Financial Records Retention Schedule

Policy Steward: Office of the Corporate Controller

Table of Contents:

• INTRODUCTION
• PURPOSE OF FINANCIAL RECORDS RETENTION
• RESPONSIBILITY & SYSTEM OF RECORD
• FINANCIAL RECORDS REQUIREMENTS
• RECORD CATEGORIES
  • Accounts Payable
  • Accounts Receivable, Including Rates and Fees
  • Budget Records
  • Contracts
  • Grant and Contract Records (Sponsored Awards)
  • Merchant Management Cash
  • Operating Cash Funds/Petty Cash/Change Funds
  • Pay and Effort
  • Payroll
  • Property
  • Purchasing Card
  • Purchasing (Non-Pcard)
  • Role Management
  • Student Accounts Receivable
  • Transportation Services
• Travel and Group Meals
• Other

INRODUCTION

University Records must be retained and managed in accordance with Policy AD35 University Archives and Records Management and the University’s Records Retention Schedules that have been approved by the Records Management Advisory Committee (RMAC), the Office of General Counsel, and Vice President for Administration. These Records Retention Schedules are derived from - or based upon - federal, state, and local statutes or regulations (i.e.; Federal Acquisition Regulations, the OMB Uniform Guidance, Internal Revenue Service, and other regulations governing the auditability and retention of financial records), University Policy, industry standards, and business needs. All University Records must be maintained in such a manner to provide ease of access, establish a suitable audit trail for all transactions, and to be reviewed prior to disposition.

University Records and Transitory/Disposable Records are defined below. See Policy AD35, Definition of Terms for additional information.

• University Records - Information that documents a transaction or regularly conducted activity of the University and that is created, received or retained pursuant to law, University policy, or in connection with a transaction, business, or activity of the University.  The term includes documents, papers, letters, books, drawings, maps, plans, photographs, tapes, film or sound recordings, microforms, digital or analog files, information stored or maintained electronically, and data- or image-processed documents.

• Transitory/Disposable Records - University Records that have temporary value and, as a result, may be destroyed after they are no longer needed. In no event shall be retained longer than the official copy of the University Records as delineated on the Records Retention Schedule. Examples include photocopies of official University Records, a printed copy of a University Record that is held by the Responsible Party or within a System of Record, a spreadsheet containing data that is exported from an officially resides in another systems, personal emails not related to University business or activity, and/or mass emails or communications.

Upon completion of the retention period, University Records must be disposed of via secure destruction or transfer to University Archives, unless an exception to the disposition process set forth below applies. In many cases, retention periods and disposition methods may be generally determined by comparing the type of record (i.e., reports, correspondence, etc.) to similar records series with known retention periods listed on the Records Retention Schedule.  If the disposition method for University Records states “Review by Archives” on the Records Retention Schedule, the Unit responsible for those records should consult the University Archivist for a final determination of disposition. For University Records that must be securely destroyed, units may arrange for shredding services by either contacting the Blue/White Shredding Program or the Inactive Records Center (IRC).

Exceptions to the disposition process are as follows:

• University Records subject to a Legal Hold (see Policy AD35, Legal Hold). A legal hold will remain in effect until it is released in writing by the Office of General Counsel.
• University Records under audit or review, either internally or externally. An audit hold will remain in effect until the hold is released by the Office of Corporate Controller. The Financial Officer will be notified regarding any accounts that are under audit hold; the Financial Officer will be responsible for contacting the Unit associated with the records.

To safeguard the privacy of individuals, records that contain Personally Identifiable Information (PII), as defined in University Policy, AD53 Privacy Policy, or student records, as defined in University Policy, AD11 Confidentiality of Student Records, must be securely destroyed beyond recovery. For additional information regarding privacy and the protection of an individual's personal information, see Policy AD53.

Unit specific retention schedules for individual offices that are developed by the Records Management Program should be utilized in conjunction with this schedule to identify records unique to that Unit. Retention periods for University Records not specifically listed on the Financial Records Retention Schedule (below), on Unit Specific Records Retention Schedule, GURU Procedures and Forms, or in the General Records Retention Schedule may be determined by contacting the Records Management Program.  

PURPOSE OF FINANCIAL RECORDS RETENTION

This Financial Records Retention Schedule provides the requirements for the length of time various financial records must be retained by the Office of the Corportate Controller or individual Units of the University, including finance or business offices. Retention Schedules for central financial systems, such as IBIS, ERS and eBuy, will be defined by the Office of the Corporate Controller in coordination with the Records Management Program. In addition, the Office of the Corporate Controller will maintain separate retention schedules for records maintained by its units.

When requirements for long-term retention of records overlap, the responsible office should retain records for the maximum retention period needed to meet legal and audit requirements and to comply with Policy AD35. In special cases retention periods 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. See Audit Holds listed below.

RESPONSIBILITY & SYSTEM OF RECORD

1. Electronic Transactions and Systems (Centrally Maintained)

When the records resulting from a transaction is electronic and in a system of record, the office responsible for overseeing the system is responsible for retaining the official electronic records. This includes transactions in IBIS, ERS, eBuy, and the DocFinity Imaging System. The retention schedule below lists which office or system is responsible for retaining the official records in the "Responsible Party / System of Record" column below.

2. Paper Records (Locally Maintained or Retained after Scanning)

When the records resulting from a transaction are paper, the office that receives the original record is responsible for retaining it. The submitting department is responsible for retaining the support until the transaction has posted to IBIS or other systems of record. 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.

Departments may scan paper records, such as purchasing card support forms, into approved systems (such as DocFinity) and then securely destroy the paper record, but the retention period still applies to the scanned record. An approved scanning process and system of record is one which has been vetted and approved by AIS Imaging Services, as meeting all requirements for retaining electronic records, 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 records according to the retention schedules.

Per FAR 4.703(c)(3) a copy of the original record must be retained for one year past the date it was scanned to allow time for validation of the electronic records in the system. This applies to all local electronic record keeping systems used for financial records, such as Purchasing Card support forms. Therefore, records that originated in paper format and are then scanned must be retained for one year before the paper record can be destroyed. This does not apply to ERS or eBuy records.

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.

FINANCIAL RECORDS REQUIREMENTS

Audit Holds: There are specific audit holds required for certain financial records which are maintained by the University, including both the Office of the Corporate Controller and the Units. The current Audit Holds will define the earliest date from which records are required to be maintained up until the current fiscal year. That information is listed “Audit Hold” column below and 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.

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 records for activities considered unrelated business income). Four years following the end of the fiscal year. Longer retention times apply to certain records retained by central offices.

RECORD CATEGORIES:

ACCOUNTS PAYABLE

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

ACCOUNTS RECEIVABLE, INCLUDING RATES AND FEES

BUDGET RECORDS *

* 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.

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

MERCHANT MANAGEMENT / CASH

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

OPERATING CASH FUNDS/PETTY CASH/CHANGE FUNDS

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.

PAYROLL

PROPERTY

PURCHASING CARD

PURCHASING (NON-PCARD)

ROLE MANAGEMENT

STUDENTS ACCOUNTS RECEIVABLE

For non financial records related, see "Student Records" Section of the General Records Retention Schedule

TRANSPORTATION SERVICES

TRAVEL AND GROUP MEALS

OTHER

(11-06-2019)