Policy: 501-Federally Titled Property
Date: 01/21/2000 (Last updated: 03/09/2010)

Table of Contents

SECTION 1 - INTRODUCTION

This Administrative Policy and Procedures Manual for the Control and Management of Federally Titled Property provides general instructions for managing Federally Titled Property in the custody of the University of Wisconsin-Madison. 

Federal sponsoring agencies require the University to observe the property management standards as prescribed by the Office of Management and Budget (OMB) Circulars No. A-21 and A-110, Federal Acquisition Regulations Part 45 and all Federal agency regulations as stated in the agreement. The University of Wisconsin-Madison, as a recipient of extramural Federal funding, accepts a responsibility to administer each funded project in accordance with these regulations.

While many of the following policies and procedures outlined in this manual also apply to University Titled Property, this administrative manual specifies special rules which apply only to Federally Titled Property.

With the varied and often complex activities pertaining to the acquisition, record keeping, utilization, reporting and disposition of Federally Titled Property, this manual cannot cover all questions on Federal Titled Property management. Principal Investigators and departmental personnel should be familiar with the provisions of each contract, grant, or agreement under their responsibility. Should inconsistencies arise between the policies and procedures in this manual and the terms contained in the contract or grant under which the property is accountable, the contract or grant shall govern.

University personnel are encouraged to contact Property Control for assistance or questions concerning Federally Titled Property. Property Control is located at 21 N. Park St., Suite 6101, Madison, WI  53715-1218.

Compliance with the policies and procedures contained in this paper is mandatory.

Back to Top

SECTION 2 - RESPONSIBILITIES

2.01 Property Control

Property Control is responsible for the overall management of Federally Titled Property acquired by and assigned to the University of Wisconsin-Madison in accordance with current Federal Property Management Requirements. This office is charged with establishing and maintaining necessary records to insure accurate accounting and reporting of all Government property while in the possession of the University.

2.02     Property Control Manager

The Property Control Manager has campus wide responsibility to implement and administer the provisions of this administrative manual and to establish and maintain equipment records and procedures necessary for campus compliance with Federal Property Management Requirements.

2.03     Office of Reseach and Sponsored Programs

The Office of Research and Sponsored Programs reviews project proposals on behalf of the Board of Regents, transmits the proposals to providers of extramural support and monitors fund expenditures. Research and Sponsored Programs is responsible for providing Property Control with contract information specifically related to property title and the dollar level at which the Government retains title.

2.04 Principal Investigator

Principal Investigator is the academic or administrative staff member responsible for initiating and conducting extramurally funded research, training or public service projects. This individual may also be referred to as the Project Director or Project Administrator. 

The Principal Investigator has the responsibility to ensure that all Federally Titled Property, either contractor-purchased or Government-furnished, is required to support research on the contract/grant under which it was acquired.  Federally Titled Property is not authorized to be used for personal purposes or gain. Failure to comply with the policies and procedures listed herein could result in a withdrawal of the privilege to use Government-owned property or it could cause the violator to be held financially liable for any willful misuse or misconduct in the control and management of Federally Titled Property in their custody, or both. Additionally, willful misuse of Federally Titled Property may result in Government termination of the Investigator's contract/grant.

2.05 University Employees

All University employees authorized by a Principal Investigator to acquire and utilize Federally Titled Property are responsible to ensure that the property acquired is needed and authorized for the purpose for which it was acquired.

Back to Top

SECTION 3 - DEFINITIONS

3.01 Acquisition Cost

The capitalized acquisition cost of an equipment item is the net invoice price of the equipment, including the cost of modifications, attachments, accessories, or auxiliary apparatus necessary to make the property usable for the purpose for which it was acquired. Other charges, such as the cost of installation and transportation should also be included.  Repairs, maintenance, and replacement parts are NOT included in the capiltalized acquisition cost.

3.02 Award

Financial assistance that provides support to accomplish a public purpose. Awards include grants or other agreements in the form of money or property in lieu of money, by the Federal Government to an eligible recipient.

