NLPES Question of the Month

October - November 2002

HOW DOES YOUR OFFICE RETAIN ITS WORKPAPERS? (For example, how long do you keep workpapers following completion of an evaluation? Do you keep some workpapers solely in electronic form--and, if so, has this worked well? How do you store confidential information in your workpapers?)

Tim Osterstock, Utah

We are required to retain our work papers indefinitely. Work papers are kept by the auditor-in-charge for the first year so they are accessible for an annual follow-up. Critical audits, that may have continued legal or political interest, are kept under lock and key in the office for a longer period. Once we are truly finished with the work papers they are sent to State Archives where they are treated as historically significant documents that must be retained for posterity. Evidently, archives thinks more highly of our work than we do or, perhaps, they just got a really good deal on warehouse space.

Heather Moritz, Colorado

After an audit is completed, we send our workpapers to State Archives for storage. State Archives holds the workpapers for a specific time period (i.e., seven years) and then destroys them. Since our workpapers are not open to public inspection without a majority vote of our Legislative Audit Committee (no such vote has ever occurred), Archives requires the State Auditor or a Deputy State Auditor to grant access in writing to any files we would like to retrieve at a later date. Confidential data can be stored in the workpapers because access is so limited. Even so, we may shred sensitive documents before sending the workpapers to Archives (e.g., juvenile probation records containing names, child abuse and neglect reports).

We do sometimes include diskettes or, more recently, CD-ROM's with the workpapers when the occasion calls for it. For example, in recent years we have increased our use of ACL and other tools for analyzing large data sets. If we have obtained a large data set and performed analysis on it as part of our audit work, we would probably include a CD-ROM or diskette in the workpapers instead of printing out a lengthy report.

Ken Levine, Texas Sunset Commission

We keep workpapers that we consider essential (we maintain a list of types of workpapers that are to be maintained in our central file system) for 12 years or to the next Sunset review of that agency. These papers have more to do with the resulting legislation from a Sunset review than the actual evaluation workpapers. We advise supervisors to work with analysts to determine what to keep, usually for two years. Items like correspondence fall under state retention records guidelines, which generally provide for a ten-year retention.

Electronic files are generally kept for four years on the server, and then downloaded to CD-ROM. We may change that to two years. As I talked about above, certain documents must be saved, either in electronic or hard copy form (or both). For example, we save all our workpapers used in development of fiscal notes for Sunset legislation during the session. For the most part, these papers are in electronic form only.

Regarding confidential workpapers, we try not to have them. Information that is legally confidential in the originating agency (agency under review...) is subject to penalties for disclosure. We try to view such info at the agency, or return it to the agency after use. Since our workpapers are not subject to open records requests, confidential information is pretty safe here. We just feel it is better to avoid maintaining such information on our site. We do, of course, have the ability to lock confidential information when necessary.

Dean Swenson, Wisconsin

At the Wisconsin Legislative Audit Bureau, the official versions of all workpapers are the paper copies, which contain hand-written notes and questions from supervisors, indicating that the workpapers have been reviewed, and the necessary supporting documentation. While an audit is in progress, however, workpapers are also saved to a shared computer network drive that all team members can access. Electronic versions of the workpapers allow team members to quickly search for information about specific issues, which is particularly useful when drafting the final audit report.

The hard-copy workpapers and their attachments are the official record. After an audit's release, the unofficial electronic versions of the workpapers are deleted from the shared computer drive. At the team's discretion, databases and other hard-to-reproduce electronic data, but not the accompanying workpapers, can be saved to a CD-ROM and stored long-term.

Workpapers containing confidential information are identified as such in red ink on the first page and are stored in the workpaper boxes. When the Audit Bureau receives a request from the public to review a project's workpapers, the project supervisor is responsible for removing the confidential workpapers.

After an audit is completed, the workpapers are generally kept in our office for 6 to 12 months, or until the team no longer needs quick access to them in order to conduct follow-up work or respond to questions from legislators and others. In some instances, workpapers may be retained in our office for several years before they are sent to the State's official records center for long-term storage.

Jim Pellegrini, Montana

We keep all workpapers for at least four years. For some projects, if we feel there may be legislative interest in the subject in future years we may keep workpapers for up to 10 years. We have three current major projects that we are keeping all documentation in electronic workpaper form. This has worked well so far, but we are working on standardizing protocol. As for confidential information, we store all of our workpapers in a vault so they are secure. We do not typically let others view our workpapers independently, so in a sense we keep everything confidential. If formally asked to release the working papers, we will remove all workpapers marked as confidential. One other thing: moving to electronic working papers will cut back on the fuel necessary to heat the office under current budget cuts.

John Norris, Alabama Department of Examiners of Public Accounts

We keep audit working papers for three audits or ten years, whichever is shorter. We keep working papers for sunset evaluations for not less than four years. For other types of reports, we have no set time.

Sunset evaluations and some audit working papers are prepared and stored in electronic form on CD. No storage problem. Reduced size of working papers is a plus for storage. Our advice - do not store CDs in a flexible container with diskettes and pack them tightly. The result is a warped and unusable CD.

Rick Riggs, Kansas

In Kansas, we have a policy that workpapers (hardcopy documents and CDs/diskettes/Zip disks of data) are to be kept a minimum of 3 years. In practice, we go through and trash workpapers whenever we run out of file space, which usually is around every 5 years. When we trash workpapers, we retain 3 items: the audit plan, any electronic media containing big datasets, and survey documents with summaries of survey results. There have been several cases over the years where we've found old audit plans, data, or surveys useful when we audit the same topic again.

Douglas Wright, Tennessee, Office of Research, Comptroller of the Treasury

We do not have a set time period for keeping our workpapers. If we start to run out of room in our storage, we can archive them at the state archive. The workpapers we create, such as interviews and summaries, are all kept electronically, in addition to many of the reports that we download from the internet. Because all of our workpapers are technically public documents, we do not have a special policy for "confidential" information.

Joel Alter, Minnesota

The topic of how long to keep workpapers is under discussion in our office, but we presently keep workpapers for ten years prior to their destruction. We keep indexed boxes of hard-copy workpapers, plus we archive electronic versions of selected workpapers (particularly items such as large spreadsheets, SPSS files, and raw data files). We have had some concerns about the ability to retrieve electronic workpapers at a future date (due to unforeseen changes in software), so we have tried to limit the number of instances in which we rely solely on electronic versions of workpapers. We usually keep the hard-copy workpapers in our building for three or four years after the completion of an evaluation-so that we can retrieve documents quickly if questions arise. After this time, most workpapers are sent away for off-site storage. Typically, archived electronic files can be retrieved by our IT staff on the same day that our staff submit a request.

When we complete a report, we annotate a final version of the report with references to the supporting workpaper files. This provides our staff with a quick reference for locating the supporting documentation for findings and statements in a report.

We have defined a small subset of workpapers that are retained indefinitely at our office. These "permanent files" include items such as workplans, project descriptions, drafts of the report submitted to the agency (before our revisions), and the final copy of the report with annotated workpaper references.

Not all of our workpapers are public information. For instance, if we get "nonpublic" data from state agencies, we must keep the data classified in this way in our workpapers. We also have authority to classify certain interviews as confidential. If there is a request for a review of workpapers by a member of the public, it is up to the project manager to ensure that confidential workpapers are removed prior to review. Our index of workpapers for a given project should clearly indicate which workpapers are confidential. Also, hard copy versions of individual workpapers that are confidential should have a yellow cover sheet that identifies them as confidential (and the basis for this designation).