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RMP-5, Records Retention Program for Financial Documents Pertaining to Federal Awards to the University - References, Introduction, Records Destruction, Procedures, ResponsibilitiesSeptember 15, 1986I. REFERENCES
A. University of California, Records Disposition Schedules Manual
B. Business and Finance Bulletins
RMP-1, "University Records Management Program," revised November 1,
1985
RMP-2, "Records Disposition Program and Procedures," revised November
1, 1985
A-53, "Official Documentation Required in Support of University
Financial Transactions," revised July 1, 1984
C. Records retention clauses of existent Federal contracts and grants
D. Federal Regulations and Requirements
Federal Acquisition Regulations (FAR) Subpart 4.7
Office of Management and Budget (OMB) Circular No.A-110, Attachment C
Federal Procurement Regulations (FPR) Part 1-20
Defense Acquisition Regulation (DAR), Appendix M, Parts 1 and 2
Department of Energy (DOE) Acquisition Regulations, Subpart
904.7-Contractor Records Retention, 904.702 Applicability
E. Federal Register
Department of Health and Human Services, Health Professions Student
Loan (HPSL) Program, June 3, 1983
Department of Health and Human Services, Nursing Student Loan (NSL)
Program, August 23, 1985
Department of Education, Title IV of the Higher Education Act, Student
Assistance General Provisions, December 31, 1980 and April 11, 1983
Department of Education, Pell Grant Program, October 6, 1983
Department of Education, Supplemental Educational Opportunity Grant
(SEOG) Program, January 19, 1981
Department of Education, College Work-Study (CW-S) Program, January
19, 1981
Department of Education, National Direct Student Loan (NDSL) Program,
January 19, 1981 Department of Education, Guaranteed Student Loan
(GSL) Program, September 17, 1979
Department of Education, Parent Loans for Undergraduate Students
(PLUS), January 21, 1981
II. INTRODUCTION
The purpose of this Bulletin is to set forth a uniform procedure, in
compliance with Federal regulations, for the destruction of financial
documents (as set forth in Business and Finance Bulletin A-53)
pertaining to Federal awards as identified by asterisks in the
University Records Disposition Schedules Manual. Such awards include,
but are not limited to, contracts and grants for research, training,
public service, construction, and student financial aid.
III. AUTHORITY FOR RECORDS DESTRUCTION
University administrative records, including financial documents as
identified in Business and Finance Bulletin A-53, are retained and
destroyed, by policy, in accordance with the University Records
Disposition Schedules Manual. In relation to most Federal contract and
grant records, the University has, by accepting the contract and grants,
entered into a binding agreement which requires it to apply Federal
disposition schedules to such records. Therefore, when disposing of
Federal contract and grant material, both the University's official
disposition schedule and the Federal disposition requirement of each
contract or grant must be applied, whichever is longer. However, it
should be noted for both contracts and grants, when an audit or
litigation is initiated before expiration of the prescribed retention
period, records must be retained until the audit findings or litigation
is resolved. Thus, when considering the appropriate retention period
and disposition of financial documents under Federal awards, the
following must be considered:
A. The retention set forth in the University Records Disposition
Schedules Manual,
B. the existence of an audit or litigation relating to the award,
C. the retention period established in the award for the general award
file,
D. for Federal procurement contracts, any "special" retention period
for certain financial documents as set forth in various Federal
procurement regulations, and
E. for Federal grants for student financial aid, any "special"
retention period for certain financial documents as set forth in
various Federal student financial aid program regulations.
IV. PROCEDURE
A. Each campus Accounting Officer (or other designated official) should
determine, pursuant to the University Records Disposition Schedules
Manual, the records retention requirements for all financial
documents generated under Federal contracts and grants at his/her
campus (both those which are active and those which may have
terminated but which have not yet been disposed of). Further, the
campus Accounting Officer (or other designated official) should
determine whether there exists an unresolved audit or litigation
relating to the Federal award under which the financial document
was generated.
B. If the retention period for the financial document as set forth in
the University Records Disposition Schedules Manual has not yet
lapsed, or if there exists an unresolved audit or litigation
relating to the award under which the financial document was
generated, the campus Accounting Officer (or other designated
official) should notify the Office of Record that the financial
documents must be retained until final resolution of the audit or
litigation.
