Records Access and Retention

This overview of documents pertaining to the grant award that must be retained includes Grantee financial records, supporting documents, and statistical records. Financial managers and program directors must retain documents for a period of at least three years from the date of submission of the annunal financial report.

Grantee financial records, supporting documents, statistical records, and all other records pertaining to the grant award must be retained for a period of at least three years from the date of submission of the annual financial report (45 CFR 74.53 or 45 CFR 92.42).

The only exceptions are the following:

  • If any litigation, claim, financial management review or audit is started before the expiration of the three-year period, the records must be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken.
  • Records for real property and equipment acquired with Federal grant funds must be retained for three years beyond the date of final disposition (i.e., the date the equipment or property was sold or otherwise disposed).
  • Indirect cost rate proposals and computations, cost allocation plans and any similar accounting computations of the rate at which a group of costs is chargeable (such as computer usage charges, or composite fringe benefit rates):
    1. If the proposal, plan, or computation was submitted by the grantee to the Federal government, then the three-year retention period for the grantee's supporting records (for the proposal, plan, or computation) starts on the date of such submission.
    2. If the grantee was not required to submit the plan, proposal or computation to the Federal government, then the three-year retention period starts at the end of the fiscal year covered by the proposal, plan or computation.

Copies of original records may be substituted for the originals only if approved and authorized by ACF.

Records Access Requirements

ACF, as the HHS awarding agency (and the HHS/Office of Inspector General (OIG)), the U.S. Comptroller General, General Accounting Office (GAO), or any of their duly authorized representatives) has the right of timely and unrestricted access to any of the grantee's books, documents, papers or other records of the grantee's that are pertinent to the grant award in order to make audits, reviews, examinations, excerpts, transcripts and/or copies of such documents.

This right also includes timely and reasonable access to all of a grantee's personnel for the purpose of interview and discussion related to such documents.

The rights of access to records and to personnel are for as long as the records are retained, and are not limited to the required retention period.

Computerized Records Requirements

If grantees choose to maintain computerized records, the same requirements still apply. The "computer age" does not change the fact that grantee financial report information and business management practices must be based on verifiable supporting documents and records.

Grantees must have supporting records for accounting, auditing, and financial status reports. Some ACF grantees have indicated that they are not printing out monthly general ledgers or other accounting records, but are instead maintaining all information in their computer systems. Therefore, for these grantees, the computerized records must be transferred or copied to diskettes or other electronic storage media at the applicable "points in time" that reflect the figures for those reports.

In addition, the diskettes or other electronic storage media must then be carefully maintained and the data periodically re-saved or whatever is necessary for the records to remain verifiable and accessible to ACF throughout the required retention period.

Also, if computer systems or software applications are subsequently upgraded and/or changed and the old records can only be accessed using the old system, then a copy of the old system must be archived in order for the records to remain accessible for the required retention period.

Records Access and Retention. HHS/ACF/ACYF/HSB. n.d. English.

Last Reviewed: November 2008

Last Updated: July 30, 2015