Procedure CR2055 Preacquisition Screening of Federally-Funded Capital Property
Process Owner: Property Inventory, a division of the Office of the Corporate Controller
Policy Steward facilitating procedure: Associate Vice President for Finance and Corporate Controller
Table of Contents:
- SCREENING FOR AVAILABILITY:
- SHARED USE OF PROPERTY:
- REASSIGNMENT OF PROPERTY:
- AUDIT COORDINATION - FINANCIAL AND PROCEDURAL:
- UNIVERSITY RECORDS RETENTION AND DISPOSITION:
- CONTACT INFORMATION:
- CROSS REFERENCES:
- PROCEDURE STATUS:
Federal regulations require that federal funds not be used to acquire certain capital property unless it is first determined, through a pre-acquisition screening process, that similar property is not available for use; reference 2 CFR OMB part 200 Uniform Guidance 200.318. The federal government's rationale for these regulations is that shared use of existing property promotes availability of property on college and university campuses, reduces unnecessary duplication of property, and consequently, frees up federal funds to be used in other categories of expenditure or for other projects.
This procedure requires a pre-acquisition screening to determine availability of like, or substantially similar, existing capital property be undertaken prior to the purchase of federally-funded property costing $50,000 or more. The screening will be confined to the business area for property costing at least $50,000 but less than $100,000. The screening will be extended University-wide for property costing $100,000 or more.
Should the screening procedure fail to identify like, or substantially similar, available property the procurement file will be documented appropriately, and the requisition(s) will be processed. However, should the screening procedure identify like, or substantially similar, property which is represented on the inventory as available for shared use or reassignment to a new project, it will be necessary for the Principal Investigator (PI) to inspect the property. Outcomes of the inspection could be:
- a certification from the PI that the property is not satisfactory for their use (in which event the procurement file will be documented, and the requisition(s) will be processed), or
- a signed shared-use agreement or transfer of property in the event the identified property is satisfactory for the PI's needs and available for shared use or reassignment.
Forms for documenting these actions are discussed in this procedure.
All tangible End-Item Deliverable (EID) items are excluded from the pre-acquisition screening process. EIDs are contractually required to be purchased or building and delivered to the Sponsor at the conclusion of the agreement.
Purchase Orders (PO's) and Shop OnLion shopping carts (here after referred to as PO's) received for processing by Financial Officers (FO's) for federally-funded capital property purchases of $50,000 or more must show evidence of having been screened against the SIMBA inventory system, according to the dollar limits cited below, to determine if similar property already exists. The search will be documented by a Federally-Funded Property Preacquisition Screening Certification appropriately signed in accordance with the requirements set forth below. PO's not accompanied by a completed certification form cannot be processed by the FO.
Preacquisition screening for property costing at least $50,000 but less than $100,000 will be conducted at the business area level only. Property Inventory may be contacted to assist in the screening process at this level if deemed necessary. The results of the search will be noted on the Federally-Funded Capital Property Pre-Acquisition Screening Certification. The budget administrator shall sign the certification form attesting to the results.
If suitably similar property found and is available for shared-use, the Asset Transfer and Retirement Form within SIMBA must be completed and the PO canceled by completing and submitting a Purchase Order Change Form. Individuals involved in the preparation and/or approval of the PO prior to the point of cancellation must be notified that the order has been canceled since existing property is available and no purchase will occur. The Capital Property Shared-Use Agreement must also be completed and sent to Property Inventory or Property Inventory, College of Medicine as appropriate..
If suitably similar property is found but is NOT available for shared-use, the completed certification form is uploaded as supporting PO documentation on the shopping cart and the PO is created following established processes and approval paths as established by Policy FN18 University Approval Authorization.
If no suitably similar property is located, the completed certification form is uploaded as supporting documentation to the shopping cart and the PO is created following established processes and approval paths.
Preacquisition screening for property costing $100,000 or more will be conducted first at the business area level by the respective budget executive, followed by a University-wide search performed by Property Inventory. The results of the search for existing property will be noted on the certification form and signed by the budget executive and the University Property Manager.
