Circulars
For more information, visit White House website
As of 08.13.2020, final updates and addition on Grants and Agreements Guidance
2 CFR PART 25 Universal Identifier and Systems for Award Management
UEI replaces DUNS
What is the Unique Entity Identifier (UEI)? The Unique Entity Identifier, or the UEI, is the official name of the “new,
non-proprietary identifier” that will replace the D-U-N-S® number. The UEI will be requested, and assigned by, the System for Award
Management (SAM.gov).
2 CFR Part 170 Reporting Subaward and Executive Compensation Information - Required reporting of first-tier subawards, including each action
that equals or exceeds $30,000. Such reporting will continue to be conducted through
www.fsrs.gov.
2 CFR Part 183 Never Contract with the Enemy NEW - 2 CFR Part 183 Never Contract with the Enemy applies ONLY to awards exceeding $50,000.00
and performed outside the U.S., including U.S. territories. It also applies to a
person or entity actively opposing U.S. or coalition forces involved in a contingency
operation (where members of the Armed Forces are actively engaged in hostilities).
2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements
for Federal Awards
2 CFR 200.216 STRICT Prohibition on certain telecommunication and video surveillance
services or equipment - prohibits federal award recipients from using government funds to enter into contracts (or extend or renew contracts)
with entities that use “covered telecommunications equipment or services,” even if
the contract is not for the purchase of such equipment or services. Covered telecommunications
equipment or services is defined as telecommunications equipment produced by:
- Huawei Technologies Company
- ZTE Corporation
- Hytera Communications Corporation
- Hangzhou Hikvision Digital Technology Company
- Dahua Technology Company
- any subsidiary or affiliate of such entities
Federal awarding agencies must work with OMB to assist entities affected by this provision.
If you are concerned that your organization may have entered into contracts that this
provision would prohibit, reach out to your contacts at the federal awarding agency
or pass-through entity for further information. Contracts need to include language
addressing this prohibition as well, even if the contract is not intended for this
purpose. This also applies to the allowability criteria on procurements made in indirect
cost.
2 CFR 200.344 Close-out timeframe to submit reports and liquidate obligations
- From 90 days to 120 days
- Deadline extensions are ONLY for the PRIME recipient, NOT the subrecipient
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards.
On December 2014, the Office of Management and Budget (OMB) officially implemented
the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards. There were eight circulars combined into the Uniform Guidance (UG)
and also referred to as A-81 (due to eight circulars combined into one). The consolidation
was made to streamline the federal grant-making and monitoring process, ease the administrative
burden for grant applicants and recipients, and reduce the risk of waste, fraud, and
abuse.
These Office of Management and Budget (OMB) circulars fall into three main categories:
Administrative requirements to Sub Part A through D (A-102, A-89 & A-110), Cost Principles
to Sub Part E (A-122, A-87, & A-21), and Audit Requirements to Sub Part F. Below is
a summary chart for easy reference.
| OMB CIRCULAR |
PARTICULARS Administrative requirements to Sub Part A through D |
| A-102 |
Grants and Cooperative agreements with state and local governments |
| A-89 |
Catalog of Federal Domestic Assistance |
| A-110 |
Uniform Administrative Requirements for Grants and other agreements with institutions
of Higher Education, hospitals and other Non-Profit Organizations |
| Cost Principles to Sub Part E |
| A-122 |
Cost Principles for Non-Profit Organizations |
| A-87 |
Cost Principles for State, Local, and Indian Tribal Government |
| A-21 |
Cost Principles Applicable to Grants and Contracts at Educational Institutions |
| Audit Requirements to Sub Part F |
| A-133 |
Requirements of an audit and explains the responsibilities of the institutions, the
agency, and the auditor. |
| A-50 |
Audit Follow-up |
OMB Circular A-21 - Cost Principles for Educational Institutions (05/10/2004) PDF (109 pages,b263kb)
- A-21: This Circular establishes principles for determining costs applicable to grants,
contracts, and other agreements with educational institutions. The principles deal
with the subject of cost determination and do not attempt to identify the circumstances
or dictate the extent of agency and institutional participation in financing a particular
project. The principles are designed to provide that the Federal Government bears
its fair share of total costs, determined in accordance with generally accepted accounting
principles, except where restricted or prohibited by law. Agencies are not expected
to place additional restrictions on individual items of cost. Provision for profit
or other increment above cost is outside the scope of this Circular.
