U.S. Department of Transportation
Federal Highway Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
202-366-4000


Skip to content
FacebookYouTubeTwitterFlickrLinkedIn

Home / Office of the Chief Financial Officer / Project Funds Management Guide for State Grants / Attachment 2

Attachment 2: Recommended Final Project Records Retention, By Phase

Project Funds Management Guide Attachments - 1 | 2 | Q&A


This attachment identifies the primary records typically necessary to support the financial record and requiring retention after the final billing for financial purposes.   The list should not be considered exhaustive nor completely applicable to all projects.  The record retention period is based on requirements for general project records by the State DOT (2 CFR 200.333) and may be longer for certain records under other laws or regulations.   All FHWA documents should be retained by FHWA in accordance with FHWA Order 1324.1B - FHWA Records Management and DOT Order 1351.28.

Table 1: Documents Needed to Close Planning and Research Projects and Associated Retention

Documents Retention after final payment
FMIS project agreement/modifications 3 years
Consultant services contract 3 years
University research contract 3 years
Revisions/change orders 3 years
Invoices and billing support documentation (timesheets, travel, etc.) 3 years
Final work products 3 years
Documentation of other costs billed to Federal funds 3 years
MPO UPWP1 3 years
Audits (may occur after project close) 3 years or after audit is closed and finding resolved, whichever is later.
Documentation of litigation or claims 3 years or after any claim or litigation is closed and finding resolved, whichever is later.

Note:

1The UPWP (Unified Planning Work Program) likely supports multiple FMIS project authorizations and should be retained until all work items under that UPWP have final billing, then 3 years.

Table 2: Documents Needed to Close Preliminary Engineering (Design/Environment) Projects and Associated Retention

Documents Retention after final payment1
FMIS project agreement/modifications 3 years
Consultant services contract 3 years
Project agreements between State DOT and local public agencies, Federal Lands Highway, or other  entity 3 years
Revisions/change orders 3 years
Invoices and billing support documentation (timesheets, travel, etc.) 3 years
Final plans/specifications/work products2 3 years
Interstate access approval2 3 years
Utility agreements2 3 years
Value engineering study(ies)2 3 years
Design exception documentation2 3 years
Design decision documentation2 3 years
NEPA documentation2 3 years after construction project/mitigation and commitments complete3
Final ROD/FEIS/FONSI2 Indefinitely3
Audits (may occur after project close) 3 years or after audit is closed and finding resolved, whichever is later.
Documentation of litigation or claims 3 years or after any claim or litigation is closed and finding resolved, whichever is later.

Notes:

1 Documentation of costs for PE should be retained until right-of-way and/or construction proceeds due to pay-back requirements that could occur under the 10-year rule.
2 Documentation may also be required to be retained to support Federal eligibility of construction costs.
3 Refer to NEPA retention requirements.

Table 3: Documents Needed to Close Right-of-Way Projects and Associated Retention

Documents Financial Retention after final payment1
FMIS project agreement/modifications 3 years
Consultant services contract 3 years
Revisions/change orders 3 years
Invoices and billing support documentation (timesheets, travel, etc.) 3 years
Right-of-way acquisition documentation2 3 years
Real property and equipment records 3 years after disposal, replacement, or transfer.3
Audits (may occur after project close) 3 years or after audit is closed and finding resolved, whichever is later.3
Documentation of litigation or claims 3 years or after any claim or litigation is closed and finding resolved, whichever is later.

Notes:

1 Documentation of costs for right-of-way acquisition should be retained until construction proceeds due to pay-back requirements that could occur under the 20 year rule.
2 Documentation may also be required to be retained to support Federal eligibility of construction costs.
3 Refer to 49 CFR 18.42(c)(2).

Table 4: Documents Needed to Close Construction Projects and Associated Retention

Documents Retention after final payment
FMIS project agreement/modifications 3 years
Plans, specification and estimate (PS&E) 3 years
Bid/award documentation 3 years
Revisions/change orders 3 years
Invoices and billing support documentation 3 years
As-built plans 3 years1
Materials records 3 years2
Field books/diaries 3 years
Documentation for construction engineering costs 3 years
Force account documentation 3 years
Utility/railroad agreements 3 years
Environmental permits 3 years3
Alternative contracting method approval/public interest finding/SEP-14 or SEP-15 approvals 3 years
Right-of-way clearance 3 years
Final acceptance checklist/supporting documentation/contractor release 3 years4
Final estimate voucher/invoice 3 years
Final acceptance of ITS/technology related elements of the project should be based on the test plans initially developed during the design phase of the project where hardware specifications and software requirements have been defined 3 years5
Materials certification (23 CFR 637) 3 years
Verify completion and/or status of environmental commitments 3 years
Warranty documentation 3 years or to end of warranty6
Final Inspection and Acceptance Report 1446 3 years
Documentation from earlier phases that supports construction cost eligibility/PS&E approval 3 years
Audits (may occur after project close) 3 years or after audit is closed and finding resolved, whichever is later.
Documentation of litigation or claims 3 years or after any claim or litigation is closed and finding resolved, whichever is later.

Notes:

1 Indefinite retention recommended until reconstruction occurs.
2 Including material certifications as applicable.
3 Other regulations may supersede retention period.
4 See https://www.fhwa.dot.gov/construction/cpmi04.pdf p. G15.
5 See http://intra.fhwa.dot.gov/aem/aem.pdf, p. 74 of 182.
6 Adequate project documentation should be retained with extended warranty provisions.

Table 5: Documents Needed to Close Projects with Other Authorizations and Associated Retention

Documents Financial Retention after final payment
Indirect cost rate approvals (to support costs in projects) 3 years1
Toll credits documentation 3 years after credits used2
Credits for bridges not on Federal-aid highways 3 years after credits used as match and final payment on project
Documentation pertaining to credits for in-kind contributions or other soft match 3 years after credits used as match and final billing on project
Documentation pertaining to GARVEE bond debt service payments 3 years after retirement of bond
   
Reportable income transactions 3 years after the end of the grantee’s (State DOT) fiscal year in which the income is earned4

Notes:

1 See 2 CFR 200.333(f) for details.
2 Including documentation on earning such credits.
4 See 2 CFR 200.333(e).

 

Page posted on May 24, 2018.
Federal Highway Administration | 1200 New Jersey Avenue, SE | Washington, DC 20590 | 202-366-4000