Standard 16: Accountable and timely project close-out.

• Primary responsible: Project manager or chief of party (PM/CoP)
  • The PM/CoP works with other project and close-out team members to develop a project information close-out plan and ensure project close-out documentation and other key project documents, records, and data are complete and properly stored.

• Others involved: Members of the CRS project team; members of the CRS cross-discipline project close-out team, which typically includes staff from programming (including MEAL), finance, human resources, supply chain management, ICT, and other operations staff (including the head of operations (HoOps)); IDEA or other HQ staffFor example, PIQA Global Grants; HQ Overseas Finance for USG prime awards.
  • Members of the project team work with the PM/CoP to prepare final project deliverables and ensure documents from earlier phases of the project cycle are complete and properly archived.
  • Members of the project close-out team prepare close-out documents and archive per the agreed protocol or share with the PM/CoP for archiving.
  • The HoOps, or the country program Records Coordinator appointed by the HoOps, incorporates the project-specific record retention plan into the country program Record Retention Schedule, per the CRS Records Management Policy.
  • For centrally-funded awards, IDEA or other HQ staff support with saving final project documentation to CRS internal systems (e.g. Gateway).

• Develop/finalize a plan to retain, archive, or dispose of project documents, records, and data (digital and otherwise) early in the close-out process.
• Retain agreed documents, records, and data after finalization and submission (as applicable), in line with the project close-out plan and any donor deadlines.

This key action complements Standard 18, key action 5, which focuses on programmatic and learning-related project documentation. This key action focuses on project-specific documents, records, and data outside of standard financial and procurement documentation which operations staff maintain per CRS policy.

Follow these steps to ensure key project close-out documentation and other important project documents, records, and dataThe term “documents, records, and data” is used throughout this key action to encompass the many types of information generated by a project, from meeting minutes, to reports, to distribution lists, to databases. are complete and accessible for future reference:

1. The PM/CoP works with the project team (for programming-related documents, records, and data) and project close-out team members (for general close-out and operations-related documents, records, and dataAs noted above, the project-specific information management close-out plan focuses on project-specific documents other than the financial and procurement documentation and records maintained by those teams for all projects, per CRS policy (e.g. POL-FIN-DOC-008: Transaction Documentation and Procure2Pay).
     ) to update the project information management planThe project team, including ICT staff, should have developed an information management plan as part of project start-up, outlining what information to document, where and how to save project documents, records, and data, etc. and develop a project information management close-out plan and data exit strategyA project data exit strategy typically addresses data storage, data transfer and formatting of data into sharable formats.

• Ensure that MEAL and ICT members of the project or project close-out team are part of the discussion.
• For externally-funded projects, review any donor requirements on project data and record retention and archiving from the project agreement to ensure these are reflected in the project information management close-out plan.
• Formalize the project information management close-out plan in a project information Retention, Archival and Disposal (RAD) Plan While the concept of a RAD plan is typically applied to project data, it can also be applied to a broader set of project information (documents, records, and data).  which reflects stakeholders’ anticipated end-of-project and post-project data and information needs.
  • Use the ELAN Data Retention Tip SheetWhile this document was developed to support Cash Transfer Programs, it contains useful guidance related to data retention, archiving, and disposal applicable to any project. for guidance and use second sheet (Example RAD Plan Template) in the Tools for Developing a Project Information RAD Plan file as a starting point if helpful.
  • Update the list of project-specific documents, records, and dataNote that records related to project personnel will be retained by CRS human resources staff per CRS policy. created and identify other documents, records, or datasets that will be generated in the close-out period (e.g. final evaluation report, endline survey data, project disposition plan, etc.).
  • Compare the list of project documents currently saved on GatewayAll key documents from the design phase of the project should have been posted as part of early start-up/handover activities. See Standard 6, key action 1. As noted in other key actions, upload other key documents prepared and submitted during project start-up and implementation to the Gateway record once finalized (e.g. after incorporating any revisions requested by the donor). to the complete list of Gateway Key Documents. Build into the RAD plan clear responsibility and timelines for ensuring complete project documentation on Gateway.
  • Refer to the first sheet (Potential Project Documents for Retention) in the Tools for Developing a Project Information RAD Plan file for ideas on documents (beyond the key documents required for Gateway) the project may have created and may need to retain and archive.
  • Ensure the RAD plan reflects project-specific applicable data, records, and other document retention requirements per CRS policies and local law.For country programs, these requirements are specified in an office-specific Records Retention Schedule required for each country program office per CRS’ Records Management Policy. For HQ departments, each department manager must review and update the master CRS Records Retention schedule annually.
  • Keep in mind that effective project information management during close-out includes deciding what not to keep. Not all project information will remain useful post-project or in perpetuity. Archiving such information can make it harder to find useful documents, records, or data, and presents risks for data security and exposure of program participants’ personally identifiable information.
• For projects using a Cash and Assets Transfer (CAT) Platform, use CRS’ CAT guidance on data protection and CAT Closure.

