Sponsored Projects Procedures

Record Management for Sponsored Projects

Research, Sponsored Projects  |  Approved October 9, 2015

Purpose

Retain and dispose of records in accordance with sponsor requirements.

Applicability

Principal Investigators (PIs) and administrators managing sponsored programs. For more information, review the Sponsored Programs Administration (SPA) website on Record Retention.

Instructions

1. Original records
   1. Most sponsored program records are in electronic format since the University of Maryland, Baltimore (UMB) uses Kuali Research, eUMB Financials and other tools. If original records are electronic and cannot be altered, there is no need to create and retain paper copies.
   2. If original records are paper, electronic versions may be substituted provided that they are subject to periodic quality control reviews, cannot be altered, and remain readable.
   3. UMB central offices maintain official records (including proposals, awards, financial transactions, invention disclosures, and others). However, program records are maintained by PIs, and departments hold some source records and details related to the official records.
   4. Be aware of confidentiality and inclusion of personal or proprietary information in the records. Use limited-access storage for documents containing personal, proprietary or confidential information.
2. Access to records
   1. Maryland Public Information Act (MPIA) requests are handled through the UMB General Counsel’s office, x6-5353, mpia@umaryland.edu. Never respond directly to an MPIA request or provide any documentation.
   2. If an auditor calls, contact Management Advisory Services and Sponsored Projects Accounting and Compliance. See procedure about how to respond to an auditor inquiry.
3. Technical (program) records are retained by the PI.
   1. Retain progress reports and final technical reports for at least 3 years after submission to the sponsor.
   2. Retain the original data and all project records for at least 3 years after submission of the final report or award termination. After the required retention period, the principal investigator/project leader may make the decision to retain the records or to discard them when the records are determined to be no longer useful for research or educational purposes.
   3. Retain clinical study data in accordance with the clinical study agreement and the Human Research Protections Program Investigator Manual.
      1. Review the clinical study agreement for a provision specifying the required period of retention for source documents. The requirement may differ based on the type of study and other factors. The ICH Guidance Document E6: Good Clinical Practice: Consolidated Guidance provides advice on retention of essential documents.
      2. For clinical studies involving children, records are to be retained indefinitely.
      3. In the event of faculty transfer, clinical study data must remain at UMB.
   4. When an invention has resulted from the project, contact the Office of Technology Transfer for advice on retention of relevant records.
4. Fiscal records are retained by UMB central offices but departments may have source records that support the transaction records.
   1. Federal awards: The Uniform Guidance, specifically 2 CFR 200.333, governs record retention under federal grants. The Federal Acquisition Regulation, specifically FAR 52.215-2, governs record retention under federal contracts. To summarize, retain records for 3 years after submission of the fiscal status report (annual or, if annual is not required, competitive segment) or after final payment under a federal contract. If any litigation, claim, or audit is started before the expiration of the 3-year period, the records must be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken.
   2. Local government awards:  Review award terms and conditions. It is recommended that all records for projects funded under State and City awards (MOUs, grants, agreements) be retained for 6 years.
   3. Other awards: Review award terms and conditions and sponsor policies. If the sponsor or award document does not specify a specific time period to retain project records, follow the Federal requirement and retain records for 3 years after final payment under the award.
5. Guidelines for discarding and destroying records
   1. Shred paper documents containing personal, proprietary or confidential information, using a cross-cut shredding device.
   2. Electronic data must be securely removed from any disk, tape, USB drive, hard drive, photocopier, facsimile machine, or other device with electronic storage before the device is transferred or discarded. Deletion of an electronic record may not eliminate all remnants of the record. Contact your IT expert for advice.