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By accepting an AIP grant agreement, a Sponsor agrees to maintain pertinent project accounts and records that fully support all project transactions and fully disclose the disposition of all grant proceeds. Sponsors must maintain accounts and records in accordance with an accounting system that will facilitate an effective audit that conforms with the Single Audit Act of 1984 and OMB A-133. Sponsors accept this obligation whenever they accept an AIP grant offer (assurance #13 and 49 CFR Part 18.42).
Access to Records
Grant Assurance #13 establishes the FAA's right of access to any pertinent books, documents, papers or other records of the grantee for the purposed of audit and examination. This right of access also extends to the DOT Office of Inspector General, the Comptroller General of the United States and any of their authorized representatives. This right of access is not limited to any specified retention period
Type of Records
Each project may present unique documentation requirements. As a minimum the retained information should include but not be limited to the following:
- Invoices and billing statements
- Canceled checks
- Final contractor payment request
- Professional services contract
- Selection documentation
- Construction contract and associated documents
- Rationale for contract type
- Basis for contract price (Cost & Price Analysis)
- Purchase orders (if applicable)
- Contract instruments (Change Orders, NTP & etc.)
- Record of Negotiations
- Audit certification of applied indirect rates (e.g. consultant overhead)
- Grant agreement and amendments
- Sponsor certifications
- Project Application
- Title VI Certification
- Drug-Free Workplace certification
- Exhibit A property map
- Certificate of Title
- Sponsor correspondence letters
- Final project report
- Record drawings
- Buy American documentation
- DBE Documentation
- Summary of test results
- Daily records and reports
- Final inspection report
- Summary of pay factor applications
Unless otherwise specified, Sponsors are obligated to retain all pertinent documentation for a period of three (3) years. Generally, this three year period commences on the date of the final reimbursement ( 49 CFR Part 18.42(c)). For situations such a potential litigation or audit investigation, the Sponsor may be required to retain such records beyond the three year period.
Because grant agreements impose obligations that extend beyond the three year time frame, we strongly recommend Sponsors retain the grant agreement and documents directly related to the grant agreement (exhibit A property map, certificate of title and etc.) indefinitely.
Real Property and Equipment
All pertinent documentation for equipment and real property shall be maintained for the duration of equipment ownership. For equipment, the three year period for record retention commences on the day the equipment is disposed or replaced, subject to FAA concurrence. For real property, the three year period commences on the day the land is formally transferred as approved by the FAA.