OMB Circular A-110 - Uniform Administrative Requirements for Grants and Other Agreements with Institutions
of Higher Education, Hospitals and Other Non-Profit Organizations PDF (33 pages, 243kb)
- A-110: This Circular sets forth standards for obtaining consistency and uniformity among
Federal agencies in administering grants to and agreements with institutions of higher
education, hospitals, and other non-profit organizations.
OMB Circular A-122 - Cost Principles for Non-Profit Organizations (05http://gk7d.daikuan918.com/grantsresearch/documents/COI_Policy.pdf/10/2004) PDF (55 pages, 220kb)
- A-122: This Circular establishes principles for determining the costs of grants, contracts,
and other agreements with non-profit organizations. It does not apply to colleges
and universities which are covered by Office of Management and Budget (OMB) Circular A-21, "Cost Principles for Educational Institutions"; State, local, and federally recognized
Indian tribal governments which OMB Circular A-87 covers, "Cost Principles for State,
Local, and Indian Tribal Governments"; or hospitals. The principles are designed to
provide that the Federal Government bears its fair share of costs except where restricted
or prohibited by law. The principles do not attempt to prescribe the extent of cost
sharing or matching on grants, contracts, or other agreements. However, such cost
sharing or matching shall not be accomplished through arbitrary limitations on individual
cost elements by Federal agencies. Provision for profit or other increment above cost
is outside the scope of this Circular.
OMB Circular A-133 - Audits of States, Local Governments, and Non-Profit Organizations (06/24/1997,
includes revisions published in Federal Register 06/27/03) PDF (33 pages,127kb)
- A-133: This Circular is issued pursuant to the Single Audit Act of 1984, P.L. 98-502, and
the Single Audit Act Amendments of 1996, P.L. 104-156. It sets forth standards for
obtaining consistency and uniformity among Federal agencies for the audit of States,
local governments, and non-profit organizations expending Federal awards.
As an integral part of its institutional mission, Chicago State University (the "University")
upholds the principles of free and unbiased inquiry, transfer of ideas and technologies
for public benefit, and stewardship of the resources entrusted to it. As Faculty and
Staff increasingly build complex relationships with private companies, financial and
other internal and external relationships must not conflict nor appear to conflict
with these principles.
Faculty and Staff of the University have a professional obligation to act in the best
interests of the University. The Financial Conflicts of Interest Policy ("Policy")
for Research delineates the requirements for disclosing significant financial interests
that may constitute financial conflicts of interest, regardless of whether the Faculty
or Staff is performing research under U.S. Public Health Service ("P.H.S.") grants
and cooperative agreements.
Faculty and Staff must report to the Research Integrity Officer if they are aware
of any not-disclosed Financial Conflicts of Interest of other personnel of the University.
Policy
Training
Disclosure Form
Allowable, Allocable, and Reasonable Costs
The legitimacy of a cost charged to a specific sponsored research award will depend
on the cost concept on allowability, allocability, and reasonableness of a given cost.
The Office of Management and Budget (OMB), the sponsor's specific requirements, the
University policy, and federal cost principles defined and determined an expense's
allowability, allocability, and reasonableness. Payment Requests must be supported
by appropriate documentation for the cost incurred and paid on a grant to be considered
allowable, allocable, and reasonable otherwise. It will be treated as unallowable.
If you are unsure whether a particular expenditure is allowable, consult your approved
project budget and/or contact the Office of Grants & Research Administration if additional
assistance is needed. PART 200 of the Uniform Administrative Requirements, Cost Principles,
and Audit Requirements for Federal Awards - Subpart E - Cost Principles provided the
following:
Allowability
§200.403 Factors affecting allowability of costs.
