Forms, Policies & Procedures

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Procedure

Record Retention Procedure

  1. SCOPE OF PROCEDURE
    This procedure outlines record retention responsibilities of Principal Investigators (PIs), Department/College Administrators, Research Office Pre-Award and Post-Award Teams, and other responsible parties involved in the administration of sponsored programs.

    All University faculty and staff who are responsible for administering externally sponsored grants and contracts should be familiar with this procedure.

  2. DEFINITIONS
    1. Sponsor or Sponsoring Agency – An external entity responsible for providing project funding if UD’s proposal is accepted and an official award agreement is subsequently executed.
    2. Record – Documentation pertinent to the programmatic and financial management of an externally-sponsored award.
    3. Record Retention Period – The required amount of time for which records must be maintained for a particular externally-sponsored award.
  3. PROCEDURE STATEMENT
    The purpose of the Research Office Record Retention Procedure is to ensure record retention and destruction for sponsored programs is conducted in accordance with UD, federal, and sponsor requirements. This mitigates potential UD financial and compliance risk by:

    • Ensuring UD’s ability to provide adequate support documentation to internal parties and authorized external entities when appropriate, especially during audit activities.
    • Establishing a limited time period for record retention, thereby mitigating UD exposure to late audit requests or potential information breaches by unauthorized external entities.

    It is the procedure of the University of Delaware (UD) to retain and dispose of documentation associated with sponsored programs in accordance with applicable sponsor requirements, as well as federal regulations per Uniform Guidance including:

    • §200.333 Retention Requirements for Records
    • §200.334 Requests for Transfer of Records
    • §200.335 Methods for Collection, Transmission, and Storage of Information
    • §200.336 Access to Records
  4. STANDARDS AND PROCEDURES
    1. PIs, Department/College Administrators, and Research Office employees are responsible for retaining award records for sponsored programs. This includes financial records, supporting documents, statistical records, and other UD records pertinent to the award. Records must be maintained for active awards and archived for expired awards based upon standards outlined in this procedure.
    2. UD is obligated to provide authorized external parties (such as sponsors or auditors) with access to award records and documentation for the purpose of audits, examinations, excerpts, and transcripts. This includes timely and reasonable access to UD personnel for the purpose of interview and discussion related to such documents. Inability of UD to provide necessary records to sponsors or other authorized parties upon request may result in adverse financial or compliance impacts, such as potential disallowance of unsupported project costs
    3. It is the preference of UD (and federal sponsors) that award records be maintained in electronic rather than paper formats when practicable. Copies of original records, either in paper or electronic format, may be substituted for original records, so long as they remain unaltered and readable.
    4. D. PIs, Department/College Administrators, and Research Office employees are responsible for maintaining primary support documentation for sponsored programs in local Shared Drives as well as other electronic systems. The table below outlines common award records and storage methods maintained under this procedure:
    5. STORAGE METHODS FOR AWARD DOCUMENTATION

      Document Type

      Storage Method

      Proposal Documentation
      submitted to the sponsor such as budgets, budget justifications, scope of work, subaward documents, abstracts, etc.

      • PeopleSoft Attachments
      • Cayuse
      • Webforms (Proposal Approvals)
      • Local Shared Drives
      • Sponsor Web-Based Portals (ex: Proposal Submissions)

      Official Award Notices
      and contractual documents issued to UD from the sponsor.

      • PeopleSoft Attachments
      • Local Shared Drives
      • Sponsor Web-Based Portals (ex: Grants Management)

      Programmatic Support Documents
      pertinent to the award administration including detailed budgets, institutional approvals, and important correspondence.

      • PeopleSoft Attachments
      • Local Shared Drives
      • Webforms (ex: Proposal Approvals, Budget Adjustments)

      Financial Reports and Invoices
      submitted to the sponsor to report expenditures and/or request payment.

