1. Please use the following two slides as a template for your presentation at NES. Grants Awards & Management At Universities Presented by: David L. Routzahn, CPPA Inventory and Surplus Control Manager University of Texas at Dallas dxr056000@utdallas.edu

2. Agenda Setting the Context Review Key Aspects of Grant Property Common Challenges Q & A

3. Page 3 Business Drivers Type of Institution Ranking Among Research Universities University Mission of Education Extensive Government Income –Research Funding –Indirect Cost Recovery Subject to CAS External Auditors –DCAA, ONR and other Sponsors Contractual Compliance Financial Accounting Compliance

4. Page 4 The Compliance “Puzzle” Code of Federal Regulations Office of Management & Budget (OMB) Circulars Governmental Accounting Standards Board (GASB) Federal Acquisition Regulations (FAR) Agency-Specific Supplements Generally Accepted Accounting Principles (GAAP) State Regulations Accounting Standards IRS Guidelines Other associated regulations (e.g. EPA) VCSs and ILPs

5. Grants Financial Assistance Awards Support to Accomplish Public Purpose Competitive Process Awarded to Eligible Recipients Support Basic or Applied Research Expand University Research Infrastructure

6. Page 6 Regulatory Requirements 2 CFR 220 ( OMB A-21) –Cost Principles for Educational Institutions 2 CFR 215 (OMB A-110) –Uniform Administrative Requirements for Grants and Cooperative Agreements with Institutions of Higher Education, Hospitals, and other Non-Profit Organizations OMB A-87 –Cost Principles for State, Local, and Indian Tribal Governments OMB A-123 –Management’s Responsibility for Internal Control OMB A-133 –Audits of Institutions of Higher Education & Other Non-Profit Institutions

7. Pre-Award Equipment Considerations Support SOW Budget justifications Identify Collaborative Efforts Clearly define –Equipment –Data Management Devices –Supplies Page 7

8. Acquisition Seek Exempt designation Define within grant award document Title without further obligation Title with University, contingent on: Use in project or program for which acquired Do not encumber without Sponsor approval May be traded in for other program acquisitions with sponsor approval

9. Acquisition Cost (CAP) Includes apparatus needed to make property usable for intended purpose Must include: Net Invoice Price Cost of modifications, attachments, accessories or auxiliary items Optional Costs per policy Installation, transportation, taxes, duty, insurance.

10. Page 10 Funds Comingling Verify ability to comingle May affect equipment title –Most restrictive usually applies Prioritize –Same Sponsor, same type of research –Same type of research, different Sponsor –Same type of award –Understand impact of award terms

11. Equipment Title – Grants SponsoredGRANT University Title Purchases Taxable Notes: –Title to GFP remains with Federal Government –Granting agency may impose future use restrictions on equipment –In rare cases when equipment is furnished on a grant or if specified in the terms of the grant, it is treated as sponsor owned. –Some Federal Sponsors retain right to title, and may opt to reclaim to non-exempt property (OMB Circulars)

12. Use Priority for asset use: Project or program for which acquired Do not encumber without Sponsor approval Make available for non-interference use Other use priority Activities from same sponsor Activities from other Federal agencies

13. Property Records Accurate records minimum data: –ID, Description, Model, S/N, FSC –Funding Source and Distribution Percentage –Title –Acquisition Date –Location –Condition –Cost –Disposition Data

14. Page 14 Physical Inventory Frequency and Reports Frequency dependent on approved procedures, State, or sponsor requirements 2 CFR 215 (OMB A-110) Biennial for CAP Annual for GFP You define schedule Report Timing, content, distribution University financials vs. sponsors Missing items GASB Annual, or based on asset category

15. Subcontracting Ensure award type matches type of recipient Ensure your flow down addresses AT LEAST: Acquisition and Title Records Physical Inventory Reports, including LTDD Use Disposition Risk and Liability Stewardship Responsibilities

16. Safeguarding Safeguard to prevent loss, damage, theft All L, D, T incidents investigated –Reported to Federal Agency if Federally-owned equipment Adequate maintenance

17. Page 17 Disposition If CAP –Per your approved procedures or best practices If GFP –Declare excess to GSA –Agency may be able to dispose through Technology Transfer Act

18. (Incoming or Outgoing) Transfers (Incoming or Outgoing) Define items involved Award type & status Funding Source Method of acquisition Current title Retention requirements Cost or no-cost? Approvals? Type of disposition “It Depends” starts here...

19. Excess GFP For equipment with current >$5K FMV: –Retain title after compensation Apply % of Federal participation in original project or program to current FMV –If not needed, request Sponsor disposition –If no disposition within 120 days Compensate Sponsor sales proceeds based on % of Federal participation in original project or program to current FMV May retain $500 for administrative expenses of sale –Sponsor may opt to transfer

20. Page 20 Audits Single Audit Concept…..however: –Potential Types Affecting Grants Internal Audit Cognizant Agency (e.g. ONR) Sponsor DCAA Contractor Self Oversight Third Party Financial Statement

21. Campus-wide Touch Points PMO 21

22. The University Culture Challenge Accountability Consequences “Entitlement” Generalization of “grant” conditions to Contracts and other agreements Shared Funding End of period purchases Screening (or not?) Page 22

23. Other Interesting Points Grant funded property NOT eligible for Indirect Cost Recovery Recipient must provide insurance for CAP Cost Sharing may be involved Basic reporting, usually end of award statement Bulk equipment? Multi-disciplinary projects

24. Page 24 Questions??? Thank you for being here today!