Except where otherwise authorized by statute, costs must meet the following general
criteria to be allowable under Federal awards:
- Be necessary and reasonable for the Federal award's performance and be allocable under
these principles.
- Conform to any limitations or exclusions set forth in these principles or the Federal
award regarding types or amount of cost items.
- Be consistent with policies and procedures that apply uniformly to the non-Federal
entity's federally financed and other activities.
- Be accorded consistent treatment. A cost may not be assigned to a Federal award as
a direct cost if any other cost incurred for the same purpose in like circumstances
has been allocated to the Federal award as an indirect cost.
- Be determined in accordance with generally accepted accounting principles (GAAP),
except for state and local governments and Indian tribes only, as otherwise provided
for in this part.
- Not be included as a cost or used to meet cost sharing or matching requirements of
any other federally-financed program in the current or a prior period. See also §200.306
Cost sharing or matching paragraph (2).
- Be adequately documented. See also §§200.300 Statutory and national policy requirements
through 200.309 Period of performance of this part.
§200.404 Reasonable costs.
A cost is reasonable if, in its nature and amount, it does not exceed that which would
be incurred by a prudent person under the circumstances prevailing at the time the
decision was made to incur the cost. Reasonableness is particularly important when
the non-Federal entity is predominantly federally funded. In determining the reasonableness
of a given cost, consideration must be given to the following:
- Whether the cost is of a type generally recognized as ordinary and necessary for the
operation of the non-Federal entity or the proper and efficient performance of the
Federal award.
- The restraints or requirements imposed by such factors as sound business practices;
arm's-length bargaining; Federal, state, local, tribal, and other laws and regulations;
and terms and conditions of the Federal award.
- Market prices for comparable goods or services for the geographic area.
- Whether the individuals concerned acted with prudence in the circumstances considering
their responsibilities to the non-Federal entity, its employees, where applicable,
its students or membership, the public at large, and the Federal Government.
- Whether the non-Federal entity significantly deviates from its established practices
and policies regarding the incurrence of costs, which may unjustifiably increase the
Federal award's cost. [78 FR 78608, Dec. 26, 2013, as amended at 79 FR 75885, Dec.
19, 2014]
§200.405 Allocable costs
- A cost is allocable to a particular Federal award or another cost objective if the
goods or services involved are chargeable or assignable to that Federal award or cost
objective in accordance with relative benefits received. This standard is met if the
cost:
- Is incurred specifically for the Federal award;
- Benefits both the Federal award and other work of the non-Federal entity and can be
distributed in proportions that may be approximated using reasonable methods; and
- It is necessary to the overall operation of the non-Federal entity and is assignable
in part to the Federal award in accordance with the principles in this subpart.
- All activities which benefit from the non-Federal entity's indirect (F&A) cost, including
unallowable activities and donated services by the non-Federal entity or third parties,
will receive an appropriate allocation of indirect costs.
- Any cost allocable to a particular Federal award under the principles provided for
in this part may not be charged to other Federal awards to overcome fund deficiencies,
avoid restrictions imposed by Federal statutes, regulations, or terms and conditions
of the Federal awards, or other reasons. However, this prohibition would not preclude
the non-Federal entity from shifting costs that are allowable under two or more Federal
awards in accordance with existing Federal statutes, regulations, or the terms and
conditions of the Federal awards.
- Direct cost allocation principles. If a cost benefits two or more projects or activities
in proportions that can be determined without undue effort or cost, the cost must
be allocated to the projects based on the proportional benefit. If a cost benefits
two or more projects or activities in proportions that cannot be determined because
of the interrelationship of the work involved, then, notwithstanding paragraph (c)
of this section, the costs may be allocated or transferred to benefitted projects
on any reasonable documented basis. Where the purchase of equipment or other capital
asset is specifically authorized under a Federal award, the costs are assignable to
the Federal award regardless of the use that may be made of the equipment or other
capital asset involved when no longer needed for the purpose for which it was originally
required. See also §§200.310 Insurance coverage through 200.316 Property trust relationship
and 200.439 Equipment and other capital expenditures.
