Record Retention Policy

I. Purpose

This policy ensures that The College of St. Scholastica (CSS) will be compliant with the provisions of the Federal Office of Management and Budget’s regulations including 2 CFR 200, Uniform Guidance, specifically the provisions related to record retention (2 CFR 200.333), as well as State and private funder requirements.

II. Policy

Federal grant records, supporting documents, statistical records, and other records pertinent to a Federal grant award will be retained for a period of three years from the date of submission of the final expenditure report. In addition, records will be maintained beyond that time period:

  1. If any litigation, claim, or audit is started before the expiration of the 3-year period, the records will be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken.
  2. If CSS is notified in writing by the Federal awarding agency, cognizant agency for audit, oversight agency for audit, cognizant agency for indirect costs, or pass-through entity to extend the retention period.
  3. If the records are for real property and equipment acquired with Federal funds, these records will be retained for 3 years after final asset disposition.
  4. If there is a requirement to report program income after the period of performance, the retention period for the records pertaining to the earning of the program income will start from the end of CSS’s fiscal year in which the program income is earned.

State and private grant records, supporting documents, statistical records, and other records pertinent to a non-federal grant award will be retained for the period required by the granting agency. If no record retention period is specified, retention will be based on federal requirements.

Primary responsibility for grant record retention is delineated in Table 1.

Table 1
Type of Record Responsibility
Participant lists Principal Investigator
Participant eligibility documents Principal Investigator
Annual Performance Reports Principal Investigator
Progress Reports (including non-competing continuations) Principal Investigator
Award Notices Foundation & Government Relations
Prior Approval Submissions Foundation & Government Relations
Award Extension Materials Foundation & Government Relations
Closeout Notices Foundation & Government Relations
Financial Records & Reports Finance
Capital Equipment: Inventory & Disposal Finance
Invoices Finance
Purchasing Card documentation Finance
Time & Effort Documentation Finance
Requisitions & Purchase Orders Purchasing

During project initiation the Principal Investigator must designate a second individual who will also have access to the grant records for which the Principal Investigator carries primary responsibility. In the event that a Principal Investigator leaves the institution, the Principal Investigator will provide all award records to the Principal Investigator’s direct supervisor. During project closeout, the Principal Investigator must communicate types and locations of participant records to the Finance and Foundation and Government Relations staff.

Print Article