3.1. Utilization and Maintenance
When property is acquired with sponsored award funds, the university must ensure that the property is (1) used for the conduct of the project, (2) made available for other research activities to the greatest extent possible to avoid duplicative purchases, (3) adequately maintained in working condition, and (4) safeguarded against loss, theft, damage or abuse. Below are the specific use and maintenance requirements for Government and university titled property.
Utilization
University Titled: Equipment purchased with federal funding and titled to the university shall be used on the project for which it was acquired as long as needed although it can also be used on other projects as long as that work does not interfere with the original purpose. 2 CFR 200.313(c) stipulates that when the project is completed, priority for use of the equipment is given to other federally sponsored projects or programs but it is also permissible to use the equipment on non-federally funded activities.
Government Titled: Use of Government property is authorized for a specific award unless the sponsor has approved of additional uses. When Government property is no longer needed for the award on which it is accountable, it is considered “excess” and disposition instructions should be requested from the sponsor or this is the time to request transfer to a follow-on contract. Disposition needs to be completed before disposal can be approved. Excess Government property cannot be used on another project until authorized by the ACO and sponsor and formally transferred to the new award.
The award PI is responsible for the direct control, maintenance, and accountability of Government property used in connection with a contract or grant, both on and off campus. PIs may assign property control functions to project staff, research coordinator, department property manager, departmental administrator, or laboratory administrative staff. In doing so, all must understand that the use and care of Government property is subject to the stewardship responsibilities codified in FAR 52.245-1 and is subject to federal audit. The Requirements for Government Property: PI Guidelines is a one-page resource for PIs responsible for Government property.
Maintenance
University Titled: Uniform Guidance (2 CFR 200) states that adequate maintenance procedures must be developed to keep property purchased on federally funded research projects in good condition. A department maintenance plan should be outlined in the Department Property Management Plan so there can be consistent application of the department’s standards.
Government Titled Property: While Government property or equipment is in the custody of CU for use on a project, the custodial department shall follow a maintenance program or calibration schedule that ensures Government equipment is properly cared for and repaired per FAR 52.245-1. The maintenance methods below are specifically applicable to Government property and equipment, as defined by the Guidebook for Contract Property Administration:
Preventive Maintenance: Includes regularly scheduled inspections, calibration, and maintenance to sustain good working condition and avoid damage to the equipment. This maintenance must be performed at regularly scheduled intervals and follow any prescribed manufacturer recommended schedules, if applicable. The PI/department shall maintain records of this maintenance providing the date maintenance was performed, specific action taken, who was responsible for performing the maintenance, and if any deficiencies were uncovered.
Corrective Maintenance: Provides for corrective action and repair. The PI/department shall develop procedures for personnel operating Government equipment with instructions on reporting deficiencies or problems to the PI, department and, ultimately, to OCG. Corrective maintenance must be reported to the sponsor by OCG and receive approval from the sponsor before taking place.
Capital Type Rehabilitation: Involves repair or replacement exceeding normal maintenance obligations and considered to be a capital improvement. Capital Type Rehabilitation must be reported to the sponsor and to the ACO by OCG and receive approval from the sponsor and the ACO before taking place.
Property with Special Requirements: Includes items whose maintenance must follow requirements in Government technical publications or manuals.