Legal Compliance
Legal compliance is an important topic that should be considered for all funding organizations. Funding transparency should be a high priority for all parties involved. Here are resources and related information for funders to consider:
Office of Foreign Assets Control – Sanctions Programs and Information
The Physician Payments Sunshine Act was passed in March 2010 as part of the Patient Protection and Affordable Care Act. The purpose of the Sunshine Act is to create greater transparency of the financial relationships among pharmaceutical and medical device manufacturers, physicians and teaching hospitals. It is administered by the Centers for Medicare and Medicaid Services (CMS) under a program called the Open Payments Program.
Records retention requirements
Records consist of information created, received and maintained as evidence of business activities. The International Council on Archives (ICA) defines a record as “recorded information produced or received in the initiation, conduct or completion of an institutional or individual activity and that comprises content, context and structure sufficient to provide evidence of the activity. While the definition of a record is often identified strongly with a document, a record can be either a tangible object or digital information which has value to an organization.”
The term includes a document, paper, letter, information stored or maintained electronically and a data-processed or image-processed document.
A records retention period provides how long to keep records before they can be destroyed. Retention periods are based on state, federal, and private sponsor requirements. A retention period is comprised of 2 parts:
- The cut-off
- The retention number
- ex: 6 years after submission of financial status report
- ex: 3 years after final termination of grant/contract
[The Guide to Records Management Records retention policy – templates and examples]
- [Slideshow from InPhilanthropy]