900 Sponsored Research and Federal Property

901: Accountability of Equipment on Sponsored Awards

Property Management Policy & Procedure Manual
Section 900: Sponsored Research and Federal Property
Effective: 03/01/1979
Revised: 05/22/2006

Purpose

To comply with federal, state and sponsor mandated requirements regarding equipment purchased or acquired on grants or contracts.

Background Information

The federal government specifies screening, tagging, use, maintenance, reporting and disposal requirements for property accountable to federal grants and contracts.  See PRO-Ex11: Types of Federal Property.

Policy

Property acquired from a research sponsor or purchased with sponsored research funds is accountable to the grant or contract.  Contract authority must exist for the acquisition of facilities, special test equipment and other capital equipment on sponsored research funds. Equipment budgeted in the grant or contract award is assumed to be approved by the award sponsor.  Additional acquisitions of capital equipment on award funds must be pre-approved in writing by the sponsor when required by the regulations of that sponsor.

There may be additional management procedures and restrictions required by an award sponsor.  In the case of federally sponsored research, procedures and restrictions are specified in OMB Circular A110 (Property Standards section), OMB Circular A21, the Federal Acquisition Regulations (FAR), and the NASA Grant Handbook, as well as terms of the individual contract or grant.  (Note: The NASA Grant Handbook has been updated as of October 19, 2000.  The revised rules are not retroactive, but affect awards begun after that date.) 

Principal Investigators acquiring equipment for sponsored research are held accountable for following the Sponsor's requirements regarding screening, receiving, acquisition, tagging, use, maintenance, storage, physical inventories, record keeping, reporting and disposition of property.

Additional Information

See Federal Publications for additional information on federal requirements at the links below:

Office of Management & Budget (OMB)
OMB Circular A21
OMB Circular A110
Federal Acquisition Regulations (FAR)

902 Principal Investigator Responsibilities

902-01: Screening

Property Management Policy & Procedure Manual
Section 902: Principal Investigator Responsibilities
Effective: 07/01/1996
Revised: 05/22/2006

Purpose

To comply with federal, state and sponsor mandated requirements regarding equipment purchased or acquired on grants or contracts.

Background Information

The federal government has outlined 15 functional areas of property management including screening, tagging, use, maintenance, reporting and disposal requirements for property accountable to federal grants and contracts.

Policy

Equipment will be screened as required by University policy, OMB Circular A110 (Property Standards section), OMB Circular A21, the Federal Acquisition Regulations (FARs), and the NASA Grant Handbook. 

Procedure

Principal Investigator Responsibilities

Screening

  1. Equipment Share Screening

State and federal policies require that scientific equipment be made available for sharing if it is not fully utilized by the accountable department. 

  • As part of the grant proposal process, a PI must contact Property Management to see if equipment budgeted in the proposal is already available for sharing at OSU.  This is part of the check-off process described in the Sponsored Project Operations Manual.
  • When practical, the PI should contact Property Management again to see if shareable equipment has become available before a purchase order is issued. If shareable equipment is identified, an agreement may be negotiated between the two departments.  Property Management can determine whether property is available for sharing from a general description of the equipment and how it will be used.  The percentage of time the equipment is in use is a standard field in the inventory record and should be updated by the responsible department as needed. Guidelines for shared use are as follows:
  • This is a "no challenge/no conflict" system.  No pressure may be applied by the lender, the borrower or the administration at any stage of the process.
  • The departments and/or individuals involved must agree in advance upon the terms of all shared use arrangements, including utilization schedules.
  • University-funded equipment, however acquired, may be shared.  Agency owned equipment may also be shared, when it does not interfere with the original contract or grant and when the Contract Administrator approves the share agreement.
  • Departments may not charge rental fees for the shared use of university owned equipment acquired with federal funds.  However, reasonable maintenance, repair, calibration, or other costs directly related to the shared use may be billed on a journal voucher.
  1. Department of Defense Screening

In the Federal Acquisition Regulations, the Department of Defense specifies the following screening requirements for contract fund acquisitions.

