A. OBJECTIVE
This procedure provides guidance on required retention periods for financial records to meet the legal, administrative and operational requirements of USNH. Note that approved methods for deletion of electronic documents are not covered by this procedure.
B. AUTHORITY
Per USNH Board of Trustees Administrative Policy BOT III.G.1.1, the Board of Trustees, under RSA 187-A:16, has the authority to manage the affairs of the University System and its component institutions. That authority includes the power to regulate the maintenance, retention, disposal and disclosure of the records of USNH consistent with state and federal law.
C. SCOPE
This procedure applies to all USNH financial records including those maintained by all USNH campuses and affiliates such as the UNH Alumni Association, the UNH Foundation, and the Keene Endowment Association.
D. DEFINITION
Financial records include all accounting, disbursement and tax-related reports and documents supporting the financial operations of USNH.
E. RESPONSIBILITY
Unless otherwise noted, the Campus Finance/Administration office or UNH Business Service Center (BSC) initiating a transaction is responsible for retaining documentation supporting the transaction. In most cases, this can be accomplished by adding copies of the documentation into the USNH designated imaging system. The retention periods described below would then be applied to the imaged document, and any paper copies can be destroyed following established procedures for the document type and sensitivity level.
F. EXCEPTIONS
1. USNH Financial Services maintains portable document format (pdf) versions of all Purchase Order and Change Order documents generated by USNH financial systems.
2. Campus Human Resources Offices are responsible for maintaining records or other information (including benefit selections and other items) per USNH On-Line Policy Manual OLPM - USY V.C.4.2.4.
G. RETENTION PERIODS
While this procedure prescribes the minimum period after each transaction date that USNH financial records should be maintained, campus finance/administration offices and UNH BSCs may, at their discretion, retain records for a longer period if there is a need to do so. See Section H below for retention beginning dates and retention periods of documentation related to grant activity.
1. Documents which must be retained permanently
- Annual audited consolidated financial statements (annual reports)
- Annual consolidated Uniform Guidance audit reports
- Detailed financial schedules by fund (USNH annual “Bigbook” representing the general ledger activity and balances)
- USNH and affiliate information and income tax returns filed with federal and state authorities (e.g., Form 990, Return of Organization Exempt from Income Tax; Form 990-T, Exempt Organization Business Income Tax Return; and related State of NH reports such as NH BET, Business Enterprise Tax Return, and Annual Report filed with NH Attorney General
- Memoranda of Understanding and other donor agreements for all endowment, life income, annuity, and trust gift funds
- Purchase and Sale Agreements for all real estate transactions
2. Documents which must be retained for 30 years
- NHHEFA Bond documents related to issuance (e.g., Blue Book) and related tax filings
- Construction invoices for all property financed with NHHEFA debt, capital leases or state capital appropriations
- Copies of bond/capital lease construction account bank statements and funds requisition schedules
3. Documents which must be retained for 7 years
- Accounts Payable (vendor) invoices and USNH Personal Reimbursement Forms with supporting documentation
- P-Card transaction documentation including images of all convenience checks with supporting documentation
- Timesheets for all personnel
- For campuses using the WISE (web-time-entry) system for time and leave reporting, the electronically-approved timesheet is the official record that should be retained for 7 years and there is no need to retain backup at the department level. Note: Until a department has been on the WISE system for 7 years, processing units should retain paper documentation for prior years to ensure that the total retention period (i.e., paper + WISE) is 7 years.
- Biennial Equipment Inventory Reports
- Documentation to support current-use gift contributions to USNH as well as their purpose restrictions, if any, should be retained for 7 years after the funds are fully spent.
- Contracts and corresponding bid documents associated with Requests for Proposals and/or Quotes should be retained for 7 years after the expiration of the contract and any associated renewals.
4. Documents which must be retained for 5 years
- Copies of receipts issued for sales of goods & services for which payment is accepted by credit card, and all related backup should be retained in accordance with Payment Card Industry Data Security Standards (PCI DSS), and must not contain Personal Identification Information
- Copies of backup for all other cash/check receipts, provided that any customer banking information is appropriately redacted
- Investment subscription documents, agreements, approvals and other supporting records should be retained for 5 years after full divestment.
