Federal Reporting and Compliance for Capital Equipment

Federal Property Management Procedures

The following are property management standards for that capital equipment acquired with Federal funds (sponsored) and that which is Federally-owned.

1. Capital equipment records at the University of Minnesota will include the following:
   1. A description of the item
   2. The manufacturer's serial number, model number and UM inventory asset tag number/barcode sticker
   3. Fund source of equipment, including an award number
   4. "Owner" with whom title is vested, usually the UM or a Federal agency
   5. Item acquisition date and its cost
   6. Information for determining the calculation of Federal participation in cost of item
   7. Location and condition of equipment and date the information was last reported
   8. Unit acquisition cost of the item
   9. Maintenance procedures will be implemented to keep the equipment in good condition
   10. The ultimate disposition data, including the date of disposal

2. Equipment owned by the Federal Government is identified to indicate Federal ownership.

3. A physical inventory of all capital equipment will be taken and results reconciled with equipment records at least once every two years.

   1. Any differences between physical inspection and accounting records will be pursued to determine the causes of the difference
   2. UM Inventory Services will verify the existence, current utilization, and continued need for the equipment

4. Principal Investigators (P.I.s) must notify Inventory Services when they receive government-furnished equipment from a granting or contracting agency. Typically, the University will not own that equipment and will be required to account for it annually.

   1. Inventory Services will need to know that the property was received and what was received. The principal investigators or recipients of Federally-owned property must report any change in the location of equipment to be found off campus or off site from its typical research locale.

5. Any loss, theft, or proposed disposal activity of Federally-owned equipment must be approved through Inventory Services prior to that disposition.

   1. Inventory Services will contact the appropriate governing Federal agency for disposal instructions of such equipment
   2. Actual disposition of such equipment will occur within the property standards of OMB Circular A-110, Subpart C.34g, and F.A.R., part 45.6.

Federal Reporting Procedures for Capital Equipment Assets

Annual Inventory Reports

1. Once yearly, Inventory Services will prepare and submit Annual Inventory Reports for contracts, grants, and cooperative agreements. These reports will be submitted after September 30 and before October 31, to report federal property acquisitions to the various agencies that provide University researchers with funding.
2. Equipment listed with NASA grants and contracts is reported on NASA form 1018 and should be attached.
3. Equipment listed with DOD grants and contracts (Army, Navy, Air Force, etc.) is reported on form DD1662 and should be attached.
4. All remaining annual reports for other grants and contracts are prepared on University letterhead.
5. It must be noted that some government agencies require negative reports when there is no equipment listed on a specific grant, contract, or cooperative agreement.
6. Inventory Services will use the information from a prepared PS report for this reporting exercise.
7. Letters should be sent out to all sub-contractors on September 1, requesting an inventory of equipment be submitted with annual reports.

Final Inventory Reports

1. Whenever a contract, grant, cooperative agreement, or an agency subcontract with the University ends, a final inventory report must be prepared and sent to the sponsoring agency. This final inventory report request is generated by an agency letter received in Sponsored Projects Administration from the corresponding agency and routed through Inventory Services.
2. The final inventory report should be prepared on University letterhead and should include a listing of capital equipment as obtained on the PS report, if there is any. It should also include a cover letter requesting title to the equipment on the newly-closed account, and stating that this is a final report.
3. It must be noted that some government agencies require negative reports when there is no equipment listed on a specific grant, contract, or cooperative agreement.

Property System Surveys

1. Each year a Property Control System Survey is conducted by the Office of Naval Research. This includes a review of the University's property system as it impacts government-owned property and the expenditure of Federal funds.
2. The survey may include a physical inspection of a sample of government-owned equipment to verify University inventory identification barcode numbers, government ownership tags, and locations of equipment.
3. The review may also include interviews with Principal Investigators who use assets.
4. The survey will also include a review of equipment records in the PS Asset Manage- ment module for each capital asset equipment item.
5. The survey will also include any other miscellaneous requests the ONR may make.

Excess Property

1. When equipment is no longer needed in the performance of a contract or grant, it should formally be declared as excess property to the sponsoring agency.
2. Department of Defense (DOD) equipment should be reported on DD Form 1428.
3. All other requests to dispose of equipment or obtain title to it can be prepared on University letterhead.

Marking Government-Owned Equipment

1. Each item of government-titled property should have a UM inventory identification barcode sticker to identify it as part of the University's property system.
2. Each item of government-titled property should have a "Property of the U.S. Government" sticker affixed to it to identify it as government-owned.
3. Ownership of equipment can be obtained from each contract or grant NOGA - from SPA.

Miscellaneous Requests for Equipment Information

1. Inventory Services must perform Sub-Contractor property system verifications.
2. Inventory Services must provide forms to departments and Principal Investigators when they are fabricating capital equipment assets.
3. Inventory Services must respond to requests from agencies and sub-contractors to return equipment.