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9.20 / U.S. Government Property Management Procedures

Purpose:
Establish procedures to be used when any award from an agency, department, bureau, or any similar operating entity of the United States (hereinafter “U.S. Government”) to Wichita State University (hereinafter “University”) includes provisions for the U.S. Government to provide property or the U.S. Government claims title to property acquired with award funds.

Preamble:
U.S. Government property is that equipment and materials for which the U.S. Government retains title as specified in an award. The University, to the extent permitted by state law, is directly responsible and accountable for all U.S. Government property in its possession, including that which has been provided to subcontractors, in compliance with the requirements of the award. This includes loss, damage, theft, destruction and disposition, but does not include normal wear and tear in utilizing the property for its intended use. The University property record becomes the official U.S. Government accounting record for any U.S. Government property in the University’s possession, or the possession of its subcontractors, and must comply with U.S. Government regulations.

Regulations for acquiring or using U.S. Government property are provided in Office of Management and Budget (OMB) Circular A-110, Grants and Agreements with Institutions of Higher Education, Hospitals, and other Nonprofit Organizations. U.S. Government awards may also include regulations specified in the Federal Acquisition Regulations (FAR) Part 45, Government Property; Department of Defense Manual 4161.2-M, Property Administration; NASA Grants Regulations, section 1260.27, other U.S. Government agency supplements, and specific property provisions included in U.S. Government awards.

Definitions:

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

Equipment: Tangible nonexpendable personal property including exempt property charged directly to the award having a useful life of more than one year and an acquisition cost of $5,000 or more per unit.

Exempt Property: Tangible personal property acquired in whole or in part with U.S. Government funds, where the awarding entity has statutory authority to vest title in the recipient without further obligation to the U.S. Government.

Materials: All personal property excluding equipment as defined in this section.

Personal Property: Property of any kind except real property. As used in these procedures, property is limited to equipment and materials as defined above.

Special Test Equipment: Single or multipurpose integrated test units engineered, designed, fabricated, or modified to accomplish special purpose testing in performing a contract. It consists of items or assemblies of equipment including standard or general-purpose items or components that are interconnected and interdependent so as to become a new functional entity for special testing purposes.

Procedures:

A.  Award Notification

Upon receipt of a U.S. Government award that includes provisions for the U.S. Government to provide property or the U.S. Government claims title to property acquired with award funds, the Principal Investigator and/or Award Notice Recipient shall immediately notify the Office of Financial Operations and Business Technology Property Accountant, the Physical Plant Warehouse and the Office of Research Administration to provide the following information:
 

1.  Award number and date of award.

2.  Title of award and U.S. Government entity name.

3. List of property to be owned by the U.S. Government including: 
  a. Name, description and, if furnished in the award notice, manufacturer’s serial number, model number, federal stock number, national stock number, or other identification number.

b. Quantity.

c. Unit price and unit of measure.

d. Whether U.S. Government provided or is to be acquired with award funds.

4.  Campus location for the storage/use of the property.

5.  Name and phone number of the University employee who is to be the custodian of the U.S. Government property as designated by the department chair or the manager of the University unit providing oversight.

B.  Principal Investigator and/or Award Notice Recipient Responsibilities
 

1.  Provide the award notification as set forth in Section A, above.

2.  Enter onto purchase requisition forms the notation “U.S. Government Property” for each applicable item.

3.  When designated the custodian of U.S. Government property, fulfill the responsibilities set forth in Section C, below.

4.  When authorized by the Office of Research and Technology Transfer, bill for the use of U.S. Government property for purposes other than the award for which it was acquired.

5.  Dispose of U.S. Government property in compliance with disposition instructions from the Office of Research and Technology Transfer as furnished by the U.S. Government.

C.  Property Custodian Responsibilities
 

1.  Verify the property has been tagged as “U.S. Government Property.”

2.  Verify the property is kept in the location designated in the University property record.

3. Verify the safekeeping of U.S. Government property is as secure or secured better than State of Kansas property in the same location. Take necessary actions to keep highly valued or non-anchored items in appropriately locked spaces.

4. Verify the property is used only for purposes authorized by the award unless authorization for other uses has been obtained from the Office of Research and Technology Transfer.

5. Verify routine maintenance requirements are met.

6. Prevent the removal of the property from the designated location.

a. Generate a property transfer document to relocate the property when instructed by the Principal Investigator, identifying the new Property Custodian (if applicable).

