GAP 200.110, Excess Federal Government Property - Use by Sponsored Projects

  1. Applicability
  2. General
  3. Definition of Terms
  4. Acquisition
  5. Record Keeping Requirements
  6. Inventory Procedures
  7. Disposition or Transfer

 


 

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.  Note that subawards issued under this GAP follow the same regulatory applicability as the prime award.

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  Unless otherwise noted, this GAP applies to all sponsored projects, unless superseded by guidelines from Non-Federal sponsors.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

The Federal Government may transfer excess government personal property to Duke University as a means of providing additional grant support and conserving supply and equipment funds. Excess government personal property includes new or used equipment and materials owned by the Federal Government but no longer needed by the holding federal agency. The Contracting/Granting Officer's approval is required before excess property can be obtained on a federal contract or grant.

The custodian of excess government personal property is responsible for the maintenance, repair, protection and preservation of the property so that it is usable for the purpose for which it was obtained. All excess government personal property is accepted subject to any written directions of the sponsoring agency. Usually title to the property remains with the Federal Government. If title remains with the Government, any enhancements and repairs to the property also stay with the Government.

Government owned property cannot be disposed of without prior written Governmental approval.

 

III. DEFINITION OF TERMS

A. EXCESS PROPERTY

Items of equipment, new or used, owned by the Federal Government and no longer needed by the holding agency, but not declared surplus.

B. HOLDING AGENCY

The agency or department of the Federal Government that physically possesses the excess property.

C. SPONSORING AGENCY

The agency of the Federal Government that is funding a project at Duke University pursuant to a grant or contract. The sponsoring agency is not necessarily the same as the holding agency, although it may be.

 

IV. ACQUISITION

When General Services Administration (G.S.A.) information on excess property is made available (usually by the sponsoring agency), the principal investigator should select items needed for a particular grant project. Materials and equipment selected should be inspected if possible. If physical verification is not possible, the principal investigator should contact the holding agency to verify the condition of the items. Interpretation of condition codes varies among agencies.

After confirming the condition of the property, the principal investigator should call the G.S.A. office identified in the catalog to freeze (reserve) items. Items are usually allocated on a first come, first served basis. Confirm the reservation by follow-up letter, which must be routed through the Office of Sponsored Programs for co-signing by a University official. Requests must explain why the property is needed and on which sponsored project it is to be used.

Excess property is usually obtained without cost to the University. However, the University specifies the method of shipment and usually pays all costs of packing, transportation, installation, and any subsequent rehabilitation and or maintenance required, unless the sponsored project provides for the payment of such costs.

 

V. RECORD KEEPING REQUIREMENTS

Forward copies of the shipping documents to the Office of Sponsored Programs for inclusion in the sponsored project file and equipment inventory: these documents must list the related project, location of the property at Duke, custodian of the property, government equipment number, and the date of acquisition. The Office of Sponsored Programs will contact Plant Accounting so that items may be tagged and properly recorded.

All excess property must be catalogued in the University’s physical property records according to the price stated by the Federal agency, even though the item was obtained at no cost to the University. The price is usually shown on the shipping document accompanying the equipment. This equipment is referred to as “Government Furnished” and is owned by the Federal Government. The University is responsible for tagging and maintaining inventory control on these items until the government instructs the University to ship the equipment to another location or relinquishes title to the University.

 

VI. INVENTORY PROCEDURES

Plant Accounting is responsible for establishing and maintaining inventory control over excess government property. They will periodically inspect the property to determine its location, condition and existence. The custodian of the equipment will be given advance notice of inspections to arrange their schedule accordingly.

 

VII. DISPOSITION OR TRANSFER

When an item of excess Federal Government personal property is no longer needed for the purpose for which it was obtained, notify the Office of Sponsored Programs with a disposition request. The disposition request should say what the department wants to do with the property, based on the condition of the property, cost of transport, and need by another area of the University. The Office of Sponsored Programs notifies the sponsoring agency. The agency gives official disposition instructions to the Office of Sponsored Programs who then notifies the department and Plant Accounting.