Managing Equipment Acquired with Federal Funding Policy
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It is the policy of New York University (NYU, “the University”) that equipment acquired with Federal funding is managed in accordance with Federal regulations, sponsor requirements and University policies. The management of equipment acquired with Federal funding at the University is an integral process supported by all Finance, Purchasing, Asset Management, departments, schools and units of NYU.
Purpose of this Policy
The purpose of this policy is to provide guidance to Principal Investigators (PI’s) and departments for managing Federally funded equipment in accordance with Federal Office of Budget and Management (OMB) Circulars, sponsor requirements and University policies.
Scope of this Policy
This policy is applicable to NYU equipment acquired with Federal funding. Equipment can be acquired through purchase, fabrication, donation or transfer from another institution.
Procedures for Implementation
a. Roles and Responsibilities
- The PI will ensure the policy and procedures described in this document are followed. PI’s will also ensure pre-acquisition screening of major equipment (normally equipment over $100,000 unless a lower threshold is required by the sponsor) to avoid unnecessary purchases.
- The Asset Management Office oversees the equipment and property administration function at Washington Square, including writing policies, implementing processes, training staff, conducting physical inventory and maintaining the official equipment and property records.
- Department Administrators (DA’s) establish and maintain equipment and property records for their assigned area in a timely, complete and accurate manner.
- Asset Custodians and Users are any staff faculty or student using NYU or equipment acquired with Federal funding. They must provide accurate, timely and complete information regarding equipment/property status and use and maintain assets in a responsible manner, including taking security precautions to discourage loss and theft of assets.
b. Identification: Tagging and Recording Equipment
Tagging and recording of equipment is the responsibility of Asset Management which records property over the capitalization threshold (i.e., $3,000) into the Fixed Asset Records and identifies the equipment with a unique NYU tag number to identify equipment acquired with Federal funding. A property/equipment record should be maintained accurately and include the following data elements:
- Asset tag number (identifying number assigned to the asset);
- Description of equipment;
- Manufacturer's serial number, model number, Federal stock number, national stock number or other identification number;
- Source of equipment, including award/contract number;
- Acquisition date (or date received, if the equipment was furnished by the Federal Government) and cost;
- Information noting the equipment was acquired using Federal funding;
- Location (building and room location of asset) and condition of the equipment and the date the information was reported;
- Unit acquisition cost;
- Final disposition record, including the date of disposal and sales price or the method used to determine current fair market value where a recipient compensates the Federal awarding agency for its share.
c. Reporting Loss, Damage or Theft
A DA must report to the Asset Management Office and the Office of Sponsored Programs (OSP) any loss, damage or theft of equipment acquired with Federal funding.
d. Physical Inventory
i. Biennial Inventory
In accordance with OMB Circular A-21, Cost Principles for Educational Institutions (http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html) and OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions (http://www.whitehouse.gov/omb/circulars_a110/#71), NYU performs a physical inventory of equipment and reconciles with the inventory records every two years for each department. Asset Management will verify the following information for each asset:
- Model No.
- Year manufactured
- Serial No.
Asset Management will prepare a report for each department. The inventory report shows the difference between quantities determined by the physical inventory and those shown in the inventory database. A typical report will include:
- A master list of all assets inventoried in departmental space by location (if requested);
- A list of all assets added to the Fixed Asset Records during the inventory, including assets found without tags and assets found with tags that are not listed in Fixed Assets Records;
- A list of assets found which belong to another department;
- A list of assets in the Fixed Asset Records, which were not located during the inventory.
The DA for each department is responsible for inventory reconciliation, which is to investigate and determine causes of the difference between the inventory report and the Fixed Asset Records. Inventory reconciliation should be reported back to the Asset Management Office within 60 days from the date of the physical inventory report. Do not move equipment acquired with Federal funds from the tagged location. If the equipment must be moved, be sure to notify the Asset Management Office and change the property record(s).
ii. Final Project Inventory
Upon completion or termination of a grant or contract, a physical inventory of all Federally-owned property shall be conducted. Sponsored Programs Administration (SPA) will conduct the final physical inventory and report the results to the sponsor.
e. Ownership of Equipment Purchased with Federal Funding
Generally, the title of ownership for equipment purchased on Federally-funded sponsored agreements rests with the University. If the Federal Government retains ownership, it should be specifically identified in the sponsor agreement.
f. Sharing of Equipment Purchased with Federal Funding
As long as the Federal Government continues to support the project or program for which the equipment was purchased, the following rule must be followed:
- The PI may not provide the equipment for use on another project without the approval of the Federal awarding agency;
- The equipment must be used in that project or program unless it no longer is needed for that project or program;
- The equipment should not be used to provide services to non-Federal outside organizations for a fee that is less than private companies charge for equivalent services, unless specifically authorized by Federal statute;
- The equipment may be used on other projects or programs if this use will not interfere with the work on the project or program for which the equipment was originally acquired. The equipment must be utilized in the following order of priority:
- Activities sponsored by the Federal awarding agency which funded the original project; then
- Activities sponsored by other Federal awarding agencies.
If the equipment is owned by the Federal Government, use on other activities not sponsored by the Federal Government must be authorized by the Federal awarding agency. User charges must be treated as program income.
When a PI wishes to dispose of items of equipment funded by the Federal government, disposition restrictions must be researched and resolved by SPA. Sponsor approval may be required prior to sale.
The department completes an NYU Asset Surplus Form to request authorization for disposal of any NYU Asset, and/or to report any surplus items.
For disposal of Federally funded equipment, an NYU Asset Surplus Form must be forwarded to SPA before Asset Management authorizes disposal of the item. Federally funded equipment may be vested in i) NYU or ii) the Federal government (i.e., government-owned property).
i. When Title to Equipment Vests in NYU
When the original sponsored project that funded the equipment is ongoing, proceeds from the sale of the equipment will be credited back into the project and be treated as program income.
- When the original sponsored project is terminated but a project(s) with the same sponsor who originally funded the equipment is ongoing, proceeds from the sale will be credited to another project with the same sponsor.
- When the original sponsored project is terminated and there are no projects with the same sponsor, proceeds from the sale will be credited to other similar Federally sponsored research.
ii. When Title to Equipment Vests in the Federal Government
SPA contacts the sponsoring agency for disposal instructions.
Click here to download the Policy PDF