questions or inquiries concerning accounting should be addressed to the Office of Contracts & Grants (302 Grinter, 392-1235), EIES Contracts & Grants Accounting Office (545 Weil, 392-6626), or IFAS Contracts & Grants Accounting Office (2029 McCarty, 392-1735).
Audits and Access to Records
All records are subject to audit and any authorized representative of the Grantor, the State or the University shall have right of access to any books, documents, papers or other records of the grantee which are pertinent to the contract or grant. The right of access shall not be limited to the required retention period but shall last as long as the records are retained.
With regard to Federal audit requirements on grants, contracts and other agreements, the University falls under OMB circular A-133 (The Single Audit Act). When a sponsor announces its intent to conduct a contract or grant audit, RGP should be informed as promptly as possible. If auditors request to meet with researchers or other departmental employees, staff from the appropriate fiscal office will accompany the auditor and be available during the visit to help interpret and understand the requests of the audit. In order to assure maximum coordination of staff time and availability of records, audit visits should be prepared for as soon as notification is received.