3.3. Records

Uniform Guidance (2 CFR 200) requires the university maintain a property control system that provides for adequate identification, records, location, utilization, maintenance, and physical inventory of equipment acquired with federal funds. Figure 4 below illustrates the information that is housed in the university property record.

According to the provisions of FAR 52.245-1(f) and (g), the records for all Government titled property transactions are auditable and should sufficiently demonstrate:

  1. Appropriate approval was granted prior to the acquisition of Government property.
  2. The purchase of Government property was completed in accordance with Federal and state procurement standards and university policies.
  3. Authorized personnel physically received the Government property.
  4. Substantiation that appropriate tagging and recording the property in the property system occurred within days of its receipt.
  5. Government property is used, maintained, and/or stored in an appropriate location.
This additional information required for Government property is housed in records that are maintained by OCG.

Asset Detail - CU or Government tag number, Asset ID, Item Description, Description Code, Category, Condition Code

Acquisition Detail - Acquisition Date, Acquisition Cost, Acquisition Code, Asset Status, Disposition Details, Federal Interest

Manufacturer Detail - Manufacturer, Model and Serial Number, Purchase Order, Invoice Number

Department Detail - Department Code, Asset Location (Building and Room Code), Responsible Person, Sponsored Award(s) number

Record Retention: All records and other documentation for equipment acquired with federal funds and for Government titled property must be retained for three years after disposition. See APS 2006 Retention of University Records for additional details.

Determining Acquisition Cost for Government Titled Property

Government Property Purchased by the University: The acquisition cost of Government titled property purchased by the university shall be recorded as the net invoice unit cost of the property. This acquisition cost may also include the costs for modifications, attachments, accessories, or auxiliary components that are necessary to make the property usable for the purpose for which it was acquired. Other charges, such as cost of installation, transportation, taxes, in-transit insurance, etc., shall be included in the unit acquisition cost in accordance with the university's regular accounting practices. Generally, only items having an acquisition cost of $5000 or more are logged and tracked in the university property record but there may be exceptions when items less than $5000 are also assigned 0F tags and accounted for in the university property record, depending on the contract terms and conditions.

Government Furnished Property (GFP): The unit acquisition cost of Government furnished property shall be determined by the Government and is disclosed in the award terms and conditions which assign the Government furnished property to the award. Normally, the unit cost of Government furnished property is provided on the transfer document covering shipment of the property to the university. In the event the unit cost is not provided on the document, OCG contacts the sender of the property for the value. If not provided by that entity, the PI receiving the property can provide an estimated value, given its function and age. Government furnished property may have a value less than $5000 but is still tracked by OCG because of its status as GFP.

Annual and closeout property reports require that all Government titled property listed in those reports be assigned a dollar value.

Recording a Change in Status

During the performance of the award, it is the responsibility of the PI and the department property manager to notify OCG of any changes in record details, use, condition, and/or location of equipment purchased with sponsored research funding and particularly with Government titled property. The department is also responsible for updating OCG on any changes regarding furnished property, such as location, responsible person, and condition (damage, repair, replacement, return, etc.). Please see
3.1 Utilization and Maintenance for guidance on the use and maintenance of Government property.

Physical Inventory of Government Property

In accordance with FAR 52.245-1(f)(iv) the university shall perform, record and disclose results of physical inventory of all Government property on campus. OCG collaborates with the department property manager to locate Government property and crosscheck the information for that property (serial number, tag number, room location, condition, etc.) with the records in the asset management system (PSAM). Any changes regarding Government property discovered during inventory are updated in the university property record and the award management system. A final physical inventory of Government property is also conducted upon the completion of an award on which Government property is accountable.

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