- If the contract is subject to CAS, costs must be allocated to the contract pursuant
to the Cost Accounting Standards. To the extent that CAS is applicable, allocating
costs in accordance with CAS takes precedence over the allocation provisions in this
part.
Definition of Some Cost
Pre-award costs (§200.458) are those incurred before the effective date of the Federal award directly pursuant
to the negotiation and in anticipation of the Federal award where such costs are necessary
for efficient and timely performance of the scope of work. Such costs are allowable
only to the extent that they would have been allowable if incurred after the date
of the Federal award and only with the written approval of the Federal awarding agency.
Scholarships and student aid costs. §200.466 (a) Costs of scholarships, fellowships, and other student aid programs at IHEs are
allowable only when the Federal award is to provide training to selected participants
and the charge is approved by the Federal awarding agency. However, tuition remission
and other forms of compensation paid as, or in lieu of, wages to students performing
necessary work are allowable provided that:
- The individual is conducting activities necessary to the Federal award.
- Tuition remission and other support are provided per the established policy of the
IHE and consistently provided in a like manner to students in return for similar activities
conducted under Federal awards and other activities.
- During the academic period, the student is enrolled in an advanced degree program
at a non-Federal entity or affiliated institution, and the student's activities in
relation to the Federal award are related to the degree program.
- The tuition or other payments are reasonable compensation for the work performed and
are conditioned explicitly upon the performance of necessary work.
- The IHE's practice is to compensate students under Federal awards and other activities
similarly.
- Charges for tuition remission and other forms of compensation paid to students as,
or in lieu of, salaries and wages must be subject to the reporting requirements in
§200.430 compensation—personal services and must be treated as direct or indirect
cost in accordance with the actual work being performed. Tuition remission may be
charged on an average rate basis. See also §200.431 Compensation—fringe benefits.
Training and education costs. The cost of training and education (§200.472 ) for employee development is allowable.
Transportation costs. Costs incurred for freight, express, cartage, postage, and other transportation services
(§200.473) relating to goods purchased, processed, or delivered, are allowable. When such costs
can readily be identified with the items involved, they may be charged directly as
transportation costs or added to the cost of such items. Where identification with
the materials received cannot readily be made, inbound transportation costs may be
charged to the appropriate indirect (F&A) cost accounts if the non-Federal entity
follows a consistent, equitable procedure in this respect. If reimbursable under the
terms and conditions of the Federal award, outbound freight should be treated as a
direct cost.
Travel costs. §200.474
- General. Travel costs are transportation, lodging, subsistence, and related items incurred
by employees who are in travel status on official business of the non-Federal entity.
Such costs may be charged on an actual cost basis, on a per diem or mileage basis
in lieu of actual costs incurred, or on a combination of the two, provided the method
used is applied to an entire trip and not to selected days of the trip, and results
in charges consistent with those normally allowed in like circumstances in the non-Federal
entity's non-federally-funded activities and accordance with non-Federal entity's
written travel reimbursement policies. Notwithstanding the provisions of §200.444
General government costs, travel costs of officials covered by that section are allowable
with the prior written approval of the Federal awarding agency or pass-through entity
when they are specifically related to the Federal award.
- Lodging and subsistence. Costs incurred by employees and officers for travel, including costs of lodging, other
subsistence, and incidental expenses, must be considered reasonable and otherwise
allowable only to the extent such costs do not exceed charges normally allowed by
the non-Federal entity in its regular operations as the result of the non-Federal
entity's written travel policy.
Participant support costs (§200.75) are direct cost items such as stipends or subsistence allowances, travel allowances,
and registration fees paid to or on behalf of participants or trainees (but not employees)
concerning conferences or training projects.
