Financial Record Retention Schedule - University Department Requirements (Formerly Appendix 21)

Policy Steward: Office of the Corporate Controller

Table of Contents:

PURPOSE OF RECORD RETENTION

Retaining records serves two purposes; in the short-term, it provides those responsible for the management of accounts with the means to monitor transactions and resolve problems. In the long-term, it enables the University to adhere to Policy AD35, University Archives and Records Management and to comply with Federal Acquisition Regulations, the OMB Uniform Guidance, Internal Revenue Service regulations, and other federal, state and local regulations governing auditability and retention of records. These retention requirements are the University's retention criteria, either derived or based upon federal, state, and/or local statute or regulations, industry standards, and business needs. These retention periods are subject to change.

This schedule provides the basis for determining the length of time various financial documents must be retained by individual University departments, including Finance Offices. Retention schedules related to central financial systems, such as IBIS, ERS and eBuy, will be determined by the Corporate Controller's Office. In addition, the Corporate Controller's Office will maintain separate retention schedules for records maintained by its units.

Retention of non-financial documents can be found in the General Retention Schedule (formerly Appendix 18).

The published retention periods in this appendix are legal or otherwise discretionary requirements. Retention beyond recommended time periods require justifiable reasons and warrant review by the Records Management Officer or designee. All documents must be maintained in such a manner so as to provide ease of access for review, and to provide a suitable audit trail for all transactions. Upon expiration of a stated period of time, the referenced document must be discarded and/or destroyed, unless permission granted by Records Management Officer or designee to retain the records. Archival records created more than 20 years prior to the current date must be reviewed before destruction. The University Archivist should be contacted before discarding any document which may be of permanent or historical value to the University (see definition of archival records in Policy AD35).

PLEASE NOTE: Transactions and records related to sponsored awards generally have longer retention periods, and those rules must be followed over other retention guidelines provided for in this document.

To safeguard the privacy of individuals, documents that contain salary information, personally identifiable information (PII), or student records must also be shredded. See Policy AD53 - Privacy Policy and AD22 - Health Insurance Portability and Accountability Act (HIPAA) for additional information regarding privacy and the protection of an individual's personal information. For documents that must be shredded, departments may arrange for Blue Bag service by contacting the Blue/White Shredding Program of the Office of Physical Plant. Exceptions to this practice are as follows:

  • Documents subject to a Legal Hold (see AD35, Legal Hold). A legal hold will remain in effect until it is released, in writing, by the Office of General Counsel.
  • If an account to which the transaction/document has posted is under audit or review, either internally or externally, the retention period extends until released by the Corporate Controller's Office. The Financial Officer will be notified regarding any accounts which are under audit; the Financial Office will be responsible for contacting the department.

When requirements for long-term retention of records overlap, the responsible office should retain records for the maximum period needed to meet legal and audit requirements and to comply with Policy AD35. In special cases retention times may be extended by request of the central offices. In such a situation the affected will be notified in writing or it will be noted in the retention schedule under the AUDIT HOLD column (earliest FY for which documents must be held).

When a hold is placed, the hold pertains to the identified fiscal year and includes all subsequent fiscal years until the hold is released.

RESPONSIBILITY

a. Online Transactions (Centrally Maintained)

When the source documentation for a transaction is online, the central administrative office responsible for maintaining the online application is responsible for retaining the online transaction record. This includes transactions in IBIS, ERS, eBuy, and the DocFinity Imaging System.

b. Paper Documents

When the source documentation for a transaction is paper, the office that receives the original document is responsible for retaining it. The submitting department is responsible for retaining the support until the transaction has posted to IBIS or other system. Originating departments have the responsibility to destroy any paper backup once central administration has successfully processed the reimbursement request, has a copy of the scanned supporting documentation and the transaction has been fully processed through the central system.

Department may scan paper documents, such as purchasing card support forms, into approved scanning systems (such as DocFinity) and the paper document destroyed, but the retention period still applies to the scanned document. An approved scanning system is one which has been vetted and approved by AIS Imaging Services as meeting all requirements for scanned documents, including appropriate indexing as well as security and access by central offices as needed for audit purposes. AIS Imaging Services also will manage the purging of images per the retention schedules.

Per FAR 4.703(c)(3) a copy of the original document must be retained for one year past the date it was scanned to allow time for validation of the imaging systems. This applies to all local imaging systems used for financial documents, such as Purchasing Card support forms. Therefore, documentation which originated in paper format, if scanned, must be maintained for one year before the paper document can be destroyed. This does not apply to ERS or eBuy documentation.

