Section 11 – Records Management

Grantees are required to keep intact and accessible all financial and programmatic records, supporting documents, statistical records and other records pertinent to an award. The records retention and custodial requirements extend not only to the records of the grantee, but to those of its subgrantees, contractors and subcontractors.

Records must be retained for a period of three years or longer as specified in each agreement. On a multi-year award, records are usually required to be kept only three years from the date of submittal of the first fiscal report for each budget period. Records under audit, involving unresolved audit findings, appeals or litigation must be held until the action is completed or the dispute resolved. (Note: Under no circumstances can a federal agency require retention of records relating to a program for more than six years. The statute of limitations, Title 28 U.S.C. 2415(b), provides that an action to recover for diversion of money paid under a grant program or an action for conversion of property of the U.S. must bebrought within six years after the right of action accrues).