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Records Retention

Documents and records relating to proposals and sponsored projects must be retained according to sponsor and University of Oregon (UO) guidelines. During the course of proposal development and the life of a sponsored project, a variety of documents are generated including formal proposals, email communications, invoices, purchase orders, financial and technical reports and lab note books. Due to the variety and range of records generated during the sponsored award life cycle, records retention at the UO is a shared responsibility across Principal Investigators (PIs), Departmental Grant Administrators (DGAs) and other business support staff, the Sponsored Projects Services office (SPS) and other central support units. In addition the formal role of University Archivist is administered within the UO Libraries organization.

The following guidance was developed in an effort to clarify the requirements and roles and responsibilities for retaining records on sponsored projects at the University of Oregon, specifically focusing on the role of the Principal Investigator and DGA/Business Office. A detailed matrix outlining the requirements for all parties is included in Section I. It is possible that there are circumstances not covered in this document regarding records related to sponsored programs, so for further clarification and guidance, please contact your SPS Sponsored Project Administrator Team.

 

Sponsor versus University of Oregon Retention Periods

This document focuses on the record retention guidelines established by Oregon Administrative Rule 166-475-0060 and these regulations are flowed down to the UO through the Oregon University System and state governance. However, various sponsoring agencies that provide external funding to UO for specific sponsored projects may also have their own records retention guidelines and requirements. These requirements are often spelled out within the award documents, contract agreement or may be found through other sponsor reference sources, such as a sponsor website. When the defined retention periods or policies for a specific sponsor or a specific sponsored project conflict with the UO retention rules defined in this document, the more conservative rule takes precedence. For example, the federal government requires a retention period of three years from the submission and acceptance of the final report for all project related documentation, a period that is much shorter than the UO policies. Therefore, the UO policies must be followed and records retained for a longer period (5years - permanent retention), as opposed to the federally mandated three year period.

Note that the OUS records retention schedule is frequently updated and the purpose of this document is to serve as a reference tool , not a definitive policy itself. The latest version of the OUR retention schedule is always available at:

 

Office of Record

Central offices, SPS and the Technology Transfer Services (TTS), are identified as the offices responsible for maintaining permanent record copy documentation on grants and contracts at the UO. Individual units, departments, other offices and individuals are also named as having responsibilities maintaining other copies in subsequent sections of this document. Once the non-permanent retention period has ended, duplicates and all other related materials should be destroyed.

In addition, SPS and TTS will serve as the unit responsible for forwarding composite grant and contract records to University Archives for permanent storage as required. These central offices will request retention copies from the creators as part of their standard business processes, however once requested it is the responsibility of the investigator, unit or other party creating the original document to forward that document to SPS or TTS for retention.

 

Retention Period Start Date Definitions

The Record Retention Periods highlighted in this document begin at various points in time, primarily related to the sponsored project timeframe or the time period of various activities, such as agreement execution dates, meeting dates, etc. The various dates referenced as the start of the records Retention Period are defined below along with guidance on how to determine the specific date for a given project or activity. Please note that when multiple dates apply to a given type of record, the most conservative Start Date/Retention Period scenario should be applied.