  • Automatic Data Processing Equipment (ADPE) with acquisition cost greater than $25,000 must be screened by submitting form DD-1851 to the Office of Naval Research (ONR) in Seattle. Acquisition is not approved until the Defense Automation Resources Information Center (DARIC) returns a Certificate of Non-Availability.
  • Industrial Plant Equipment (IPE) is defined as equipment used for any of the following purposes: cutting, abrading, grinding, shaping, forming, joining, testing, measuring, heating, treating, or otherwise altering the physical, electrical or chemical properties of materials, components, or end items entailed in manufacturing, maintenance, supply, processing, assembly, or research and development activities.  IPE with acquisition cost greater than $15,000 must be screened by submitting form DD-1419 to the ONR office in Seattle. Acquisition is not authorized until the Defense Industrial Plant Equipment Center (DIPEC) returns a Certificate of Non-Availability.
  1. NASA Screening

In the NASA supplement to the Federal Acquisition Regulation, NASA specifies the following screening requirements for property acquired on NASA contracts.

  • Automated Data Processing Equipment (ADPE) with acquisition cost greater than $25,000 must be screened by submitting form DD-1851 to the ONR office in Seattle. Acquisition is not authorized until NASA approval is received.
  • Centrally-reportable equipment is defined as plant equipment, special test equipment (including components), special tooling and non-flight space property that is commercially available, identifiable by a manufacturer and model number, and valued at $5,000 or more.  Centrally-reportable equipment must be screened by submitting form DD-1419 to the ONR office in Seattle. Acquisition is not authorized until NASA approval is received.

Additional Information

See Federal Publications for additional information on federal requirements at the links below:

Office of Management & Budget (OMB)
OMB Circular A21
OMB Circular A110
Federal Acquisition Regulations (FAR)

902-02: Principal Investigator Responsibilities - Ordering, Receiving & Tagging

Property Management Policy & Procedure Manual
Section 902: Principal Investigator Responsibilities
Effective: 07/01/1996
Revised: 05/22/2006

Purpose

To comply with federal, state and sponsor mandated requirements regarding equipment purchased or acquired on grants or contracts.

Background Information

The federal government specifies screening, tagging, use, maintenance, reporting and disposal requirements for property accountable to federal grants and contracts.

Policy

Departments will order, receive and tag equipment as required by the contract or grant, OMB Circular A110 (Property Standards section), OMB Circular A21, the Federal Acquisition Regulations (FARs), and the NASA Grant Handbook.

Procedure

Principal Investigator Responsibilities

Ordering, Receiving & Tagging Procedures

  1. Ordering

Acquisition documents should be detailed with accurate descriptions of assets and properly coded with the contract or grant index or identifier. Items and quantities requisitioned, purchased or fabricated should be reasonable, contractually authorized, based on firm requirements, and not available from existing stocks.

Orders for supplies and assets should be processed in a timely manner to minimize emergency acquisitions or requisitions. Economic ordering practices should be applied, when applicable. Outstanding orders should be monitored until received, and cancelled or amended promptly when contract modification or other events change requirements.

  1. Receiving

Government furnished property (GFP) received for sponsored research must be reviewed immediately upon arrival (see FAR 45.502-2 Discrepancies Incident to Shipment). If overages, shortages, or damages are discovered the PI should provide a statement of the condition and apparent causes to the sponsor's property administrator within 48 hours. However, when the shipment has moved by Government bill of lading and carrier liability is indicated, the PI should report the discrepancy to the sponsor's property administrator within five working days. (A copy of all correspondence with the sponsor's property administrator should be sent to the Office of Post Award Administration (OPAA) and Property Management.)

On contractor-acquired property, the PI is responsible for necessary action to correct overages, shortages, or damages in shipment of property from a vendor or supplier. However, when the shipment has moved by Government bill of lading and carrier liability is indicated, the PI should report the discrepancy to the sponsor's property administrator within five working days. (A copy of all correspondence with the sponsor's property administrator should be sent to OPAA and Property Management.)

Packing slips, bills of lading, reports of discrepancies and related documentation must be returned to the department's Accounting Office and filed with other related grant and contract related information. Packing slips for capital equipment should be attached to the copy of the invoice and sent to Property Management where they will be kept for audit and a copy should also remain with the department. (See FARs 45.502, 45.502-1, 45.502-2)

The receiving process should also include the proper identification of the new equipment (see FAR 45.506 Identification). This includes identifying serial numbers for the asset record, adding the asset to inventory and marking the asset with identifying tags (see "3. Tagging" in this document).

