Maintenance and Retention of Grant Program Records

In order to comply with common contract and grant requirements set by funding agencies, it is important that the following items be maintained by the Project Director as part of grant program records. This list is not all-inclusive.

  1. A copy of the original proposal and Request for Proposal (RFP).
  2. Copies of fully executed contracts, subcontracts, and sequentially numbered amendments.
  3. Copies of original budget and sequentially numbered amended budget.
  4. All communication sent by the funder, including prior written approval for changes in budget or key personnel.
  5. Copies of all reports submitted to the funder, both financial and programmatic.
  6. Financial records including all invoices to the funder and a schedule of expenditures. Expenditures are examined in the audit process. Therefore, all documentation necessary to support an expense should be included. These records must contain information pertaining to grant or subgrant awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Minimally, this should include such items as: the purchase order, vendor quote and invoice, proof of payment, and college credit card reconciliation report.
  7. Copies of all funder issued monitoring reports and audit reports. This includes copies of any responses to the funder regarding findings and corrective action plans.
  8. Staff roster including roles and percentage of effort for all employees working on the grant.
  9. Time and attendance records. Time and attendance records include time sheets and screen prints of the bi-weekly payroll approval from the E-Staff system. They must match the amounts invoiced and the amounts booked by the Office for Finance in the General Ledger. A review to ensure that all items correctly match should be done on a regular basis through frequent collaboration with the Office for Finance department.
  10. Time and Effort Certification forms. ( Also known as the Personnel Activity Report form, page 35)
  11. General Ledger Balance Report. The General Ledger Balance Report must match the amounts invoiced as well as the expenditure and payroll reconciliation sheets.
  12. Access to employee files (to be facilitated by Human Resources). Project Directors keep copies of the email(s) sent to HR requesting the position to be filled, employee resumes, performance reviews, and signed job descriptions for grant funded employees with their grant files. These documents must be redacted to ensure removal of Protected Personally Identifiable Information (Protected PII).
  13. Inventory records including invoices, purchase orders, proof of payment, location, and property control numbers for items purchased with grant funds.
  14. Participant files are often required to contain things such as: proof of eligibility, participant applications and intake forms, information release forms, proof of attendance at program activities, consent forms, transcripts, proof of citizenship, scholarship contracts, mentor visit notes, case notes, and documentation demonstrating payment to students (check or wire transfers).
  15. Evaluation records including the evaluation plan, reports, and data collection devices such as: copies of surveys, pre-and post-tests, and questionnaires given to participants to evaluate a grant program.

For grants from the U.S. Department of Education, the College maintains all records that fully show (1) the amount of funds under the grant or subgrant; (2) how the subgrantee uses those funds; (3) the total cost of each project; (4) the share of the total cost of each project provided from other sources; (5) other records to facilitate an effective audit; and (6) other records to show compliance with federal program requirements. 34 C.F.R. §§76.730-.731 and §§75.730-.731. The College also maintains records of significant project experiences and results. 34 C.F.R. §75.732. These records and accounts must be retained and made available for programmatic or financial audit.

Records Retention

During the project period, grant program records should be located in the Project Director’s office, and the Sponsored Projects Office should be made aware of their location. For consistency and compliance with state and federal regulations, grant program records must be maintained at the College for a minimum of ten years after the due date of the final financial report. However, if any litigation, claim, or audit is started before the expiration of the records retention period, the records will be trained until all litigation, claims, or audit findings involving the records have been resolved and final action taken. 2 C.F.R. §200.334. At the close of the project period, Project Directors must forward all grant records to the Sponsored Projects Office. These records are scanned and retained on secure drive. Grant program records should be kept by the Project Director, the Sponsored Projects Office, and the Office for Finance.


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