- Per §§200.68, participant support costs (PSC) are excluded from the Modified Total Direct Cost (MTDC) base.
- Per §200.308 (b), transferring funds budgeted for participant support cost to other
categories of expense requires prior approvals from Federal awarding agencies for budget and program plan revisions.
The budget awarded for participant support cannot be transferred to other expense
categories unless approved in writing by the Program Officer.
- The budget can be moved into participant support costs.
- Re-budgeting between the defined participant support cost categories is permitted.
Participant support costs categories include:
Stipend - A set amount to be paid directly to the participant. Conditions for receiving a
stipend should be in writing and program completion attested to by the project PI.
Granting agencies may have specific guidelines for participant stipends.
Travel - Travel includes the costs of transportation and associated costs. It must follow
sponsor guidelines (e.g., U.S. flag carrier, coach class, most direct route) as well
as university policies and guidelines. The sole purpose of the trip must be to participate
in the project activity. If a training activity involves additional field trips,
the transportation costs of participants may be allowable.
NOTE: Field trips for recreational purposes are not permitted.
Subsistence -Housing and meal expenses necessary for the individual to participate in the project
are generally allowed, provided these costs are reasonable and limited to the days
of attendance. Although participants who live in the local area are not entitled to
subsistence payments or per diem, they may participate in meals and refreshments provided
at the meeting or conference.
NOTES: Do not duplicate support for individuals covered by other federal funding sources.
While employees are not normally considered participants may receive conference meals
under this provision.
Fees - Costs directly associated with attending conferences, symposia, or training projects.
Such costs include registration, conference, and similar fees.
Other Costs - Certain other costs may also be allowable if consistent with university
policy and practice and specified in the proposal approved by the sponsor upon review.
Example: training materials or laboratory supplies were approved by the sponsor.
Costs that do not fall under Participant Support Cost (PSC):
- Guest speaker or lecturer fees.
- Conference support costs such as facility and audio/visual equipment rental.
- Service or independent contractor agreements.
- Incentives (prizes), memorabilia, or gifts.
- Employee compensation and expenses
(Note: Exception for employee meals; they are allowable where provided to all attendees
of a sponsored conference.)
Important things to remember in managing Participant Support Cost (PSC):
- It is necessary that the Participant Support Cost is written as part of the funding
opportunity or agency rules and specifically included in the proposal.
- Depending on the awarding agency, the conditions or constraints vary for re-budgeting
awarded participant support funds.
- Re-budgeting will change the scope of the award and must have the agency's approval
- The addition of a participant program, where not previously awarded, is generally
considered a change in scope requiring an agency’s prior approval.
- A separate account or sub-account is required when PSCs have been explicitly awarded.
Expenses beyond the budget should be in the already established participant support
account/sub-account. A separate account/sub-account is not required where costs are
allowed by the agency but not explicitly awarded.
For samples of participant support acceptance letters click here
For frequently asked questions regarding participant support, click here.
[78 FR 78608, Dec. 26, 2013, as amended at 79 FR 75885, Dec. 19, 2014]
Unallowable Costs
This section is not exhaustive and is intended as a quick reference for common types
of costs.
The following are examples of generally unallowable expenditures and are not all-inclusive.
Entertainment Costs
Costs incurred for amusement, social activities, entertainment, and related items
include meals, lodging, rentals, alcoholic beverages, transportation, and gratuities.
Goods or Services for Personal Use
Costs of goods or services for the personal use of the institution’s employees, regardless
of whether the cost is reported as taxable income to the employees.
Pre-Agreement Costs
Costs incurred before the effective date of the sponsored project, whether or not
they would have been allowable if incurred after such date, are unallowable unless
specifically set forth and identified in the sponsored agreement or approved through
prior approval procedures.
Memberships In Civic or Community Organizations
The costs of an individual’s membership in civic or community organizations are not
allowable—likewise, any social, dining, country club, or organization memberships.
Items Not Normally Treated As Direct Costs
The following items are normally included in facilities and administrative (F&A) costs.