GENERAL RETENTION TIMES

a. Minimum Paper and Electronic Record Retention Times

Specific rules: There are specific retention times required for certain documents which are maintained by the Department. These are detailed in the schedules below. In some cases, there will be notations which indicate a fiscal year back to which records must be maintained - these years are set based on audit requirements for indirect and fringe cost calculations, using general fund financial records, by the Defense Contract Audit Agency (DCAA). Until these audits are complete, general fund records must be maintained.

General rules:

Tax-Exempt Debt Related Records: Life of the bond issue, plus the life of any issue that refunds the issue, plus six years. Records related to tax-exempt debt include but are not limited to documentation of the use of the debt proceeds (project costs), how debt financed property is used, relevant sponsored research contracts and grants in facilities financed with tax-exempt debt, relevant third party leases of space, etc.

Direct Charges and Revenues to Contracts and Grants: Per OMB Uniform Guidance 2CFR Part 200 - three years following the contract end date (date of submission of final expenditure report). This may be extended if the contract/agreement is under audit or if circumstances related to tax-exempt financing require it (see Tax-Exempt Debt Related Records above).

Cost Sharing: Any cost sharing records, including those on general funds, must be maintained for the same length of time as the direct charges to the award. This supersedes any general fund retention limits listed in the schedules below.

NOTE: Retention is based on the end date of the award, not a particular fund established under an agreement. Units who are managing part of an agreement must be aware of the agreement dates and must maintain records based on the agreement end date, not on the end date of their particular fund. In IBIS, the agreement end date will be the close-out date for the agreement.

Business Transaction Records (not contract or grant-related): Current Year + 2 years - although general fund transactions may need to be held longer for audit purposes. Endowment and gift accounts follow the same retention as general funds.

Taxable Income (Cash receipt information and billings, and all documents for activities considered unrelated business income). Four years following the end of the fiscal year. Longer retention times apply to certain documents retained by central offices.

b. 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. For example, when the transaction is complete and the transaction has posted as an actual in IBIS. Departments should not maintain documentation held by central offices more than one month after the transaction, unless for some reason the transaction has not yet posted.

RECORD CATEGORIES:

ACCOUNTS PAYABLE

Acounts Payable Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Back-Up for IBIS FORMS, specifically SRFC - forwarded to Accounting Operations, such as:
  • Group Meal/ Group Meeting Support Form
  • Refund Request Form
  • Request for Cash Advance
  • Request for Travel Advance
  • Vendor Invoices
Central - DocFinity Per DocFinity Retention Guidelines From 2011-2012 fiscal year to/including the current fiscal year
Back-Up for SRFC, held in Department Department Current fiscal year + 2 years From 2011-2012 fiscal year to/including the current fiscal year
IBIS FORMS - SRFC, JVDP, JVCN Central - IBIS Per IBIS Retention Guidelines  
Non-Office Telecommunication Agreements (NTUA) (Obsolete, 02-12-16)
Cellular Usage Agreements (CUA) (After 02-12-16)
Department Current active agreement + prior agreement. Ended agreements should be held for two years after end date.  
Special Request for Check PAPER
Only used for wire transfers/foreign drafts
Central - DocFinity Per DocFinity Retention Guidelines  
Telephone bills or other invoices not imaged centrally Department Current fiscal year + 2 years From 2011-2012 fiscal year to/including the current fiscal year

NOTE: Documents maintained in DocFinity by Accounting Operations can be viewed by Finance Office personnel.

ACCOUNTS RECEIVABLE, INCLUDING RATES AND FEES

Accounts Receivable Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
AD15 Fee Approvals for Research Service Centers Department Current fiscal year + 7 prior years of rate history From 2008-2009 fiscal year to/including the current fiscal year
AD15 Fee Approvals - General Department Current fiscal year + 3 prior years of rate history  
Central Accounts Receivable Program (CARP) - Data entered into system Central - CARP Indefinite  
Central Accounts Receivable Program (CARP) - Local documentation not entered into CARP Department 3 years after invoice paid  
Facility Usage Invoices Department Current fiscal year + 2 prior years, after closed or written-off. Open invoices should be retained.  
Other Departmental Invoices Department Current fiscal year + 2 prior years, after closed or written-off. Open invoices should be retained.  
Pre-Numbered Receipt Books (completed) Department Current fiscal year + 2 prior years  
Report of Cash Receipts - Paper and Back-Up Department Current fiscal year + 2 prior years  

BUDGET RECORDS *

Budget Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Budget Amendments Central - IBIS Per IBIS Retention Guidelines  
General Salary Increase Records Central - IBIS or EDDs Per IBIS and EDDs Retention Guidelines  
Initial Operating Budget Central - IBIS Per IBIS Retention Guidelines  

* No paper copies should be maintained.

