Chapter 17-300: Administrative Records

The University's administrative records management program is outlined in the RMP Series of the Business and Finance Bulletins. Following are some of the topics covered in that Series that would be of interest to Contract and Grant Officers:

17-310 Records Disposition Schedules for Contract and Grant Documents

The University's disposition schedules for contract and grant related records are set forth in the University Records Disposition Schedules Manual, Section I.D., Contracts, Grants, and Agreements (Extramural) for Research, Training & Public Service. These schedules present the name or description of the record; establish the Office of Record for the document; and set the schedule for disposition in years. Guidance on Retention and Disposition Requirements for Administrative Records Relating to Research, published on the OP RPAC web site, provides a comprehensive listing of records retention and disposition requirements for all research-related records including those for animal and human subjects, conflict of interest, misconduct, environmental health and safety, etc.

17-311 Office of Record

For extramural awards and proposals and for basic agreements, the Office of Record has been established as the "Contract and Grant Office (campus or OP) with operational responsibility." This designates the office at the operational level, i.e., the appropriate campus, OP or Laboratory Contract and Grant Office or, for certain agricultural programs, the Vice President--Agriculture and Natural Resources. This has the effect of assigning Office of Record responsibility to the office with day-to-day administrative responsibilities. Under this procedure, a campus or Laboratory Contract and Grant Office would be the Office of Record for an award document even though an acceptance or execution by the President and/or Officers of The Regents was required under specific Regental authorization.

17-312 Retention Period

The following retention requirements apply to the Office of Record copy of a contract and grant record. The retention period for other copies is generally 0-5 years.

a. Awards.

For all extramural contracts (including interagency agreements and project orders under basic agreements), grants (including private), and cooperative agreements (including private), the prescribed retention period for the Record Copy is the longer of: six years after expiration/termination; resolution of any litigation, claim, or audit; or the period stated in the award document. Other copies should be retained for a period of 0-5 years.

Federal and State of California funding agencies usually require records retention for three years (occasionally four years) measured from "final payment" for contracts and measured from "submission of final expenditures report" for grants. However, because it is administratively unreasonably burdensome for Accounting offices to notify the appropriate Office of Record when final payment or submission of the final expenditures report occurs for every extramural award, the retention period for extramural award records is measured from expiration/termination of the extramural award (a much easier point in time to assess) forward six years. It is presumed that six years from expiration/termination will more than accommodate the three or four years from final payment or submission of the final expenditures report retention period imposed by extramural sponsors.

For those rare awards where the retention period set forth in the award document exceeds that shown in the University Records Disposition Schedules Manual, award documents must be retained in accordance with the requirement specified in the award document. Additionally, when litigation, claims, or audits are initiated prior to the end of the records retention period, records must be retained until final resolution.

b. Proposals.

For proposals to extramural sponsors, the retention period varies in accordance with the disposition of the proposal. A pending proposal must be retained until a decision is made to fund, reject, or withdraw the proposal. When a proposal is rejected or withdrawn, the records may be discarded immediately or may be retained up to two years after rejection or withdrawal. When a proposal is funded, the proposal records become part of the award records and are governed by the award's disposition schedule.

c. CGX Advice Forms.

Forms used to input proposal or award information into the Corporate Contracts and Grants System (CGX) may be disposed of once the information has been entered into the CGX system. They should not be retained beyond three years.

d. CGX Report Records.

A series of quarterly, annual, and "upon request" reports are produced based on data compiled from the campus CGX Advice Forms. The retention periods for the record copy of most of the quarterly reports is "until superseded by next quarterly report," with the exception of "Contract & Grant Proposals (sorted by campus-sponsor-department)" which is 5 years for the record copy, and "Summary Report of Contract and Grant Awards" which is 10 years for the record copy.

The retention period for the record copy of all annual reports is 10 years, except for the "Annual Comparison of Award Amounts" which is 2 years. The office of record for all these reports is OP RPAC.

The retention period for all "upon request" CGX reports is 0-2 years and the office of record is the requesting office. For further information, see the "Contract and Grant Reports--Computer Generated" section of the University Records Disposition Schedules Manual.

17-320 Records Related to Human and Animal Research Subjects

Policy coverage and general guidance concerning retention of records related to human research subjects and related Institutional Review Board (IRB) records are presented in Chapter 18, Section 18-272, of this Manual.

Policy coverage and general guidance concerning retention of records related to animal research subjects and related Animal Research Committee (ARC) records are presented in Chapter 18, Section 18-465, of this Manual. Retention and disposition requirements of records relating to animal and human subject research is published on the OP RPAC UC Research Policies and Guidance website under “Guidance on Retention and Disposition Requirements for Administrative Records Relating to Research.”

17-330 Vital Records

17-331 Definition

Business and Finance Bulletin RMP-4, Vital Records Protection, Section II, defines a vital record as:

A record is vital when the re-establishment of an authentic replacement of a lost or unavailable record would be impossible or prohibitively difficult and, thus, abridge, jeopardize, or otherwise affect a significant right of an individual, a significant right or asset of the University, or the performance of an essential function of the University so adversely that extraordinary precautions are required to preserve and protect effectively that record from both normal and unusual hazards, present and potential.

17-332 Vital Contract and Grant Records

No contract and grant records have been pre-identified as vital records in the University Records Disposition Schedules Manual. However, it is the responsibility of an individual department to review its inventory of records in relation to the "Criteria for Identification of Vital Records" set forth inRMP-4, Vital Records Protection, to identify records that are vital and to advise the Records Management Coordinator at that location of the identity of the vital record and the type of protection given to it (seeRMP-4, Section VI, Selection of Methods of Protection).

17-340 Microfilm

Pursuant to Business and Finance Bulletin RMP-6, Microfilm Guidelines, it may be appropriate to produce and/or maintain University records on microfilm. It should be noted that microfilmed records are subject to all legal and policy restrictions concerning access to and privacy of records and to the University Records Disposition Schedules Manual. Before any contract or grant records are produced or converted to microfilm, the University's Microfilm Guidelines in RMP-6 should be considered.