  • See PRO-Ex1: Creating an Asset Record from a Banner Invoice to add contractor-acquired property to inventory from an invoice.
  • See PRO-Ex3: Fixed Asset Data Entry form for the method of adding government-furnished property to inventory. A copy of the packing list should accompany the Fixed Asset Data Entry form for GFP, and care should be taken to identify the contract or grant number the GFP will be accountable to for reporting purposes. Property Management should be notified of GFP within 5 days of receipt.

The federal government requires specific information to be maintained in the asset record (see far 45.505-1 Basic information).  This includes, but is not limited to:

  • The name, description, and National Stock Number (if furnished by the Government or available in the property control system).
  • Quantity received (or fabricated), issued, and on hand.
  • Unit price (and unit of measure).
  • Contract number or equivalent code designation.
  • Location.
  • Disposition.
  • Posting reference and date of transaction.
  1. Tagging

All property acquired as part of a sponsored research project that meets the OSU capital equipment definition or the sponsor's capital equipment definition must be added to inventory. When an inventory number is assigned, a barcode inventory tag is sent to the responsible department. Affix this tag to the equipment within five working days of receipt. Use a clear laminate cover (obtained from Property Management) to protect tags that will be exposed to the weather elements or to other harsh environments.

Federally-owned equipment also requires a "Property of U.S. Government" tag, furnished by Property Management. This tag is sent with the barcode tag to the responsible department when the inventory number is assigned. Place this tag on the equipment at the same time as the barcode tag. Some sponsoring organizations supply their own numbered tags for equipment tracking as well. Affix these tags to the equipment upon receipt.

Equipment with Federal and\or sponsoring organization tags may not be cannibalized or disposed of without written authorization from the sponsoring agency. Request for this authorization needs to be coordinated with Property Management and OPAA.

Additional Information

See Federal Publications for additional information on federal requirements at the links below:

Office of Management & Budget (OMB)
OMB Circular A21
OMB Circular A110
Federal Acquisition Regulations (FAR)

903: Reporting & Inventories

Property Management Policy & Procedure Manual
Section 900: Sponsored Research and Federal Property
Effective: 07/01/1996
Revised: 01/18/2012

Purpose

To properly perform periodic physical inventories requested by sponsors and to complete appropriate reports.

Background Information

Federal property is reviewed every two years as part of OSU's biennial physical inventory.  In some cases a federal agency or other sponsoring organization may require an annual or more frequent inventory of equipment.  The Department of Defense (DOD), NASA and the Department of Energy (DOE) require inventories according to the following schedule:

  • October 15th of each year, OSU completes summary reports of values for various DOD-owned property categories, plus additions and deletions on form DD 1662 and submits them to the Office of Naval Research in Seattle.  The DD 1662 is used for government owned property on Department of Defense contracts and is effective as of September 30th.  This form is not required for DOD grants, only contracts.
  • October 15th of each year, OSU completes summary reports of values for various NASA-owned property categories on NASA form 1018 and submits them to ONR in Seattle (or to the appropriate national lab, such as JPL).  This form is completed for NASA contracts or sub-contracts with NASA-owned property but is not required for grants.
  • October 15 of each year, NASA-owned property on research grants is reported.  There is no specific form for grants.  A simple memo and a complete inventory list are sent to the NASA office in charge of the award.  Negative reports (in the form of a memo stating that there is no government owned property accountable to a given award) are required for grants in effect on/before October 19, 2000.  The new NASA Grant Handbook does not require negative reports for grants awarded after October 19, 2000.

Policy

The reporting of equipment and taking of physical inventory will be accomplished as required by the grant or contract, OMB Circular A110 (Property Standards section), OMB Circular A21, the Federal Acquisition Regulations (FARs), and the NASA Grant Handbook.

When federally owned property is no longer needed to perform the contract (also called excess property), the Principal Investigator (PI) is responsible for informing Property Management.

Procedure

Reporting and Inventories Required By Sponsor

Responsible Party Action

Business Affairs, Fixed Assets

Generate a list of property accountable to each award and submits it to the Principal Investigator or the department's inventory coordinator, for a physical inventory. This inventory list includes each asset's recorded condition.

