1. A Property Management Primer Key Elements Affecting Equipment in Research
Presented by: Ivonne Bachar, CPPM CF Director, Property Mgmt. Office Stanford University Event: NCURA – Regions VI and VII Denver, CO April 4-6, 2011

2. Discussion Encouraged!
Today’s Focal Points
Property Life Cycles – A Birds Eye Look
Key Terms
Regulatory Context
Pre-Award
Post Award
Close-outs and Audits
Discussion Encouraged!

3. Terms & Concepts Accountability Stewardship Title Property Equipment
Capital
Depreciation
Title
Property
Equipment
Exempt Equipment
Material
Supplies
Screening
CAP
GFP/GFM
NOTES:

4. Property Life Cycle Close-out and Disposal Getting the Goods Property
Rules & Business Needs
Policies & Procedures
Phase I
Phase II
Phase III
Close-out and
Disposal
(Once item is excess)
Getting the
Goods
(Need thru Acquisition)
Property
Control
(In-use period)
Tracking – Training – Awareness
Reporting – Reconciliation – Adjustments
Audits – Process Improvements

5. “Regulatory” Context Office of Management & Budget (OMB) Circulars
Federal Acquisition Regulations (FAR)
Agency-Specific Supplements
State Regulations
Accounting Standards (GASB, GAAP, FASB)
IRS Guidelines
Export Controls
Other associated regulations (e.g. EPA)
Data Security
VCSs and ILPs
Agreement-specific Terms & Conditions
NOTES:

6. Contractor Outcomes (Property Mgmt. System Components)
Acquisition
Receipt
Records
Physical Inventory
Sub-contractor control
Reports
Utilization
Maintenance
Contract close-out
FAR
“Contractors shall develop property management plans and systems, at the contract, program, site or entity level that reflect their efforts to obtain best value”
Notes:
Imbedded Outcomes:
Identification, Storage, Movement, Disposal, Management, and Audit

7. Regulatory Requirements (Grants)
Code of Federal Regulation / OMB Circulars
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
A-87
Cost Principles for State, Local, and Indian Tribal Governments
A-123
Management’s Responsibility for Internal Control
A-133
Audits of Institutions of Higher Education & Other Non-Profit Institutions
NOTES:

8. FAR for Contracts Alternate II > > > Preferred Option
Key Clauses:
Alternate II
>>Government Property
>>Property Plan
NOTES:
Alternate II > > > Preferred Option

9. , Alternate II
Gives title to recipient for equipment under $5,000, provided that the recipient obtained CO’s approval before each acquisition.
Gives title to recipient for equipment $5,000 or greater, with CO’s permission. (Note: Sponsor holds title during life of contract)
NOTES:
Applies only to Contractor Acquired Property
Beware of Tax Implications

10. Pre-Award Support SOW Property Plan for contract proposals
Budget justifications
Identify methods of acquisition
Clearly define
Fabrications
Deliverables
Acceptance and delivery criteria
Negotiate appropriate clause

11. Acquisition Approved budget vs. authority to purchase
Approvals & Screening
Financial & Reporting Categorization
Explicit listing of GFP needed
Import & Export
End of period purchases
NOTES:

12. Methods of Acquisition and Lifecycle Changes
Sponsor Furnished
Or Loaned
University (Contractor) Acquired
Lease
Rent
Donation
If Sponsor Title
Considered GFP
Incoming Transfers
Title Transfers
Purchases
Fabrications

13. Equipment Title – Grants
Sponsored
GRANT
University
Title
Purchases
Taxable
(OMB Circulars)
13⅞
Notes:
In some cases 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

14. Equipment Title – Contracts
<$5K University Title
F&A (aka IDC) Applies
FAR (Alt. II)
$5K> Sponsor Title
No F&A (aka IDC)
Federal
Sponsored CONTRACT
Sponsor Title
Non-Taxable
No F&A (aka IDC)
14⅞
(FAR Clause)
FAR
or per T&C
Notes:
Equipment furnished by Sponsor, remains sponsor-owned
Non-Federal, Sponsor-Owned equipment may be taxable (e.g. State of California)
May request title transfer to Sponsor-owned property upon completion of award

15. Property Title Driven by agreement type and T&Cs Affected by
Acquisition Method
Source of funding
Title determines taxability
May change throughout life of agreement
Determines reporting
Limits disposition options
How might this affect
Project Budgets or the
Proposal Process?
NOTES:

16. Remember Property at Subcontractor!
Physical Inventory
Frequency dependent on approved policies and procedures, State, or sponsor requirements
OMB A-110 & A21
Biennial – you define schedule
Verification & reconciliation
Report
Timing, content, distribution
University financials vs. sponsors
Missing items
FAR
Periodically or per accepted procedures
GASB
Annual, or based on asset category
Remember Property at Subcontractor!
NOTES:

17. Transfers (Incoming or Outgoing)
Define items involved
Award type & status
Funding Source
Method of acquisition
Current title
Retention requirements
Cost or no-cost?
Approvals
Import-Export Issues
NOTES:
“It Depends” starts here...

18. Subcontracting Ensure your flow down addresses AT LEAST:
Confirm recipient’s property system
Acquisition and Title
Identification and Records
Physical inventory
Reports, including LDDT
Use
Disposition
Risk and Liability
Stewardship responsibilities
NOTES:

19. Subcontracts Title Issues, cont.
The Prime needs to be careful not to give the sub greater title rights than the prime has been given; consider:
What type of instrument is the Prime?
Is the sub an eligible recipient?
Is the sub doing research or other professional services?
Are there restrictions on the prime’s clear title?
How is GP affected?
At what point is title granted to sub?
NOTES:

20. Include Sub-award info
Reports
Agency Specific
Management and Self Assessment
Internal Audit
Interim
Financial and/or Accountability
Physical Inventory
Loss, Damage, Destruction, Theft
Corrective Action
Final Closeout
NOTES:
Include Sub-award info

21. Other “Hot Spots” International and Collaborative Agreements
Self-Assessments
Import - Export controls
Fabrications
Journal Transfers
P-Card Purchases
Indirect Cost implications
Multi-disciplinary projects
Multi-source funding
Data Security

22. It’s about integration
Rules and
Requirements
Orgs, Policies,
Procedures,
People
Assets and Tech
Infrastructure
Notes:
Property
Professional
Skills

23. Thank you for being here today!!!
Questions???
Concerns???
NOTES:
Thank you for being here today!!!