3.03 Cannibalization

Cannibalization refers to either the reduction of equipment to parts in order to obtain needed components for other equipment, or the alteration of a piece of property that is generally obsolete due to age or technological advances.

3.04 Capital Equipment

Capital equipment is currently defined as any non-expendable individual item not permanently attached to buildings or grounds costing $5,000 or more and having a useful life of more than one year. Capital equipment can be Contractor-Acquired Property (CAP) or Government-Furnished Property (GFP). Federal agencies may establish higher dollar minimums for determining capital or reportable equipment, however, the University will inventory and report all property meeting the $5,000 minimum or report such property as set forth in the specific Federal agreement. See Office of Research and Sponsored Programs Notice 97-5.

3.05 Contractor

University of Wisconsin - Madison; The Board of Regents of the University of Wisconsin System

3.06 Contractor-Acquired Property (CAP)

Property purchased or otherwise provided by the contractor using contract funds.

3.07 Departmental Property Administrator

An employee designated by the department to administer property transactions within the department. The Departmental Property Administrator is the liaison between the department and Property Control. He/she is responsible for attaching decals to equipment and completing the Equipment Verification Form. 

3.08 Exempt Property

Property acquired in whole or in part with Federal research grant funds, the title to which is vested in the University without further obligation to the Federal government. Most property acquired by the University under Federal research grants qualifies as "exempt property" pursuant to Pub. L. 95-224.

3.09 Federally Titled Property

All property owned by or title to which is vested in the Federal Government under the terms of a contract or grant. Federally Titled Property includes both Government-Furnish Property and Contractor-Acquired Property.

3.10 Government Agency

A Department/Organization under the Administrative Branch of the Federal Government.

3.11 Government Contract/Grant

An instrument designed for allocating funds to the University by a Government Agency for use in the performance of research or other purposes, of which the Government has an interest.

3.12 Government-Furnished Property (GFP)

Property in the possession of or acquired directly by the Government, and subsequently delivered or otherwise made available to the contractor for use in performance of the contract. Government-Furnished Property is classified as Federally Titled Property unless ownership transfer is indicated. Government-Furnished Property is inventoried regardless of value.

3.13 Government-Owned Property

See Federaly Titled Property.

3.14 Principal Investigator

A University employee designated to perform or direct research under the terms of a Government contract/grant. Principal Investigators may also include Co-Investigators and Project Directors with implied equal responsibility.

3.15 Property Administrator

A Government Agency Employee that is designated to administer the contract requirements and obligations relative to Government property. If an authorized representative has not been designated as the Property Administrator, the contracting officer is the Property Administrator.

3.16 Property Control Officer

A University employee, normally the Property Control Manager, who is designated to acquire, administer, and maintain records and inventory control over Federally Titled Property assigned to the University and in the possession of a Principal Investigator.

3.17 Property Control System

Identifies a contractor's internal management program encompassing the protection, preservation, accounting, control and reporting of Federally Titled Property from its acquisition through disposal.

3.18 University

The Board of Regents of the University of Wisconsin System, the University of Wisconsin-Madison, its divisions and departments thereof.

Back to Top

SECTION 4 - PROPERTY MANAGEMENT STANDARDS

4.01 The University of Wisconsin's property management standards for Federally Titled non-expendable personal property shall include the following:

4.01.1 Property inventory records shall be maintained accurately and shall include:

  1. Equipment description and manufacturer's name
  2. Serial number, model number, and UW inventory number
  3. Location (building-wing-room and using department)
  4. Type of equipment (generally identified by the first two digits of the Equipment Classification Code)
  5. Acquisition Number (Purchase order, internal requisition, Federal Transfer Order Number)
  6. Acquisition Date
  7. Acquisition Cost
  8. Source of funding (each appropriation, if multiple) includes Fiscal Year- Fund-Project-UDDS-Program-Account
  9. Federal Agency name and Award Number
  10. Insurance code (identifies movable equipment or general contents
  11. Useful life
  12. Property Ownership (Federal, University, non-federal sponsor)
  13. Information from which one can calculate the percentage of Federal participation in the cost of the equipment
  14. Condition of the equipment

4.02 Property owned by the Federal Government shall be identified to indicate Federal ownership.

4.03 A physical inventory of property shall be taken and the results reconciled with the University property system once every two years. Any differences between quantities determined by the physical inspection and those shown in the property records shall be investigated to determine the causes of the difference. The physical inventory will verify the existence, current utilization and continued need for the property.

