Research Policy Analysis and Coordination
Chapter 15-100: Introduction
Property management is an essential function of the University because a large portion of the corporation's assets is made up of equipment and other property. Sound and prudent property management practices at the local level must be guided by consistent and articulated property management policies and procedures that apply Universitywide. In addition, the University must meet its responsibilities to extramural sponsors when they support the acquisition of equipment under their awards. Section 15-F01 of this chapter outlines the federal property standards with which University property policy and procedures comply.
Primary University guidance about the post-award management and disposition of tangible personal property owned by or in the custody of The Regents is contained in Business and Finance Bulletin BUS-29, Management and Control of University Equipment. This Manual Chapter supplements BUS-29 with respect to the University's contract and grant administration function. Property policy and procedures also are discussed in several other University documents, which are referenced in Section 15-999 Related University References, of this Manual Chapter.
15-110 Applicability of University Policy
University property management policy and procedures as implemented by the OP Executive Director — Procurement Services apply to all property, including that acquired under extramural awards, with the exception of:
- Property/assets in the custody of the Chief Investment Officer/Treasurer pursuant to Section 21.4 of the Bylaws of The Regents of the University of California; and
- Government-owned property at the DOE Laboratory (to which DOE policies apply), namely, Lawrence Berkeley National Laboratory (LBNL).
Many of the terms related to property administration, including "fabricated property," “plant equipment," "government-furnished property," and "excess government property" are defined in BUS-29 Section I.I. D., Definitions, with additional definitions found in BUS-38, Disposition of Excess Property and Transfer of University-Owned Property, Section II. Policy Definitions. Definitions of key terms that are used in this Manual chapter are given in Sections 15-121 through15-128 and 15-240, below.
15-121 Personal Property
"Personal property" is: “Any movable item subject to ownership”.
"Equipment" is defined in 2 CFR 200.33 as "an article of non-expendable tangible personal property having a useful life of more than one year, and an acquisition cost which equals or exceeds the lesser of the capitalization level established by the institution for financial statement purposes, or $5,000." The University of California has established a capitalization threshold of $5000. Items that cost less than $5000 or have a useful life of one year or less are considered supplies. In some cases, a purchased item may be a system made up of separate or separable parts, but it must be sold as a system by the vendor in order to qualify as a single piece of equipment. Merely grouping individual items on one purchase order does not constitute purchase of an equipment system. (See Chapter 7-205 and Chapter 2-526).
15-123 Inventorial Equipment
"Inventorial equipment" refers to equipment (as defined above) that is recorded in the University's inventory system. With some exceptions, University-owned equipment that is free- standing is considered inventorial equipment. Firearms, for example, regardless of cost, always are inventoried as is equipment acquired under non-federal awards that set a dollar limit of less than $5000 for inventorial items. Government-owned equipment is always considered inventorial. Items that enhance the value or prolong the useful life of the equipment on which they are installed or attached are considered capital equipment if they cost more than $5000. However, the cost of these items is added to the value of the equipment to which they are installed or attached and the items are not separately tagged and inventoried.
15-124 General and Special Purpose Equipment
"Special purpose equipment" is equipment which is used only for research, medical, scientific, or other technical purposes. "General purpose equipment" is equipment which is not limited only to research, medical, scientific, or other technical purposes (e.g., office furniture, computers, air conditioning). Equipment that is specifically designed for scientific purposes is special purpose equipment. Equipment that is not specifically designed for scientific purposes still may qualify as special purpose equipment if its use for scientific purposes makes it unusable for general purposes (e.g., a refrigerator used for storing radioactive or hazardous materials).
15-125 Expendable Personal Property
"Expendable personal property" (e.g., supplies) is all tangible personal property other than nonexpendable property.
15-126 Theft-Sensitive Items
"Theft-sensitive items" or “Other Inventorial Items “are items whose acquisition cost is below the inventorial threshold of $5000, but which a sponsor may identify or the campus chooses to carry on its inventory for tracking and control purposes. Examples of theft-sensitive items are given in BUS-29 Section I. E. 3.
15-127 Exempt Property
The term "exempt" refers to exemption from further accountability to the federal government. "Exempt property" is tangible personal property acquired in whole or in part with federal research grant funds, the title to which is vested in the University without further obligation to the federal government, unless the sponsoring agency explicitly reserves the right to transfer title and issues disposition instructions within 120 days after the end of the federal support of the project for which the property was acquired. Most equipment acquired by the University under federal research grants qualifies as "exempt property" pursuant to Pub. L. 95-224. This statute, approved February 3, 1978, authorized federal agencies, in their research grants to colleges and universities, to vest title to equipment purchased with grant funds in the recipient institution. Equipment acquired under other types of funding mechanisms, e.g. training grants and contracts, is considered "nonexempt."
15-130 Contract and Grant Officer Responsibilities
Campus Contract and Grant Officers have certain responsibilities specifically pertaining to property administration, pursuant to BUS-29 Section II.B. 2. These responsibilities are:
- II.B.2.a. Upon receipt of an award, to notify the Equipment Management Department “of the award provisions regarding reporting and vesting of title.”
- II.B.2.b. Upon completion or termination of an award, “the Contract and Grant Office in coordination with the Principal Investigator and sponsoring department ascertains the status of title to equipment procured under each award and notifies the Equipment Management Department accordingly”…..and,
- II.B.4.b. “The [sponsor] contracting officer may transfer title to the University at the beginning, during, or at the end of an award.”