  • Activity Completion Date: This date is the point in time when a specific technical or research activity has ended. It directly applies to efforts on a human subject or animal research protocol as well as a particular chain of technical, scientific or research activities that take place in a laboratory or workspace.
    • For human subject or animal subject protocols, this date should be no later than the Protocol Expiration Date
    • For lab activities, this date is best determined by the PI and technical team
  • Activity Date: This date is the general date on which the activity in question took place. This date could include the date on which requests for sample products were made/received, patent application dates or agreement execution dates. For a chain of activities, such as requests, responses and resulting “back-and-forth” the Activity Date should be the final date in the related series of events.
    • This date must be determined on an ad hoc basis by referencing documentation and other records
  • Activity Start Date: The date when a specific technical or research activity was initiated. It directly applies to efforts on animal research protocols.
    • For animal subject protocols, this date must be later than the Protocol Approval Date
  • Bi-Yearly Report Date: The date on which the bi-annual returned overhead report is released to the broader UO research community.
  • Final Financial Report Date: The date when the final financial report for a sponsored project is submitted by SPS to the sponsor. For grants awarded as a competitive segment of funding, this date applies to the final financial report for the segment.
    • For recently terminated awards, the date is entered in EPCS. Using the EPCS HOME>> link in the upper left hand corner of EPCS, select Logs>> and then Retention Date Log. Search the Grant Number to determine the retention period start date
    • For awards that terminated prior to this feature being built in EPCS, grant records and correspondence, including the financial reports, can be reviewed to determine the submission date. For further assistance in determining this date, please contact SPS
    • When a Final Financial Report is not required for the grant, the default date is 90 days after the Project End Date entered in Banner to allow for a closeout period
  • Grant End Date: The date when the UO sponsored project period ends and grant activity ceases.
    • The Project End Date field entered in Banner stores this date
  • Litigation Resolution Date: The date when any external court or internal investigator ceases and a final determination has been issued by the investigating party. When appeals are involved, this date is the date of resolution for the final related appeal.
    • This date can be referenced by the issuance date on any resolution documentation
  • Internal Funding Award Date: The date institutional councils or boards reviewing proposals make the recommendation for awards or when an institutional body issues a funding determination
    • This date will be indicated on any funding determination communications or internal meeting documents
  • Pay Date: The date when any compensation for services made via payroll systems is made to an individual, either check issue dates or direct deposit dates
  • Submission Date: The date a proposal for external funding is submitting officially to the potential sponsor institution from the UO
    • This date can be located on the Proposal Tab of the applicable record in EPCS, labeled as the Submit Date.
    • Please note that this date is accurate only when submissions are appropriately routed through SPS. However, if SPS is notified of a submission after the fact, this filed is populated with the date the PI finalizes the EPCS record.

Responsible Group 1: Principal Investigators

Principal Investigators (PIs) are responsible for the overall fiscal and technical administration of their sponsored projects and therefore also play an important role in University Records Retention.

  • Technical/Scientific Records:
    • Grant Projects Research Records: Documents on the research activity associated with sponsored projects, including research data, working papers, research/activity reports, summary reports, and related documentation and correspondence.
      • Retention Period: 5 years
      • Retention Period Start Date: Final Financial Report Date
    • Institutionally Funded Research Records : Documents related to research activities that are not supported by external funders but are aimed at leading to funding sources (pilot research, emergency funding, emerging research opportunities, new research fields, developing laboratories, and centrally shared research resources). Documents include applications, reports, notes, working papers, funding summaries, award letters, personal data, final research reports and related documentation and correspondence.
      • Retention Period: 3 years
      • Retention Period Start Date: Internal Funding Award Date
    • Laboratory Notebooks and Reports: Documents generated during routine research activities or related to the results of laboratory testing. The series can include notebooks, binders, journals, test details such as case numbers, names, tests and procedures performed, results, evaluations, and related data.
      • Retention Period: 6 years
      • Retention Period Start Date: Activity Completion Date

 

  • Proposal-Related Records:
    • Unfunded Proposal Records: Grant proposal documents which have not been funded, including supporting statistics, demographic data, draft proposals, suggested revisions; final proposals, and related documentation and correspondence.
      • Retention Period: 18 months
      • Retention Period Stare Date: Submission Date
    • Funded Proposal Records1: Grant proposal documents which are funded, including supporting statistics, demographic data, draft proposals, suggested revisions; final proposals, and related documentation and correspondence.
      • Retention Period: 18 months
      • Retention Period Start Date: Final Financial Report Date
  • Compliance Records:
    • Human Subjects Records: Documents related to all levels of OPHS review of research that involves any type of use of human subjects, including protocol applications, signed consent forms, sample questionnaires or surveys, and related memoranda and correspondence.
      • Retention Period: 3 years
      • Retention Period Stare Date: Activity Completion Date or Final Financial Report Date (whichever is later)
    • Animal Subjects Records: Documents related to the care and use of animals for research purposes, including institutional animal care and use forms, research protocol check-off forms and related correspondence.
      • Retention Period: 1 year
      • Retention Period Start Date: Activity Start Date or Final Financial Report Date(whichever is later)

