RECORDS

Retain records

Under the legal terms of awards to the University, auditors have the right of access to all official University records associated with a project. The University is obligated to make such records readily available for examination.

Because auditors may visit departments to review supporting documentation and interview personnel who have certified effort on projects, departments must maintain complete records. In addition, individuals who have signed Effort Certification Statements must be able to confirm that the effort as certified was accurate at the time it was signed.

Contact the Records and Information Management Office at (612) 625-3497 for further information.

PI must retain:

• Scientific records and data
• Animal and human subjects materials:
  • Initial submission to the Committee (copy of original signed application form, copy of original consent form, copy of original protocol).
  • Written (original) response from the Committee following the initial review.
  • Copy of the response to stipulations/additional information requested by the Committee, including cover letters, etc.
  • Notice of Final Approval.
  • Copies of all correspondence sent to the Committee requesting consideration of changes or reporting adverse events.
  • Original responses from the Committee to all requests for changes, etc.
  • Original notice of renewal of approval and certification, where applicable.

RSPP keeps copies of materials sent to investigators, but the investigator must keep any originals, and both the investigator's and RSPP's records should be the same.

The department must retain:

• Financial and personnel records
• For a detailed list, see the Record Retention Schedule at http://www.ogc1.umn.edu/stellent/groups/public/documents/webasset/da_031145.pdf.

SPA will retain:

• Rejected proposals for one year after the fiscal year in which they were rejected.
• Pending proposals for two years after the fiscal year in which they were submitted.
• Awarded proposals and award files for three years after project closeout.

AUDIT

What things are usually audited?

• cost transfers: to an auditor, a cost transfer means that something happened that should not have occurred. They will look at the transfer documents to see if they are appropriate and timely

• general purpose equipment purchased at the end of the project: auditors question whether the equipment was needed or just purchased to use up funds. They will select a number of equipment items purchased on the project, review the transaction date in comparison with the grant end date, and discuss with the PIs all those purchases within 60 days of the end date.

Types of audits:

• An audit that is part of the annual general financial audit of University financial statements.

• A sponsored-project specific audit of financial systems and expenditures in accordance with OMB Circular A-133. The University is required to provide these audits to the federal government. Sponsored Financial Reporting and SPA coordinate these audits.

• The sponsor can request that an individual award be audited. These audits can be financial or programmatic.

• All University accounts are subject to inspection and audit by the University's Department of Audits.

Auditors usually review these records:

• central records from offices such as SPA, Sponsored Financial Reporting, Payroll, and Academic Affairs,
• departmental files, and

• laboratory records.

The sponsor or auditors should contact SFR before beginning an audit. SFR will then notify the department. If the PI or department is contacted by the auditor directly, refer them to SFR before scheduling any visits or releasing any documents.

At the conclusion of audits, auditors will typically conduct a meeting to review findings and tentative conclusions.

For external audits, the University has an opportunity at this meeting, called an exit conference, to comment on the proposed findings and to present additional information. All exit conferences are coordinated by SFR. Other University representatives will be requested to attend such briefings as deemed necessary by the anticipated significance and nature of the audit recommendations. Following the exit conference, the SFR coordinates the University's response to audit findings and recommendations. The PI or department may be called upon to provide additional information or documentation in order to prepare the institution's response.

Financial liability for audit disallowances, other than for those which result from deficiencies in the University's policies and procedures, rests with the department, school or center having primary responsibility for the project on which costs are questioned.