FAQs for GRS 2.4, Employee Compensation and Benefits Records
Download all Frequently Asked Questions of Individual GRS Schedules in a PDF
QUESTION RELATED TO GRS 2.4, “PAYROLL” SECTION ITEMS 010 TO 050
1. Who holds the record copy of records described in items 010 through 050: the agency or the payroll service provider?
The GRS is agnostic on ownership of and responsibility for the record copy. Responsibility for retention of records for the length of time required for each of these five items should be negotiated and agreed upon between an agency and its payroll services provider.
QUESTIONS RELATED TO GRS 2.4, ITEM 010
2. The retention period for these records has been shortened from ‘Destroy 2 years after employee separation or retirement’ to ‘Destroy 3 years after paying agency or payroll processor validates data.’ Are the records less valuable than they used to be?
No, the value of the records has not changed. We made the change in response to an agency notifying us that the retention period change we made in July 2017 via GRS Transmittal 28 required these records to be kept much longer than needed. After further analysis, we determined that a 3-year minimum retention period after the data is validated is appropriate for these records because errors are identified within this time period. Additionally, the agency payroll record retained under GRS 2.4, item 040, which has a 56-year retention period, should be sufficient documentation for other claims. The schedule authorizes agencies to retain records longer than 3 years if they wish to do so.
3. The records listed in this item look to me like system inputs. Why did you not cover them under GRS 5.2, item 020 (Intermediary records)?
GRS 2.4, item 010 concerns only record copies of documents listed in the series description. These record copies may be in electronic or paper form. If a payroll system receives paper, scans it, and enters it into the system, and the agency considers the scanned electronic version to be the record copy, then the paper is indeed system input covered by GRS 5.2, item 020.
QUESTIONS RELATED TO GRS 2.4, ITEM 030
4. The disposition instruction for this item used to state ‘Destroy after GAO audit or when 3 years old, whichever is sooner’ and now it states ‘Destroy when 3 years old, but longer retention is authorized if required for business use.” Why did the retention period change?
The previous retention period allowed agencies to destroy the records earlier than the legally-necessary period for retaining the records under two applicable regulations . GAO audits always occur within 3 years, but 29 CFR 516.5(a) requires an employer to preserve payroll records for at least 3 years. Under the previous disposition instruction, if a GAO audit occurred before the 3-year mark, the records could be destroyed then, contrary to this regulatory requirement. In addition, the statute of limitations period under the Fair Labor Standards Act (FLSA), 29 U.S.C. § 55, necessitates a 3-year retention period. Claims under the FLSA generally must be filed within 2 years, but the limitations period may be extended up to 3 years in some situations.
While these records may be required for GAO audit, they still must be kept for at least 3 years regardless of that audit, but are generally not needed beyond 3 years. The previous retention period did not allow agencies to retain the records longer than 3 years as a result. However, we found no reason to limit longer retention if the agency has a business need, so we’ve added that option.
5. Who is responsible for retaining time and attendance records for 3 years? The agency, or the payroll provider (if different from the agency)?
Every office involved in documenting employees’ time worked is responsible for retaining the records it receives and creates for 3 years. Timekeepers in individual offices need to be able to document that the time and attendance information they sent to the payroll system provider was accurate. Only total hours of time worked and leave taken is forwarded to the payroll system provider. Backup documentation justifying those totals is usually retained by the timekeeper.
QUESTION RELATED TO ITEMS GRS 2.4, 100 AND 101
6. Why do these items not cover records created and maintained by the Department of Labor (DOL) Office of Workers’ Compensation?
Items 100 and 101 cover records agencies create about employee personnel injury compensation. At these agencies, the records are administrative in nature. DOL’s Office of Workers’ Compensation maintains personnel injury compensation records for employees across the Federal Government. As such, these records document how DOL carries out that mission. Therefore, DOL schedules these records on an agency-specific records schedule.
QUESTION RELATED TO GRS 2.4, ITEM 110
7. Why does this item have no disposition authority number?
Item 110 has no associated disposition authority number because it has no instruction either to destroy the records or to save them permanently. The instruction instead merely directs the user to place the records into the “appropriate retirement system.” Their ultimate disposition is governed by a disposition authority connected to the retirement system records.