6.7 Policies and Procedures for Equipment Purchased with Federal and Certain Other Sponsored Funds
This policy section outlines additional mandatory responsibilities and procedures required for the control, use, care, maintenance, and reporting for equipment acquired with Federal funds and certain other sponsored funds (where specific grant provisions may dictate) and Government owned equipment.
Upon acceptance of a federal award, the university becomes responsible and accountable for the Government property acquired with the underlying grant funds. The federal Government's guidance, rules and regulations codified in OMB Circular A-110 require the University to procure, use, and control property in accordance with Federal laws, executive orders, and directives from granting Sponsoring Agencies. The Government relies upon the University's internal control structure, environment and procedures to ensure compliance and adherence with these requirements.
Definitions of terms associated with government property:
Contractor - includes any person or organization that enters into a contract with the United States or any department or agency thereof. For purposes of this policy, WSU is the contractor.
Contracting Officer - Government representative who enters into, administers, or terminates contracts on behalf of the Sponsoring agency.
Government-furnished property - property in the possession of, or directly acquired by the Government and subsequently furnished to the Contractor for performance of a grant or contract.
Contractor-acquired property - property acquired, fabricated or otherwise procured by the Contractor performing a contract, to which the Government has title.
Property Administrator - an authorized representative of the Contracting Officer assigned to administer the contract requirements and obligations relating to government property in the custody or control of the Contractor.
A required process when equipment is being purchased with federal funds to determine the existence of similar assets on campus prior to acquisition of assets required by or specified in a grant to avoid duplicating asset purchases. Screening must occur even when the equipment require is specifically approved and funded in the award. Certain federal agencies may require additional screening which would be specified in individual award documents, if required. (refer to Section 6.1.1)
The university's Property Management Office is responsible for maintaining the Fixed Asset System in Banner Finance. This system contains the official property records of the university in the form and structure required or mandated by Sponsoring Agencies. The property records include information such as location, description, unit acquisition cost, asset type and tag date for each individual piece of equipment acquired which meets the University capitalization threshold.
As required by OMB Circular A-110, the university conducts a physical inventory on a biennial basis and the results are reconciled with current property records. All equipment encompassed by this section is subject to the biennial inventory.
Subcontractor Control of Government Equipment
For subcontracts involving equipment, WSU delegates to the subcontractor, via the subcontract document, responsibility for all government equipment acquired or borrowed by a subcontractor. Each subcontract entered into must contain specific provisions concerning the subcontractor's responsibility for government property. Such provisions require that the subcontractor assume the same responsibility and obligations of WSU (those outlined within this policy) with respect to the property while it is under the subcontractor's control. The subcontractor's property control system should include procedures necessary for satisfying these requirements and responsibilities.
Reporting of Government Property in the Possession of the University
The PMO is responsible for preparing annual, special or periodic property reports required by federal agreements. On a monthly basis, SPA notifies Fiscal Operations when a report is due for submission to the Contracting Officer. The applicable university Department, its Dean or their designee, and the PI are responsible for investigating any loss, damage, destruction or theft of equipment and must promptly furnish a written narrative to the Property Administrator as soon as the facts become known.
Utilization of Equipment
The PI, their designee, or the responsible university employee should restrict the utilization of equipment acquired for use under a specific grant or contract to the purposes of that grant or contract unless otherwise noted in the award document or written approvals from the Contracting Officer.
Periodically, all property including government property in the custody of a department should be reviewed for utilization. Any property that is either temporarily or permanently not in use should be reported as excess equipment to the PMO. The PMO will screen excess equipment against other campus needs and then to external users if necessary, to assure Government property utilization is maximized. Equipment that has become idle or which represents excess equipment, after a reasonable period of time must be reported to the Contracting Officer for disposition instructions.
Equipment Care and Maintenance
Principal Investigators, their designees and departments are responsible for safeguarding government property against loss or damage. PIs and other responsible individuals must ensure that the property is maintained and repaired by qualified personnel or return it to the manufacturer when repairs are required. Records must be maintained documenting normal and routine preventive maintenance (i.e., lubrication, cleaning, calibration, and regularly scheduled inspections). The maintenance records should include the date, description of the maintenance performed, details of inspections, who performed the maintenance or inspection, deficiencies discovered, and the corrective action taken.
Sponsored Program Related Property Closeout
Immediately upon termination or completion of a government grant or contract, the department, PI or individual(s) having custody of equipment must perform a physical inventory adequate for appropriate disposition of all government property. It is the responsibility of the PI or their designee to request disposition instructions from the agency or it's authorized Contracting Officer. The PMO can assist by providing the equipment inventory detail for the grant or contract.
The university is relieved of responsibility for government owned property only when the:
Sponsoring Agency Property Administrators determine when property has been consumed or expended properly and in reasonable amounts in the performance of the federal contract.
Government property is shipped from WSU pursuant to the Property Administrator instructions, except when the shipment is to a subcontractor or other WSU location designated or authorized by the Administrator.
Contracting Officer determines and notifies the University in writing that the underlying government property has been lost, damaged, destroyed or stolen during the performance of a federal contract.
Title transfers to WSU and thereby ceases to be government property pursuant to the grant or contract provisions.
Questions regarding this APPM should be directed to the Associate Vice President and Controller for Fiscal Operations.