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Grant and Contract Records

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.

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.

For most grant-related financial records, the FSR submission is the trigger date used to signify the start of the record retention period. The trigger represents an event, in order of precedence:

  1. FSR Submission: The date the Financial Status Report (FSR) was submitted to the sponsor. FSR Submission types are Final FSR or Quarterly or Annual FSRs for awards renewed quarterly or annually.
  2. Final Invoice Date: The date the Final Invoice was submitted to the sponsor, where no FSR is required.
  3. Budget Closeout: The date the final budget reconciliation was completed, where the sponsor does not require an FSR or Final Invoice. Includes invoicable budgets.

Locate the FSR date for a given budget using GrantTracker. If the “Trigger” field is not populated, the date should be available in the notes section of Grant Tracker. Click here to view the step by step guide on locating the trigger date in GrantTracker.

Please note that for sub-budgets, departments should look to the parent budget for the trigger date which is used to signify the start of the retention period. For both competitive and non-competitive grant renewals, the trigger date is based on the annual or quarterly FSR submission, not the final termination date of the grant.

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.

However, SNAP grants are unusual in that only one FSR is submitted. This submission takes place at the end of the final renewal period. This means that for SNAP grants only, all financial records are retained for the full term of the award.

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. State and federal auditors have a 6-year window of opportunity to audit financial records that begins either when the FSR is submitted, the date the Final Invoice was submitted to the sponsor where no additional FSR is required, or the date the final budget reconciliation was completed where the sponsor does not require an FSR or Final Invoice. Unless you have a SNAP grant, these submissions take place annually or sometimes quarterly for your grant. Only departments with SNAP grants or those grants where no FSR or Final Invoice is required must retain their financial records for the full term of the award.

Original receipts should be forwarded to the UW except in the following circumstances:

  • Locally based staff who are reimbursed from an established UW office in-country (e.g. UW Kenya, I-TECH local offices), with the agreement of UW Banking Operations.
  • Local laws require original receipts to be retained in-country

In the above cases, scanned copies of receipts can be forwarded to the UW. Paper receipts can be scanned and forwarded as PDFs. Electronic receipts should be forwarded in their original format.

Departments who have a scanning policy on file with Records Management Services can destroy their paper receipts once they have been scanned. To begin scanning documents, first visit our Scanning Policy Builder. Departments without a scanning policy must retain their scanned paper receipts for the full retention period. See UW General Schedule Research and Grant/Contract Records.

For studies that are considered clinical trials and focus on drug testing or development use Research Data—Drug Development. For all other clinical trials use Research Records and Data. Choose the series description that best fits your study.

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.

Renewals have no impact on the retention of financial records. See series for the retention of financial records related to grants/contracts.

You can send boxes for storage at any time. On receipt of the boxes we would use the current anticipated study end date as the first trigger. This is the date the current renewal is projected to end. As your stored boxes near the end of their retention period, you will receive an automatic notification email from our database asking for the most current award renewal date. Each time we receive a new projected end date we will revise the study end trigger date in our database.

Please note that we will not start the count-down of the actual retention until there are no more changes to the trigger date. The retention clock will not start until the award is no longer renewed.

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.