Hi Amy:

> My concern is this:  we are being told that we need to keep most items 7 years even if they don't have a 7 year retention based on state or federal rules because they may come up in the scope of NERC/ FERC audits.  

Unfortunately, I can't speak to NERC/FERC requirements, but I share your concerns. For example, DCAA is one of our auditors and they are 8 years behind in conducting their audits. Couple years ago, each department at my company determined their retention schedules. Many erred on side of caution by having audit-based retentions (e.g., "Audit Complete", "10Y after Final Rates Determined", etc.) that exceed regulations (like FAR 4.7). However, this has caused other issues: (1) the burden to keep and provide records beyond what is required, and (2) extra man-hours spent tracking things down for audits due to lack of a unified understanding of when "Audit Complete" or "Final Rates Determined" occurred.

We recently kicked off an IG program to start addressing various issues which include how to better disseminate audit complete, final payment, etc., but our main records concern is how to comply with regulations, keep what is needed for audits and defensibly destroy/delete the rest to minimize exposure risk? 

I'm new to Records Management and would greatly appreciate guidance on this topic from the list as well.

Best,
Steph

Stephanie Young, MSLS
Ball Aerospace
Boulder, CO
303-335-4479

 



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