Business Policies and Procedures Manual
Chapter 40: Sponsored Agreements

Management of Equipment Acquired Under Federal Agreements

BPPM 40.13

For more information contact:
   Sponsored Programs Services
   509-335-2058

Policy

All equipment acquired under federal grants and contracts must be properly identified, recorded, maintained, and disposed of. The department chair, equipment coordinator, and principal investigator share responsibility for care, maintenance, safeguarding, and use of federal equipment in their custody.

Property Requirements

Uniform Guidance

Such property is managed in accordance with Uniform Guidance 2 CFR 200.

FAR (48 CFR)

Federal Acquisition Regulations (FAR) provide additional federal requirements for property management on contracts. Note: Most of the regulations used by the University are located in FAR Part 45.

View FAR Part 45 on the FAR website.

DFARS

Defense Federal Acquisition Regulation Supplement (DFARS) provides additional requirements for property management on federal defense contracts.

To view the DFARS, go to the DFARS website.

NASA Grants Handbook

NASA Grants Handbook sections 1260.130 through 1260.137 provide uniform standards governing management and disposition of property charged to projects supported by National Aeronautics and Space Administration (NASA) grants and cooperative agreements.

Award Conditions

Various sponsor agencies may reference other specific property management requirements in the award documents.

Property Inventory

Departments are to tag and inventory newly-acquired (i.e., purchased, leased, borrowed, or fabricated) equipment in accordance with procedures in BPPM 20.50.

Property Reporting

Sponsored Programs Services (SPS), with the assistance of the department administrator or principal investigator, provides property reports to the sponsor in accordance with the award terms and governing federal regulations.

Annual Property Reports

Department of Defense (DoD) Contracts

DoD Form 1662 is used to report government-furnished property and property acquired on Department of Defense (DoD) contracts.

Government-titled property held by the University under DoD contracts, regardless of value, must be reported annually by October 31. If WSU no longer holds property under a DoD contract, an annual report is not required unless held property was indicated in the previous annual report.

NASA Contracts

NASA Form 1018 is used to report government-furnished property and property acquired on NASA contracts.

Government-titled property held by the University under NASA contracts, regardless of value, must be reported annually by October 15. If WSU no longer holds property under a NASA contract, the University is required to submit an annual report indicating that no property is held.

DoD and NASA Grants and Cooperative Agreements

A listing of government-titled property held by the University under grants or cooperative agreements must be reported annually by October 31. If WSU no longer holds property under a grant or cooperative agreement, an annual report is not required unless held property was indicated in the previous annual report.

DoD Property Reports

Property reports for DoD grants and cooperative agreements other than contracts are to be submitted in narrative format by letter, fax, or e-mail to the DoD property administrator.

NASA Property Reports

Property reports for NASA grants and cooperative agreements other than contracts are to be submitted in narrative format by letter, fax, or e-mail to the government property administrator or DoD property administrator, the NASA Industrial Property Officer (IPO), and the NASA Deputy Chief Financial Officer (CFO).

Final Property Reports

DoD Contracts

Immediately upon termination or completion of a DoD contract, the University must perform and require each subcontractor to perform a physical inventory of all property acquired under the contract.

A final report on DoD Form 1662 must be submitted to the cognizant DoD agency immediately upon final disposition of all property acquired under the contract.

NASA Contracts

A final report on NASA Form 1018 must be submitted to NASA within 30 days after disposition of all property acquired under the NASA contract.

DoD Grants and Cooperative Agreements

A report must be submitted to the cognizant DoD agency within 90 days after a grant or cooperative agreement is terminated.

Property reports for grants and cooperative agreements are to be submitted in narrative format by letter, fax, or e-mail to the cognizant DoD property administrator.

NASA Grants and Cooperative Agreements

A report must be submitted to NASA within 60 days after a grant or cooperative agreement is terminated.

Property reports for grants and cooperative agreements are to be submitted in narrative format by letter, fax, or e-mail to the government property administrator or DoD property administrator, the NASA Industrial Property Officer (IPO), and the NASA Deputy Chief Financial Officer (CFO).

Property Closeout

At award closeout equipment must be processed and reported in accordance with:

University Requirements

SPS takes the following actions to process and report government property at award closeout:

  • For closeout of a DoD or NASA contract/award, the custodial department completes a draft property report on an agency-designated form (e.g., DoD Form 1662, NASA Form 1018). See Final Property Reports for information concerning final reports.
  • For closeout of a contract, grant, or cooperative agreement which does not require a specific agency form, the custodial department completes a draft property report using a spreadsheet format. The report is to include the following information:
    • Manufacturer/description,
    • WSU tag number
    • Model/serial number
    • Date acquired
    • Purchase order number or vendor order number
    • Disposition requested

    Some agencies also require the following additional information:

    • Condition of equipment
    • Location/custodian
  • The custodial department e-mails the draft report to SPS; e-mail sps@wsu.edu.
  • Upon receipt, SPS mails, e-mails or faxes the completed report to the appropriate government representatives, as indicated in the award documentation or governing agency guidelines. See also Final Property Reports.

    Contracts require that annual reports continue to be submitted until the University receives final disposition instructions. See Annual Property Reports.

  • Upon receipt of disposition instructions from the government representative, SPS ensures that the departmental administrator completes a Dispose Asset transaction in Workday to update the WSU’s property inventory records accordingly. (See BPPM 20.50 and the Workday Dispose Assets reference guide.)

    For property acquired under a grant or cooperative agreement, if title is granted to WSU, or if the property is abandoned in place, no further reports are required.

    For property acquired under a contract, a terminating report must be submitted to indicate final disposition if the previous report indicated that the University held contracted property. See Final Property Reports above for information concerning contract reports.