CONTRACTS

The statute of limitations for breach of contract in the Commonwealth of Pennsylvania is 4 years; therefore Penn State has set this as the minimum retention period for all contracts, including leases.

NOTE: Risk Management and the Assistant Treasurer do not maintain copies of executed agreements. The contracting department is responsible for maintaining the contracts in their files as noted below. Scanned copies may be kept, but should be accessible by others in the department if needed (on department network).

Research Awards through the Office of Sponsored Programs are maintained centrally through OSP. See Grant and Contract Records section above.

Agreements and contracts processed as part of a Purchase Order or signed by Purchasing are maintained centrally through Purchasing. See Purchasing section below.

Contracts Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Amendments and Addendums (Non-Sponsored Awards) Department Same retention as original agreement  
Electronic or Click-Through On-line Agreements - including one-time delegation emails received See FNG02 Limited Delegation of Contract Approvals - Electronic Agreements Department 4 years after end of agreement  
Facility Use Agreements, including Banquet Event Orders (BEO) Department 4 years after end date of event  
Leases - Equipment, Vehicle (does not include short-term vehicle rental contracts while on travel status) Department 4 years after termination of lease  
Leases - Real Estate Central - Real Estate OPP 4 years after termination, then archived  
Master Entertainment Agreements Department 4 years after end date of event  
Non-Disclosure Agreement (NDA) Department 4 years following the end date of the obligation to keep information confidential  
University Scholar Agreements Department Back-Up with SRFC for central scanning, or maintain in department for current + 4 years.  
All Other Contracts not listed above (Non-Sponsored Awards) Department 4 years after end date of event or end of contract  

GRANT AND CONTRACT RECORDS (SPONSORED AWARDS)

In accordance with the OMB Uniform Guidance 2CFR Part 200, financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of three years from the date of submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial reports, as authorized by the Federal awarding agency; except if any litigation, claim, or audit is started before the expiration of the three year period, the records shall be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken (units must check with Research Accounting for this determination).

In IBIS, the end date of the agreement is the CONTRACT END DATE, which can be found for a particular account by using ICNA - Contract Information Inquiry or IACT - Inquiry on Account. Do not use the Account End Date, as this is the date the account number closes, not the agreement itself.

It is highly recommended that separate contract and grant files be maintained for all sponsored awards to support all transactions and actions on a contract or grant which is not maintained in a centrally maintained system (IBIS, eBuy, ERS, SIMS, DocFinity, etc).

SIMS, which is maintained by the Office of Sponsored Programs, is the official record of contractual documents for the University. If a document is in SIMS, it does not need to be maintained by the department. SIMS retention is managed through OSP.

Grants and Contract Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
30 Day Memos (Late Payroll transfer documentation) Finance Office 3 years AFTER the end date of the agreement.  
Annual Effort Certification (Sponsored Awards) Finance Office 10 years  
Cost Accounting Justification Administrative /Clerical Costs Finance Office 3 years AFTER the end date of the agreement.  
Cost Accounting Justification Non-Personnel Costs Finance Office 3 years AFTER the end date of the agreement.  
Cost Accounting Justification Non-Personnel Costs Checklist Form Finance Office 3 years AFTER the end date of the agreement.  
Paper Records not maintained centrally Department 3 years AFTER the end date of the agreement  
Salary Assignment Sheets (back-up for Pay and Effort)Recommend filing by person Finance Office 10 years  

MERCHANT MANAGEMENT / CASH

All supporting documents for cash deposits - register slips, deposit tickets, etc should be held for current + 2 years.

