Administrative Record-Keeping
The communities are required to maintain all financial and program records
pertinent to the project. These files should be kept in a centrally located
filing system. This system should be complete, logically constructed, and stored
in a secure location. Following is a list of suggested general categories for
the filing system:
| Contract and Project Information | EPA Milestone Requirements * |
| Approved Legal Document (IAA or equal) | Preliminary & Final Plan of Operation |
| Correspondence File and Log | Operation and Maintenance Manual |
| Approved Contract | Chief Operator’s Employment Manual |
| Contract Brief | Flood and Other Insurance Policies |
| Agreements and Amendments | |
| Project Status Reports | Construction * |
| Correspondence File and Log | |
| Professional Services | Telephone Log |
| Correspondence and File Log | Bidding Information |
| Engineering Agreements/Amendments | Approved Plans and Specifications |
| Procurement Procedures | Addendums |
| Telephone Log | Bid Bonds |
| Approved Shop Drawings | Performance Bond |
| Notice of Award | |
| Financial Records | Notice to Proceed |
| Project Procurement Procedures | Contract Agreements |
| Capital Outlay Projections | List of Subcontractors |
| Cash Flow Plan | Right-of-Way Easements |
| Reimbursement Requests and Log | Construction Permits |
| Invoices | Change Orders File and Log |
| Professional Services Agreements | Material Certifications and Test Reports |
| Contractor’s Pay Estimates | Construction Progress Schedules |
| Force Account Payroll Records | Lien Waivers |
| Administrative Expenses | DBE/MBE/WBE Contracts & Reports |
| Canceled Checks | Certified Payrolls and Labor Interviews |
| Periodic Audit Reports | Approved Shop Drawings |
| Personal Property Inventory | As-Built Notes and Marked-Up Plans |
| Photographs | |
| Grant Closeout | |
| Correspondence File and Log | |
| Final Inspection Report | |
| Project Performance Certificate | |
| Final Invoice Summaries | |
| * If required for project |
Administrative Documentation
Under the terms of the grant award, communities must be in compliance with
applicable federal documentation regulations. While each community may be responsible
for various phases and tasks of the project, the general methodology for recording
and tracking costs should be consistent regardless of the actual work undertaken.
To assist the community in conducting a self-assessment of its financial and project-related systems and practices, a community documentation requirement checklist is provided as the Guide’s Attachment 7. This checklist covers the following topics:
The community should denote whether systems and procedures are currently in place to cover each of these areas. If the answer is "no" to any of these items, the community should determine the applicability of the requirement to its particular situation. In some cases, an item may not apply to the community. For example, documenting "out-of-town" travel policies when no significant travel is contemplated would not necessarily require a written policy or procedure. If, however, a formal policy, procedure or practice is not in place for an applicable item, then steps should be taken to rectify the situation.
Quality Assurance
The community is required to develop and implement a quality assurance program
that is sufficient to insure data of adequate quality so as to meet project
objectives and to minimize loss of data. See 40 CFR 31.45 for additional information
on quality assurance. The RPO is also available to discuss quality requirements
applicable to a specific community project.
Documentation Retention and Access Requirements
The following document retention requirements apply to all required program
and financial records as well as all other documents that can be reasonably
considered as necessary. The requirements do not apply to the records of contractors
or subcontractors.
The retention period for general project documents begins when the community submits its final request for payment. If the expenditure report has been waived, then the retention period begins when the report would have been due.
Unless specified otherwise, records are to be retained for three years from the retention period start date as specified above. If any exploration (litigation, claim, negotiation, audit, or other action) into the records has started before the retention period has expired, then the records must be retained until the exploratory action is complete and all issues have been resolved, or until the end of the three year period, whichever is later. If the RPO requests the community to transfer records into the RPO’s custody, then the three year retention period is no longer applicable to the community.
The grantor and the Comptroller General of the United States, or any of their representatives, have the right to access any of the project records of the grantees and subgrantees.
Frequently Asked Questions (FAQ’s)
How often will the RPO audit community supporting documentation for a project?
The documentation checklist in Attachment 7 looks imposing. What are the most important items?
Does a community need to have a section on quality assurance in the project work plan required by the IAA?
Other FAQ’s will be added as comments are received.
Please address all comments and suggestions about the contents of this Web page to rougeweb@co.wayne.mi.us.
The Rouge River National Wet Weather Demonstration Project is funded, in part, by the United States Environmental Protection Agency (EPA) Grants #XP995743-01, -02, -03, -04, -05, -06, -08 and C-264000-01.