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| Retention
of Grant Documents |
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Type
of Grant |
Description
of Record |
Recommended
Retention Period |
| Federal
Grant |
In
general, the federal retention is three years, starting,
with some exceptions, with the date of submission of the
final or annual expenditure report, or, for property and
equipment records, the date of transfer, replacement,
sale or junk of the item.
Records under audit, involving unresolved audit findings,
or under appeals or litigation must be held until the
action is completed or the dispute resolved.
Note: A federal agency cannot require a grantee to retain
program records for more than six years. The statute of
limitations, 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.
Note that grantees do NOT have to hold and maintain records
until they are audited; instead, they only need to hold
them long enough to satisfy the three-year retention period.
As a consequence, any records held beyond the minimum
three-year retention period because of state law or the
grantee's normal requirements are subject to review and
audit.
Grantees are permitted to retain records on microfilm
instead of original records. We have assumed that this
ruling will eventually be extended to cover electronic
imaging, if it has NOT been already.
Note: NYS requirements are for six years. Presumably this
would apply to Federal flow-through grants from New York
state.
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6
Years |
| New
York State Grants |
The
New York State Department of Social Services Contract
Operations Manual (Rev 10/96) states the "Accounting
and other fiscal record, although NOT required with the
submission of vouchers, must be retained for a fixed period
of years as required by each contract, usually six years. |
6
Years |
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