 

  • Finance Records:
    • Grants and Contracts Accounting Records: Documents related to the establishment and administration of individually sponsored grant and contract funds and accounts, including project summaries, grant authorizations, contract documents, project budget change and adjustment forms, invoices, receipts, equipment purchase orders, prior approval request forms, account request forms, subcontracts, monthly budget summary statements, balance sheets, financial reports, property reports, patent/invention reports, assignment of refunds and rebates documents, equipment disposition reports, and related documentation and correspondence.
      • Retention Period: 5 years
      • Retention Period Start Date: Final Financial Report Date

Responsible Group 2: Department, Center or Institute Business and Support Staff (including DGAs)

Department Grant Administrators (DGAs) and business support units within the UO’s centers, institutes and departments also have responsibilities in the maintenance of documents related to sponsored projects. DGAs are in a support role for PIs, but there are also records that must be maintained at the unit level described in this section.

  • Technical/Scientific Records:
    • Laboratory Reports: Documents related to the results of laboratory testing, such as test details, case numbers, names, tests and procedures performed, results, evaluations, and related data.
      • Retention Period: 6 years
      • Retention Period Start Date: Activity Completion Date
    • Proposal-Related Records: DGAs and unit support staff should assist PIs and ensure individual records related to both funded and un-funded proposals are maintained as described in Section E.
  • Finance Records:
    • Grant Indirect Cost/Returned Overhead Records: Documents related to returned overhead costs for institutional departments, specifically related to the returned overhead report and the final report issued for budget adjustments, including spreadsheets, work sheets, and related documentation.
      • Retention Period: 2 years
      • Retention Period Start Date: Bi-Yearly Report Date
    • Grants and Contracts Accounting Records: Documents related to the establishment and administration of individually sponsored grant and contract funds and accounts, including project summaries, grant authorizations, contract documents, project budget change and adjustment forms, invoices, receipts, equipment purchase orders, prior approval request forms, account request forms, subcontracts, monthly budget summary statements, balance sheets, financial reports, property reports, patent/invention reports, assignment of refunds and rebates documents, equipment disposition reports, and related documentation and correspondence.
      • Retention Period: 5 years
      • Retention Period Start Date: Final Financial Report Date
    • Other Payroll Expenses (OPE) Reports: Documents that substantiate payroll overhead costs on sponsored projects, such as employee names, social security numbers, institutions, classifications of positions, units of employment, pay periods, gross pay amounts, various withholdings, etc.
      • Retention Period: 1 year
      • Retention Period Start Date: Pay Date
    • Personnel Activity Report Forms (PARs): Record of Classified and Academic employees' efforts involving indirect activities such as instruction and departmental research, and direct activities toward externally funded projects. This includes all signed and certified PARs.
      • Retention Period: 2 years
      • Retention Period Start Date: Final Financial Report Date

 

  • Other Records:
    • Technology Transfer Records: Documents regarding the transfer of technology from UO to outside agencies as the result of research projects and grants carried out at UO. This includes original patents, patent applications, international licensing agreements, use of other patented invention agreements, invention disclosure forms, descriptions and titles of inventions, sources of funding to create the inventions, details of the provenance of the inventions and their documentation, to whom the inventions have been disclosed, suggested manufacturers, reports issued concerning the inventions, and signatures of inventors and technically qualified witnesses.
      • Retention Period: 3 years
      • Retention Period Start Date: Activity Date or Grant End Date (whichever is later)

Responsible Group 3: Sponsored Projects Services

As the UO’s central unit responsible for the management and administration of sponsored grants and contracts, SPS plays a large role in records retention and document maintenance. The high-level information related to the documents maintained by SPS and the related retention periods is provided below.