Principal Investigator (PI)

Conduct a physical inventory using the list and communicates to Business Affairs, Fixed Assets the property's (1) current location, (2) current condition, and (3) if it still needed for current project. Any discrepancies must be explained and communicated to Business Affairs, Fixed Assets.

Business Affairs, Fixed Assets

Analyze data to complete and submits the appropriate forms to the Office of Post Award Administration (OPAA) for final signature.

Office of Post Award Administration (OPAA)

Sign the original forms, retains copies, and forwards the originals to the appropriate agency.

Reporting of Lost, Damaged or Destroyed Property

Responsible Party Action

Principal Investigator (PI)

  1. Promptly identify, investigate and report incidents of loss, damage and destruction of government owned property in accordance with instructions in the award documents. 
  2. Fully document each incident with the following information (1) What happened, (2) where, (3) when, (4) how, and (5) who was involved.
  3. Notify the following parties within five working days of the loss:
  • The Sponsor's Contract Officer;
  • OPAA for coordination of reporting procedures;
  • Departmental Inventory Coordinator (for processing of a Property Disposition Request (PDR) if the asset cannot be repaired);
  • Business Affairs, Fixed Assets, for notification of the sponsor's Property Administrator, and preparation of requests for relief of accountability;
  • The State Police, if the event is the result of criminal activity;
  • Risk Management.

Business Affairs, Fixed Assets

  1. Submits the information provided by the PI to (1) the sponsor's property office requesting release of accountability, and (2) OPAA.
  2. Upon receipt of the release, inputs the PDR into FIS Banner.

Note: Even though Federally owned property is not insured by the State of Oregon, Risk Management maintains records of certain types of loss and damage and should be notified.

Reporting of Excess Equipment

Responsible Party Action

Principal Investigator (PI)

  1. Determines when equipment is no longer necessary for the performance of the contract or award.
  2. Prepares list of excess equipment and submits to Business Affairs, Fixed Assets.

Business Affairs, Fixed Assets

  1. Prepares and submits either a "request for disposition" letter or Form 1428 - Inventory Schedule B to (1) the sponsor's property office, and (2) OPAA in accordance with FAR 45.606. (Such schedules are used for screening with other Federal agencies so that the equipment may be redirected to another agency.)
  2. Upon receipt of sponsor's instructions for equipment disposition, forwards information to departmental inventory coordinator.
Department  Complies with instructions (returns equipment to sponsor, ships to a third party, sends to OSU Surplus Property Department, etc.)

904 Contract Close-out

904-01: Contract Close-Out - Accountable Equipment

Property Management Policy & Procedure Manual
Section 900: Sponsored Research and Federal Property
Effective: 07/01/1996
Revised: 08/11/2008

Purpose

To properly verify accountable equipment at the close of a federal contract or award.

Background Information

Federal Acquisition Regulation (FAR) 45.508-1 specifies the reporting requirements for federal contracts.

Policy

Upon termination or completion of an award, federally owned property must be verified and reported according to FAR 45.508-1 or within the time specified within the grant or contract.

Final reports are due to NASA on or before 60 days after the expiration date of the award. Final reports are due to DoD awards on or before 90 days after the expiration of the award.

Procedure

Reporting and Inventories Required By Sponsor

Responsible Party Action
Office of Post Award Administration (OPAA)
  1. Notify Property Management that an award close out is necessary.  (OPAA must send a list of acquired equipment to the sponsor when required by the award document, regardless of whether it is sponsor-owned property or not.)   
Property Management 
  1. Prepare and submits a list identifying the accountable equipment to the Principal Investigator (PI).
  2. Request physical inventory be taken by the Principal Investigator (PI) and to report the current condition of the equipment.
PI
  1. Take physical inventory and reports results to Property Management.
Property Management 
  1. Complete appropriate forms (as required by the sponsor) and submits to OPAA for final signature.
OPAA  
  1. Ask the PI what equipment disposition s/he wants to request from the sponsor.
  2. Review, sign off and submit forms (required by sponsor) to the sponsor's property office requesting final disposition instructions.
  3. Upon receipt of instructions, notifies Property Management of final disposition instructions.
Property Management
  1. Follow the sponsor's disposition instructions for equipment (return to sponsor, transfer to new award, released to OSU, etc.). See examples.

