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It is the policy of New York University (NYU, “the University”) that all financial records and supporting documentation for Federal awards are retained in accordance with the Federal Office of Budget and Management (OMB) Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and other Non-profit Organizations (http://www.whitehouse.gov/omb/circulars_a110/), unless a longer duration is required by the sponsor. For all other awards, records should be retained in accordance with sponsor requirements.
The purpose of this policy is to set forth the requirements for record retention and destruction of sponsored award financial records in accordance with NYU, Federal and sponsor terms and conditions.
This policy is applicable to all schools, departments, units and personnel of the University involved in managing and administering sponsored awards.
Departments are responsible to ensure that personnel who handle records are aware of the record retention policy and that supervisors are overseeing compliance with the policy requirements. Copies of original records, either in paper or in computer or electronic format, may be substituted for the original records.
For Federal awards, financial records, supporting documents, statistical records and all other records pertinent to an award shall be retained for three years from the date of submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, as prescribed by the sponsor. The only exceptions are the following:
Sponsor Rights to Access Documentation and/or Interview Personnel
The Sponsor and other government entities have the right of timely and unrestricted access to any records of NYU that are pertinent to the awards, for the purpose of audits and examinations. This right also includes timely and reasonable access to NYU personnel for the purpose of interview and discussion related to such documents. In order to avoid disallowance of expenses against grants and contracts, proper financial records must be maintained for compliance and audit purposes. The financial records of each department must be maintained in accordance with OMB Circular A-110 requirements, unless a longer duration is required by the Sponsor. If no retention period is indicated in the award document, documentation should be retained for three years after the final financial report is submitted to the sponsor.
Departments must maintain any documentation, including emails, to support charges to a sponsored project that were not previously submitted through University administrative systems such as:
All P-Card holders must retain documentation for such purchases irrespective of the procedures outlined for all other sources. Documentation must be maintained for the retention period prescribed by OMB Circular A-110, unless a longer duration is required by the Sponsor. Documents may be imaged provided information is legible and not missing any pages.
Destruction of Records
This should be in compliance with NYU’s policy on destruction.
Type of Records for Federally-sponsored awards:
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|Effective Date:||September 01, 2013|
|Issuing Authority:||Sponsored Programs Administration|
|Responsible Officer:||Assistant Vice President for Post-Award Administration|