Purpose

To describe the minimum retention periods departments are required to retain financial documents. These policies are based on legal regulations and general business practices of Vanderbilt and are applicable to the institution as a whole.

Introduction

None

Policy

University policy requires that all departments match the monthly Report of Transactions (MD091) to supporting documentation. Specifically, each month a departmental representative should review the MD091, reconcile all transactions to the appropriate source document, certify the completion of his/her reconciliation, and file the supporting documentation (purchase orders and invoice copies, travel reports, etc.) by account number or month. CERTIFYING THE COMPLETION OF YOUR RECONCILIATION: It is important to note that the certification process varies between the Medical Center and University Central. In the Medical Center, the departmental representative is required to utilize the online signoff feature in eDog, the General Ledger Web Application. When the departmental representative signs off on his/her center for a specific report period/fiscal year, eDog records his/her VUnet ID, name, and the date of certification. In University Central, the departmental representative is required to sign and date the paper copy of the MD091. University Central departments utilizing electronic downloads may use alternative procedures to certify review of transactions. RETENTION OF RECORDS FOR UNRESTRICTED CENTERS: Departments should retain the MD091´s and supporting documentation for the current fiscal year and one complete prior fiscal year.* An exception exists when the department is the sole source for documentation, in which case the retention period is eight years. For example, departments are the sole source of support for procurement card transactions and, thus, should retain that support for eight years. Please see the following schedule for more detailed information regarding retention periods for unrestricted centers: Accounting, Procurement and Disbursements Documents Document Departmental Retention Period   Report of Transactions (MD091) - Current fiscal year and one complete prior fiscal year*   Supporting documentation:   1180 Form departmental copies - Current fiscal year and one complete prior fiscal year Check Request Form copies - Current fiscal year and one complete prior fiscal year Purchase Order; Small Purchase Order Form; Purchase Requisition Form; Capital Equipment Purchase Requisition Form copies; Vendor invoice reports - Current fiscal year and one complete prior fiscal year, but documents for the lease of fixed assets should be maintained until at least two years after the end of the lease term Travel documentation that is not support for travel expenses paid via P-card (incl. Travel Expense Reports, Travel Authorization Form, Super Saver Form, etc.) - Current fiscal year and one complete prior fiscal year, but only if the traveler´s account receivable is cleared of that trip Support for deposits to Cashier (incl. daily deposit records, validation receipts, cash register tapes, cash receipt cards, etc.); Deposit receipts from Cashier - Eight years for any original support retained only by the department - Current fiscal year and one complete prior fiscal year for any copies of support submitted with the deposit and for deposit receipts Support for Procurement Card (P-card) transactions (incl. sales receipt or invoice, packing slip that includes price, original cash register receipts, support for travel expenses paid via P-card, etc.) - Eight years since the original support is retained only by the department Support for Journal Entry Uploads -Current fiscal year and one complete prior fiscal year (for Medical Center departments) -Eight years since the original support is retained only by the department (for University Central departments) Human Resource Services (HRS) and Payroll Documents (a more complete listing is available from HR Records Management at 2-8310) Document Departmental Retention Period Timesheets 3 years Personnel Action Forms 3 years after the employee´s termination Position Management Forms 3 years after the employee´s termination Position Description Questionnaire 3 years after the employee´s termination RETENTION OF RECORDS FOR RESTRICTED CENTERS (GRANTS AND AWARDS): Departments must retain all records until three years after grant expiration or grant renewal.* Please note that this pertains to the expiration of the grant as opposed to the expiration of the cost center (since a single grant may have multiple cost centers assigned). For example, a five-year project that began in March 1999 and concluded with the final expenditure report submitted in June 2004 requires retention of all records until July 2007. "All records" applies not only to financial records but also to programmatic and statistical records, any supporting documents and all other records that are required by the terms of a grant or that may reasonably be considered pertinent to a grant. This includes justification memos, memos to the file, explanations from Principal Investigators regarding the allowability/allocability to the grant, notes made by the administrator on copies of documentation, etc. If these types of grant documents exist, they must be retained for eight years. For awards under Streamlined Non-Competing Award Procedures (SNAP), the three-year retention period is calculated from the date the Financial Status Report (FSR) for the entire competitive segment is submitted (other than those to foreign organizations and Federal institutions). If the FSR is submitted on time, the retention period is three years and three months. If the FSR is submitted after the deadline, the retention period will be longer than three years and three months. PURGING RECORDS Departments may discard listed documents after the minimum retention period. Please consider confidentiality when discarding any files containing cost, budget, or salary information. *In the Medical Center, effective February 2004, departmental representatives are no longer required to initial and retain paper copies of the MD091. Instead, the record of their review resides in eDog. However, departmental representatives should not purge all of the paper records they are currently retaining. The required retention period for the certification of the MD091 remains the same as above ( "the current fiscal year and one complete prior fiscal year" for unrestricted centers and "three years after grant expiration or grant renewal" for restricted centers). The only change is the manner in which the completion of the monthly reconciliation is documented. During this transition period, departmental representatives will meet the above-mentioned required retention period by having both paper record of their signoff on the MD091 and electronic record in eDog.

Glossary of Terms

Cross References

Policy 215

provides information on roles responsibilities of Center Fiscal Reviewers.

Related Forms

None.

Effective Date