4.04 A control system shall be in effect to insure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft of non-expendable Federally Titled Property shall be investigated and fully documented. In addition, the University shall promptly notify the Federal sponsoring agency.

4.05 Adequate maintenance procedures shall be implemented to keep the property in good working condition.

4.06 Where the University is authorized or required to sell the property, proper sales procedures shall be established which would provide for competitive bidding to the extent practicable and result in the highest possible return.

4.07 Ultimate disposition data, including date of disposal and sales price or the method used to determine current fair market value where the University compensates the Federal awarding agency for its share will be maintained by the University's Surplus Disposal Department, SWAP, a subdepartment of Purchasing Services.

Back to Top

SECTION 5 - ACQUISITION

5.01 Equipment Screening

5.01.1 The Federal Office of Management and Budget Circular A-110 requires the University to have procedures in place in order to avoid unnecessary and duplicative purchases of equipment using Federal funds. See Office of Research and Sponsored Programs Notice 95-4.

5.01.2 Prior to initiating the process of acquisition of equipment items with federal funds, it is the responsibility of the Principal Investigator to screen University inventories to avoid equipment duplication.

5.01.3 Property Control will provide reports upon request to assist Principal Investigators in determining if equipment is currently available on campus as an alternative to the purchase of new equipment. Capital Inventory System data is also available on the Internet.

5.02 Contractor-Acquired Property

5.02.1 Many Federal agencies require contractors to obtain prior approval for the purchase of equipment not reflected in the budget proposal. The Federal Contracting Officer will ascertain whether the Federal Government can furnish the equipment. The Principal Investigator is responsible for obtaining such approval when required in advance of purchase.

5.02.2 When acquiring equipment by requisition or direct charge, correct account codes are essential for determining capital vs. non-capital equipment.  Only capital equipment should be coded to 4XXX series accounts.

5.02.3 The capitalized acquisition cost of an equipment item includes the net invoice price of the equipment, including the cost of modifications, attachments, accessories, or auxiliary apparatus necessary to make the property usable for the purpose for which it was acquired. Other charges, such as the cost of installation and transportation should be included. Repairs, maintenance, and replacement parts should NOT be included in the acquisition cost.

5.02.4 Equipment purchases must conform to all applicable University, State and Federal procurement guidelines.  See Purchasing Services How to Purchase Goods and Services.

5.03 Federal Excess Property/Government-Furnished Property

5.03.1 Principal Investigator may be authorized by the Contracting Officer to acquire Federal Excess Property for use on specified contracts or grants. This authorization should be stated in the terms and conditions of the official agreement with the sponsor.

5.03.2 Once the Principal Investigator locates Federal Excess Property, he/she should contact the Holding Agency listed to ensure the property is still available and to place a hold on the property.

5.03.3 The Principal Investigator contacts Property Control to initiate the transfer process. The following information must be furnished for each item of excess property: Holding agency property number (if available); Holding agency name and address; Item description including name, model and serial numbers, manufacturer, condition, acquisition cost; Contract/grant number to which the property is being transferred; Ordering agency name and address (agency awarding contract); UW fund/account; Holding agency name and address (currently has equipment); Location of equipment (if different from the holding agency address); Ship to name and address and shipping instructions.

5.03.4 Property Control will complete the Federal Transfer Order SF122, assign a University Transfer Order Number and forward to the Principal Investigator for signature. The Principal Investigator will also be requested at this time to provide a brief justification statement relative to the requirements for this equipment on the grant. The Principal Investigator will return all documentation to Property Control.

