RCUH Policies and Procedures
of the University of Hawai‘i
1.500 Record Retention and Custodial Policy
Record-retention periods must comply with federal and State laws, as applicable, and with the specific requirements of the sponsor. In cases where a conflict exists, the longer retention period shall apply.
I. Federal Grants and Contracts
The following is extracted from the U.S. Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards and the University of Hawai‘i (UH) Administrative Procedure (AP) 8.926 Administrative and Financial Management Requirements for Extramurally Financed Research and Training Programs/Activities, Section 8 (a)–(d):
A. Financial records, supporting documents, statistical records, and all other records pertinent to a sponsored agreement shall be retained for a period of three years from the start date described below, with the following qualifications:
1. If any litigation, claim, or audit is started before the expiration of the 3-year period, the records shall be retained until all litigations, claims, or audit findings involving the records have been resolved.
2. Records for non-expendable property acquired with Federal funds shall be retained for 3 years after the property’s final disposition.
B. The start of the record retention period may be determined by the following:
1. The date of the submission of the final expenditure report for grants and other agreements, or
2. The date of the submission of the annual financial status report for grants and other agreements that are renewed annually, or
3. The date of final payment for contracts, or as specified in FAR Subpart 4.7 Contractor Records Retention.
II. State Requirements
Record-retention periods must follow the applicable UH and State of Hawai‘i guidelines. Refer to AP 8.926 Administrative and Financial Management Requirements for Extramurally Financed Research and Training Programs/Activities, and the State of Hawai‘i General Records Schedule.
III. Other Sponsors
Record-retention periods must comply with the individual sponsor’s requirements. In the absence of sponsor requirements, all records and supporting documents shall be retained for a period of 6 years after submission of final report to the sponsor.
IV. Records Availability
All records shall be made available to federal and non-federal sponsors, RCUH, and their respective audit agencies, as well as UH and State audit agencies, when requested for audits, examinations, excerpts, and transcripts.
V. Relevant Documents
FAR Subpart 4.7 Contractor Records Retention State of Hawai‘i General Records Schedule
UH AP 8.926 Administrative and Financial Management Requirements for Extramurally Financed Research and Training Programs/Activities
Date Revised: 1/18/2017