Government Property Management
Policy number: 10.5
Policy section: Research
Revised Date: December 16, 2019
Definitions of capitalized terms are set forth in Appendix A.
The purpose of this policy is to establish policies and procedures for safeguarding property funded through Sponsored Projects, and to establish related management and reporting requirements.
3. Policy Statement
The University requires that all Sponsored Projects be managed in compliance with federal laws, regulations, and policies, including regulations dealing with the management of government property. Current federal laws, regulations, and policies are identified in the Research Handbook.
4. General Management of Government Property
- Principal Investigators/Project Directors and others participating in a Sponsored Project must manage, safeguard, and report property funded through an Award in compliance with University Policies and with requirements established by a Sponsor. In the case of property funded or otherwise provided by the federal government, federal laws, regulations, and policies, including but not limited to applicable Federal Acquisition Regulations and agency-specific regulations and policies, must govern property management.
- The Principal Investigator/Project Director is responsible for management of Sponsored Project property and is responsible for informing the appropriate Administrative Offices of changes or difficulties related to Sponsor-funded or Sponsor-owned property. Management of Sponsored Project property will be monitored and/or aided by the Administrative Offices. The Administrative Offices will keep the Principal Investigator/Project Director informed of changes in compliance and regulatory requirements applicable to property management, and are authorized to contact all Sponsors to determine the nature and extent of all compliance and/or regulatory constraints that apply to property management for a Sponsored Project and to file any and all required reports that relate to such property.
5. Transfer of Property to Another Institution
Subject to University Policy 4.9, Excess Property, to the extent not superseded by federal requirements, property purchased or provided by Sponsored Projects may be transferred to another institution as follows:
- All requests to transfer equipment purchased or provided by Awards to another institution must be reviewed and approved by the Associate Vice President for Research. No property funded by Sponsored Projects shall be removed from the University without the approval of the Associate Vice President for Research.
- Prior to approval of any transfer of equipment, the Associate Vice President for Research will determine in consultation with the Principal Investigator/Project Director and the Principal Investigator/Project Director’s department chair, that the University no longer needs the property.
- Sponsor approval is required to transfer to another institution property purchased or funded by an active Award.
- Documentation following procedures outlined in the Research Handbook is required in advance of the transfer of equipment to another institution, and must include written agreement from the institution to which the property will be transferred to accept title to and accountability for the property.
- The University may not incur any cost for packing and shipping the equipment being transferred to another institution, unless stipulated in the Award.
6. Roles and Responsibilities: Principal Investigator/Project Director
The Principal Investigator/Project Director is responsible for:
- Procuring property in accordance with University Policies, and applicable federal regulations;
- Safeguarding, to the extent practicable, property acquired as a result of an Award and maintaining and caring for the property in a prudent and proper manner;
- Monitoring property acquired as a result of an Award;
- Making reports of change of location of property, changes in need, annual and bi-annual inventories and other property reports required by an Award (i) to the Asset Management Department and (ii) when required, to the Office of Research and Graduate Studies, to the Sponsor and for a federal Award, to the Cognizant Property Administrator identified in the Award; and
- Complying with government Sponsor instructions for disposition of government property when that property is no longer required for the Sponsored Project or at termination or official close-out of the Award and providing the Asset Management Department and the Office of Research and Graduate Studies with documentation of these actions.
7. Roles and Responsibilities: Office of Research and Graduate Studies
The Office of Research and Graduate Studies is responsible for:
- Coordinating the filing of property management reports required by the Sponsor or Award and negotiating approval of changes and other property-related matters with the Sponsor; and
- Determining, at the time an Award is received, whether title to property is vested in the Sponsor or in the University and requesting instructions for disposition of federally-owned property or, when required by an Award, of federally-funded property at official close-out of government Awards.
8. Roles and Responsibilities: Asset Management Department
The Asset Management Department is responsible for:
- Maintaining the official University property records and documentation of procurement, inventories and changes in status;
- Providing detailed listings for annual and bi-annual inventories, special reports requested, and Award close-out process; and
- Auditing inventories of property periodically.
9. Roles and Responsibilities: Office of Grant and Contract Accounting
The Office of Grant and Contract Accounting is responsible for:
- Reviewing the allowability of property charges to Sponsored Projects.
- Providing the Asset Management Department with documentation for property purchases using Sponsored Project Funding.
10. Roles and Responsibilities: Purchasing Department
The Purchasing Department is responsible for assisting in the disposition of property, if requested, in accordance with University Policy 4.9, Excess Property.
