Research & Cost Accounting

Record retention

These procedures are issued in accordance with Rice Policy No. 812. 

Purpose

Proper records management serves multiple purposes. It helps ensure that the University meets the requirements of sound business practices as well as compliance with sponsor and other legal and statutory standards for protection, storage and retrieval of information. Rice Policy No. 812, Records Management, sets forth the overall requirements for departments to manage, retain and dispose of records and includes information on the following topics:

• Departmental responsibility to develop a records management plan,
• Proper disposal methods,
• Records subject to a legal or regulatory claim, proceeding or audit, and
• Safeguarding confidential records.

Definitions

Banner is an Ellucian higher education software system used as the financial system of record for financial data, including the general ledger and primary subsidiary ledger transactions of the University.

Cayuse is an electronic research administration software from Evisions used for proposals and awards. Cayuse data interfaces with Banner. Cayuse documents are uploaded to OnBase.

Concur is an on-line software system for recording and documenting PCard purchases and all travel, entertainment and business meeting expenditures. The expenditure transactions interface with Banner.

Financial records are all proposal and award documents plus all documents supporting financial transactions and reports. Examples of financial records include: original and supplemental proposals; original awards and amendments; budgets; encumbrances; direct cost expenditures; fringe benefit rate agreements; indirect  cost rate agreements; requests for payments and payments received; financial reports. Uniform Guidance states: “when original records are electronic and cannot be altered, there is no need to create and retain paper copies. When original records are paper, electronic versions may be substituted through the use of duplication or other forms of electronic media provided that they are subject to periodic quality control reviews, provide reasonable safeguards against alteration, and remain readable.”

OMB Uniform Guidance include administrative requirements, cost principles and audit requirements for federal awards (which includes research grant awards).

OnBase is a document imaging system from Hyland Software and is used as the system of document record retention by various university offices, including the Controller’s Office and the Office of Sponsored Research (SPARC).

Sponsored projects are externally-funded activities in which a formal document or agreement (example: a grant, contract, letter award or a cooperative agreement) is provided to Rice University by a sponsor or a written agreement (contract or subaward) is entered into by Rice University and a sponsor. A sponsored project may be thought of as a transaction in which there is a specified statement of work with a related, reciprocal transfer of something of value. In addition, when the terms and conditions of a gift or contribution provided to Rice University require that the funding be considered a sponsored project, the award will be assigned and maintained through a sponsored project fund (R fund).

Retention period for all financial records of sponsored projects is a minimum of four (4) years beyond the project end date. If a sponsor’s record retention period is greater than four (4) years or more after the project end date, the period specified in the award agreement is to be followed. 

Rice Marketplace is a procurement software system from SciQuest used for the system of document records for encumbrances/purchase orders. It interfaces with Banner.

WebApps is a Rice-developed web application system that provides on-line, real-time Banner data to principal investigators (PIs), department administrators and central offices.

Responsibility

Records management of sponsored projects is a shared responsibility among many offices, departments and individuals. The underlying principle of this shared responsibility is that the area with the original record is responsible for the management, retention and disposal of the records. This responsibility includes establishing and maintaining procedures for the protection of essential records in the event of a natural disaster or other emergency.

These retention guidelines do not require the retention of the original paper document(s); an electronic copy is sufficient as long as it is legible and contains the same data.  See the definitions section below for additional federal guidance on electronic records. 

Records must be retained in accordance with Rice policy and sponsor requirements. To ensure compliance with sponsor and other regulatory record retention requirements, financial records for individual sponsored projects are to be retained for a minimum of four (4) years after the project end date. This period meets the record retention requirements of all federal agencies and many other sponsors. (Example: An expense is charged in May 2011 during the first year of a three-year federal project; the project is later granted a no-cost extension until 10/31/14.  The expense records for the May 2011 transaction must be kept through 10/31/18, which is four years after the revised project end date of 10/31/14.)

If a sponsor’s record retention period is greater than four (4) years after the project end date, the period specified in the award agreement is to be followed.  For instance, the Cancer Prevention & Research Institute of Texas requires that records “be kept for four (4) years after the final reimbursement for the award has been paid and until any (if applicable) litigation, claims or audit findings have been resolved.”

As stated in Rice Policy No. 812, if a record is relevant to a pending or anticipated claim, investigation, audit, agency charge, enforcement action or litigation, the records must be retained until the final resolution of the matter.  If there is any question whether a department or office's normal document destruction schedule should be temporarily suspended because of a pending matter, the department or office shall consult with the Office of the General Counsel before any such destruction. 

Responsibility matrix for financial records

In the event an area retains the original of a type of financial record not listed below, the record is to be maintained in accordance with these guidelines.

Management information

When a central office has retention responsibility, the department initiating a transaction may discard copies of documentation supporting the transaction when it is no longer needed for management purposes.  A department may keep copies of documents for longer periods.