1. Recordkeeping. The grantee must ensure that records are maintained sufficient to establish that each member was eligible to participate and that the member successfully completed all requirements. A program may store member files electronically if the program can ensure that the validity and integrity of the record is not compromised. The Corporation will recognize electronically stored files where:
The electronic storage procedures and system provide for the safe-keeping and security of the records, including:
Sufficient prevention of unauthorized alterations or erasures of records;
Effective security measures to ensure that only authorized persons have access to records;
Adequate measures designed to prevent physical damage to records; and
A system providing for back-up and recovery of records; and
The electronic storage procedures and system provide for the easy retrieval of records in a timely fashion, including:
a. Storage of the records in a physically accessible location;
b. Clear and accurate labeling of all records; and
c. Storage of the records in a usable, readable format.
Where there is a requirement for a signature on a record, electronically stored records must include an image of the original signature; records without signatures, when required, are considered incomplete.
2. Verification. The grantee must obtain and maintain documentation as required by 45 CFR§2522.200(c). The Corporation does not require programs to make and retain copies of the actual documents used to confirm age or citizenship eligibility requirements, such as a driver’s license, or birth certificate, as long as the grantee has a consistent practice of identifying the documents that were reviewed and maintaining a record of the review.
To verify whether the member meets the requirements relating to high-school education, the grantee must obtain from the member, and maintain in the member’s file, a written declaration under penalty of law that the member meets the requirements of these provisions relating to high school education as required by 45 CFR§2522.200(b). If the member has been determined to be incapable of obtaining a high school diploma or its equivalent, the grantee must retain a copy of the supporting independent evaluation.
3. Confidential Member Information. The grantee must maintain the confidentiality of information regarding individual members. The grantee must obtain the prior written consent of all members before using their names, photographs and other identifying information for publicity, promotional or other purposes. Grantees may release aggregate and other non-identifying information, and are required to release member information to the Corporation and its designated contractors. The grantee must permit a member who submits a written request for access to review records that pertain to the member and were created pursuant to this grant.