5.03.5 Property Control will sign the Transfer Order and forward the Order and justification statement to the Ordering Agency Contracting Officer for processing. A copy will be sent to the Principal Investigator.

5.03.6 The Contracting Officer will forward the approval copy to Property Control, who, upon receipt, will promptly forward a copy to the Principal Investigator and the holding agency, if requested.

5.03.7 Upon receipt of the transfer approval, the Principal Investigator will arrange for shipment of the property to the University. The Principal Investigator should notify Property Control when the equipment arrives on campus.

5.03.8 The Principal Investigator should examine the property immediately upon delivery and report any discrepancies to Property Control. This can include property not received, property damaged in transit or property items not in required condition for work performance.  Property Control will notify the Contracting Officer of these instances and request instructions. The Principal Investigator should file a claim with the carrier for any property damaged in transit.

5.03.9 Once the shipment is verified, Property Control will record the items in the University's Property System.

Back to Top

SECTION 6 - RECEIVING

6.01 All Federally Titled Property received as Government-Furnished property (GFP) or as Contractor-Acquired Property (CAP) must be inspected and checked promptly before the University assumes accountability.

6.02 Discrepancies in receipt of Government-Furnished property must be immediately reported to Property Control. The responsibility for inspecting and certifying that the property was received in good order and condition rests with the Principal Investigator.

6.03 Discrepancies in receipt of Contractor-Acquired Property must immediately be reported to Accounting Services-Accounts Payable. If the Order is marked as "Positive Approval", Accounts Payable will contact the department for authorization to pay the invoice.  All other orders are considered "Negative Approval" which allows for the usual payment process, without special department approval.  An invoice is automatically processed for payment and a copy is sent to the department for review. It is the department's responsibility to review the approved invoice and contact Accounts Payable prior to payment if there is a problem with the goods received.

6.04 After payment has been made for University acquired Federal property, Property Control will establish the necessary records and issue an identification decal to affix to the property by the Departmental Property Administrator.

Back to Top

SECTION 7 - IDENTIFICATION

7.01 All Federally Titled Property will be identified and clearly marked to indicate Federal ownership.

7.02 For Contractor-Acquired Property, Property Control will access the award summary in WISDM by funding source (Project) to determine where title vests for the equipment. This database is maintained by the Office of Research and Sponsored Programs.

7.03 Government-Furnished Property will be inventoried as Federally Titled Property provided the Government retains title to the property.

7.04 University Issued Decals:

7.04.1 If title to equipment vests with the Federal Government, Property Control will assign and issue a Federal decal.  The Federal decal is silver with red border and lettering indicating "Property of U.S. Government". These decals have the prefix "F".

7.05 Federal Agency Issued Decals:

7.05.1 Some Federal Agencies require agency decals to be affixed to their property. Upon receipt of these decals from the agency, Property Control will forward the decals to the Departmental Property Administrator requesting the decals be attached to the equipment items specified. A signed statement from the department certifying the decals have been attached will be required. The Federal agency decal number will be noted in the equipment record.

Back to Top

SECTION 8 - EQUIPMENT ACQUISITION FORM (EAF)

8.01 After entry of the initial inventory record for an equipment item, the Property System generates a report of that record called the Equipment Acquisition Form. The Equipment Acquisition Form reflects the inventory information entered for a specific piece of equipment and is the mechanism used to obtain information that was not available during the inventory process. Property Control forwards the equipment decal and Equipment Acquisition Form to the Departmental Property Administrator.

8.02 The Departmental Property Administrator should attach the Federal decal to the equipment item, verify the information printed on the form, supply any missing information and return the completed Equipment Acquisition Form to Property Control within thirty (30) days of receipt.

8.03 Follow-up Equipment Acquisition Forms will continue to be sent to the department on a bimonthly basis until such time that a completed Equipment Acquisition Form is returned with the required information.  In extreme cases, the department chair and/or dean may be contacted for assistance in obtaining delinquent Equipment Acquisition Forms.

