Can the records for ESG be retained in an electronic format or must hard copy records be retained?

Date Published: February 2015

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Documentation of each program participant's qualification as homeless or at risk of homelessness and other program participant records must be retained in accordance with the requirements at 24 CFR part 576.500(y). Recipients/subrecipients may store files electronically, but must be able to produce records in hard copy upon request, or allow them to be viewed as part of an on-site or remote monitoring or audits conducted by designated federal agency staff or by the HUD Office of Inspector General. Additionally, if the recipient/subrecipient uses an electronic system, it must maintain an adequate back-up system for the files, and must ensure that privacy protections are established and followed that adhere to other federal privacy regulations, such as HIPAA (Health Insurance Portability & Accountability Act).

The OMB OmniCircular, at 2 CFR part 200.335, encourages the use of electronic recordkeeping whenever practicable.

Tags: ESG Program Requirements - Expenditures and Recordkeeping