My grants are with the NIH, what are their digital signature requirements?

Beginning January 25, 2022 NIH will require Senior/Key Personnel digital signatures on Other Support documentation.  Other Support is a component of the proposal that is submitted at the “Just in Time” stage.  Other Support is also required as part of the Research Performance Progress Report (RPPR), whenever updates are needed.

My grant sponsor is a federal agency. What are the federal guidelines on ink versus digital signatures?

Electronic signatures and digital records are considered acceptable document formats for federal agencies. 

Federal agencies are in the process of converting to a paperless environment as a response to the Government Paperwork Elimination Act (GPEA) passed in 2003.  In support of GPEA the Office of Management and Budget (OMB) provided additional procedures and guidance to implement the Act.  In both GPEA and the OMB guidance, electronic signatures and records are valid and enforceable and encouraged.

If a research study is being transferred to the ownership of another university, is it all right to transfer the research data to the other university?

Yes it is. However, please review Grants Information Memorandum 37 to ensure the principal investigator is aware of the compliance issues regarding the transfer of research data.

The retention for research records starts with “Close of Study”. How do I apply retention when our grant is renewed so many times?

Each time your grant is renewed, update your records to reflect the currently projected date it will end. Simply update these reference dates each time until the study is closed. The retention clock should not start until the award is no longer renewed.

How does “Close of Study” or “Final Termination of Grant/Contract” apply to renewals?

Since a renewal is an authorization for followup support to a project, for administrative records and research records and data, the retention period is triggered after the final renewal ends, the grant is closed and there is no further research supporting that project.

I have a grant that started in 1962. Don't I have to keep the financial reports from the beginning of the grant?

The University retention requirements are established to ensure the availability of financial records that may be required for audit purposes. These retention periods either meet or exceed federal and state requirements.

I have a SNAP grant. How does the retention for financial records apply to my award?

Financial records for SNAP grants follow the same retention requirements as any other awards. The retention period, as it is for all other grant financial records is 6 years after submission of the FSR.  And like all other grant financial records, use the trigger of submission of a Financial Status Report (FSR) to begin the retention count-down.