      • PeopleSoft Attachments
      • Local Shared Drives
      • Sponsor Web-Based Portals (ex: Federal Financial Reports, Payment Management Systems)

      Financial Backup
      supporting award expenditures and reporting such as account reconciliations, receipts, cost transfer forms, and expense approvals.

      • PeopleSoft Attachments
      • Local Shared Drives
      • Webforms (ex: Automated Closeout Reports, Journal Vouchers, Cost Transfers, Purchase Orders)
      • Concur/Works (ex: Expense Approvals)
      • Effort Reporting System

      Technical Reports and Deliverables
      submitted to the sponsor to report research program outcomes.

      • Local Shared Drives
      • Sponsor Web-Based Portals (ex: Technical Reports)
      • Webforms (ex: Automated Closeout Reports)

      Compliance Protocols
      and approvals related to sponsored research programs (e.g. human and animal subjects).

      • IRBNet (ex: IRB/IACUC Protocols)
      • Local Shared Drives
    6. Records should be disposed of upon expiration of the required record retention period for an award in order to limit excess audit risk and potential information breaches to UD. Unless a longer duration is required by the sponsor, or per other exceptions outlined in the table below, it is UD’s procedure to retain records for four years after an award’s end date. Destruction of such records should follow UD protocols to ensure they are no longer needed for reference.
    7. EXCEPTIONS TO THE STANDARD FOUR-YEAR RECORD RETENTION PERIOD

      Exception Scenario

      Retention Period

      Exception Description

      Sponsor or Award Specific Retention Period

      Per Sponsor Requirements

      Retention requirements may vary depending on award guidelines, terms, and conditions set by the sponsor. These may be stricter than the standard four-year retention period and will be evaluated on a case by case basis. PIs and their Department/College Administrators should contact the Research Office with any questions regarding the specific record retention requirements applicable to their award.

      Litigation, Claim, or Audit

      Until Resolution

      If any litigation, claim, or audit is started before the expiration of the four-year period, the records shall be retained until all litigation, claims or audit findings involving the records have been resolved and final action has been taken.

      Written Notice for Extension

      Per Written Notice

      UD will comply with any official written notice by a Federal sponsor, cognizant agency for audit, oversight agency for audit, cognizant agency for indirect costs, or pass-through entity to extend the record retention period.

      Final Financial Report Submitted ≥1 Year After the Award End Date

      3 Years After Final Financial Report Submissions

      If under rare circumstances, the final financial report was submitted or revised ≥1 year past the award’s expiration date, the award will be retained for 3 years after the final financial report was submitted to the sponsor.

      Real Property and Equipment

      3 Years After Final Disposition

      Records for real property and equipment acquired with Federal funds must be retained for three years after final disposition.

      Records Transferred

      Not Applicable to UD

      When records are transferred to or maintained by a Federal sponsor or pass-through entity, the record retention requirement is not applicable to UD.

      Program Income Transactions

      3 Years After the Applicable Fiscal Year End Date

      In some cases, UD must report program income after the period of performance. When this requirement exists, the retention period for the records pertaining to the earning of the program income starts from the end of UD’s fiscal year in which the program income is earned..

      Facilities and Administrative Cost Rate Proposals

      3 Years After the Date of Proposal Submission, or 3 Years After the Applicable Fiscal Year End Date

      For facilities and administrative cost rate computations or proposals, cost allocation plans, and any similar accounting computations of the rate at which a particular group of costs is chargeable (such as computer usage chargeback rates or composite fringe benefit rates):

      • If submitted for negotiation, a three-year retention period for supporting records starts from the date of such submission.
      • If not submitted for negotiation, a three-year retention period starts from the end of the fiscal year covered.

Procedure Details:

OWNER: UD Research Office

RESPONSIBLE OFFICE: UD Research Office

ORIGINATION DATE: February 7, 2020

Procedure Source Email https://research.udel.edu/forms-policies-procedures/?entry=51660



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Phone: (302) 831-2792

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Newark, DE 19716
Phone: (302) 831-2136
Fax: (302) 831-2828
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