Financial Records Retention for Sponsored Programs

Background

It is the policy of New York University that all financial records and supporting documentation for Federal awards are retained in accordance with the OMB Uniform Guidance unless a longer duration is required by the sponsor. For all other awards, records should be retained in accordance with sponsor requirements.

NYU Approach

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:

  • If any litigation, claim, or audit is started before the expiration of the three-year period, the records shall be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken.
  • Records for real property and equipment acquired with Federal funds shall be retained for three years after final disposition.
  • When records are transferred to or maintained by a Federal sponsor, the three-year retention requirement is not applicable for NYU.
  • Indirect cost rate proposals:
    • If submitted for negotiation, the three-year retention period for its supporting records starts on the date of such submission.
    • If not submitted for negotiation, the three-year retention period starts at the end of the fiscal year (or other accounting period) covered by the proposal.

For non-Federal sponsors, retention requirements will vary with the sponsor. New York State, for example, has a six-year retention period. The grant award should specify the specific timeframe.

Departmental Responsibilities

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:

  • PeopleSync
  • Maximus Effort Reporting System (ERS)
  • Journal Entry Management System (JEMS)
  • AP Workflow
  • Accounts Payable
  • iBuy NYU

All P-Card holders must retain documentation for such purchases irrespective of the procedures outlined for all other sources. Documents may be imaged provided information is legible and not missing any pages.

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