Common Property Questions

What is capital equipment?

Capital equipment is a commercially available piece of equipment that has a useful life of at least one year and a total cost of $5K or more.

What is a fabrication?

A fabrication is an assembly of materials, non-consumable supplies, and hardware into a one-of-a-kind piece of equipment that meets a research need. Fabrications are distinguished from standalone equipment by either original development or original components. Fabrication components must be essential and integral to the function of the entire piece of equipment, to the extent that removal of any one component would reduce the functionality of the whole piece of equipment.

In order to be considered capital equipment, fabrications must also have a useful life of at least one year and a total cost of $5K or more. 

Can an upgrade or refurbishment charge to existing equipment be capitalized?

Upgrades and refurbishments that provide a substantial increase in either the functionality or efficiency of existing equipment, allowing it to perform additional tasks that were not originally anticipated, may be capitalized if the estimated useful life of the upgrade is at least one year and the total cost for the upgrade is $5K or more.

Example of what may not be considered capital: If the refurbishment/upgrade cost is $1,000 it does not meet the criteria for a capital equipment upgrade and it will need to be categorized as expenses.

When will tag numbers and physical tags be created for property in my Department?

At the beginning of the month, the Property Accounting Office (PAO) generates a report for all fixed asset expenditures during the prior month and assigns a unique tag number for each piece of standalone equipment. PAO prints and mails these tags to the Department Property Manager who is responsible for affixing the tags to their equipment.

Fabrications are assigned a tag number when the fabrication and Chartfield request forms are submitted to PAO. The tag for fabrications will be printed and mailed to the Department Property Manager when the fabrication has been placed into service.

Government-titled property is assigned a tag number by the OCG Property Specialist as soon as the department has physically accepted the property. The OCG Property Specialist prints and affixes the tag for Government property as quickly as possible after the department has accepted the property. 

How do I request prior approval from the sponsor for equipment purchases?

Approval requests to purchase Government-titled property will be submitted by the OCG Property Specialist. The Department Property Manager or Principal Investigator (PI) coordinates with the OCG Property Specialist unless the department has been given authorization to submit requests directly to the sponsor. If the terms and conditions of the award require prior written approval from the sponsor to purchase University titled property, the Department Administrator or PI may work with their Contract or Grant Officer in OCG to submit a request to the sponsor. 

Who is responsible for identifying Government property and how will a department know if it has Government property?

The OCG Property Specialist reviews the terms and conditions for each new award and award modification and lists any special conditions in OCG’s award database, including whether property purchased on the award will be Government-titled property or if sponsor prior approval is required.

FAR 52.245-1 (alternate II) is the most frequently used clause to govern the use and management of the Government-titled property, but each agency or subaward agreements can cite their own specific terms governing property.

It is the responsibility of the Principal Investigator and the Fiscal Manager to review the Terms and Conditions pages in Boulder eRA when they receive both new awards and modifications to existing awards.

What should you do if your department receives property from a sponsor?

Contact the OCG Compliance team. The OCG Compliance Officer will either negotiate a bailment agreement or ensure that the award records are updated to reflect the University’s accountability for sponsor-furnished property. Principal Investigators and department personnel are not authorized to sign bailment or loan agreements on behalf of the University. The OCG Compliance Officer will ensure that the bailment agreement includes the correct identifications, documentation, and insurances for property loaned to the University.

What should you do if your department wants to loan property to an external entity?

Some collaborations may necessitate the University loaning equipment to an external entity for a specific purpose. To negotiate and execute a bailment agreement for loaning University property to an external entity, contact the OCG Compliance team. University property cannot be loaned to an external entity without the execution of a bailment agreement by the OCG Compliance Officer.

What is a bailment agreement?

A bailment agreement is a legal agreement that documents the terms and conditions of property loaned between two entities.  While title to the property is not transferred, a bailment agreement will document the period of the loan, transfer process, insurance, and other relevant conditions of the loan.  In order to negotiate and execute a bailment agreement for loaning property to (or from) an external entity, contact the OCG Compliance team.

In the definition of capital equipment, what constitutes an “item”?

An item that is capital equipment can be an item purchased from another entity (a standalone item), a fabricated piece of equipment, or a system. To be capital equipment, systems, fabricated or created pieces of equipment will not function without all of the components working together. Such items are dependent on the system as a whole to serve its purpose in research. 

Example: A custom built vapor delivery system composed of gas cylinders, copper tubing and brass fittings. 

For definition, reference Campus Controller’s Office Cost Principle: Purchase, Use and Disposition of Sponsored Project Equipment and other documents related to equipment.

Are labor costs allowable as part of equipment costs?

Yes, labor costs are allowable if an Internal Service Center (ISC) has been set up in the department. In this case, labor charges can be included on the fabrication SpeedType. Contact Budget and Fiscal Planning to set up the ISC. OCG and CCO are currently discussing how to include labor costs when an ISC is not a feasible option. 

Can components from a fabrication be removed for other use?

Maybe, depending on sponsor approval and terms and conditions related to the property. Removing components from fabrication is a process called cannibalization and requires prior approval for any item built using federal funds. Contact OCG Property ( for specific terms of the award regarding this process. Instructions will be obtained from the sponsor and coordinated through OCG.