Section 7: File Maintenance

Introduction

Sound fiscal and program management of the Texas Behavioral Traffic Safety Program can be verified through the development and maintenance of complete and accurate files. This section provides detailed procedures on the basic file content and responsibilities for maintaining files from project initiation through activation, closeout, audit, and final storage.

Background

The TxDOT Traffic Safety Electronic Grants Management System (eGrants) electronically houses the official records of the administration of Traffic Safety Division - Behavioral Traffic Safety Section (TRF-BTS) funds. These files document that proper management and accounting methods were used to allocate and disburse public funds to an approved project. The proper and careful management of these files and the documents they contain helps to ensure that:
  • The project is established and the subgrantee is selected in a competitive, equitable, and legal manner.
  • Appropriate management of the project occurs during implementation, including proper disbursement of funds for approved and incurred costs.
  • The project is adequately monitored and evaluated to ensure the effective use of funds.
  • Documents are readily available to state and federal auditors, reviewers, and managers to verify completed work, legitimate expenditures, and adequate oversight.

File of Record

The TxDOT Traffic Safety Division (TRF), located at TxDOT’s Riverside Annex in Austin, Texas, is the record keeper for the State and Community Highway Safety Grant Program. Subgrantees are required to retain all source documents to support incurred expenditures.

File of Record Content

The contents of the file of record will vary, depending on the type of agreement. The file of record will include any or all of the following:
  • Project proposal/grant agreement and any amendments.
  • Correspondence.
  • Requests for Reimbursement (RFRs) with all supporting documentation.
  • Performance Reports with all supporting documentation.
  • Monitoring reports.
  • Pre-approvals (Supplemental Requests).
  • Equipment inventories.
  • Project accomplishments.
  • Other supporting documentation.

Managing File Contents

In the file of record, each project file will contain the original document or reference to the document that verifies the legal and administrative actions necessary for the award, implementation, monitoring, and evaluation of each project.

File Security

All file information is a matter of public record and is subject to the Texas Public Information Act (TPIA).
However, unless required by the TPIA, proper file management precludes public access to the files, which may include information of a sensitive nature such as personnel salaries, budget information, and internal correspondence.
 Access to the file of record will therefore generally be limited to those governmental officials with responsibility for the submission, operation, and close-out of the projects. These officials will include project managers and program managers, program planners and administrators, and auditors.
TxDOT policy requires that we safeguard confidential/sensitive information. Therefore, as a reminder, all attachments submitted via eGrants must not contain confidential/sensitive information. Before submitting any attachments, redact, blank-out, or block such information, including social security numbers (even if it is only the last 4 digits of an SSN), items such as bank account numbers (generally found at the bottom of a check), credit card data (displaying the last 4 digits is acceptable), and/or any other confidential/sensitive data that is not required/needed to support grants-management, performance reports, reimbursement requests, or monitoring reports.

File Retention

Texas Government Code §441.1855, enacted by Senate Bill 20, requires that all grant agreement records, including each grant contract entered into by a state agency and all grant contract solicitation documents related to the grant, must be retained for seven years from the date the grant is completed or expires, or all issues that arise from any litigation, claim, negotiation, audit, open records request, administrative review, or other action involving the grant contract or documents are resolved, whichever occurs last. TRF eGrants records are purged annually, according to the TxDOT Records Retention Schedule, and based on the annual federal fiscal year closeout on December 31. The term “records” is explained to include all books, documents, papers, accounting records, and other evidence pertaining to costs incurred and work performed.
The file of record (eGrants) will retain all grant agreements and grant related documents for seven years.
As stated in the Grant Agreement General Terms and Conditions, the subgrantee is required to retain the agency's grant agreement and grant related documents for four years from the date of final payment under this agreement, until completion of all audits, or until pending litigation has been completely and fully resolved, whichever occurs last.