Record Retention Time Periods
The table below identifies responsibilities by role and type of sponsored program (SP) record. Principal investigators/program directors (PI/PDs) are the responsible party for their departmental team's records, but they can delegate many activates to team members. Research Operations (RO), the Institutional Review Board (IRB), the Institutional Animal Care and Use Committee (IACUC), and the Office of General Counsel (OGC) also have distinct responsibilities.
Review BMC's SP Record Retention Policy.
| Role | Type of Record | Retention Period |
|---|---|---|
| PI/PD | Human participation records or materials, including IRB and study participation records | Seven (7) years after termination of study, per IRB, or a longer period if required by sponsor; (3) after completion of the study; the FDA requires retention for two (2) years after marketing approval of an FDA-regulated test object, for investigators and sponsor-investigators or, for discontinued investigation, for investigators, after the investigation has been discontinued and the FDA is notified or, for sponsor-investigators, after last shipment and delivery of the study object |
| Non-human research records | Seven (7) years after the project has ended, i.e. 1) final reporting to the research sponsor, 2) final financial closeout of the sponsor’s award, 3) final publication of research results, or 4) cessation of academic or scientific activity on a specific research project, regardless of whether the results are ever published | |
| Administrative and financial records | Three (3) years from the date of the submission of the final expenditure report or for awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, as authorized by the federal awarding agency | |
| RO | Awarded grant and contract applications, award notices, amendments, and progress reports; Federal Financial reports; and all related financial and administrative data and documentation, e.g. journal entries, invoices, and copies of checks | Three (3) years from the submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, as authorized by the federal awarding agency |
| Equipment and real property records | Three (3) years after final disposition | |
| Indirect cost and fringe benefit rate proposals, cost allocation plans and supporting records | Three (3) years from date of submission | |
| Records for program income transactions after the period of performance | Three (3) years from the end of the fiscal year in which the program income is earned | |
| Records involved in an audit, claim, litigation, negotiation, or other similar action that commences prior to the expiration of the required retention period | The later of full resolution of the issues or the end of the regular three (3) year period | |
| IACUC | Required committee records include the assurance provided by the federal Office of Laboratory Animal Welfare; minutes of IACUC meetings; records of IACUC attendance, activities, and deliberations; documentation of IACUC protocols, proposed significant amendments, and committee determinations; report of semiannual IACUC evaluations and recommendations to the Institutional Official, including minority views; and accrediting body determinations records, including all materials related to protocol reviews, and regulatory and sponsor required documentation | Three (3) years, with the exception of records that relate directly to protocols that must be kept for the duration of the activity and an additional three (3) years after completion of the activity |
| IRB | Required board records include: membership rosters, written procedures and guidelines, electronic submissions, all minutes, Human Research Protection Program (HRPP) advisory committee meetings’ proceedings and related communications, other documents related to IRB activities (eg, rationales for IRB determinations, records related to the IRB office’s operations, and administrative forms | Seven (7) years after completion of the study
Federal requirement: 3 years after completion of the research |
| OGC | Records relating to investigators’ disclosure of significant financial interest, including the review of and response to such disclosures, determinations of conflict of interest and resulting financial management plans, quality assurance, and investigation of non-compliance | Three (3) years from submission of the final expenditures report to a Public Health System sponsor, or as sponsor policy, the BMC-sponsor agreement, or BMC requirements stipulates |