Records Retention

What is records retention?

Records retention is the term applied to the safeguarding of important records that document decisions, policies, financial activities and internal controls.  They also document and maintain the University’s history and activities.  Emory’s Records Retention Policy ensures that the University maintains the integrity of the records for an appropriate and/or required period of time for administrative, legal, financial, and historical purposes. 

Historically records were paper but today also include text, video and audio files. A record is any recorded information regardless of media, characteristics, physical form, or means of transmission made or received and maintained by Emory pursuant to its legal obligations or in the transaction of its business.  In most cases only the original record needs to be kept; however, in some instances copies can substitute for the original record.    For the purposes of this handbook, we are primarily talking about original financial records of sponsored programs.  However, it also includes technical, patent and trademark records or any other record that an auditor might request.

For more information regarding records management go to: http://records.emory.edu.

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Why is records retention important?

Good records prevent audit findings and possibly prevent damages in a lawsuit; therefore, important records should be available and easily accessible when needed.  This is particularly true in light of the Federal agencies beginning to use statistical audits of groups of records rather than specific audits of single awards.  Statistical audits are more cost effective than single program audits.  A single missing document in a statistical audit could result in the auditors extrapolating a finding of a few dollars to thousands or hundreds of thousands of dollars, depending on the sample size.

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What are the general rules for sponsored programs records retention?

For original sponsored program financial records the general rule is that, Emory must keep the records for three years from the LAST activity on the award.  For example,  a five-year award where the last activity was the final financial status report that was submitted 90 days after the end of the award, the minimum retention period would be eight (8) years and three (3) months from the START of the award.  The last activity could be the date of the final payment receipt or the date the final technical or financial report was sent.  If an audit is underway for an award or groups of awards or records, Emory must keep all the records until the audit is completed; then the financial records can be disposed of if the audit end date is greater than the required retention period.

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What are the challenges of sponsored programs record retention?

At Emory the various schools, departments, institutes, centers and bureaus share responsibilities for record retention amongst their constituents.  The Office of Grants and Contracts Accounting (OGCA) has very few original grant and contract financial records.  Other custodians of record throughout the University control the bulk of original sponsored program financial records and may apply different rules or procedures for a number of valid reasons.  For example, the departments/schools maintain control over the original records for travel and purchase (T and P) cards.  Logically, the units would keep those records by individual or by date of transaction rather than by sponsored program.  Similarly, Procurement and Payment Services keeps check and invoice support for all University purchases including grants, by check number and purchase order number or vendor name.   In addition to the requirements for the particular sponsored project, University record retention guidelines must be adhered to.  For more information, see http://records.emory.edu or contact the University Archivist.

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