Examples:

  1. Release - If the sponsoring organization releases equipment title to OSU, OPAA notifies Property Management to correct the title codes on the equipment records. The release date is also recorded on the inventory record in place of the contract number. The PI\Department is also notified of any release. If the value of the released asset is below the capital threshold for OSU, Property Management will remove it from inventory and notify the owning department to add the item to their supply inventory.

    Property Management will compute the value of each released asset as if it had started to depreciate upon acquisition.  Assets that had an acquisition value below the capital threshold, or a depreciated value that does not meet the capital threshold, will be removed from inventory and treated as minor equipment.  Per OUS instructions, released assets whose depreciated value meets the capital threshold will first be removed from inventory, then a new record will be created and capitalized at the depreciated value.  The records will be cross-referenced and a new bar code tag will be submitted to the department.  The department should remove the original bar code tag and the "Property of US Government" tag, and place the new tag on the asset.

  2. Transfer - The sponsor may allow accountability for equipment to be transferred to a new or follow-on award. OPAA will notify Property Management to make the necessary changes (new grant code and sponsor ID number) to the asset records. Title will remain vested with the sponsor. When accountability transfers to a new award the equipment is no longer considered contractor-acquired property, but government furnished property (GFP).   This results in the title remaining with the Federal Government and the title of GFP will almost never be released to OSU.
  3. Return - If the disposition instructions from the sponsoring organization require that the equipment be returned to the sponsor or sent on to a third party, the responsible department will handle the shipping arrangements. A copy of the disposition instructions should be attached to a completed Property Disposition Request (PDR) form and forwarded to OPAA.  OPAA will forward the PDR to Property Management for removal of the record from inventory.

904-02: Contract Close-out - Residual Supplies

Property Management Policy & Procedure Manual
Section 900: Sponsored Research and Federal Property
Effective: 07/01/1996
Revised: 05/22/2006

Purpose

To properly account for and report unconsumed supplies acquired on a federal contract or award.

Background Information

Federal Acquisition Regulation (FAR) 45.508-1 specifies the reporting requirements for federal contracts.

Policy

Upon termination or completion of an award, a project's residual (unconsumed) supplies that exceed $5,000 actual cash value (i.e., the value that OSU could receive if they were auctioned off in their current condition) may have to be inventoried and reported if required by the terms of the grant or contract.

Procedure

Reporting Residual Supplies

Responsible Party Action
Office of Post Award Administration (OPAA)
  1. Notify Property Management that an award close out is necessary for supplies.
  2. Request from the PI the value of minor equipment and residual supplies that were purchased on the award.
Principle Investigator 
  1. Furnish this information to OPAA.
Property Management
  1. Prepare appropriate forms (as required by sponsor) and forward to OPAA.  
OPAA 
  1. Submit the appropriate forms to the sponsor. 
  2. Upon receipt of the sponsor's disposition instructions, notify department of necessary action (if any) to be taken.
Department 
  1. Follow the disposition instructions provided by OPAA.

905: Property in the Hands of Subcontractors

Property Management Policy & Procedure Manual
Section 900: Sponsored Research and Federal Property
Effective: 04/01/2000
Revised: 05/22/2006

Purpose

To properly account for the equipment in the hands of subcontractors.

Background Information

Subcontracts are predicated on the prime award, and a copy of the prime award is always attached to the subcontract agreement.  The terms of the prime award flow down to the subcontractor.  However, such terms are not automatic in the area of federally owned property.

Policy

A subcontractor must have an approved property system, including procedures for the care and maintenance of equipment, in order to receive federally owned equipment.  The subcontractor is required to adequately care for and maintain such property (as required by federal regulations per OMB Circular A-110 or FAR 45.510) and assure that it is used only as authorized by the contract.  Equipment reports must be submitted to OSU for referral to the sponsoring agency, as required by the prime award and\or at contract closeout.

The Contract Office must give prior approval for the acquisition of equipment not specified in the subcontract where title will vest with the federal government.  A subcontractor will assume full risk for loss, damage or destruction of federal property in the subcontractor's possession or control except to the extent that the subcontract, with the advance approval of the Contracts Office, relieves the subcontractor from such liability, per FAR 52.245-4.  If there are unusual property requirements, they will be stated in a special conditions attachment to the subcontract. These will include title restrictions and reporting requirements.