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Retention of Grant Documents

Federal Grant

6 Years

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.

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.

New York State Grants

6 Years

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.