Document Retention

Delegates must maintain records for 10 years to demonstrate compliance with regulatory requirements, including standards of conduct education, FWA and general compliance training, OIG/GSA exclusion checks, and supporting policies and procedures. A delegate may be called upon by our organization, or a regulatory agency to provide documentation upon request. Failure to comply may result in any of a series of regulatory enforcement actions and our remediation activities.


  • Communication of Standards/Code of Conduct in an email, website portal or contract;
  • FWA and general compliance training methods, materials used for training, attestations or electronic certifications that include the date of the training;
  • Method of OIG/GSA and state (if applicable) exclusion checks and a copy of a sanction check report for each employee/contractor; and
  • Policies and procedures that describe the processes used to meet the regulatory requirements.