Introduction

The Office of Grants Management is the repository of grant documentation for Open Society Foundations and has primary legal responsibility for the maintenance of grant records. Effective October 2012, GM maintains electronic grant records in Foundation Connect; prior to that date, GM stored its records in the Grant Tracker system. Grant documentation is contained in a unique electronic proposal record using a system-generated log identification number

Prior to the launch of Foundation Connect, GM also kept a paper file for each grant awarded. GM currently does not maintain paper grant files, with the exception of sensitive grants that only have minimal information recorded in Foundation Connect, and grants made by the OSI-Budapest Foundation entity, for which paper copies of grant agreements must be retained for legal reasons.

OSF U.S. entities are required by the IRS to keep records for a period of three years after the filing of annual tax returns. (See IRS Publication 4221-PF, Compliance Guide for 501(c)(3) Private Foundations (available at http://www.irs.gov/pub/irs-pdf/p4221pf.pdf). The European foundations must retain paper grant records for six years and electronic records indefinitely.

At a bare minimum, for audit purposes, OSF must maintain records that show:

A. Name and address of grantee

B. Amount distributed

C. Purpose of grant

D. Approval process history

E. Evidence that the grant was in compliance with OSF’s Conflict-of-Interest Policy

F. For the European entities, a “grant balance sheet”, with signatures from the granteeconfirming receipt of installments

In addition, grant records contain:

A. Proposals and budgets

B. Docket write-ups/Pre-Grant Inquiries

C. Payment approval history

D. Grant agreements

E. Finance and narrative reports

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