Direct charging of these costs may be appropriate where a major project or activity
explicitly budgets for them and can be specifically identified with the project or
activity. “Major project” is defined as a project that requires support that is significantly
greater than the routine level of such services and or supplies provided by academic
departments. Examples of items include:
- Administrative and clerical staff salaries.
- Office supplies, postage, local telephone costs, and memberships.
Please see the following links.
CSU ensures that all cost is charged to the appropriate Federal grant, contract, cooperative
agreement, or subaward when first incurred. However, there are circumstances where
it may be necessary to transfer expenditures to a Federal award following the initial
recording of the charge. A reallocation of cost from one fund to another is called
cost transfer. When this happens, CSU maintains to follow all provisions stated in
the notice of Grant awards and 2 CFR Chapter I, Chapter II, Part 200, et al., Uniform
Administrative Requirements (Uniform Guidance - UG), Cost Principles, and Audit Requirements
for Federal Awards is followed at CSU. The UG provisions include a requirement for
CSU to relate financial data to performance data and to ensure such data is current,
accurate, documented, and complete. These standards also require that accounting records
which are supported by source documentation. This supporting documentation will assist
in determining the reasonableness, allocability, and allowability of the cost in accordance
with the terms and conditions of the award.
To initiate a cost transfer, the Grant Accountant must prepare a transfer request
for submission to the appropriate accounting personnel. All cost transfers must be
the same amount as the original charge unless the transfer is divided among different
departments. If divided, an explanation of the division must accompany the transfer
request. The department requesting the cost transfer must have incurred the item of
cost and must identify the goods and services and their quantities in the transfer
request. All cost transfers must be for allowable costs and must be made within 120
days of the end of the month in which the original charge is posted to the ledger.
The university identifies these recurring adjusting journal entries for posting to
the general ledger in each accounting period. Nonrecurring adjusting journal entries
must be prepared to reflect account balances properly. Nonrecurring adjusting journal
entries include, but are not limited to, the following items:
- Correction of posting errors - Correct clerical errors (such as typographical errors
or transposition of account digits).
- Pre-Award Costs – At times, it is necessary to begin spending on a research award
before receiving the award document
- Pre-award costs must be authorized in accordance with sponsor and University policies.
Such costs must be charged to a department or discretionary account and transferred
to the new award account when established.
- Transfer of pre-award costs should be made in a timely manner to ensure costs are
recorded in the proper accounting period. However, they cannot be charged to the fund
until it is in effect.
- Closely Related Projects – To meet this definition, the same PI must manage projects,
scientifically and technically related, contain no change in the scope of the grant,
the arrangement must not be detrimental to the effort approved under each award, and
the relatedness must not be used to circumvent the terms and conditions of each individual
award.
- When research on separate projects is closely related, costs that are allowable and
allocable to either project may be incurred.
- If, after charging an expense to one of the accounts, it is determined that all or
part of the expense is more appropriately charged to a second account, the allocable
portion of the expense can be transferred to the second account with a proper explanation.
- Cost Overruns
- As discussed above, it may only be transferred to another research account when the
projects are closely related.
- Overruns that cannot be transferred to a related research account must be funded with
non-federal funds. Such amounts must be properly accounted for as cost-sharing and
included in the organized research base.
- Disallowed Cost – If a disallowance is identified, that cost must be transferred to
an appropriate non-federal account.
- Accrual of income and expense items
- Cost Transfers shall be supported by source documentation establishing:
- Timeliness
- Any cost transfers must be done in a timely manner based on sponsor guidelines but
no more than 120 days of finding the error.
Important to Remember
- Adequate Documentation for All Journal Vouchers
- All journal vouchers for journal entries are prepared only based on adequate supporting
documentation.
- Authorization of Entries
- All journal vouchers for entries into the general ledger are authorized and approved
by the Chief Accountant or Director of Administration and Finance who is not involved
in the origination of the entries.
