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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 maintian accounts and records in accordance with an accounting system that will facilitate an effective audit that complies with the Single Audit Act of 1984.
Sponsors accept this obligation whenever they accept an AIP grant offer(assurance #13, 49 CFR Part 18.42).
Access to Records
The Federal Aviation Administration, the Office of Inspector General, the Comptroller General of the United States and any of their authorized representatives shall have right of access to any pertinent books, documents, papers or other records of the grantees for purposes of audits and examinations (Grant Assurance #13). 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
- Purchase orders
- Contract instruments (Change Orders, NTP & etc.)
- Record of Negotiations
- Cost or fee analysis
- Audit certification of overhead rates for professional consultant
- Grant agreement and amendments
- Sponsor certifications
- Project Application
- Certificate of Title
- Drug-Free Workplace certification
- Exhibit A property map
- 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 required, Sponsors are obligated to retain all pertinent documentation for a period of three (3) years. Generally, the 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 beyond the three year time frame, we strongly recommend the agreement and documents directly related to the grant agreement (exhibit A property map, certificate of title and etc.) be retained indefinitely.
Real Property and Equipment
All pertinent documentation for equipment and real property shall be maintained for the duration of 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.