8.04 Property Control will promptly update the equipment records when the Equipment Acquisition Forms are returned.

Back to Top

SECTION 9 - MOVING PROPERTY

9.01 The Principal Investigator is responsible for reporting all movement of Federally Titled Property in his/her custody to Property Control.

9.02 A change in the location of Federally Titled Property within a building needs to be reported only if the item will remain in the new location for a period of ninety (90) days or more.

9.03 Federally Titled Property moved between University Buildings must be reported immediately. 

9.04 Principal Investigators can report changes of location by the following methods:

9.04.1 Send memo to Property Control through campus mail.

9.04.2 Send email to any of the Property Control staff.

9.04.3 Access the Property Transaction Form on the web. Printout and complete the form and send to Property Control by campus mail or complete the form on the web and send it to Property Control electronically.

9.05 Federally Titled Property moved off-campus to a non-University site must be reported immediately. Information to be reported includes the decal number, property description, complete address of new location, a brief explanation why the property was moved to this location and the length of time the property will remain at the new location.  Receipt of equipment at off-campus sites must be verified and documented.  (See SECTION 10 - VERIFICATION OF PROPERTY LOCATED OFF-CAMPUS.)

9.06 All Federally Titled Property returned to campus from an off-campus site must be immediately reported to Property Control.

9.07 Property Control will update the equipment record as equipment information changes.  Property System data must reflect the current status of all Federally titled property.

9.08 When moving or shipping Federally titled property, the Principal Investigator must exercise adequate care in packing and crating to ensure the equipment reaches its destination in good condition. Shipments, both foreign and domestic, valued at $50,000 or more must be reported to Risk Management to arrange for proper insurance coverage during shipment. 

9.09 Loss or damage occurring during shipment must be reported to Property Control.  Property Control will advise the Contracting Administrator and request repair or disposition instructions.

Back to Top

SECTION 10 - VERIFICATION OF PROPERTY LOCATED OFF-CAMPUS

10.01 Tagging, location and usage of all Federally Titled Property located off-campus, for which the University of Wisconsin has custody, must be documented.

10.02 An Off-Campus Equipment Verification Form must be completed by site personnel for each equipment item under their custody. One Verification Form can be used for a group of items provided a listing of the equipment is attached to and becomes part of the Form.

10.03 Property shipped to off-campus sites and not yet tagged requires departments to forward the Off-Campus Equipment Verification Form to site personnel when the equipment is initially inventoried and the Equipment Acquisition Form and decal are received from Property Control.

10.04 Property already tagged and moved from campus to an off-campus site requires a completed Verification Form from site personnel upon receipt of the equipment at the site.

10.05 Each time property is moved from one off-campus site to another off-campus site, a new Verification Form must be completed.

10.06 During the required biennial physical inventory of Federally titled property, all property located at an off-campus site must be physically verified. The Off Campus Equipment Verification Form can be used for this purpose. One Form can be used for multiple equipment located at a specific site provided a listing of that equipment is attached to and becomes a part of that Form. (See SECTION 12 - PHYSICAL INVENTORIES.)

10.07 Departments should retain a copy of the Off-Campus Equipment Verification Form and forward the original to Property Control. These Forms should be readily available for inspection by Federal and University auditors.

10.08 Departments are required to return the completed Verification Form to Property Control within thirty (30) days from receipt of the equipment at the off-campus site.

10.09 Movement of Federally Titled Property must be immediately reported to Property Control.  (See SECTION 9 - MOVING PROPERTY.)

10.10 Departments can copy and use the Off-Campus Equiment Verification Form.  Departments are permitted to design and use forms developed within their departments, provided the forms include the information required, i.e., verification of tagging, location, usage and signature of site representative.

Back to Top

SECTION 11 - STORAGE, MAINTENANCE AND SECURITY

11.01 Storage

11.01.1 The Principal Investigator, when temporarily storing Federally Titled property, must take appropriate measures to adequately protect and preserve such property in order to prevent loss, damage and deterioration. All storage areas should be clean and materials secured according to best housekeeping methods.

