FAQs for GRS 1.1, Financial Management and Reporting Records
Download all Frequently Asked Questions of Individual GRS Schedules in a PDF
QUESTIONS RELATED TO ITEMS 010 AND 011
1. My agency has scheduled accountable officers’ and similar financial records for a 7-year retention period. Which takes precedence: my agency’s 7-year retention period or the GRS 6-year retention period?
The GRS takes precedence because it supersedes an agency schedule authority. However, because GRS 1.1, item 010, has a flexible retention period (destroy 6 years after final payment or cancellation, but longer retention is authorized if required for business use), your agency can use either the GRS 6-year retention period or keep the 7-year retention period (or even longer). However, you must cite the GRS item as the authority for whichever retention period you use, not the superseded agency schedule.
2. If I scan paper travel receipts into an e-system as voucher attachments, can I destroy the original paper?
Yes, as long as you meet both of the following prerequisites. First, your agency must identify the e-system as the repository for vouchers available for audit by the Government Accountability Office (GAO). Your agency must retain the records in this e-system for 6 years, per GRS 1.1, item 010. Second, the scanned image must contain everything available in the original paper. GAO states, “There shouldn't be anything on the paper that isn't reflected in the electronic version.” (1) If these two conditions are met, the original paper travel receipts may, after the scanned image is verified to contain all information in the original, be destroyed per GRS 5.2, item 020.
3. Why is item 010 followed by an item (011) for “all other copies” but none of the other items have a similar all-other-copies counterpart?
Copies of records in item 010 are likely to produce extra copies retained in other business units for separate business purposes. For instance, a purchase order may exist in multiple copies not only where it is held for financial audit but also in accounts payable, shipping and receiving, and other offices. These are not non-record copies held for convenience, but records retained for specific and unique business purposes. Because the record copy is retained for the primary purpose of audit, other copies can be disposed of when their business use ceases. Copies of records covered by other items in this schedule are more likely to be held simply for convenience. They serve no unique business purpose, are therefore non-record by definition, and do not need to be scheduled.
4. Why are travel and transportation records intermingled with financial management records in items 010 and 011?
While the logistics of arranging for travel and transportation may be a distinct business process, at root many of these records document paying money in exchange for services. Agencies retain them primarily to enable financial audit. That is whythey co-exist in items 010 and 011, which cover a wide range of financial transaction records.
QUESTIONS RELATED TO ITEM 012
5. Does this item cover all unsolicited and all unaccepted bids?
No. This item covers only bids that are both unsolicited and unaccepted. These bids have a much shorter retention period than bids that are unsolicited but accepted or solicited but unaccepted. (Item 010 of this schedule addresses both these latter types of bids.) Any accepted bids have obvious business and legal value documenting a contract, and any solicited bids have further value if there are legal challenges to the contract award. Bids that agencies neither solicit nor accept do not fulfill continuing business purposes and agencies thus do not need to retain them for long.
6. Does this item’s disposition mesh with the Federal Acquisition Regulation (FAR)?
Yes. The FAR Implementation Team, which drafted the update to the FAR published in the Federal Register on December 4, 2015, requested that we add this item. The FAR update contains directions to dispose of these materials “ in accordance with agency procedures” (80 FR 75913). That instruction is consistent with this item’s disposition to destroy “when no longer required for business use.”
QUESTION RELATED TO ITEM 013
7. Why does this item cover only an agency’s copy of the data it submitted to FPDS, but not the master data held in FPDS itself?
The GRS covers records common to multiple agencies. FPDS is a system owned by the General Services Administration (GSA). Although multiple agencies own and submit the system’s source data, once collected in FPDS the data is unique to GSA and GSA must schedule it. As a result, the GRS does not cover the data within the FPDS. GSA’s FPDS master data is permanent under N1-137-96-1, item 1. For this reason, agency-retained copies of their own submitted data are temporary.
QUESTION RELATED TO ITEM 020
8. Item 020 is for background materials used to prepare an annual agency financial statement. Why isn’t there an item for the agency financial statements themselves?
Agency financial statements are scheduled under GRS 5.7, item 050, “Mandatory reports to external Federal entities regarding administrative matters.”
9. Does this item cover records of all audits?
This item covers records of an agency’s audits of its annual financial statement—the assessment of its assets’ market value. It does not cover records of other financial or non-financial audits.
QUESTION RELATED TO ITEM 030
10. Besides being included in item 030, purchase orders, contracts, and invoices also appear in item 010. How can I tell which item is the correct one for my records?
Purchase orders, contracts, and invoices appear in item 010 when they document financial transactions subject to audit to ensure that government spends its resources appropriately and within the confines of the law. Some of those purchase orders, contracts and invoices serve as a baseline to document agency investment in “property, plant and equipment” (PP&E) assets, and these are the subject of item 030.
Determining the value of PP&E assets involves knowing the original purchase price and the rate of amortization over the course of years. Many assets eventually wear out and are removed from inventory, while others (such as real estate and structures) may have a usable life of many decades or remain in government ownership to the end of the republic.
The same records may exist in both the financial management and the PP&E asset accounting offices. They are scheduled differently based on the business purpose the records serve in each office. Their retention period is 6 years in item 010 to ensure their availability for financial audit. But their retention period in item 030 may be for many decades. For this reason, it is advisable that duplicates of purchase orders, contracts, and invoices concerning PP&E assets be supplied to that office for inclusion in the files documenting those assets that are covered by item 030.
QUESTION RELATED TO ITEM 060
11. Why did you schedule contract dispute records both here and in GRS 6.7, item 020? Why are the retention periods so dramatically different?
Per 41 U.S.C. 7103, when someone appeals a decision arising under the Contracts Dispute Act, the agency contracting officer issues the final decision on the appeal. GRS 1.1, item 060, covers records the contracting officer creates in the course of that appeal. GRS 6.7, item 020, covers the case file the agency’s General Counsel creates while representing the agency in both the original lawsuit and the appeal. General Counsel’s 7-year retention period ensures records survive through the time period in which a person may file an appeal. Retaining the contracting officer’s records for 1 year after the decision is sufficient because the matter is not subject to further litigation.
(1) This statement was made by a GAO representative to NARA’s GRS Team on January 24, 2017.