Issuance No: A19
Issuance Date: October 2, 2007; Revised 12/6/16
Subject: Record Retention Policy
Uniform Guidance 2 CFR 200.333 indicates “financial records, supporting documents, statistical records and all other non-federal entity records pertinent to a Federal award must be retained for a period of three (3) years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.” Records and/or documents may include, but are not limited to, paper documents, e-mails, web files, text files, sound and movie files, PDF documents and all Microsoft Office or other formatted files, etc. The three (3) year retention period assumes no audit/litigation problems would require an extended retention period. If any litigation, claim or audit is started before the expiration of the original retention period, the records must be retained until all findings have been resolved and final action has been taken, or until the end of the regular three (3) year record retention period, whichever is later.
The WDB will adhere to the requirements outlined above to include all records for WIOA Title I and WDB funded programs.
Custody of Records:
To avoid duplicate record keeping, subcontractors will retain records that are required for joint use (recipients/grantees or subrecipients/subgrantees). In the event the WDB identifies a need for such records, during the prescribed period of time, the WDB will have the right to transfer those records to its custody. When the records are transferred to or maintained by the WDB, the retention requirement does not apply to the subcontractor that relinquished its records.
If any records are unintentionally disposed through acts of man or God prior to the three year period, the WDB must be notified immediately. The WDB will request approval from DWD before any records are destroyed.