11.01.2 The property should be clearly identified as Government-owned property.

11.02 Maintenance

11.02.1 The Principal Investigator is responsible for the care and maintenance of Federally Titled Property in his/her custody. The same care and maintenance procedures that are applicable to University-owned equipment will be afforded Federally Titled property. All repairs and maintenance costs are NON-CAPITAL, and the account used in the funding string should reflect this.

11.03 Security

11.03.1 The Principal Investigator is responsible for the security of Federally Titled Property accountable under his/her contract(s). Adequate measures must be taken to prevent loss, theft, or unauthorized movement of Federally Titled Property from the premises on which such property is located.

Back to Top

SECTION 12 - PHYSICAL INVENTORIES

12.01 Interim Physical Inventories

12.01.1 A complete physical inventory of all Federally Titled Property will be conducted once every two years.

12.01.2 A computer listing of Federally Titled Property to be inventoried will be distributed to the Departmental Property Administrators in April of each odd numbered year. Property Control will segregate the computer listings by Department and UW Fund/Account Numbers for ease in distribution to the various Principal Investigators.

12.01.3 The Departmental Property Administrator is responsible for distributing the Inventory Listings to the specific Principal Investigators within their respective departments.

12.01.4 The Principal Investigator is responsible for completing the Inventory of Federally Titled Property in their custody, following the instructions included with the physical inventory packet. The Principal Investigator may delegate completion of the inventory, however, the Principal Investigator is ultimately responsible for the accuracy of all information returned to Property Control.

12.01.5 For each piece of Federally Titled Property NOT-FOUND during the physical inventory, the Principal Investigator must provide an explanation of the circumstances surrounding the loss. Copies of any documentation relating to the loss should be returned with the explanation.

12.01.6 Property Control will reconcile the results of the Physical Inventory with the University's Property System and is required to report the results and all discrepancies to the Office of Naval Research and the sponsoring Federal Agencies.

12.01.7 During the interim between formal physical inventories, Property Control may distribute equipment lists to those departments having custody of Federally Titled Property. This will serve as a reminder to departments that all changes in the status of Federally Titled Property must be promptly reported to Property Control. This verification exercise will help maintain a degree of accuracy required in the Property System and will help lessen the burden when completing the formal physical inventories.

12.02 Final Physical Inventories

12.02.1 Once a contract/grant has terminated, the sponsoring agency requires the University to conduct a final physical inventory of all equipment acquired under the contract as part of the contract close-out procedures.

12.02.2 Property Control will forward a listing of the equipment accountable under the contract/grant to the Departmental Property Administrator/Principal Investigator for verification. 

12.02.3 The Principal Investigator should verify all information contained in the listing, make corrections where necessary, note any discrepancies, list the current condition of each item including cost of repair if item is not working, furnish disposition instructions and promptly return the listing to Property Control. 

12.02.4 Property Control will submit the Final Property Inventory Report to the agency.  This report will contain the results of the final inventory, possibly including a request for transfer of equipment title to the University of Wisconsin. 

12.02.5 When the Government approves title transfer to the University, the Federal decals must be replaced with University decals. Property Control will forward a list of the transferred equipment along with the new University decals to the Principal Investigator or Departmental Property Administrator. All Federal markings should be removed and University decals attached.

12.02.6 Equipment no longer in use and considered obsolete will be removed from the Property System. 

12.02.7 If the Government disapproves title transfer, the University has the option to request transfer of equipment accountability from the expired contract to a successor contract, or to another federal contract on which the equipment is being used.

Back to Top

SECTION 13 - REPORTING

13.01 Property Control has the responsibility to submit in a timely manner all property reports to the appropriate Federal agencies required for contract and grant reporting.

13.02 Principal Investigators receiving requests for Federal property reports directly from a Federal agency, should forward those report requests to Property Control.