In addition, the National Institutes of Health (NIH) Grants Policy Statement states:
“Cost transfers to NIH grants by grantees…should be accomplished within 90 days…transfers must
be supported by documentation that fully explains how the error occurred and a certification
of the correctness of the new charge by a responsible organizational official of the
grantee…” “An explanation merely stating that the transfer was made “to correct error”
or “to transfer to a correct project” is not sufficient. Transfers of costs from one
project…to the next solely to cover cost overruns are not allowable.”
“Grantees must maintain documentation of cost transfers, pursuant to 45 CFR 74.53
or 92.42, and make it available for audit or other review. The grantee should have
systems in place to detect such errors within a reasonable time frame; untimely discovery
of errors could indicate poor internal controls. Frequent errors in recording costs
may indicate the need for accounting system improvements, enhanced internal controls,
or both.”
Close-out
The final stage in the grant lifecycle is grant closeout. This phase begins when
the grant award period has expired or the Chicago State University draws down its entire grant award. Federal awarding agencies will notify Chicago State University as it nears the end of its grant term to request final reports. Suppose Chicago
State University is nearing the end of its grant term but has not yet expended its
entire grant award. In that case, it may be able to seek an extension from the federal
awarding agency.
2 CFR Part 200 Sections 200.343 thru 200.345 give detailed guidance on grant closeout
activities. Generally, the federal awarding agency will request and review the following
items within 90 days after the expiration of the grant award:
- Work plan and progress reports
- SF-269 Financial Status Reports
- Requests for payments
- Compliance with matching requirements
- Federally-owned property records
As the federal awarding agency conducts its review, it can still discover and collect
payments for disallowed costs and other deficits in the grant administration. Please see the grant close-out form sample here.
GRANT CLOSE-OUT Procedure 20.6 – Grant Close-out Page 118
Please note that all subrecipient records and documentation, including risk assessments/evidences,
are all kept in the department (OGRA) shared R drive.
Why should we retain financial records?
- It provides those responsible for managing cost objects with the means to monitor
transactions and resolve problems.
- It enables the Institute to comply with various requirements—Federal Acquisition Regulation
(FAR), A-110, Uniform Guidance, IRS and other federal, state, and local regulations—which
govern the auditing and retaining of records. Retention requirements are typically
defined by the type of award (grant, contract, cooperative agreement) and the sponsor
(federal, non-federal, foundation).
- For federal awards that fall under OMB's Uniform Guidance, see a summary of the revised
requirements for paper vs. electronic retention here:
- For older federal grants and cooperative agreements, A-110 states that financial records,
supporting documents, statistical records, and all other records pertinent to an award
should be retained for three years from the date of submission of the final expenditure
report; for awards that are renewed quarterly or annually, the records should be retained
from the date of submission of the quarterly or annual financial report, as authorized
by the federal awarding agency.
- For federal contracts, FAR dictates that records must be retained for three years
after the final payment. This includes books, documents, accounting procedures and
practices, and other data—regardless of whether such items are written, computerized,
or in any other form—and other supporting evidence to satisfy the contract negotiation,
administration, and audit requirements of the contracting agencies and the Comptroller
General. For financial and cost accounts, pay administration and acquisition, and
supply records, the required retention requirement is two to four years.
Time of Retention
Generally, legal and audit requirements dictate how long financial and project records
should be retained.
- When requirements for long-term records retention overlap, the responsible office
should retain records for the maximum period needed to meet legal and audit requirements.
A-110 specifies the following:
- Direct charges to contracts and grants: Three years following the date CSU OGRA considers
the project to have been formally closed by the sponsor, unless an audit or litigation
is underway.
- All cost objects included in the F&A cost rate: Three years following the federal
government's final sign-off for that year. Contact the Office of Grants and Research
Administration (OGRA) for further information.
Longer retention times apply to certain documents. See Retention of Copies for Department Files.
Scientific Data/Technical Records Retention
The Principal Investigator is responsible for retaining scientific and technical data
and related compliance documentation.
All Rights Reserved