  • Technical Records:
    • Grant Projects Research Records: See Section E.
    • Institutionally Funded Research Records: Documents described in Section E as well as applicant case files, agendas, minutes, reports, notes and other committee documents.
      • Retention Period:
        • Permanent: Minutes and final research reports
        • 5 years: Funding summaries and funded applications
        • 1 year: All other documents
      • Retention Period Start Date: Internal Funding Award Date
  • Proposal-Related Records: See Section E.
      • Retention Period:
        • Permanent: Funded Proposals
        • 3 years: Other Funded Proposal Documents
        • 18 months: Unfunded Proposals
      • Retention Period Start Date: Internal Funding Award Date
  • Finance Records:
    • Grant Direct Payment Records: Requests and justification for transfers of direct payment funds from federal grantors, including federal cash position reports, spreadsheets of federal sources and cash needs, requests for cash, credit advice from the U. S. Treasury, and related documentation and correspondence.
      • Retention Period: 5 years
      • Retention Period Start Date: Final Financial Report Date
    • Grant Indirect Cost/Returned Overhead Records: See Section E.
      • Retention Period: 5 years
      • Retention Period Start Date: Bi-Yearly Report Date
    • Grants and Contracts Accounting Records: See Section E and F.
      • Retention Period: 5 years
      • Retention Period Start Date: Final Financial Report Date
    • Personnel Activity Report Forms (PARs): See Section F.
      • Retention Period: 6 years
      • Retention Period Start Date: Final Financial Report Date

 

  • Other Records:
    • Commercial Company Records: Documents related to cooperative relationships with commercial companies in sharing research materials and data, such as cash receipt acknowledgments, requests for sample products, acceptances of products, and related correspondence.
      • Retention Period: 5 years
      • Retention Period Start Date: Activity Date or Grant End Date (whichever is later)

Responsible Group 4: Other Central Support Offices

There are many other units across campus who pay a role in maintaining documents related to sponsored projects; a high-level overview is provided below.

  • Compliance Records:
    • Human Subjects Records (Retention Role - Research Compliance Services (RCS)): See Section E.
      • Retention Period: 3 years
      • Retention Period Stare Date: Activity Completion Date or Final Financial Report Date(whichever is later)
    • Animal Subjects Records (Retention Role - Institutional Animal Care and Use Committee (IACUC)): See Section E.
      • Retention Period: 3 years
      • Retention Period Start Date: Activity Completion Date or Final Financial Report Date(whichever is later)
  • Finance Records:
    • Other Payroll Expenses (OPE) Reports (Retention Role - Business Affairs Office (BAO)): See Section F.
      • Retention Period: 6 years
      • Retention Period Start Date: Pay Date
    • Other Payroll Expenses (OPE) Reports (Retention Role -Payroll Office): See Section F.
      • Retention Period: 1 year
      • Retention Period Start Date: Pay Date
  • Other Records:
    • Commercial Company Records (Retention Role -Technology Transfer Services (TTS)): See Section G.
      • Retention Period: 5 years
      • Retention Period Start Date: Activity Date or Grant End Date (whichever is later)
    • Technology Transfer Records (Retention Role - TTS): See Section F.
      • Retention Period:
        • Permanent: Original patents, formal invention assignment forms, license agreements, patent legal transactions, and invention disclosure form
        • 6 years: All other documents
      • Retention Period Start Date: Activity Date or Grant End Date (whichever is later)
    • Scientific Misconduct Records (Retention Role - Academic Affairs): Documents series providing a record of accusations of misconduct brought forward by or against faculty or students and relating to research projects, such as accusation statements, inquiry committee findings, and related correspondence.
      • Retention Period:
        • 1 year: Records in litigation
        • 6 years: Non- litigation records
      • Retention Period Start Date:
        • Litigation Resolution Date: Records in litigation
        • Grant End Date: Non- litigation records

Record Retention Guidance Matrix

Series Number

Item Name

Description

Responsible Unit

Time Period

Retention Period Start Date

1

Commercial Companies Records

This series documents cooperative relationships with commercial companies in sharing research materials and data. This series may include but is not limited to: cash receipt acknowledgments; requests for sample products; acceptances of products; and related correspondence.