13.03 Property Control will forward copies of all Federal property reports to the Principal Investigator.

Back to Top

SECTION 14 - CONSUMPTION

14.01 Consumption is the process of incorporating Federally Titled Property into an end item or otherwise consuming the property in the performance of a contract or grant.

14.02 All Federally Titled Property incorporated into an end item or consumed in performance of the contract must be documented.

14.03 The Principal Investigator is responsible for ensuring that all Federally Titled Property is used in reasonable amounts and only on the contract or grant for which the property was acquired.

14.04 The Principal Investigator is responsible for promptly reporting to Property Control all property in excess of the amount required to complete full performance under the contract.

Back to Top

SECTION 15 - UTILIZATION

15.01 The Principal Investigator is responsible for the utilization of all Federally Titled Property accountable under his/her contract. Federally Titled Property is to be used only for the purposes authorized by the contract.

15.02 Federally Titled Property no longer required for work under the contract must be reported in writing to Property Control. A University Proerty Transacion Form  can be used in reporting idle/excess property. Information to be reported includes decal number, item description, location, condition and current estimated value.

15.03 Property Control will report the equipment as excess to our needs and request disposition instruction from the Contract Administrator.

15.04 Idle/excess Federally Titled Property cannot be disposed in any manner until written authorization and disposition instructions are received from Property Control.  Property must be stored and secured properly.  See (SECTION 11 - STORAGE, MAINTENANCE AND SECURITY) regarding storage and security of Federally titled property.

Back to Top

SECTION 16 - SUBCONTRACTOR PROPERTY REQUIREMENTS

16.01 University of Wisconsin subcontractors who control or possess Federally Titled Property must adequately care for and maintain this property and ensure that it is used for purposes authorized under the contract or grant.

16.02 Appropriate provisions of the prime contract clauses will be included in subcontracts involving Federally Titled Property. These provisions should require that the subcontractor assume the responsibility and obligations of the University with respect to that property while it is under the subcontractor's control. These obligations will include appropriate care, utilization, storage, movement, disposition and record keeping.

16.03 Federally Titled Property located at a subcontractor facility will be inventoried once every two years.  Departments will forward to each subcontractor an inventory listing that must be reviewed by the subcontractor.  In addition, an Off Campus Equipment Verification Form must be completed for each equipment item.

Back to Top

SECTION 17 - DISPOSITION

17.01. Trade-In

17.01.1 Federally Titled Property cannot be traded-in or exchanged for new equipment without written authorization from the Federal Government and Property Control.

17.01.2 The Principal Investigator must submit a request to Property Control for trade-in or exchange of property.  The request should include the decal number, description, condition, location and trade-in value for the item being traded. In addition, you must provide a description and cost of the item proposed for purchase.  Include a brief statement concerning why this exchange is required.

17.01.3 Property Control will forward the trade-in request to the Contracting Officer.

17.01.4 When the response is received from the Contracting Officer, Property Control will advise whether the trade/exchange is approved or disallowed.

17.01.5 If the trade/exchange is disallowed, and the Principal Investigator has no further use for the equipment, the Principal Investigator must report the equipment as excess following the steps in SECTION 17.05 - EXCESS PROPERTY.

17.02 Cannibalization or Scrapping

17.02.1 Federally Titled Property cannot be cannibalized or scrapped without written authorization from the Federal Government and Property Control.

17.02.2 The Principal Investigator must submit his/her request for cannibalization or scrapping to Property Control.

17.02.3 Property Control will forward the request to the Contracting Officer.

17.02.4 Upon receipt of instructions from the Contracting Officer, Property Control will advise the Principal Investigator. 

17.02.5 Property authorized for cannibalization or scrapping will be removed from the University's Property System.

17.03 Lost

17.03.1. When Federally Titled Property cannot be located, the Principal Investigator must immediately report the loss to Property Control. Include in the report the decal number, complete description, condition of the item before loss, date and time loss first noticed, actions taken to try and locate item and other facts or circumstances surrounding the loss.