C. Where the retention period under the University Records Disposition
Schedules Manual for the financial document itself, has been
satisfied and where no audit or litigation exist, the campus
Accounting Officer (or other designated official) shall further
consider disposition of financial documents in light of the
retention requirements of the extramural award to which the
financial document is related, as discussed in D., E., and F., below.
D. Financial Documents (under Federal Procurement Contracts) for which
"Special" Retention Periods are Established by Federal Procurement
Regulations
Federal Acquisition Regulations (FAR) Subpart 4.7,
Federal Procurement Regulations (FPR) Part 1-20, and Defense
Acquisition Regulation (DAR) Appendix M, Parts 1 and 2, provide
specific retention periods for particular generic types of
financial documents under Federal procurement contracts. These
three major Federal procurement regulations governing all Federal
procurement contracts are attached as Exhibits A, B, and C. Note
that these sections identify generic classes of financial records
for which "special" disposition periods are established as well
as the methods for the calculation of the retention period. In most
cases, the "special" retention periods set forth for these financial
documents are shorter than the retention period for the general
contract records themselves. In such cases, inaccordance with the
appropriate regulation in Exhibits A, B, and C, financial documents
may be disposed of at the end of the "special" shorter retention
period (provided that the University's retention period for the
financial document has been satisfied and there is no
pending audit or litigation related to the document). No special
approval or authorization from the Federal funding agency is
required.
It should be noted that FAR Subpart 4.7 excepts certain Department of
Energy (DOE) contracts from the "special", usually shorter, records
retention periods set forth therein. DOE Acquisition Regulation
904.702 discusses the very limited types of DOE contracts (usually
management and operating contracts) for which the "special"
retention periods of FAR Subpart 4.7 would not apply as follows:
...Contracts containing the Safety and Health Clause at
952.223-71, the Radiation Protection and Nuclear Criticality
clause at 952.223-72, or the Nuclear Safety clause at
952.223-74 must also include the Preservation of Individual
Occupational Radiation Exposure Records clause at 952.223-75
which will necessitate retention of records in accordance with
the schedules contained in Chapter V of DOE Order 1324.2 and
any pertinent superseding provisions, rather than those found
at FAR 4.7. These schedules are required by DOE, pursuant to
an agreement with the General Accounting Office, in situations
where prudence dictates longer retention periods for records
involving employee health matters.
E. Financial Documents under Federal Grants and under Federal
Procurement Contracts for Which No "Special" Retention Period is
Established
Those financial documents under Federal procurement contracts for
which no "special" retention schedule is set forth in FAR Subpart
4.7, FPR Part 1-20, or DAR Appendix M, Parts 1 and 2, are subject
to the standard records retention schedules set forth in the
University Records Disposition Schedules Manual for the extramural
contract under which the financial document was generated.
Those financial documents under Federal grants, other than those for
Federal student financial aid programs discussed below in subsection F,
are subject to the records retention requirements set forth in
Office of Management and Budget (OMB) Circular No. A-110,
Attachment C, for the extramural grant under which the financial
document was generated. OMB Circular No. A-110 is attached as
Exhibit D.
F. Financial Documents under Federal Grants for Student Financial Aid
Programs for which "Special" Retention Periods are Established by
Federal Regulations
Federal regulations listed in Reference Section I.E. prescribe the
retention period for particular generic types of financial documents
under each Federal student financial aid program. The specific
period of retention of these records varies depending on the program involved,
but in all cases the retention period is longer than the three years
after submission of the final expenditures report prescribed for
other Federal grant programs pursuant to OMB Circular No. A-110,
Attachment C. For instance, National Defense/Direct Student Loan
records must be retained for at least five years from the date the
loan was cancelled, paid in full, or assigned to the Federal
government for collection. Most other types of Federal student
financial aid records must be retained for a period of five years
after the Fiscal-Operations report for that year has been filed.
V. RESPONSIBILITIES
It will be the responsibility of each campus officer responsible for
financial records within his/her jurisdiction (i.e., Accounting
Officer, Financial Aids Officer, Contracts and Grants Officer, etc.)
to destroy financial records applicable to Federal contract and grant
activities in accordance with the procedure prescribed above and to
communicate the authorized retention period to the campus Records
Management Coordinator for dissemination to campus departments.
Further, the campus Accounting Officer (or other designated official)
should ascertain that any external audit activity is completed prior to
destruction of financial records relating to Federal contract and grant
awards.
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