4.5. Property Disposal/Relief of Stewardship

• Item is inoperable, obsolete and/or no longer needed.

CU Property: Property that is no longer operable or needed is considered excess and the department is encouraged to initiate disposal. The department completes the Property Disposal Request Form and routes it through DocuSign for the necessary approvals. OCG reviews the award terms and conditions to determine any further obligations to the sponsor for the property. If the disposal is allowable under the award terms, OCG signs the disposal request form which is then routed to Property Services and PAO to finalize the physical disposal of the excess property. According to the campus record retention policy, records for this property must be retained for three years after disposal.

Government Property: If the property is titled to the Government and has been identified as excess, the department notifies OCG before disposing of it or trading it in. Government titled property cannot be disposed without authorization from the sponsor, the ACO.  OCG requests disposition instructions from the sponsor and the ACO, indicating that the property is considered “excess” and no longer needed by the university. The sponsor will provide one of the following disposition instructions:

1. Title to the excess property may be transferred to the university.
2. Transfer accountability of the property to another contract held by the university.
3. Title to the excess property may be retained by the Government and the university must return the property according to the sponsor’s instructions.

After the disposition instructions are received from the ACO and or the sponsor, OCG, the department and PAO coordinate to update the university property records and comply with the instructions.

Disposition coordinated with OCG, PAO and Property Services

• Item is returned to vendor for full credit.
• Item is traded in for credit or newer parts.

CU Property: The department may determine that property should be returned to the manufacturer for upgrade or trade in for a newer piece of equipment. The department obtains approval from Property Services before returning the asset to the manufacturer or if there is a trade-in because the PSC requires input on such transactions. The department should also contact PAO to update the asset management records and OCG if the property was acquired on a sponsored award.

Government Property: Approval from the sponsor must be received before Government property can be returned to the manufacturer. When Government titled property needs to be returned to the manufacturer for a repair, upgrade or trade-in, the department must notify OCG prior to returning the property to the manufacturer. OCG requests approval from the sponsor to return the property to the manufacturer. Once approval is obtained, OCG coordinates with the department and PAO to update the university property record.

Disposition coordinated with OCG, PSC, PAO, and Property Services.

• Under the award terms, the item is a deliverable
• Under the award terms, the item is furnished or loaned

When property acquired with award funds is titled to the sponsor or is considered a deliverable under the terms of the award, the department is responsible for delivering the property according to the sponsor’s instructions. The department contacts OCG before shipping any deliverables to ensure compliance with the award terms and conditions. After the property is returned, OCG and PAO will coordinate to ensure the university property record accurately reflects the status of the property.

If Government property is to be returned to the sponsor, the department works with the OCG to complete the return of Government property according to the sponsor’s instructions. According to the campus record retention policy, records for this property must be retained for three years after return. See 4.1 Federal Award Closeout for information on closing a project with Government property.

Disposition is coordinated with OCG, PAO, and Property Services

University titled property may be transferred between departments on campus or to another non-profit institution. Government titled property cannot be transferred without approval from gaining and losing sponsor. To initiate a transfer for property acquired with award funds, the department first contacts OCG to confirm that all the sponsor’s obligations for the property have been fulfilled. The process for transferring property to another department or to another non-profit institution is as follows:

Transfers to another CU department:

1. The departments involved in the transfer complete the Property Disposal Request form and submit it to ocgproperty@colorado.edu, including signatures from both the transferring and receiving departments.
2. OCG determines whether all obligations to the sponsor have been met.
3. OCG countersigns the request form and returns the fully executed copy to the departments.
4. Both the transferring and receiving departments must sign the Interdepartmental Transfer Form and return to PAO. Both departments are responsible for notifying PAO that the property has transferred, who then updates the property record. 

Permanent transfers to another non-profit institution:

1. The PI who is transferring to a new institution needs to create a detailed inventory of property to be transferred which includes item descriptions, serial numbers, CU tag numbers, acquisition costs and dates, and condition descriptions.
2. The PI’s department Chair or Institute Director must review and approve, via signature, the detailed list of items to be transferred and when approved the PI submits the list to ocgproperty@colorado.edu
3. OCG reviews the list of property items that will be transferred, university property records, and award records to determine whether any existing obligations to the sponsor remain for the property. If the receiving institution is reimbursing the university for items that are being transferred, the PI’s department is responsible for invoicing the receiving institution and ensuring payment is received. It is the responsibility of the receiving institution to pay for any shipping or moving costs associated with the property transfer.
4. Approvals from OCG and Research and Innovation Office, if applicable, are provided to the department, PAO, and Property Services.
5. The department works with Property Services and PAO for final approvals and changes to the university property record.
6. PAO contacts the office at the receiving institution responsible for receiving the property to report what is being sent to them by CU and confirms the institution is willing to accept it.
7. Detailed procedures for property transferred to a new institution when a CU PI is transferring to that institution is available in the Procedural Guidance for PI’s Departing CU Boulder.

According to campus policy, computers and other electronic devices containing hardware with stored data must be erased by Property Services or a department IT representative before leaving campus. Government titled devices do not have the same requirement if they are being returned to a National Lab or a federal agency.

Disposition is coordinated with OCG, PAO, and Property Services

• Item is disassembled for parts to use on other equipment.

CU Property: The department may choose to disassemble existing property in order to use component parts for other purposes. For property acquired with federal funds, the department must complete the Property Disposal Request form and submit it to ocgproperty@colorado.edu. If cannibalization is allowable under the award terms and there are no further obligations to the sponsor, OCG countersigns the disposal request form and returns it to the department. The department is responsible for ensuring that approval from Property Services is received and for contacting PAO to update the university property record.

Government Property: When a department would like to cannibalize Government titled property the department must notify OCG prior to cannibalizing the Government property. Approval from the sponsor must be received before Government property can be cannibalized. OCG submits that request and when approved coordinates with the department and PAO to update the university property record.

Disposition coordinated with OCG and PAO.