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Guidelines for Participant Support Costs 


Purpose

To provide guidance to Principal Investigators (PIs), department/research administrators, Grants and Contracts Accounting Analysts and anyone else who manages sponsored projects about retaining and disposing records in accordance with sponsor requirements.

Background

The federal government expects universities to comply with Uniform Guidance Retention requirements for records as set forth 200.334.

The majority of sponsored projects have legal requirements as to how long project records, particularly financial records, must be retained. These guidelines recognize legal requirements as well as the substantial physical and fiscal resources required to retain (e.g. technical/programmatic notes, GRAMS records and other tools). If original records are electronic and cannot be altered, there is no need to create and retain paper copies.

    1. If original records are paper, electronic versions may be substituted provided that they are subject to periodic quality control reviews, cannot be altered, and remain readable.
    2. University central offices maintain official records (including proposals, awards, financial transactions, invention disclosures, and others). However, program records are maintained by PIs, and departments hold some source records and details related to the official records.
    3. Be aware of confidentiality and inclusion of personal or proprietary information in the records. Use limited-access storage for documents containing personal, proprietary or confidential information.
  2. Access to records
    1. The Texas Public Information Act (TPIA) requests are handled through the University of North Texas System's General Counsel's office. Never respond directly to a request or provide any documentation.
    2. If an auditor calls, please contact DeeAnna Oliveira in Grants and Contracts Administration (GCA).
  3. Technical (program) records are retained by the PI.
    1. Retain progress reports and final technical reports for at least 3 years after submission to the sponsor.
    2. Retain the original data and all project records for at least 3 years after submission of the final financial report or progress report whichever is later. After the required retention period, the principal investigator/project director may make the decision to retain the records or to discard them when the records are determined to be no longer useful for research or educational purposes.
    3. Retain clinical data in accordance with the clinical agreement.
      1. Review the clinical agreement or sponsor agency policy for a provision specifying the required period of retention for source documents. The requirement may differ based on the type of clinical study and other factors.
      2. Refer to University of North Texas retention policies.
    4. When an invention has resulted from the project, contact Research Commercial Agreements (RCA) for advice on retention of relevant records.
  4. Fiscal records are retained by university central offices but departments may have source records that support the transaction records.
    1. Federal awards: The Uniform Guidance, specifically 2 CFR 200.334 governs record retention under federal grants. The Federal Acquisition Regulation, specifically FAR 52.215-2, Audit and Records Negotiation governs record retention under federal contracts. To summarize, retain records for 3 years after submission of the final fiscal status report or after final payment under a federal contract. If any litigation, claim, or audit is started before the expiration of the 3-year period, the records must be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken.
    2. Local and State government awards: Review award terms and conditions. It is recommended that all records for projects funded under State and City awards (MOU's, grants, agreements) be retained for 3 years after submission of the final fiscal status report or after final payment when no final financial report is required under a local or state contract.
    3. Other awards: Review award terms and conditions and sponsor policies. If the sponsor or award document does not specify a specific time period to retain project records, follow the Federal requirement and retain records for 3 years after final financial report or final payment when no final financial report is required under the award.
  5. Guidelines for discarding and destroying records
    1. Shred paper documents containing personal, proprietary or confidential information, using a cross-cut shredding device.

Electronic data must be securely removed from any disk, tape, USB drive, hard drive, photocopier, facsimile machine, or other device with electronic storage before the device is transferred or discarded. Deletion of an electronic record may not eliminate all remnants of the record. Contact your IT expert for advice.

Policy Guideline Created: August 8, 2024
Questions? Contact Grants and Contracts Administration or 940.565.3940
Read the full policy: UNT Policy Guidelines for Record Retention