Federal rules require the retention of client records based on the submission date of the final Expenditure Report for the grant year in which the client was closed. This process pertains to paper client records as well as electronic consumer records.

Social Security Cost Reimbursements: To ensure the availability of claims documentation for auditing and post-payment quality control purposes, all Cost Reimbursement payment-related documentation should be retained for a minimum of six years after the close of the federal fiscal year in which payment was made. Per the General Records Schedule (GRS) for Federal Records Management. 

Federal Policy

Records are retained until three (3) years after the submission date of the final Expenditure Report for the grant year in which the client was closed.

The following is an excerpt from EDGAR stating the record retention policy:

EDGAR 34CFR 80.42(b c): "Length of retention period. (1) Except as otherwise provided, records must be retained for three years from the starting date specified in paragraph (c) of this section. (c) Starting date of retention period. (1) General. When grant support is continued or renewed at annual or other intervals, the retention period for the records of each funding period starts on the day the grantee or subgrantee submits to the awarding agency its single or last expenditure report for that period."

State Policy: In accordance with Record Retention Schedule 39 (39-27), Nebraska Department of Education-Vocational Rehabilitation, per Nebraska Secretary of State, terminated and outcomes cases will not be destroyed until five (5) years after the FY records closed; thus, still in compliance with federal guidelines stated above.

Retention and Destruction Chart:

Federal Fiscal Year Closed	Last Federal Expenditure Report	Records Destroyed
FFY 17	11/15/18	11/15/22
FFY 18	10/29/19	10/29/23
FFY 19	12/30/20	12/30/24
FFY 20	1/30/22	1/30/26
FFY 21	1/30/23	1/30/27
FFY 22	1/30/24	1/30/28
FFY 23	1/30/25	1/30/29
FFY 24	1/30/26	1/30/30
FFY 25	1/30/27	1/30/31
FFY 26	1/30/28	1/30/32
FFY 27	1/30/29	1/30/33
FFY 28	1/30/30	1/30/34

State Records Retention Center:

1. At a maximum, cases closed after three fiscal years may be sent to the State Records Center for storage until released for destruction. If space is an issue or per office procedures, cases may be sent to State Records Center after one (1) fiscal year.

2. Offices who retain cases until the destruction date must complete the Records Disposition Report when the records are destroyed. This form is available on the Secretary of State's web site.  Once the report has been filed, you will receive a confirmation email from the Secretary of State’s Office which you should print off and keep for your records as well as forwarding the confirmation email to Edie Schleiger, edie.schleiger@nebraska.gov

3. Any questions on how to send and retrieve materials to Records Retention Center email Edie Schleiger, edie.schleiger@nebraska.gov

4. To request a casefile or specific information from the casefile, email edie.schleiger@nebraska.gov with the name of the client, date of birth, box number the file is in and last four digits of SSN. Records Management can either send the file OR they can scan and send a link of a specific file content. Example, link to the Individualized Plan for Employment.
5. In accordance with Record Retention Schedule 39 (39-27), Nebraska Department of Education-Vocational Rehabilitation, per Nebraska Secretary of State, cases will not be destroyed until (5) years after the FY records closed.

Social Security Cost Reimbursements:  Cost Reimbursement cases will be flagged in the case management system QE2 and retained in the system for six years after the close of the federal fiscal year in which payment was made. Proof of payment can include the types of documentation listed below and will be requested from E1:

• Copies of all direct cost invoices that show: date of service, type of service rendered, cost of service, proof of payment, name and address of payee, etc.
• Copies of bills, invoices and receipts under the vendor’s letterhead.
• Copies of signed and dated certification that the services were provided

Once a cost reimbursement has been received a copy of the signed Individualized Plan for Employment (IPE) and any amendments must be uploaded to the QE2 case. The Assistant Director will flag the case in QE2 once the cost reimbursement is received and QE2 will generate a To Do List to upload the IPE and any amendments.