It is the campus department's responsibility (contract/grant administrator) to review the award document and budget to verify approved purchases, before equipment is ordered. Although prior NASA approval is not required, the Principal Investigator and Grants Administrator will ensure that purchase acquisitions of general purpose equipment for NASA Grants costing over $5,000 are required and will be used for the exclusive purpose of research activity. All proper checks will be conducted before each purchase is made, to ensure that the department is complying with the FDP provisions for purchase acquisitions. If non-research uses are contemplated for general or special purpose equipment, approval form the Grant Office is required. Reference to the Federal link for FDP requirements may be accessed at: http://www.thefdp.org/
Determination of Title vestment and award expiration would be addressed in the award document. That information should be included on the requisition. The ordering department initiates the purchase requisition for submission to Supply Chain Management.
When Supply Chain Management receives the requisition, there should be an internal verification (award document) for the requested purchase:
- Knowledge of award end date.
- Type of grant (multi-year award, etc.
- Assurance of no purchased general purpose equipment, unless approved by granting agency.
- Exceptions and questions should be referred to Extramural funds Accounting department for approval or advice.
Title Status of Equipment at Acquisition
The title status of equipment purchased under contracts and grants will have to be determined. This information may be in the contract/grant instrument or in basic agreements with the agency. The title status of equipment purchases will determine the degree of control, tagging, and applicability of state sales tax.
- Title with the Federal Government: Non-taxable
- Title with the Regents or other: Taxable
When all checks are made, Procurement will issue final purchase order. At this point, the purchase orders are downloaded daily from Procurements system to the Equipment Management's Berkeley Equipment Tracking System (BETS) and processed by appropriate Equipment Management staff.
Equipment Management assigns property numbers and all appropriate codes for equipment ordered. When equipment is downloaded into BETS, all purchases default to acquisition code 31. Depending upon award documentation addressing Title vestment, a determination will be made by the Contract/Grant specialist to assign acquisition code 30 for equipment considered Contractor-acquired, Government property.
- Identification of Government Equipment
- The Equipment Management Office identifies and records government contract and grant equipment. All equipment is identified with a UCB property tag, in addition, government equipment is also tagged with a separate decal labeled "Property of U.S. Government". Whenever requested, decals from specific agencies will also be affixed to the equipment in question. Most equipment is received within a two month period unless otherwise specified. Items are tagged within 2 days and dispersed to campus departments.
- Utilization of Equipment
- The utilization of property acquired for use under a specific contract is restricted to the purposes of that contract. Departments are to maintain records of the authorized and current use of equipment; periodically review equipment needs and Equipment utilization to identify excess items; report surplus equipment to Equipment Management. When it is desirable to continue using the equipment on another contract, written approval is required from the contracting officer. Requests for such approvals are made through Equipment Management.
- Storage and Movement
- When equipment is temporarily not utilized, but required for authorized use in the future, it must be adequately stored to protect it from theft, corrosion, contamination, and damage to sensitive parts. Government equipment may be moved to off-campus storage sites only with the approval of the appropriate Contract or Grant Property Administrator.
- Care and Maintainence
- The custodial department is responsible for providing the care necessary to maintain the equipment in the condition received or better (normal wear excepted). The maintenance program shall be preventive in nature, providing lubrication, cleaning, calibration, and inspection on a regular schedule; records must be kept of these actions.
- Loss, Damage, or Destruction
- All cases of loss, damage or destruction to government property shall be thoroughly documented and immediately reported to the government property administrator through Equipment Management. The extent of the University's liability is subject to a written determination by the contracting officer.
- Inventory of Equipment
- Each year, an inventory listing of government equipment on each active grant or contract ( BET920 by fund number) will be provided to the custodial department(return/required or information/not required). This listing must be verified, dated and responsibility acknowledged. Utilization and condition changes of this equipment, if any, should be updated on this listing. The physical inventory shall be conducted on a biennial basis.
- Completion of the biennial equipment inventory will be reported by Equipment Management, with data on adjustments of government property, to the government property administrator.
- Government property shall not be loaned without the specific written consent of the government contracting officer or property administrator. The department must prepare a request to Equipment Management who will forward it to the agency for approval.
- Transfers of Government Owned Material/Active Contracts
- These transfers are not authorized unless approval is obtained from the sponsoring government agency through the Sponsored Projects Office.
- Sale or Transfer of Equipment and Supplies To Another Institution Occasioned By Transfer of a Faculty Member - Federally Funded
- On some occasions a faculty member will transfer to another institution or campus and will request that certain equipment and supplies be transferred with him/her to that institution or campus. In such cases, refer to the policy as stated in Bus 38 , Section VIII.
- Expired Contracts or Grants
- Upon completion of a contract or grant, the requested department will conduct a physical inventory of all property assigned to the related contract or grant. An equipment list will be provided by Equipment Management, to perform this task. This inventory will assist the department in the "completeness" of the equipment items acquired, confirming the condition of all items, and assist in determining the appropriate disposition actions for it. The Principal Investigator must justify equipment from the expiring contract or grant, that he/she wishes to retain for either immediate use on another project or authorized future projects retain the equipment. Any items which may be considered "excess to a department's needs", must first be reported to Equipment Management, via an Equipment Inventory Modification Request, ( EIMR ) and a memo, before "scrapping" or "dismantling for parts" of any equipment. The Administrative Contracting Officer will in turn, be notified of this intent, and the Equipment Management Office will request for "relief of accountability" on behalf of the requesting department. Once that approval has been received, the equipment in question will be appropriately handled. The Equipment Management Office will submit the final inventory report to the contracting agency, via the Sponsored Projects Office, requesting Title be transferred to the University, and requesting disposition instructions for equipment.
- Disposition of Excess Property
- Excessed property, must be reported promptly to Equipment Management, via an Equipment Inventory Modification Request, ( EIMR ) and a memo, before "scrapping" or "dismantling for parts" of any equipment. The Administrative Contracting Officer will in turn, be notified of this intent, and the Equipment Management Office will request for "relief of accountability" on behalf of the requesting department. Once that approval has been received, the equipment in question will be appropriately handled.
- Release From Responsibility
- The University is relieved of responsibility for agency property, with concurrence of the Agency Contracting Officer by the following: Consumption of property in performance of the contract. Retention by the University for consideration given the agency. Sale of property, if the proceeds of the sale are received by or credited to the agency. Shipment from University premises of that of a subcontractor. Transfer of title to the University. Abandonment in place by the agency. Loss, damage or destruction.