Procedure Library

Record Management for Sponsored Projects

Purpose

Ensure that projects are retained and disposed of in compliance with sponsor, federal, state, and institutional requirements. 

Applicability

Principal Investigators (PIs) and department administrators responsible for managing sponsored projects.

Most sponsored projects have legally mandated retention periods - especially for financial, technical, and clinical records. These requirements must be followed to protect the University, meet federal audit standards, and comply with state law.

"Records" includes any documentary material, regardless of format (paper, electronic, or other media), created or received during the proposal, conduct, reporting, or closeout of sponsored activities.

Instructions

Managing Original Records

Electronic Original Records

• • Most sponsored project records originate in electronic systems (Peoplesoft, eProposal, etc.)
  • If electronic records cannot be altered and remain readable, paper copies do not need to be created.

Paper Original Records

• • Paper records may be digitized if:
    • The scanned copy undergoes periodic quality control checks.
    • The file is unalterable.
    • The file remains accessible throughout the retention period.

---

Record Ownership

• Central University offices maintain official records such as proposals, awards, financial transactions, and invention disclosures.
• PIs maintain scientific and programmatic records.
• Departments maintain supporting source documentation when applicable.

---

Confidentiality

Records containing personally identifiable information, proprietary data, or confidential materials must be stored in restricted-access, secure locations.

---

Access to Records

GRAMA and FOIA Requests

• All Utah Government Records Access and Management Act (GRAMA) and Freedom of Information Act (FOIA) requests must be routed to the Office of General Counsel.
• Do not respond directly to requesters.

2025-2026 GRAMA Updates

Utah's GRAMA system has undergone significant restructuring:

• The State Records Committee has been replaced by an Administrative Law Judge for appeals (SB277, 2025).
• A 2026 proposal would extend the standard response window from 10-15 business days, add penalties for intentional record destruction, and lengthen the appeal timeline. 

GRAMA/FOIA inquiries should be referred to General Counsel. 

---

Audits

If an auditor contacts you:

• Notify the Office of Research Management and Compliance

---

Retention Requirements

Technical & Programmatic Records (PI Responsibility)

• Progress and final technical reports: Retain for at least 3 years after submission to the sponsor.
• Original research data and all project records: Retain for at least 3 years after final report submission or award termination.
  • Requirement confirmed in updated federal retention rules (2 CFR 200.334).
• After the required periods, the PI may choose whether to retain or discard materials.

Clinical Studies

• Follow the clinical study agreement for specific retention periods.
• Clinical studies involving children must retain records indefinitely.
• If faculty leave the institution, clinical records must remain with the University of Utah.
• For inventions arising from a study, consult the Technology Licensing Office (TLO) before discarding any records.

Federal Awards (governed by 2 CFR 200.334)

• Retain records 3 years from submission of the final financial report.
• For awards reporting quarterly/annually, retention is 3 years from those respective reports.
• Records involved in litigation/audits must be retained until all issues are resolved.
• Additional retention rules apply for:
  • Property/equipment (3 years after disposition)
  • Program income after period of performance
  • Indirect cost proposals (period varies)

HHS Awards (NIH, HRSA, etc.)

As of Oct. 1, 2025, HHS uses:

• 2 CFR 200 (Uniform Guidance), and 
• 2 CFR 300 for HHS-specific modifications.

Departments should consult agency-specific instructions when managing HHS-sponsored projects.

Federal Contracts

For federally funded contracts, record retention is governed by the Federal Acquisition Regulation (FAR). The applicable clause is:

FAR 25.215.2 - Audit and Records - Negotiation

Under this clause:

• Records must be retained for 3 years after final payment under the contract.
• If litigation, claim, or audit is initiated before the end of the 3-year period, records must be retained until all such issues are fully resolved.

This aligns with the federal retention rules summarized for grants, but is legally separate under the FAR.

State and Local Government Awards

• Follow the award's terms and conditions.
• Recommended retention period for state/city awards (MOUs, grants, agreements): 6 years
  • For guidance on the Utah State General Retention Schedule, see University Archives and Records Management.

Other Sponsors

• Follow sponsor-specified policies.
• If no retention period is stated, follow the federal default of 3 years after final payment.

---

Destroying Records

Paper Records

• Shred any document containing personal, proprietary, or confidential information using a cross-cut shredder.

Electronic Records

• Before transferring or discarding an electronic device, electronic files must be securely erased.
• Simple deletion is not sufficient; consult IT for secure destruction methods.

 

Related Policies and Procedures

• Research Handbook > Award Management > Records Retention
• Policy 3-014: University Financial Record Retention