PROPERTY ACCOUNTING - EQUIPMENT TITLE, DISPOSITION AND SUBCONTRACTS

• 1.0 Purpose
• 2.0 Policy
  • 2.1 Transfer of Title
  • 2.2 University Acceptance of Title
  • 2.3 Title to Grant Property
  • 2.4 Excess Government Property
  • 2.4 Disposition of Property
  • 2.5 Subcontracts
• 3.0 Definitions
• 4.0 References
• 5.0 Approvals and Revisions

1.0 Purpose

This policy describes the general guidelines for how property titles are to be handled by the University.

2.0 Policy [Top]

2.1 Transfer of Title

Most government contracts/grants allow transfer of title from the government to the University for authorized property.

Financial Reporting and Analysis is responsible for maintaining central records of government-owned property and will request title transfer for contracts/grants as applicable.

Financial Reporting and Analysis will inform principal investigators about the status of titles to equipment for their contracts/grants.

2.2 University Acceptance of Title

When the University accepts title to property from the government, the following conditions apply:

• The property will be used for the applicable contract/grant.
• For equipment items costing $1,000 or more, the government may transfer title to a third party prior to final payment under the contract/grant or four months after completion of the project.
• The University agrees to use the property in research for the government and will not charge for depreciation, amortization or use under any government contract, grant or subcontract.

See also:

• Policy X.A.2, "Property Accounting: Transfer of Research Equipment from the University,"
• Policy X.A.3, "Property Accounting: Transfer of Research Equipment to the University."

2.3 Title to Grant Property

Unless specifically excepted in a grant, title to Public Health Service (PHS) and National Science Foundation (NSF) acquired grant equipment is automatically vested in the University when received, subject to the same government right to direct title transfer for a period up to 120 days after expiration of the grant. However, the University remains accountable to the government for the proper use and disposition of such equipment. Therefore, Financial Reporting and Analysis will maintain property records on all grant equipment until it is disposed of. Procedures for acquisition, maintenance, use and inventory remain applicable.

2.4 Excess Government Property

Title to excess property will normally pass to the University after notifying NSF of receipt.

2.4 Disposition of Property

Disposition of government property is governed by the terms of the contract/ grant. In summary, if title remains with the government, the government agency must approve any transfer. Even if title is transferred to the University for items costing $1,000 or more, the government still retains the right to transfer title to a third party.

Only by one of the following conditions can the University be relieved of responsibility for government property.

• Consumption of Property in Performance of the Contract/Grant
• The government agency must approve this condition indicating approved consumption in reasonable amounts.
• Shipment from University Facilities
• Lost, Damaged, Destroyed or Consumed in Excess of Normal Requirements
• The principal investigator must fully document this condition. The government agency will assess the extent of the University's liability.
• Transfer of Title
  • See preceding Transfer of Title section.
• Sale
  • The government will approve the sale and receive the proceeds.

Financial Analysis will require biannual certification by principal investigators on a continuing need for GFE/CP government property in their possession to support active contracts/grants. This certification will coincide with the University's biennial physical inventory.

The government will determine disposition for items no longer required.

2.5 Subcontracts

When the University has a prime government contract with subcontracts, the Office of Sponsored Programs will ensure government property control provisions are included in the subcontracts as appropriate.

The University is responsible and accountable for government property provided in a subcontract and in possession of the subcontractor.

Government property reports for the prime contract must include all subcontract government property.

3.0 Definitions [Top]

4.0 References [Top]

5.0 Approvals and Revisions [Top]