Merchant Management/Cash Records Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Bank validated copies of deposit tickets Department Current fiscal year + 2 years  
Charge-back and Customer Disputes Department Current fiscal year + 2 years  
Daily Settlements and batches from Swipe Credit Card Terminals Department Current fiscal year + 2 years  
Payment Card Industry - Data Security Standards (PCI-DSS)
Self-Assessment Questionnaires (SAQ) - (PCI-DSS) Department 3 years  
PCI-DSS quarterly scans Department 3 years  
Monthly Merchant Statements Department Current fiscal year + 3 years  
Credit Card Processing Merchant Request Central -Corporate Controller 3 years  
Credit Card Processing Terminal Request Central -Corporate Controller 3 years  
Penn State eCommerce Electronic Credit Card daily settlements and batches Central - AIS Current fiscal year + 2 years  
Penn State eCommerce Electronic Credit Card sales receipts Central - AIS Current fiscal year + 2 years  
Processor and Gateway Contract (must be approved Centrally) Central - Corporate Controller 7 years from the end of the contract  
RECRs (Electronic Commerce Report of Cash Receipts) Central - AIS Current fiscal year + 2 years  
Refunds to customers Department Current fiscal year + 2 years  
Report of Cash Receipts - Paper and Back-Up Department Current fiscal year + 2 years  
Sales Receipts from Swipe Credit Card Terminals Department Current fiscal year +2 years  
Third Party Credit Card Hardware and Software contracts Department 7 years from the end of the contract  
Transfer of Accountability - Logs and Forms 
(maintain in chronological order)
Department and Courier Current fiscal year + 2 years  

OPERATING CASH FUNDS/PETTY CASH/CHANGE FUNDS

Operating Cash Funds/Petty Cash/Change Funds Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
REQUEST FOR CASH ADVANCE: Long-Term Advances from Fund Short-Term Advances from Fund   Custodian Custodian   Until settled, then 2 years Until settled, then 2 years  
Bank Authorization Documentation, including signature cards and authorized signers Custodian Until account closed, then 2 years.  
Bank Statements Custodian Current fiscal year + 2 years  
Canceled Checks (if not imaged by banking institution) Custodian Current fiscal year + 7 years (per IRS)  
Deposit Records Custodian Current fiscal year + 2 years  
Disbursement Records Receipt for Petty Cash Expended Custodian Current fiscal year + 2 years unless scanned as back-up to SRFC in IBIS  
Monthly Reconciliations Custodian Current fiscal year + 2 years  
Travel Advance other than through SRFC Financial Officer After settlement:   Current fiscal year +2 years  

PAY AND EFFORT

These are retention for those transactions which are NOT direct charges to grants and contract. See Grant and Contract Records for those retention periods.

Pay and Effort Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Appointment Records for Employees (other than IBIS) Department Per HR Guidelines  
Appointment Records for Graduate Assistants (other than IBIS) Department Seven years after end of appointment  
Cross-Foot Error Messages - EDDS reports Central - EDDS Current Fiscal Year + 3 prior years  
Effort Certification (General Funds) Finance Office Current Fiscal Year + 3 prior years
From 2011-2012 fiscal year to/including the current fiscal year
Pay and Effort Forms (PYTR) Central - IBIS Per IBIS Retention Guidelines  
Payroll Vouchers Central - EDDS Current Fiscal Year + 3 prior years From 2011-2012 fiscal year to/including the current fiscal year
Salary Assignment Sheets Finance Office Current Fiscal Year + 3 prior years From 2011-2012 fiscal year to/including the current fiscal year

PAYROLL

Payroll Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Annual Election Forms (i.e. United Way) Central 7 years  
I9 - Wage and Graduate Assistants Department See HR Retention Schedules  
IBIS Forms: PADJ; SUPP Central - IBIS Per IBIS Retention Guidelines  
Permanent Election Forms (W-4, W-4E, Direct Deposit) unless amended Central 7 years after date of final pay  
Wage payroll time slips or time clock cards. Department 3 years AFTER the end date of the agreement if posted to contract or grant; otherwise current fiscal year + 1 prior year.  

