AC 31.2015

August 3, 2015

MEMORANDUM TO FEDERAL AGENCY CONTACTS: Conflict Between GRS 1.1 and the FAR

Many agency records officers are fielding questions from their finance and procurement offices about the conflicting retention periods for procurement records described in General Records Schedule (GRS) 1.1 and the current version of the Federal Acquisition Regulation (FAR). The GRS authorizes disposal for all procurement records 6 years after final payment or cancellation. However, the FAR states that records of procurement actions above the simplified acquisition threshold (SAT) must be retained for 6 years and 3 months, while records of procurement actions below the SAT may be destroyed when 3 years old.

The General Services Administration (GSA) concurred with NARA’s revisions to GRS 1.1, stating that its research showed that the FAR publishes retention periods as specified in the GRS. The process for updating the FAR did not begin until NARA published GRS 1.1 and is not yet completed. Updating the FAR is a deliberative process, managed by a FAR Implementation Team with representation from GSA, DoD, and NASA. NARA has been assured that the revision of the FAR is continuing and progress is being made. We anticipate that the new FAR text will cite the new GRS as the authority for the retention and disposition of procurement records. In the meantime, agencies should not destroy records below the SAT at 3 years of age as the authorization for that retention period was superseded by GRS 1.1.  

PAUL M. WESTER, JR.
Chief Records Officer
for the U.S. Government