Failure to follow property management procedures resulting in loss of federal or other Funding may result in charges to the responsible Principal Investigator/Project Director and/or college, school, department, division, center, or institute. Deliberately charging unallowable costs or refusing to comply with reporting or management requirements related to a federally funded Sponsored Project (i) may result in additional federal sanctions that may include, but are not limited to, the exclusion from future federal Funding and criminal prosecution for fraud and (ii) may constitute Research Misconduct under University Policy 10.6, Standards for Addressing Research Misconduct.
12. Related Policies, Procedures, and Guidelines
- University Policy 4.9, Excess Property
- University Policy 10.1, Sponsored Research and Activities
- University Policy 10.6, Standards for Addressing Research Misconduct
- Research Handbook
Appendix A: Definitions
“Administrative Offices” means, for the purposes of this policy, the University’s Office of Research and Graduate Studies, Office of Grant and Contract Accounting, and Purchasing Department. For the purposes of this policy, “Administrative Offices” also includes the Asset Management Department.
"Award" means a Grant, subgrant, Contract, subcontract or Cooperative Agreement that provides for Funding.
"Contract" means a legally enforceable agreement between the University and a Sponsor that provides Funding when a primary purpose is delivery to the Sponsor of property or services for the benefit of the Sponsor, in addition to the research, educational, or service benefit to the University.
"Cooperative Agreement" means a legally enforceable agreement between the University and a Sponsor that provides Funding when substantial interaction between the Sponsor and the University is anticipated during the performance of the Sponsored Project.
“Funding” means financial support for a Sponsored Project, including money, property, services, or anything of value in lieu of money.
"Grant" means a legally enforceable agreement between the University and a Sponsor that provides Funding when:
- the Sponsor has no expectation of delivery of a specific product or service other than a final written report;
- no substantial interaction between the Sponsor and the University during performance is anticipated; and
- the agreement contains general terms and conditions that stipulate a period of performance and minimal reporting requirements.
"Principal Investigator/Project Director” means the individual solely responsible for technical conduct of a Sponsored Project, technical contact with the Sponsor, expenditure of Sponsored Project Funding, and fulfillment of technical performance and reporting obligations under an Award. "Principal Investigator” (PI) includes an individual designated in an Award as "Project Director" (PD), when performing the functions of a Principal Investigator, or other individuals performing the functions of a Principal Investigator. For the period of the Award, the Principal Investigator/Project Director must be a full-time employee (staff, tenured or, tenure track faculty, Research Professor, Research Associate Professor, Research Assistant Professor, or, if approved by the Provost or his or her designee, a non-tenure track, non-tenure eligible faculty member) appointed pursuant to University Policy 2.3, Faculty Ranks, Academic Titles, and Voting Rights.
“Proposal” means the document submitted to a Sponsor requesting Funding for a Sponsored Project which includes, without limitation, (i) Financial Obligations, Regulatory Obligations, Reporting Obligations or Accounting Obligations, as described under “Sponsored Projects”, (ii) a Statement of Work and (iii) a budget.
“Research Handbook” is a document maintained by the Office of Research and Graduate Studies specifying current procedures and requirements for the proposal, acceptance, execution, and oversight of Sponsored Projects.
"Sponsor” means any external entity that provides Funding to the University. Sponsors may be (i) governmental agencies (for example, federal, state or local governments or their administrative organizations); (ii) nonprofit organizations (for example, universities, nonprofit corporations, foundations or associations); (iii) for profit organizations (for example, corporations, partnerships, sole proprietorships and other business entities); or (iv) individuals.
"Sponsored Projects” means all projects, programs, research, training, public service, and other activities that receive external Funding through Grants to the University or through Contracts or Cooperative Agreements between the University and a Sponsor, where one or more of the following obligations applies:
- Financial Obligation. The University is required to comply with conditions imposed when a Sponsor awards Funding for the performance of services or delivery of products described in a Statement of Work;
- Regulatory Obligation. The University is required to comply with Sponsor regulations.
- Reporting Obligation. The University is required to provide to the Sponsor technical performance reports or regulatory or administrative reports; or
- Accounting Obligation. The University is required to establish a separate accounting record of project expenditures to demonstrate allowability of costs, to maintain financial accountability, to make financial reports to the Sponsor, and to preserve appropriate records for audit.
“Statement of Work” means the component of a Proposal or an Award that describes the specific work to be undertaken and the products that will be produced by the Sponsored Project.
“University Policies” means, for the purposes of this policy, all University Policies included in the University Policy Manual and all other procedures, guidelines and requirements of the Office of Research and Graduate Studies and the Office of Grant and Contract Accounting included in the Research Handbook, and the procedures, guidelines and requirements of all University colleges, schools, departments, centers, institutes and divisions.
Revised: December 16, 2019
Adopted: January 15, 2015