PROPERTY

Property Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Capital Equipment and Property Inventory Central - Property Inventory Perpetual  
Federally-Funded Capital Equipment Pre-Acquisition Screening Certification and related Capital Equipment Shared-Use Agreement (Successful searches) Department - both Borrowing and Lending 1 year after termination of Shared-Used Agreement  
Request for Authorization to Use University Tangible Assets at a Non-University Location Department While equipment held; then current + one fiscal year after return  
Special Property Audits Assigned Property Administrator Current Fiscal Year + 7 prior years  
Tangible Property Records - Under Commonwealth of PA Agreement ($1.00 - $4,999.99) Department Current Fiscal Year + 3 prior years  

PURCHASING CARD

Purchasing Card Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Cardholder Agreement Central - ABS Digital Record - Indefinitely while cardholder active + 2 years after no longer hold card  
IBIS FORMS - APCA, UPCA Central - IBIS Digital Record - indefinitely while cardholder active + 2 years after no longer hold card  
P-Card Support Forms Documentation/Receipts Posted to Contracts and Grants Department 3 years AFTER the end date of the agreement.  
Posted to Other Accounts, including general Department Current Fiscal Year+ 2 prior years
From 2011-2012 fiscal year to/including the current fiscal year
Purchasing Card Statements Cardholders Current statement, plus prior 12 months If cardholder leaves University employment, statements should not be retained.  
Reconciler Delegation Form Finance Office 2 years after no longer serve as reconciler  

PURCHASING (NON-PCARD)

Purchasing (Non-PCARD) Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Federally-Funded Capital Equipment Pre-Acquisition Screening Certification (Accompanies related purchase order; applies to unsuccessful searches, or searches that were successful, but not available for shared-use) Central - eBuy Current fiscal year + 7 years  
Limited Order Department 3 years AFTER the end date of the agreement if posted to contract or grant; otherwise current fiscal year + 3 prior years.  
Purchase Orders and supporting documentation, invoices, credits, PO Change forms, Receiving Reports (For contracts related to POs, see contracts section) Central - eBuy Current fiscal year + 7 years  
Request for Quote, Request for Information, Request for Proposal and Supplier Responses Central - eBuy Current fiscal year + 7 years  

ROLE MANAGEMENT

Role Management Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
ADBA - Add Direct Bill Authorization Central - digital 7 years  
Designated/Delegated/Proxy Authorization Cards (not required if WebRAT and Workflow used to document authorizations) Finance Office While active +2 years from end of authorization  
IBIS Approval Path Change Reports Central - EDDS 7 years  
ROLE Workflow Forms Central - digital 7 years  
UDBA - Update Direct Bill Authorization Central - digital 7 years  
WebRAT Role Updates Central - digital 7 years  

STUDENTS ACCOUNTS RECEIVABLE

See "Student Records" Section of the General Retention Schedule

Students Accounts Receivable Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Internal Scholarships and Endowed Scholarships Department 3 years after award disbursed  
Student account records, receipts, aid award letters, etc. not available in ISIS Finance Office Until student account closed, then 2 years  

TRANSPORTATION SERVICES

Transportatio Services Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Appeal of Parking Violations Transportation Services Current fiscal year + 3 years  
Fleet Direct Billing Records Central - ABS (VAUX) Current fiscal year + 3 years  
Long-Term Vehicle Assignment Request Department/Finance Office Current fiscal year + 2 years  
Long-Term Vehicle Usage Log Department Current fiscal year + 5 years  
Parking Violations Transportation Services Current fiscal year + 3 years  
Reservation and Authorization for use of University Vehicle Central - ABS Current fiscal year + 3  

 

TRAVEL AND GROUP MEALS

Travel and Group Means Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Employee Travel Form/Worksheet for the ERS System Department Only retain until report paid/settled  
ERS Travel Reports, including all imaged receipts and documentation *
Original receipts for foreign travel should be submitted to Accounting Operations for VAT Reclamation
Central - ERS Current + 7 years  
Hospitality Services Inter-Office Charge Slip Department Current fiscal year +1 year  
Non-Employee Travel Reimbursement Form Department Only retain until report paid/settled  
One Day Travel - Meal Reimbursement Report Department Only retain until report paid/settled  
Request for Travel Exception or email approval of exceptions Finance Office Approved form or email should be scanned into ERS documentation; otherwise current + 7 years  
Travel Advance other than through SRFC Financial Officer After settlement:   Current fiscal year +2 years  
Travel Itinerary and Per Diem Computation Worksheet Department Only retain until report paid/settled  

OTHER

Other Records Retention
FILE DESCRIPTION RESPONSIBLE RETENTION PERIOD AUDIT HOLD
Telephone logs (records of incoming and outgoing calls) Department Current fiscal year + 1 year  
Telephone Service Requests (Paper) Department Current fiscal year + 1 year  
WTSR - Workflow Telephone Service Request Central - digital Current fiscal year + 1 year  

 

(6-22-17)