17.03.2 If the loss is due to a suspected theft, follow steps in 17.04.

17.03.3 Property Control will notify the Contracting Officer of the loss and request to be relieved of further accountability for the equipment.

17.03.4 Property Control will notify the department upon relief of accountability and will remove the equipment record from the University's Property System.

17.03.5 Should the missing item be located at a later date, the Principal Investigator must immediately inform Property Control.

17.04   Theft

17.04.1 Theft of Federally Titled Property must be reported to University Police. In addition, the Federal sponsoring agency may require you to report the theft to the Federal Bureau of Investigation.

17.04.2 When reporting the theft to the University Police, you should inform them the property is Government-owned.

17.04.3 The Principal Investigator must inform Property Control of the theft as soon as possible and should furnish a copy of the police theft report.

17.04.4 Property Control will notify the Contracting Officer of the theft and will request to be relieved of further accountability for the equipment.

17.04.5 Upon relief of accountability, Property Control will notify the Principal Investigator and will remove the equipment record from the University's Property System.

17.04.6 Subsequent recovery of stolen property must be reported to the Contracting Officer.

17.05. Excess Property

17.05.1 Excess Federally Titled Property (equipment no longer required in performance of the contract) cannot be disposed, sold, transferred or junked without written authorization from the Government and Property Control.

17.05.2 The Principal Investigator must report all excess Federally Titled Property to Property Control.  Information required is decal number, description, current condition, current value, shipping weight and approximate dimensions.

17.05.3 Property Control will forward a report to the Contracting Officer requesting disposition instructions.

17.05.4 When the disposition instructions are received, Property Control will notify the Principal Investigator.

17.05.5 The Principal Investigator will ship the property as instructed by the Contracting Officer and will forward a copy of all shipping documentation to Property Control.

17.05.6 Once the property has been shipped, Property Control will remove the equipment record from the University's Property System.

17.06 Equipment Damaged Beyond Repair

17.06.1. The Principal Investigator must immediately report equipment damaged beyond repair to Property Control.

17.06.2 Property Control will notify the Contracting Officer requesting authorization to dispose of the equipment and be relieved of further accountability to the Government.

17.06.3 Upon receipt of authorization to dispose, Property Control will advise the Principal Investigator.

17.06.4 The property will be disposed in compliance with University policy.  See Purchasing Policies and Procedures #18.

Back to Top

SECTION 18 - CONTRACT PROPERTY CLOSEOUT

18.01 The Office of Research and Sponsored Programs will notify Property Control of the completion or expiration of all contracts and grants.

18.02 Property Control will reconcile grant total capitalized expenditures in the WISDM to the total cost of equipment reflected in the University's property system. 

18.03 Any discrepancies will be investigated and resolved.  A report of grant expenditures will be compared to property system records to identify the discrepancy.  The property records will be adjusted accordingly.

18.04 Property Control will require the department to conduct a physical inventory of all Federally Titled Property accountable under the specific contract or grant. (See Section 12.02 - Final Physical Inventories.)

18.05 The department must provide the following information for each Federally Titled equipment item:  Condition, cost of repair if equipment item is not working, disposition instructions.

18.06 Property Control will submit the final property report and verified property list to the funding sponsor requesting title transfer to the University.

18.07 The funding sponsor can transfer title to the University, require that the equipment be crated and returned to the sponsoring agency or could allow continued use of the equipment by transferring accountability to a new contract or grant.

18.08 Property Control is responsible for updating the equipment records for equipment title transferred to the University. The Principal Investigator is responsible for removing all Federal markings from the equipment.

18.09 The Principal Investigator is responsible for crating and shipping equipment for return to the sponsor.

18.10 Property Control will adjust the equipment records to reflect equipment where accountability was authorized for transfer to a new contract or grant. This equipment will be considered Government-Furnished property.

18.11 Property Control will notify the funding sponsor in writing if no equipment was purchased or furnished under the completed grant or contract.

Federal Property Manual (December 2009)

Back to Top