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CRE Analysis

10. How long would the grantee institution need to maintain research records?

Comment by Mayo Foundation

CRE Response:

Currently, Circular A-110 provides that recipients must maintain "all . . . records pertinent to an award" for three years following completion of the project. OMB Circ. A-110, § ___.53(b). While the circular does not define "records", it appears that in establishing a three year document retention policy, OMB was focusing on financial records, as opposed to the kinds of scientific research data now being discussed.

Although a three-year period makes sense for financial data, three years may well be an insufficient length of time for purposes of preserving data that, perhaps years after the grant, may become of interest to others, or may be used in developing federal policy or rules. Unlike financial data, the value of scientific data is of indefinite duration. OMB should encourage the retention of this valuable data. CRE therefore proposes that a mechanism be created whereby the recipient takes measures to maintain and safeguard the data for possible future disclosure.