FAQs for GRS 1.2, Grant and Cooperative Agreement Records
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1. What is the difference between a grant, a cooperative agreement, and a contract in the context of this schedule?
A grant is an award of financial assistance in the form of money, or property in lieu of money, by the Federal government to an eligible grantee. The principle purpose of a grant is to transfer a thing of value from a Federal agency to a state or local government or other recipient to carry out a public purpose of support or stimulation authorized by Federal statute (31 U.S.C. 6304). A cooperative agreement is an award of financial assistance that is used to enter into the same kind of relationship as a grant, but differs from a grant in that it provides for substantial involvement between the grant-making Federal agency and the award recipient to carry out the activity contemplated by the award (31 U.S.C. 6305). Contracts are used to acquire property or services for the direct benefit or use of the Federal government.
QUESTIONS ABOUT RECORDS NOT COVERED BY GRS 1.2
2. Why does this schedule not cover Government-wide systems such as GRANTS.GOV, GRANTSOLUTIONS.GOV, and USASPENDING.GOV?
Grants.gov is owned by the Department of Health and Human Services (HHS). HHS has scheduled the web version of material posted there by other agencies as temporary, assuming agencies manage that content as records in their own records-management environments. The web version has the unique and sole business purpose of making grant information available to the public for a relatively short period of time.
GRANTSOLUTIONS.GOV is also owned by HHS and managed by the Administration for Children and Families (ACF) within HHS, in partnership with the Denali Commission. Its business purpose is to provide grants management products and support to Federal grant-making agencies. ACF has scheduled the GRANTSOLUTION.GOV database and web portal as temporary. Agencies are responsible for managing the content they post and output they receive as records in their own records management environments.
USASPENDING.gov is owned by the Office of Management and Budget (OMB). Although it contains copies of records posted by other agencies, the records OMB collects in this system combine to create a new business purpose, different from the business purpose for which the individual records exist at the creating agency. OMB is responsible for scheduling that unique totality of records in USASPENDING.gov.
3. Why does this schedule not cover Service Level Agreements?
A Service Level Agreement (SLA) is an agreement between a customer (the agency, in this context) and a service provider that describes the service, documents service level performance targets, establishes incentives for meeting performance targets, clarifies the responsibilities of both the service provider and the customer, delineates how they will discover and handle disputes, and specifies how they will remedy performance failures. The process of executing an SLA is a commercial transaction between a customer and a service provider. The services described in an SLA are paid for by the agency. However, unlike a grant or cooperative agreement, an SLA is not a funding or obligation document. For this reason, we do not include SLAs under this schedule.
4. Why does this schedule not cover inter-agency agreements?
An inter-agency agreement (IAA) is a written agreement between two Federal agencies, or major organizational units within an agency, that establishes a reimbursable order for goods or services. Unlike grants and cooperative agreements as defined in this schedule, IAAs are between co-equal partners. For this reason, we do not include IAAs under this schedule. GRS 1.1, item 010, covers IAAs for goods or services.
QUESTIONS RELATED TO GRS 1.2, ITEM 020
5. Why does the GRS include successful applications?
We have determined, based on data and experience with requests for grant case files in our holdings, that these records do not generally warrant permanent retention. They are often quite voluminous, contain little information of significance, and attract little research attention. If an agency believes it has grant case files of historical value it can submit a schedule for those records to NARA.
6. Why do successful grant and cooperative agreement application case files have a 10-year retention period?
The 10-year retention period aligns with the 10-year statute of limitations in the False Claims Act (31 U.S.C. 3731(b)), which governs claims related to these records.
QUESTION RELATED TO GRS 1.2, ITEM 022
7. Why is there an “all other copies” item for Grant and Cooperative Agreement Case Files, but none of the other items have a similar catch-all item?
Other business units may retain extra copies of these case files for separate business purposes. These extra copies are therefore not non-record copies and must be scheduled. Extra copies of records covered by other items in this schedule are more likely to be held simply for convenience, making them non-record copies by definition.
QUESTION RELATED TO GRS 1.2, ITEM 030
8. Why are final products or deliverables scheduled as temporary records?
We have determined, based on research into how agencies have scheduled these records and experience with requests for these records in our holdings, that they do not generally warrant permanent retention. If an agency believes its grant or cooperative agreement products or deliverables do warrant permanent retention by the National Archives, it can submit a request to deviate from the GRS with a proposed agency-specific schedule.