Most of us do not concern ourselves with records retention since “someone takes care of it”. At Emory, however, the schools departments institutes, and centers share responsibilities for record retention amongst their constituents, which could include YOU. Records are kept to document decisions, policies, expenditures, internal controls, and to maintain Emory’s history and activities. Many are aware of record keeping during audits or lawsuits. It is at those times that good records prevent audit findings and possibly prevent damages in a lawsuit. you can help by making sure important records are available when needed. This is particularly true now that the Federal agencies are beginning to use statistical audits of groups of records rather than specific audits of single awards. Statistical audits are more cost effective than single program audits. A single missing document in a statistical audit could result in the auditors extrapolating a finding of a few dollars to thousands or hundreds of thousands of dollars, depending on the sample size.
For original sponsored program financial records, the general rule is that Emory must keep the records for three years from the last activity on the award. For a five year award where the last activity was the final financial status report that was submitted 90 days after the end of the award. The minimum retention age eight years and three months from the start of an award. this last activity could be the date of the final payment receipt or the date the final technical or financial report was sent. If an audit is underway for an award or groups of awards or records, Emory must keep all the records until the audit is completed; then all the financial records can be disposed of it the audit end date is greater than the required retention period. Some agencies have specific rules that require holding their records for four or five years after the award ends. Contact the OGCA director if you have a question on a retention period for any original sponsored program documents you hold. For safety, Emory keeps many original records a minimum of seven years from the date of the transaction.
The Office of Grants and Contracts Accounting (OGCA) has very few original grant and contract financial records. Other custodians of record throughout the University control the bulk of original sponsored program financial records. They may apply different rules or procedures for a number of valid reasons. for Example, the departments/schools maintain control over the original records for travel and purchase (T and P) cards. Logically, the units would keep those records by individual or by date of transaction rather than by sponsored program. In most cases, they need to keep these records at least seven years, and probably ten years, and have a way to find them for a sponsored program audit. Similarly, Procurement and Payment Services keeps check and invoice support for all University purchases including grants by check number and purchase order number or vendor name.
Decentralized record retention will cause record retrieval problems and expense. However, not finding the record can be even costlier to Emory. For more information, please go here or contact the University Archivist, Kate Donovan Jarvis.