GAP 200.100, Capital Equipment Purchases on Sponsored Projects

  1. Applicability
  2. General
  3. Purchasing Procedure
  4. Property Control and Record Keeping Requirements

 


 

I. APPLICABILITY

Federal awards issued prior to December 26, 2014 should be managed in accordance with OMB Circulars A-21, A-110, and A-133.  Federal awards issued on or after December 26, 2014 should be managed in accordance with 2 CFR Part 200:  Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (The Uniform Guidance).  It is important to verify the appropriate regulations applicable to your award.  Documentation of appropriate regulations may be found in the Award Notice issued by the funding agency.

These guidelines pertain to federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-Federal sponsor’s policies and/or procedures.

This GAP supersedes previous GAP versions, Duke Policies, Guidelines, etc.  Unless otherwise noted, this GAP applies to all sponsored projects, unless superseded by guidelines from Non-Federal sponsors.

 

II. GENERAL

This procedure describes special requirements for capital equipment purchases charged to all projects sponsored by Federal and State agencies and Non-Federal agencies as applicable under sponsor rules. See GAP 200.050, Plant & Equipment Capitalization forthe definition of capital equipment. Note that although Federal Sponsors may not require purchase of American made products, they encourage it.

 

III. PURCHASING PROCEDURE

A. Purchase Order (outside vendors)

1. SAP Buy@Duke Cart

  1. Complete the Cart in Buy@Duke. The department is responsible for ensuring that items being purchased are allowable by the Sponsor and funds are available. All charges to Sponsored Projects must be in compliance with GAP 200.320, Direct Costing on Sponsored Projects.
  2. If the Sponsor is a Federal agency, attach in the notes and attachments section of the Cart the Equipment Screening form required in accordance with GAP 200.080, Equipment Screening and Shared Use on Federal Sponsored Projects.
  3. The Cart will be routed to the Office of Sponsored Projects automatically by the SAP system. The Office of Sponsored Programs will review the Cart for compliance with the terms of the award, appropriateness of the WBS element used, and availability of funds. If the Sponsor requires prior approval of the purchase, the principal investigator is responsible for requesting such approval. The sponsor’s approval must be sent to the Office of Sponsored Projects.
  4. If the Cart is acceptable, and they have received all required information, the Office of Sponsored Projects will approve the Cart directly in SAP. It will then be routed to Procurement Services.
  5. Procurement Services will follow normal purchasing procedures plus sponsoring agency requirements, if any. Procurement Services will follow their departmental procedures to obtain the bids and inform the principal investigator of the bids received. If the department has already obtained bids they can attach them to the Cart also.
  6. Procurement Services will issue a Purchase Order.

 

B. Interdepartmental Request and Invoice (IRI) (internal to Duke)

  1. Complete an IRI and obtain any departmental authorizations required. The department is responsible for ensuring that items being purchased are allowable by the Sponsor and funds are available. All charges to Sponsored Projects must be in compliance with GAP 200.320, Direct Costing on Sponsored Projects.
  2. Send IRI to the Office of Sponsored Programs. If the Sponsor is a Federal agency, include an equipment screening form - refer to GAP 200.080, Equipment Screening and Shared Use on Federal Sponsored Projects.
  3. The Office of Sponsored Programs will review the IRI for compliance with the terms of the award, appropriateness of the WBS element used, and availability of funds. If the Sponsor requires prior approval of the purchase, the principal investigator is responsible for requesting such approval. The sponsor’s approval must be attached to the IRI.
  4. If acceptable, the Office of Sponsored Programs will approve the IRI and forward it to the Duke Vendor.

 

IV. PROPERTY CONTROL AND RECORD KEEPING REQUIREMENTS

For equipment purchased on Sponsored Projects, property control and record keeping responsibilities include the following:

A. Principal Investigator

As custodian of the equipment, the principal investigator is responsible for:

  • Safeguarding and maintaining equipment in good repair
  • Promptly notifying the Office of Sponsored Programs if sponsor-owned equipment becomes surplus, lost, stolen, or missing
  • Promptly notifying Plant Accounting of any change in the location of the equipment

B. Procurement Services

Procurement Services should keep the following in the permanent Purchase Order file and/or SAP system:

  • Buy@Duke Cart or past Purchase Requisition
  • Purchase Order
  • Bids obtained
  • Equipment Screening form if required
  • Sponsored Programs' approval, and any other special approvals.

C. Office of Sponsored Programs

The Office of Sponsored Programs is responsible for:

  • Coordinating with Plant Accounting to ensure that the University's capital asset records are accurate and up-to-date.
  • Notifying appropriate sponsors of any sponsor-owned equipment that becomes surplus, lost, stolen, or missing
  • Expediting the disposal of sponsor-owned equipment according to the requests of the sponsor in coordination with the principal investigator and Plant Accounting
  • Submitting property reports to sponsoring agencies as required by the award document.

D. Plant Accounting

Plant Accounting is responsible for:

  • Tagging all capital equipment with the appropriate property control tags as appropriate and recording specific information such as description, model, location, serial number, etc., as required by 2 CFR Part 200 §200.313
  • Maintaining the capital asset records on an accurate and up-to-date basis
  • Periodically conducting an independent physical verification of all capital and sponsor-owned equipment and adjusting the capital asset records based on their findings, as required by 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

 

 

Note: This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.