Loans, Transfers, and Disposals

Loans

WSU-Owned

Departments holding equipment that is no longer used are encouraged to explore opportunities to loan or exchange with other departments prior to arranging for disposal or sale. Inform Property Inventory of the loan by completing a Transfer Asset transaction in Workday, in accordance with instructions in the Workday Transfer Assets reference guide. (See also BPPM 20.50.) Indicate only a change in location if the ownership remains with the loaning department.

Federally-Owned

Federal regulations encourage loan or transfer of government-owned equipment to other federally-supported projects when no longer needed on the original project. Request authorization from SPS prior to transfer.

When the transfer occurs, initiate a Transfer Asset transaction in Workday, in accordance with instructions in the Workday Transfer Assets reference guide. (See also BPPM 20.50.) Indicate “Federally Owned” in the Transfer Comments field. Property Inventory works with SPS to ensure that federal officials are notified of the change.

See BPPM 20.78 for transfer of federal excess equipment.

Title Transfer

Transfer to WSU from the Federal Government

On many contracts/awards title is transferred from the federal agency to WSU partway through or at the end of a project period. When this is the case, the custodial department must include SPS’s acknowledgment that the property now belongs to WSU when the department adds the equipment to WSU’s inventory systems. See BPPM 20.50.

Transfer to Another Institution

See BPPM 40.16 and 20.50.

Sale or Transfer to Other WSU Departments

Follow procedures for surplus equipment in BPPM 20.76 and 20.80.

Disposal of Federally-Funded WSU-Owned Equipment

The item may be subject to a specified accountability period which must expire before the University may sell the item. Contact Sponsored Programs Services for information.

Cost of $5,000 or More

When any accountability period has expired which applies to an item with a cost of $5,000 or more, WSU may either:

  • Keep the item and pay the federal agency its share of the market value, or
  • Request instructions from the agency. Instructions from the agency may be:
    • Sell it and pay the agency its share of the proceeds.
    • Ship it elsewhere.

Disposal of Federal Excess Property

See BPPM 20.78.

Maintenance and Use

Departments are responsible for the care, maintenance and use of all equipment in their custody. For equipment acquired under grants and contracts, the principal investigator shares this responsibility with the department.

Accountability

Department management is responsible for properly documenting equipment receipt, storage, preservation, recordkeeping, physical control, inventory, and disposal.

Security

Principal investigators and departmental personnel are responsible for keeping equipment in a reasonably secure location.

Insurance

WSU-owned equipment is usually not insured unless obtained under an agreement which permits the sponsor to pay insurance premiums. Risk Management Services purchases all insurance for University equipment and property. See Executive Policy EP6.

Care and Maintenance

Care and maintenance includes:

  • Periodic inspection,
  • Regularly scheduled lubrication or other preventative maintenance,
  • Protection from exposure, and
  • Proper cleaning prior to storage.

The goal is to maintain the efficiency and usefulness of the equipment for as long as possible.

Departments should keep records of maintenance, major repair, and deficiencies revealed during periodic inspection. (Principal investigators are responsible for ensuring that any special equipment care and maintenance requirements required by grants and contracts are implemented.)

Utilization

The equipment clause in most current contracts requires that federal equipment be used only for the contract for which it was acquired unless otherwise provided or approved by the cognizant federal agency contract administrator. The principal investigator is responsible for ensuring compliance with this requirement.

The principal investigator is also responsible for notifying Sponsored Programs Services when there is no further reason for retaining an equipment item acquired under a federal agreement.

Subcontractor Control

Subcontract Requirements

Before a subcontractor under a federal contract/award may take temporary possession of federal equipment furnished by the University, the subcontract must include:

  • Provisions authorizing transfer, loan, or temporary reassignment of the equipment.
  • Federal flow-down provisions. Flow-down provisions are defined as requirements from the funding federal agency which apply to all entities operating under the award contract, e.g., contracting institutions, subcontractors.
  • Special terms and conditions.
  • Provisions requiring certification that the subcontractor has a property control system that is either federally-approved or meets federal property regulations, unless exempted by the special terms and conditions.
  • Periods for which the subcontractor must submit property reports to WSU. When feasible, the subcontract is to include the subcontracting agency form numbers and applicable web site addresses for obtaining the forms.
  • Other reporting requirements specified in the prime award.
ORSO

Notify the Office of Research Support and Operations (ORSO) during subcontract development to ensure that the subcontract also includes provisions for:

  • Conditions of use
  • Control of equipment
  • Period of use
  • Return of equipment
  • Location of use
  • Shipping costs
  • Insurance
  • Loss, damage, or destruction
  • Liability
  • Maintenance

In addition, ORSO may request a copy of the subcontractor’s federally-approved property control system or a copy of its property control policies.

Sponsored Programs Services (SPS)

SPS works with departmental research administrators to ensure that the subcontractor submits property reports for the reporting periods specified in the subcontract.

SPS works with departmental research administrators and principal investigators (PIs) to take action at award closure in cases where the subcontractor holds the title to the property. See Property Closeout.

Transfer Asset Transaction

Upon approval of the subcontract, the responsible WSU department, principal investigator, business asset accountant, or business asset tracking specialist must complete a Transfer Asset transaction in Workday indicating a change of location. (See the Workday Transfer Assets reference guide and BPPM 20.50).

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Revisions:  May 2021 (Rev. 568); Sept. 2020 (Rev. 555); Feb. 2010 (Rev. 356); Feb. 2003 (Rev. 224); Jan. 2002 (Rev. 200); Oct. 2000 (Rev. 171); Dec. 1983 – new policy (Rev 54).