Paperless Office and Federal Grants

Up until very recently, those of us who managed grants from ED, NIH, or other federal agencies had to be careful about going "paperless." But as of this year, the new Office of Management and Budget regulations allow for keeping records paperless, as long as one's paperless system meets some general guidelines.

Federal Regulation Allowing Paperless Records

CFR Col. 78 No. 248 (12/26/13) Chapter II Part 200.335 reads...

In accordance with the May 2013 Executive Order on Making Open and Machine Readable the New Default for Government Information, the Federal awarding agency and the non0Federal entity should, whenever practicable, collect, transmit, and store Federal award-related information in open and machine readable formats rather than in closed formats or on paper.  The Federal awarding agency or pass-through entity must always provide or accept paper versions of Federal award-related information to and from the non-Federal entity upon request. If paper copes are submitted, the Federal awarding agency or pass-through entity must not require more than an original and two copies.  When original records are electronic and cannot be altered, there is no need to create and retain paper copies.  When original records are paper, electronic versions may be substituted through the use of duplication or other forms of electronic media provided they are subject to periodic quality control reviews, provide reasonable safeguards against alteration, and remain readable.

This means that when a grant program undergoes an A133 audit, paperless documents are fully acceptable.  There is, however, some language that should probably be considered in adopting a fully paperless Federal grant.**

Open Format

They didn't say "PDF" but this appears to be what they mean.  Paperless records should probably be in formats that can easily be read across multiple platforms or in free software.  Much of the Federal paperless stuff is done in PDF format using Adobe.

Unalterable

If you're savvy at all with PDFs, you know that they often CAN be altered (thank you PDF Pen) - but it seems that the point here is to avoid saving records in .doc or .xls formats when creating records.  The extra-safe method might be to encrypt all PDF records, so that they cannot easily be altered. A friend who does A133 audits shared with me that they might look for discrepancies between the date that a file was created and the date that it was modified.

No Need to Retain Paper Copies

This is the juicy bit of the regulation. My grants have been "paperless" for several years - but we kept a paper copy of required files. This language means that we are finally able to jettison those file-cabinets once and for all, and rely upon the assurance that a paper-version of an electronic document is not necessary.

When we went through our files, we collected everything that needed to be destroyed and sent it in bulk for shredding.  It cost us a little to have that service, but we decided it was more cost and time efficient than having student workers stand in front of our small office shredder for weeks.  

Keeping a Records Policy

Records can (and should) be destroyed when they have reached a certain age (depending upon the regulations related to your Federal grant). If you are operating a paperless office, old electronic records should be deleted as well. 

Image Credit: http://bit.ly/1cvYJe9

Posted on June 2, 2015 .