GAP 200.240, Retention Period of Accounting Documents

I.   Policy Statement

II.  General Responsibility

III. General Guidelines

IV. Document Retention Schedule - Controller's Division

V.  Document Retention Schedule - Financial Services Departments

VI. Document Retention Schedule - Other Departments

 

 

I. Policy Statement

Duke University has put into place guidelines in order to standardize retention of accounting documents, designating specific retention periods, as well as official methods and locations for storage.  

Minimum retention requirements for accounting documents are established as part of an effective internal control program to ensure the University can provide the documents requested by any federal, state and local agencies within the Statutes of Limitations.  Other benefits include ensuring preservation of historical accounting documents, optimizing the use of space, minimizing the cost of document retention, and ensuring the proper destruction of outdated and useless documents.

All University accounting documents should be retained in the manner outlined in this GAP. Official accounting documents of the University should be destroyed in accordance with GAP 200.250, Destruction of Accounting Documents. 

When referencing the document retention schedule, keep these factors in mind:

• Retention periods are classified by broad categories of documents for the departments of the Controller’s Division (see section IV) and by department for all other relevant accounting documents generated by Financial Services (see section V). If you are unsure as to what category a particular accounting document belongs, please e-mail, AcctgSysAdmin@duke.edu
• Retention periods for departments outside of the Controllers Division and Financial Services should follow the general guidelines outlined in section VI. If you are unsure as to what category a particular accounting document belongs, please e-mail, AcctgSysAdmin@duke.edu
• If you are aware of an audit of Duke’s financial records being conducted by a federal or state agency, do not destroy any accounting documents that may be required for the audit until completion of the audit.
• Where documents having one retention period cannot be separated from documents having a longer retention period, both documents should be retained for the longer period.
• Duplicate copies of a document (i.e., documents that are not the original or official copy) do not need specific approval for their destruction.
• Documents in this procedure, which have retention periods of less than one year or are to be retained until superseded do not need specific approval for their destruction.

 

II. General Responsibility

Each department or unit that maintains University accounting documents is responsible for establishing document retention management practices that adhere to the policies outlined in this GAP and GAP 200.250, Destruction of Accounting Documents.

Each unit’s administrative manager or a designee must:

• implement the unit’s and/or office's document management practices;
• ensure that those practices are consistent with this policy;
• educate all other staff in adhering to these practices;
• ensure that access to confidential files is restricted; the carryover of these restrictions to University Archives should be negotiated at the time of transfer;
• destroy inactive documents that have exceeded their applicable retention periods, if they have no archival value. The University Archivist should be contacted if you have inactive documents that may be of historical value. If you question whether a document or class of documents has archival value to the University, contact the University Archivist.

On-line transactions
Administrative offices responsible for maintaining on-line applications retain the on-line transactions. Example: Administrative Services Management (ASM) has oversight of the SAP system.

Internal Billing transactions
Departments initiating the invoices retain the original documents

Microfiche
Departments responsible for the microfiche retain the original fiche.

 

III. General Guidelines

Sponsored Projects

The required duration and form of record retention of financial documents supporting externally sponsored projects depends upon the nature of the funding agreement.

Duration
For federally and non-federally sponsored grants, documents should be retained for a minimum period of three years from the date of submission of the final financial invoice/report.

For federally and non-federally sponsored contracts, documents should be retained for a minimum period of seven years from the date of submission of the final invoice. Note that federal contracts are subject to the requirements of the Federal Acquisition Regulations (FAR). Under the FAR, original records related to contracts must be maintained for a year after they are converted to an electronic format.

Exceptions to these general guidelines are:

• A sponsor or a specific award defines a retention period of a different length – sponsor requirements take precedent over the default durations listed above.
• If litigation is pending - retain documents until settled.
• Documents representing real property and equipment acquired with federal funds retain for three years after disposal.
• Documents transferred or maintained by federal awarding agency - no retention period.

Form
Under the requirements of the Uniform Guidance, financial documents may be maintained in electronic or paper formats. Acceptable forms of electronic retention include PDFs, scans, and other methods that ensure the documents are readable and reasonably safeguarded against being altered.

If the source document, such as a receipt, is an electronic record then there is no need to create and maintain paper copies. If the source document is a paper version, the project may convert it to an electronic record if the above conditions are met.

Regardless of the retention method, projects should allow vendors to supply paper copies of records. Additionally, the project must be able to provide paper copies to auditors or officials upon request.

Departments

Original documents from external sources should be maintained a minimum of 7 years with a few exceptions. Retention of departmental copies is at the discretion of the department. Departmental procedure should be established.

Administrative Departments

Original documents, files, film, and microfiche should be maintained for a minimum of 7 years with a few exceptions.

Office of the University Archivist

The University Archivist will be a resource for developing retention guidelines for documents not covered by this procedure. The University Archives is the official repository for permanent but inactive documents.

 

IV. Document Retention Schedules - Controller's Division

FINANCIAL-RELATED DOCUMENTS - CONTROLLER'S DIVISION
	Type of Document	Reponsible Department	Required Retention Period
	Account reconciliations (assets and liabilities)	Appropriate department	7 years
	Accounting reports (monthly departmental reports)	Appropriate department	7 years / 3 years
	Accounts payable invoices, check requests, and related documents	Appropriate department	7 years
	Actuarial reports (FASB plans, WC, LTD, health plans)	Appropriate department	Permanent
	Annual GAAP financial reports	Financial Reporting	Permanent
	Banking records - deposit and withdrawal records, voided and canceled checks, and other bank-related documents	Appropriate department	7 years
	Correspondence with governmental and other external regulatory parties	Appropriate department	Permanent
	Departmental policies, procedures, and other related documentation	Appropriate department	3 years
	General ledger master data	AcctgSysAdmin	1 year + CFY/Permanent
	Information / Income / Corporate Tax Returns	Corporate Tax	Permanent
	Payroll -  time cards	Payroll	7 years
	Payroll - Personnel-related documents	Appropriate department	7 years
	Payroll - record of payment and deductions	Appropriate department	7 years
	Payroll and other tax-related documents filed with federal and state authorities (W2, 941,1042s, etc.)	Appropriate department	7 years
	Personnel files - departmental copies including performance measurement documentation	Appropriate department	3 years after seperation
	SAP Journal entries and related back-up documentation	Appropriate department	7 years
	Sales / Excise / Miscellaneous tax returns and support	Corporate Tax	7 years
	Supporting documentation for Annual GAAP financial reports & interim reporting	Financial Reporting	7 years
	Supporting documentation for Information / Income / Corporate Tax Returns	Corporate Tax & Financial Reporting	7 years
	Unclaimed property filings and supporting documentation	Corporate Tax	Permanent

 

V. Document Retention Schedules – Financial Services

Budget and Analysis (University)
Bursar's Office
Employee Travel and Reimbursement
Endowment/Investment Accounting Office
Plant Accounting
Treasury Operations

 

VI. Document Retention Schedules– Other Departments

Departments
IRS and CN Department of Revenue Agreement