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Record Retention

Project files, including all pertinent programmatic and financial documents relating to the project, shall be retained by each agency for at least three (3) years after the date of submission of the final fiscal and program reports. Some documents should be kept permanently. An agency/program should seek the guidance of an independent auditor to determine this.

The following are exceptions to the standard record retention period: 

  • If any litigation, claim, audit, or other action involving the records has started before the expiration of the 3-year period, the records must be retained until all issues involving the records have been resolved and final action taken. 
  • When notified by the CVAD, the Federal awarding agency, cognizant agency for audit, oversight agency for audit, cognizant agency for indirect costs, or pass-through entity to extend the retention period. 
  • Records for real property and equipment acquired with Federal funds must be retained for 3 years after the final disposition. 
  • When records are transferred to or maintained by the Federal awarding agency or pass-through entity, the 3-year retention period requirement is not applicable to the non-Federal entity. 
  • When required for program income earned after the period of performance, the retention period starts from the end of the non-Federal entity’s fiscal year in which the program income is earned. 
  • Indirect cost proposals submitted for negotiation must be retained for 3 years from the date of submission. 
  • Indirect cost proposals not required to be submitted for negotiation must be maintained for 3 years from the end of the fiscal year covered by the proposal.
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