SPS

5 years

Activity Date/ Grant End Date

TTS

5 years

Activity Date/ Grant End Date

2

Grant Direct Payment Records

This series documents requests and justification for transfers of direct payment funds from federal grantors. This series may include but is not limited to: federal cash position reports; spreadsheets of various federal sources and cash needs; requests for cash; credit advice from the U. S. Treasury; and related documentation and correspondence.

SPS

5 years

Final Financial Report Date

3

Grant Indirect Cost/Returned Overhead Records

This series provides a record of the analysis of grant indirect costs in order to prepare returned overhead figures for institutional departments and is used to submit notification for the budget to be adjusted. The returned overhead report is prepared twice during the year. Estimates are prepared and reviewed by departments and used in budget preparation. A final report is used for budget adjustment. This series may include but is not limited to: spreadsheets; work sheets; and related documentation and correspondence.

SPS

5 years

Bi-Yearly Report Date

Units

2 years

Bi-Yearly Report Date

4

Grant Projects Research Records

This series documents the research activity associated with grant-funded projects. This series may include but is not limited to: research data; working papers; research/activity reports; summary reports; and related documentation and correspondence.

PI

5 years

Final Financial Report Date

SPS

Permanent

 

5

Grant Proposal Funded Records

This series documents grant proposals developed and prepared by the institutional units that were funded. This series may include but is not limited to: supporting statistics; demographic data; draft proposals; suggested revisions; final proposals; and related documentation and correspondence.

SPS

Permanent

 

PI

3 years

Final Financial Report Date

Units

3 years

Final Financial Report Date

6

Grant Proposal Unfunded Records

This series documents grant proposals developed by institutional units which have not been funded. This series may include but is not limited to: supporting statistics; demographic data; draft proposals; suggested revisions; final proposals; and related documentation and correspondence.

SPS

18 months

Submission Date

PI

18 months

Submission Date

Units

18 months

Submission Date

7

Grants and Contracts Accounting Records

This series provides a record of the establishment and administration of individually sponsored grant and contract restricted funds accounts, documents compliance with fiscal reporting requirements, and includes billing information for accounts receivable from sponsoring agencies and from departments for gift account fees. Grants may be federal, state, corporate, or private. This series may include but is not limited to: project summaries; grant authorizations; contract documents; project budget change and adjustment forms; invoices; receipts; cashier's receipts; equipment purchase orders; prior approval request forms; account request forms; vendor telephone contact logs; subcontracts; grants and contracts monthly budget summary statements; institution billings balance sheets; SF272 reports for grants and contracts that are operating on direct payments; final financial reports; property reports; patent/invention reports; contractor's release report; assignment of refunds and rebates documents; equipment disposition reports; and related documentation and correspondence.

SPS

Permanent

 

PI

5 years

Final Financial Report Date

Units

5 years

Final Financial Report Date

8

Human Subjects Records

This series documents the review of research proposals that involve any type of use of human subjects. Reviews may be made by the entire review board, selected members, or the board's chair. Records may include: applications for approval by the review board; Protection of Human Subjects forms (OMB-0531-0009); Protection of Human Subject -- Assurance/Certification/ Declaration forms (OMB-0925-0637); descriptions of protocol; signed consent forms; sample questionnaires or surveys; copies of grant proposals; review summaries; and related memoranda and correspondence.

RCS

3 years

Activity Completion Date

PI

3 years

Activity Completion Date

9

Institutional Animal Care and Use Records

This series documents the care and proposed use of animals by the university for research purposes. Records include: institutional animal care and use forms; research proposal check-off forms; and related correspondence.