5. Documents which must be retained for 4 years
If not specified below these retention periods begin on the first day of the fiscal year that the form is filed.
- IRS Form W-2, Wage and Tax Statement
- IRS Form W-2G, Certain Gambling Winnings
- IRS Form W-3, Transmittal of Wage and Tax Statements
- IRS Form W-4, Employee’s Withholding Allowance Certificate. This special purpose IRS form must be retained for 4 years after the employee’s termination from USNH.
- IRS Form W-8BEN, Certificate of Foreign Status of Beneficial Owner for United States Withholding
- IRS Form W-9, Request for Taxpayer Identification Number and Certification - This special purpose IRS form must be retained for 4 years after termination of the entity’s relationship as a vendor of USNH. Following IRS best practices USNH will solicit new Forms W-9 from current vendors using self-service mechanisms on a cyclical basis such that current vendor data is updated every five years at a minimum.
- IRS Form 941, Employer’s Quarterly Federal Tax Return
- IRS Form 945, Annual Return of Withheld Federal Income Tax
- IRS Form 1042, Annual Withholding Tax Return for U. S. Source Income of Foreign Persons
- IRS Form 1042-S, Foreign Person’s U. S. Source Income Subject to Withholding
- IRS Form 1098-T, Tuition Statement
- IRS Form 8233, Exemption From Withholding on Compensation for Independent (and Certain Dependent) Personal Services of a Nonresident Alien Individual
- IRS Form 8283, Noncash Charitable Contributions, and related appraisals
- IRS Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business
6. Documents which must be retained for 3 years
Grant and contract proposals, awards, agreements and related supporting documentation, should be maintained for a minimum of three years after the awards closing date as defined in section H below.
H. GRANT AND CONTRACT TRANSACTIONS
The retention period for federal grant or contract-related transactions is tied to the closing date of the award, including all extensions, rather than the date of each individual transaction. The retention period beginning dates for records under selected types of federal awards are noted below. These retention beginning dates apply unless the terms of the award specifically state otherwise or there is a pending audit or litigation matter. In the case of the latter, the retention period begins on the date of resolution of all audit findings or all appeals related to any litigation. The USNH transaction retention schedule above should be applied from these dates in all cases for all documents listed in section G.1-7 above.
- For federal awards that are renewed quarterly or annually, the retention period begins on the date of the submission of the quarterly or annual financial report including the expenditure.
- The retention period for records of real property and equipment acquired with federal funds begins on the date of final disposition of the asset.
- The retention period for expenditures made under federal contracts begins on the date the final payment on the contract is received.
- The retention period for financial records and supporting documents for all other grant-related transactions begins on the date of submission of the final expenditure report including the activity.
- For federal contracts, the record retention period varies between two and ten years from the final payment. This includes books, documents, accounting procedures and practices, and other data regardless of whether such items are written, computerized, or in any other form and other supporting evidence to satisfy the contract negotiation, administration, and audit requirements of the contracting agencies and the Comptroller General. For financial and cost accounting records, payroll documents and acquisition, and supply records, the required retention requirement is two to four years.
Campus business offices are strongly encouraged to consult their Office of Sponsored Programs to determine the appropriate retention period for records related to specific grants or contracts and ensure that the records are not related to pending audits or litigation. In any case where the sponsoring agency’s retention period is longer than that dictated by this procedure, the longer period shall apply.
I. RECORDS DESTRUCTION AND DISPOSAL
At the end of the required retention period, records should be disposed of unless the records are required for a current audit, regulatory review or litigation. Records containing sensitive and/or confidential information should be shredded or incinerated and properly disposed. The Campus Finance/Administration office responsible for retaining documentation should maintain a record documenting all records that were destroyed. This record must include a brief description of the records, the dates the record originated, if available, the date of destruction and the reason why the record is being destroyed (for example, expiration of required record retention period).
J. DOCUMENT SCANNING
Campus business offices should be imaging and indexing their departmental documentation. See Imaging Invoice in BDMS, Imaging PCard in BDMS, and Imaging JV in BDMS for related imaging procedures.
