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  1. Hi, With the increase in online T&E solutions, has DCAA established additional guideline related to Original Receipts vs. scanned and digital copies, etc. My question is related to 4.703.(c).3 (see below) "The contractor or subcontractor retains the original records for a minimum of one year after imaging to permit periodic validation of the imaging systems." I have delved deep into the internet and have found no guidance. If we meet (c) 1 and 2 then 3. defeats the purpose of reduction of paperwork, time for scanning and maintaining originals, etc. I have been through DCAA audits where the scanned document was accepted because of policies, procedures, internal audit, approvals, etc. were followed. If a company has an expense policy that covers the process, will DCAA waive 3? If DCAA doesn't accept a scan or electronic copy as "original" why should a company use one of the new online T&E services? Thoughts? As always, thank you for your review, input and guidance Marc 4.703.. . . (c) Nothing in this section shall be construed to preclude a contractor from duplicating or storing original records in electronic form unless they contain significant information not shown on the record copy. Original records need not be maintained or produced in an audit if the contractor or subcontractor provides photographic or electronic images of the original records and meets the following requirements: (1) The contractor or subcontractor has established procedures to ensure that the imaging process preserves accurate images of the original records, including signatures and other written or graphic images, and that the imaging process is reliable and secure so as to maintain the integrity of the records. (2) The contractor or subcontractor maintains an effective indexing system to permit timely and convenient access to the imaged records. (3) The contractor or subcontractor retains the original records for a minimum of one year after imaging to permit periodic validation of the imaging systems. (d) If the information described in paragraph (a) of this section is maintained on a computer, contractors shall retain the computer data on a reliable medium for the time periods prescribed. Contractors may transfer computer data in machine readable form from one reliable computer medium to another. Contractors’ computer data retention and transfer procedures shall maintain the integrity, reliability, and security of the original computer data. Contractors shall also retain an audit trail describing the data transfer. For the record retention time periods prescribed, contractors shall not destroy, discard, delete, or write over such computer data.
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