Key project documents: The list of Gateway project and award record documents is the key starting point for identifying documents to be retained as part of a project information management close-out plan. However, identifying all applicable documents that are saved or will be saved on Gateway is only one part of the retention and archiving process. Discussions about likely end-of-project and post-project stakeholder data and information needs may highlight the need to retain other project documents, records, and data to address anticipated internal and external stakeholder information and learning needs.For example, if it’s anticipated that the project will be audited, or if there is likely to be significant internal or external interest in project data and learning because the project was a pilot or included a research component.  It may also be necessary to retain “more than the usual” project documentation if project implementation occurred in a highly volatile context, or otherwise dealt with significant risks, issues or other challenges or changes. . Additionally, the project team may decide to include a copy of documents stored on Gateway in a more comprehensive project archiveThe Gateway “document type” field helps staff navigate Gateway key documents. However, storing project documents in a comprehensive project archive with flexible options for folder names, etc. may make it easier for staff to search project documents, records, and data, including in the case of an audit or other review. saved in a separate platform or format (see step 2 below).

2. The PM/CoP works with ICT staff to determine the most appropriate platform,In addition to uploading required key documents to Gateway. formats (e.g. for project data), and system for archiving the project documents, records, and data identified for retention in the RAD plan.

• For less complex projects, Gateway may be the most appropriate platform, with documents above and beyond the required Gateway key documents stored in a well-organized project archive Zip file.
• Other options for digital file archiving may include a OneDrive folder or SharePoint space.
• Agree on a final labeling convention that will be clear for others looking for project files without guidance from the project team. Circulate the file labeling convention to all staff who will be saving and/or uploading documents and include it as a reference document (e.g. a README file) in the main archive folder.
• Arrange for a backup copy of the archived digital documents, records and data (stored in a different digital location).
• See the ELAN Data Retention Tip Sheet for additional guidance.

3. In addition to saving files to GatewayIf a team member who finalizes a document to be saved on Gateway does not have a Gateway user license, the PM/CoP should ensure that the staff member shares the document with the PM/CoP or designate for uploading. per Gateway key document requirements, the PM/CoP ensures that members of the close-out and project teams save files to the agreed platform (or in a “project archive” folder to be uploaded to Gateway as a zipped file) per the RAD plan, using the agreed naming convention. 

• Ensure staff seek support as needed from ICT staff to anonymize project monitoring data and protect the confidentiality of any other sensitive project data.
• Make sure that project staff who depart the project prior to the project end date have uploaded or handed over any final documents/current draft versions of documents identified in the RAD plan for which they were responsible.

Documenting close-out decision-making: Clear, timely documentation of project decisions is good practice throughout the project management cycle. It is especially important during close-out as the PM/CoP and project team make many final decisions as they prepare to disband. Senior management must ensure project staff document and archive documentation of significant decisions taken during the close-out period, especially decisions that impact the project budget,For example, if the budget manager or other individual per CRS’ map of authority authorizes an expense as part of final programming activities that was not part of the originally approved CRS or partner budget (though it is within approved budget line item flexibility), document the justification for incurring and approving that unplanned expense. If a cost that was originally planned to be charged to a donor budget is instead charged to CRS cost share as part of financial close-out, document that change and the reason. If a questioned cost is resolved during financial close-out with partners, provide a detailed explanation of the resolution. If an authorized staff member approves a waiver in line with CRS policy, ensure the justification for requesting and approving the waiver is crystal clear.  along with the rationale for such decisions. Documentation of such decisions helps staff who may be called upon after project close-out to help an internal or external stakeholder to understand final project expenditures, information in a project report, etc. Handover notes prepared during the close-out period, the minutes of project close-out team meetings, the final version of the comprehensive project close-out plan, and similar close-out documentation can also help shed light/reconstruct the story of close-out decisions. Include these documents in the project archive.      

4. For ICT devices approved for disposal under the project disposition plan, ICT staff should ensure all project data on the devices has been archived per the project RAD plan and then wipe clean all project data, other agency data, and CRS-licensed programs and applications before completing disposal.
5. The HoOps (or Records Coordinator appointed by the HoOps) adds the agreed project-specific record retention plan to the country program Record Retention Schedule, per the Records Retention Policy.