IACUC

3 years

Activity Completion Date

PI

1 year

Activity Start Date

10

Institutionally Funded Research Records

This series documents the activities of the institutional councils and boards, which review proposals and make recommendations for awards to faculty (especially new faculty) for research that is not otherwise supported by organized or directed programs but is designed to lead to other funding sources. Examples of projects funded are pilot research, emergency funding, emerging research opportunities, new research field or new research field for investigator, developing research laboratories, and centrally shared research resources. This series may include but is not limited to: applicant case files; agendas; minutes; reports; notes; working papers; funding summaries; award letters; applications for research support; personal data; final research reports; and related documentation and correspondence.

SPS

5 years

Meeting/Review Date

Minutes and Final Technical Research Reports

SPS

Permanent

 

Other

SPS

1 year

Meeting/Review Date

All Documents

PI

3 years

Meeting/Review Date

11

Laboratory Notebooks

This series documents the routine research activities of non-grant funded research projects. This series may include but is not limited to: notebooks; binders; or any other type of journal format.

PI

6 years

Activity Completion Date

12

Laboratory Reports

This series documents the results of laboratory testing performed for clients. The reports may include but are not limited to: case numbers; client names; details of tests and procedures performed; test results; evaluations; and related data.

PI

6 years

Activity Completion Date

Units

1 year

Activity Completion Date

13

Other Payroll Expenses (OPE) Reports

Payroll Expenses (OPE) Reports This series is used to substantiate payroll overhead costs. Information in this series may include but is not limited to: employee names; social security numbers; institutions; classifications of positions; units of employment; pay periods; gross pay amounts; various withholdings; overhead amounts; and the accounts used to pay employees.

BAO

6 years

Pay Date

Units

1 year

Pay Date

Payroll

1 year

Pay Date

14

Personnel Activity Report Forms (PAR)

This series provides a record of Classified and Academic employees' efforts involving indirect activities such as instruction and departmental research, and direct activities toward externally funded projects. The series is maintained in compliance with regulations of the Federal Office of Management and Budget (OMB) as set forth in OMB Circular A21 and in agreement with the U.S. Department of Health and Human Services. The PAR system is used to produce an equitable distribution and/or substantiation report of charges for employees' activities and to distinguish the employees' direct activities from their indirect activities. Information on the individual forms includes: institution name; employee name; social security number; monthly salary rate; department code; account name and number; transaction codes; pay amounts for each account number; PAR codes; comments; authorizing signatures; and dates of authorization.

SPS

6 years

Final Financial Report Date

Units

2 years

Final Financial Report Date

15

Scientific Misconduct Records

Misconduct Records This series is used to provide a record of accusations of misconduct brought forward by or against faculty or students and relating to research projects. These records include: accusation statements; inquiry committee findings; and related correspondence. (Non-litigation records)

Academic Affairs

6 years

Grant End Date

All records in litigation

Academic Affairs

1 year

Litigation Resolution Date

16

Technology Transfer Records

This series documents the transfer of technology from this institution to outside agencies as the result of research projects and grants carried out at the institution. This series may include but is not limited to: original patents; patent applications; international licensing agreements; agreements giving permission for institutional researchers to use other patented inventions in their research; and related documentation and correspondence. The series may also include: invention disclosure forms that list the names of the inventors; descriptions and titles of inventions; sources of funding to create the inventions; details of the provenance of the inventions and their documentation; to whom the inventions have been disclosed; suggested manufacturers; reports issued concerning the inventions; and signatures of inventors and technically qualified witnesses.

TTS

6 years

Activity Date/Grant End Date

Original patents, formal invention assignment forms, license agreements, patent legal transactions, and invention disclosure forms

TTS

Permanent

 

All Documents

Units

3 years

Activity Date/Grant End Date

SPS is responsible for retaining a copy of the proposal submissions permanently, so if changes are made to a proposal after SPS review, please ensure the final submitted version is forwarded