Record Retention and Contract Administration - 2100.5

(Revised: 02/2022)

Good Record Keeping

Departments are responsible for maintaining records in sufficient detail to allow anyone to review documentation and understand how the procurement was requested, conducted, awarded, and administered.

Buyers shall provide contract administrators with the necessary instructions to maintain good record keeping activities and ensure the records are turned over to the procurement office at the completion of the contract term.  The records maintained by the contract administrator are incorporated into the procurement file and retained for compliance and/or auditing purposes.

Setting Up a Contract File

Contract administration responsibilities may also include establishing the department’s procurement file dependent upon the department policies and procedures as to who performs the contract administration duties.

Consequently, contract administrators should organize documentation according to department procurement processes in addition to the DGS/PD recommendations.

The DGS/PD recommends creating files by:

• Developing a user-friendly filing system.  File by Contract/PO number or supplier name.
• Establishing a separate hard copy file for each Contract/PO administered.
• Developing a log sheet for a diary of activities.  This may include dates and times of discussion and subject matter discussed.
• Developing spreadsheets for tracking expenditures, invoices, and/or timekeeping for the life of the transaction.
• Creating file dividers for:
  • Original Contract/PO and all amendments/addendums/supplements/changes
  • Work Authorizations
  • Deliverables
  • Correspondence – acceptance letters, termination notices, etc.
  • Invoices
  • SB/DVBE participation and all related supporting documentation including the Prime Contractor’s Certification – DVBE Subcontracting Report (STD 817) and payments made by prime contractors to the DVBE subcontractors when provided.

The above information is specific to post award contract administration.  Department purchasing authority transaction files will include all of the above as well as the file documentation required by the specific purchasing category.

Record Retention Requirements

The Attorney General’s Office has directed that in view of the need for purchase order and contract purchase files for antitrust litigation, such records should be retained for seven years from the end of the fiscal year in which encumbrance is liquidated. Destroy after the required seven years or when audited by the Bureau of State Audits or the Department of General Services, whichever comes first.

All records related to the Prime Contractor’s Certification – DVBE Contracting Report (STD 817) submittal, including payments made to DVBE subcontractors, are to be retained for a minimum of six years from the receipt of the records.

Since there are various sources that dictate records retention requirements (e.g. statute, policy, pending litigation, etc.) and the retention varies depending on document type and can vary by department, depending on their internal retention schedule, there is not a one size fits all retention rule. When in doubt, departments should retain for the longest period applicable.