Decoding Grant Management-Success Tip: Adequate Documentation

February 6, 2025

Like zombies rising from the dead, inadequate documentation has a way of returning to haunt you in an alarming way. Want an example? I analyzed a case study where the review of administrative and clerical costs resulted in $1.7 million in costs being deemed unallowable! All those moaning sounds are not just the zombies. So what makes documentation “adequate,” and what are some examples of adequate documentation? Here are some tips for grant managers.

Documentation Requirements

According to the OMB Uniform Guidance for Grants, the award recipient must be able to support accounting and cost records with adequate source documentation. The documentation should provide the means to verify the proper separation of costs among various federal awards and non-federal spending. The extent of the documentation required is affected by the size and complexity of the non-federal entities and the existing control mechanisms. The nature and type of the documentation needed may also vary, depending on the relationship to specific internal controls.

Examples of Adequacy

Adequate source documentation includes having receipts with sufficient detail to be able to determine:

What the funds were spent on
When the spending occurred
Who made the purchase

Another example includes timecards or other labor reporting completed promptly. A timecard should have sufficient detail to determine:

What award was worked on
When the work was done
Who worked on the award
When the time was reported

Some specific examples of adequate source documentation might include:

A purchase request or requisition signed by a manager with direct budgetary responsibility for the project or program being charged for the purchase
Reports supported by financial records that are reviewed and signed by an appropriate level of management

An example of poor source documentation is a receipt that provides too little detail about the purchase, such as a credit card receipt listing the total purchase amount but not the item(s) purchased. Without purchase details, federal recipients cannot ensure that purchases are allowable under the terms and conditions of a federal award.

Other Types of Documentation

Not all examples are related to financial records. Adequate program documentation can include having a detailed narrative explaining the project or program objectives. Consider some of the specific documentation requirements for information technology departments. The overall control environment requires that IT departments document each major application system in an operations and maintenance manual. Examples of adequate source documentation in an IT systems manual would include:

The software functions and hardware requirements, how the system operates, and how the databases interact
Explanations of various system messages and queries that are run or received
A document listing the restart and notification procedures in the event of a system error or failure
A list of reports that are routinely generated by the various systems

Likewise, purchasing departments have a variety of additional types of documentation to maintain. For example, purchases should be properly authorized by following internal policies and procurement standards. Therefore, purchasing documentation without evidence of proper authorization may be considered insufficient source documentation. It is recommended that the authorization document be included with the rest of the related purchase documentation to support purchasing compliance. Without prior authorization documented in the purchasing records, the non-federal entity may not be able to demonstrate that the purchases were properly authorized before the purchase was made. It is recommended that the authorization document be included with the rest of the related purchasing documentation to support purchasing compliance.