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