Grants Record Management Policy

Background

The Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Final Rule, 2 CFR 200, Dec. 26, 2014, ("Uniform Guidance") sets forth requirements for retaining records associated with grant management. Davidson College has responsibility for proper retention and disposition of grant and research related records.

Purpose

This policy provides for the systematic review, retention and disposition of records received, created or maintained by the college in connection with grants, contracts proposals and awards.

Policy

The policy includes a schedule of how long various records should be retained and how they should be disposed of. The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate inadvertent destruction of records, and to reduce costs by promoting efficiency in the college's operations and freeing up storage space.

This policy applies equally to records that exist in electronic or paper form. Each record should be stored in a manner that is accessible by more than one authorized user of the record, so that the record remains accessible in the absence of one of those users. Generally, records should not be kept in email. If an email or attachment to an email contains a document that must be retained under this policy, the user must assure that the record is kept in the file or database in which records of the same type generally are kept. Any email whose function or content does not require retention for any period under this policy and that is not important to ongoing college business should be routinely disposed of as soon as possible after it is read. Such email includes transitory communications to set up meetings, notices or correspondence concerning a subject not identified on the Record Retention Schedule and email of a personal nature.

Procedure

Record Retention Schedule
The purpose of this schedule is to provide guidance in the proper retention and disposition of grant records. It is organized by record type including a description of the documents for each category.

1. Non-funded grant records. These official records may include applications, grant proposal narratives, budget, letters of support, and notifications or rejection.

  • Official office of record: Office of Sponsored Programs.
  • Retention: One year from the notification date.
  • Disposition: Records returned to the PI.

2. Funded grant records. These official records may include final reports, attachments, proposals, budget, contract and agreements, compliance certification and other correspondence.

  • Official office of record: Office of Sponsored Programs.
  • Retention: Seven years from the end of funding period, or from the final no-cost extension end date. 
  • Disposition: Shred - delete records.

3. Grant accounting records. These official records document the financial administration for funded grants and may include financial reports, budget, sub award documentation, grant affiliated P-Card transactions and effort reports.

  • Official office of record: Office of Sponsored Programs.
  • Retention: Seven years from the end of funding period, or from the final no-cost extension end date.
  • Disposition: Shred - delete records.

4. Research records. These official records include data or results from scientific inquiry, including, but not limited to, research proposals, laboratory records/notebooks, study results, progress reports, abstracts, theses, oral presentations, internal reports, journal articles, etc. 

  • Official record of responsibility: Principal Investigator (PI).
  • Retention: Seven years from the end of funding period, or from the final no-cost extension end date.
  • Disposition: Shred - delete records.

Responsibilities

It is the responsibility of the Office of Sponsored Programs to maintain retention and disposition of grant records.

It is the responsibility of the Principal Investigator (PI) to maintain retention and disposition of research records. 

Definitions

Grant Record: Documentation pertaining to the programmatic and financial management of an award. These documents can be maintained in electronic or paper form. Examples include, but are not limited to: award notices, support documents, financial statements and invoices, backup documentation and technical reports and deliverables. 

Research Record: The record of data or results that embody the facts resulting from scientific inquiry, including but not limited to, research proposals, laboratory records, both physical and electronic, progress reports, abstracts, theses, oral presentations, internal reports, journal articles, and any documents and materials.

Record Retention Schedule: A document that identifies and describes an organization's records, provides instructions for the disposition of records throughout their life cycle.

Official Record: A complete, final, and authorized copy of a record, especially the copy bearing an original signature or seal. Records include evidence of college organization, functions, policies, decisions, procedures, operations, and internal or external transactions. Records can be recorded in any physical form or medium, including hardcopy and electronic.

Office of Record: The organization or administrative unit that is officially designated for the maintenance, preservation, and disposition of record copies.

Retention Period: The length of time records should be kept in a certain location or form for administrative, legal, fiscal, historical, or other purposes. Official records should be retained as long as required to meet legal, administrative, financial and operational requirements of the college.

Preservation and Transfer: Material selected for preservation shall be sent to Archives and Records Management in accordance with a records retention schedule developed by the Records Manager in consultation with the Office of Sponsored Programs. All official records that are permanently preserved must remain accessible to relevant employees. Electronic records of permanent or enduring value will be preserved in a way that appears best to allow future accessibility of their content.

Disposition: When records are no longer required to be retained under this policy and are no longer in active use, they should be destroyed or discarded as follows:

  1. Paper Records: Confidential records must be destroyed by shredding. All other records may simply be discarded, preferably in recycle bins. 
  2. Electronic Records: Confidential records must be securely disposed of. Contact Technology & Innovation for additional information on secure disposal methods for electronic data or for help in disposing of such data. All other electronic records may be deleted with simple file or email delete commands. If in doubt as to the proper method to destroy a document, dispose of it in the same manner as a confidential record.

Administration of Policy

The Assistant Dean for Research Development / Director of Sponsored Programs shall oversee this policy and review it at least once every three years. Changes to this policy shall be made in accordance with the college's Policy on Policies.

Adopted: May 24, 2017
Last Updated: December 21, 2022
Last Reviewed: June 27, 2024