7.  Keep U.S. Government property segregated from all other property.

8.  Maintain receipt and issue records for material acquired by the University as provided in Department of Defense Manual 4161.2-M, Chapter 5, Part I Property at Non-Profit Contractors as outlined in a through c, below.
  a. Maintain a file for each award of receiving notices, purchase requisitions, purchase orders and other records pertaining to U.S. Government property in their possession.

b. Maintain a record of the consumption of material as it is used in the execution of the statement of work of the award. Such record will identify the quantity, unit price, description, part number, “U.S. Government Property” tag number when applicable, with the “used on” identifier such as drawing number or identified project parts list. Note that equipment is not to be categorized as material in this record.

c. Obtain approval from the Office of Research and Technology Transfer for any consumption of U.S. Government property that is for a purpose other than specified by the award under which the U.S. Government retains title.

9. Maintain records of special test equipment. These records may consist of U.S. Government invoices, contractor purchase documents, or other documentation evidencing acquisition of issue or to end-use.

a. Any item of special test equipment built under the award shall be tagged separately as “U.S. Government Property.”

10. Dispose of U.S. Government property based on disposition instructions provided by the Office of Research Administration.

D.  Academic Departments and Other Units Responsibilities
 

1.  Provide oversight to ensure the Principal Investigator and/or Award Notice Recipient and the Property Custodian fulfill their respective responsibilities.

2.  Approve designation of the employee who will serve as Property Custodian.

E.  Office of Research and Technology Transfer Responsibilities
 

1.  Review U.S. Government awards and ensure the appropriate notifications required by these procedures are provided.

2. Review purchase requisitions to ensure “U.S. Government Property” identifier is entered for each applicable item.

3. Provide billing rate for use of U.S. Government property for other purposes when properly authorized under terms of the award. Initiate credit to the applicable award for the revenue from such billings.

4. Record and/or process requests for changes to U.S. Government property status.

5. Provide U.S. Government property reports required by awards.

6. Obtain disposition instructions from the overseeing U.S. Government entity.
  a. Provide disposition instructions to the Principal Investigator and the Property Custodian.

b. Compile disposition information and submit the information to the Office of Financial Operations and Business Technology Property Accountant.

F.  Office of Financial Operations and Business Technology Property Accountant Responsibilities
 

1.  Upon receipt of U.S. Government provided property, affix a “U.S. Government Property” identification tag to each piece of equipment.

2.  Affix a “U.S. Government Property” identification tag to each piece of property procured or produced by award funds.

3. Create a U.S. Government property record that includes the information specified in OMB Circular A-110, Subpart C, Section .34 (f)(1): 

a. Description of the property.

b. Manufacturer’s serial number, model number, federal stock number, national stock number, or other identification number.

c. Source of the property, including the award number.

d. Whether title vests in the recipient or the U.S. Government.

e. Acquisition date (or date received, if the equipment was furnished by the U.S. Government) and unit cost.

f. Information from which one can calculate the percentage of U.S. Government participation in the cost of the property (not applicable to equipment provided by the U.S. Government).

g. Location and condition of the property and the date the information was reported.

h. Ultimate disposition data, including date of disposal and sales price or the method used to determine current fair market value where a recipient compensates the awarding entity for its share.

4.  Provide for a physical inventory and reconcilement at least every two years as specified in OMB Circular A-110, Subpart C, Section .34(f)(3).

5.  Record the disposition of U.S. Government property in accordance with federal entity disposition instructions provided by the Office of Research and Technology Transfer.

G.  Purchasing Department Responsibilities
 

1.  Flow-down to subcontractors the applicable U.S. Government property requirements of the award for property or property provided to the subcontractor or acquired by the subcontractor.

2.  Pass-through the purchase requisition notation “U.S. Government Property” on procurement documents and requires it to be inserted into shipping documents by the supplier.

H.  Physical Plant Warehouse Responsibilities
 

1.  Upon receipt of U.S. Government Property, place the equipment in a segregated and secure holding area.

2.  Immediately notify the Principal Investigator and/or the Award Notice Recipient and the Office of Financial Operations and Business Technology Property Accountant of the receipt of U.S. Government property.

3. Verify requests to move any items designated as U.S. Government property have the approval of the Principal Investigator and/or the Award Notice Recipient before moving the items.

Implementation:
These procedures shall be included in the WSU Policies and Procedures Manual and shared with appropriate constituencies of the University.

The Vice President for Research and Technology Transfer shall have primary responsibility for publication, dissemination and implementation of these procedures.

Effective Date:
October 1, 2000

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