Record Retention
The University is required to retain all contract-related records (federal and non-federal) in accordance with the Commonwealth of Virginia, The Library of Virginia Record Retention and Disposition Schedule for College and University Records. Although, federal grantee records are required for three years, Virginia Commonwealth University must retain accounting and administration records for five years or in accordance with contract or grant stipulations, whichever is greater, then destroyed once an approved "Records Retention and Disposition Schedule" has been obtained.
See: Records Management
This means the university retains grant-related financial records for the current fiscal year, plus five more years or until audited, whichever is longer, except for the following items:
- Grants involved with litigations or claims
- Grants under audit
- Records for nonexpendable property acquired with federal funds
- Records transferred to or maintained by the federal sponsoring agency
Only the Office of Sponsored Programs (OSP) and Office of Grants and Contracts Accounting (OGCA) know when particular grants or contracts were audited. Departments must verify a grant's or contract's audit status with OGCA before destroying any related documents.
For the items in the OGCA list immediately preceding, the retention period is dated from submission of the final expenditure report; for grants renewed annually, the retention period dates from submission of the annual financial status report. For records under audit, such records should be retained not only until audits of such records are completed, but until all audit findings are fully resolved or negotiated.