If suitably similar property is found and is available for shared-used, Property Inventory notifies the budget executive who completes the Asset Transfer and Retirement Form within SIMBA and cancels the PO by submitting a Purchase Order Change Form. Individuals involved in the preparation and/or approval of the PO prior to the point of cancellation must be notified that the order has been canceled since existing property is available and no purchase will occur. The Capital Property Shared-Use Agreement must also be completed and sent to Property Inventory or Property Inventory, College of Medicine, as appropriate. The Capital Property Shared-Use Agreement should be uploaded as supporting document to for the Asset Transfer and Retirement Form. See Shared Use of Property for further details.
If suitably similar property is found but is NOT available for shared-used, Property Inventory returns the completed certification form to the budget executive and the form is uploaded as supporting PO documentation on the shopping cart and the PO is created following established processes and approval paths established by Policy FN18 University Approval Authorization.
If no similar property is located, the completed certification form is uploaded as supporting documentation to the shopping card and the PO is created following established processes and approval paths.
If it is determined that suitably similar property is available for shared use, a Capital Property Shared-Use Agreement must be completed by the proposed borrower and lender/custodian. The purpose of this agreement is to ensure understanding of the terms and conditions according to which the property is to be shared. Any subsequent revisions to this agreement must be documented and approved by all parties involved. Copies of the Shared-Use Agreement (and any such revisions) must be maintained by both the borrower and lender. The original agreement must be forwarded to Property Inventory in order to maintain accurate inventory records.
Per Uniform Guidance 2 CFR 200.313 property shared-use should be allowed in the following order:
- On project or program for which item was acquired
- On other Federal government awards (1st preference to other programs supported by acquiring agency)
- Other Federal government programs
- Use for non-federally-funded programs or projects. Users fees should be considered if appropriate and must be approved in accordance with Policy FN27 Establishing and Billing Service Center User Rates.
If it is determined that suitably similar property can be reassigned to the new project (no matter the length of time), an Asset Transfer and Retirement must be completed within the SIMBA.
Violation of a financial policy and/or procedure should be reported to your supervisor, unit manager, Human Resources representative, and/or office responsible for the policy and/or procedure. Where those resources are inadequate, you may choose to make an anonymous report through the Penn State University hotline by calling 1-800-560-1637.
The Financial Officer is responsible for ensuring that procedures pertaining to the accountability and safeguarding of all cash receipts, cash funds, and other assets are established and followed in accordance with approved University policies and procedures. Regular audits relating to advances, cash, travel, equipment accountability, and other expenditures provide a means to protect University assets. The Financial Officer is responsible for working with Internal Audit when audits are being performed in the administrative area. Audits relating to sponsored activities or other audits performed by external auditors may also be performed. The Financial Officer would also be responsible for working with the external auditor and/or a central university officer related to these procedures.
University Records retention must be managed in accordance with Policy AD35 - University Archives and Records Management and retention schedules approved by the Records Management Advisory Committee, Office of General Counsel, and Vice President for Administration. These records retention schedules are derived from - or based upon - federal, state, and local statute or regulations, University Policy, industry standards, and business needs. All University Records must be maintained in such a manner to provide ease of access, establish a suitable audit trail for all transactions, and to be reviewed prior to disposition.
Upon completion of the retention period, University Records must be disposed of via secure destruction or transfer to University Archives, unless an exception to the disposition process set forth below applies. If the disposition method for University Records states "Review by Archives" on the records retention schedule, the employees responsible for those records should consult the University Archivist for a final determination of disposition. For University Records that must be securely destroyed, units may arrange for shredding services by either contacting the Blue/White Shredding Program or the Inactive Records Center.
Exceptions to the practice are as follows:
- University Records subject to a Legal Hold (see AD35, Legal Hold). A legal hold will remain in effect until it is released in writing by the Office of General Counsel
- University Records under audit or review, either internally or externally. An audit hold will remind in effect until released by the Office of the Corporate Controller. The Financial Officer will be notified regarding any accounts that are under audit; the Financial Officer will be responsible for contacting the unit associated with the accounts.
Additional questions may be directed to the Office of Records Management.
For questions, additional detail, or to request changes to this procedures, please contact Property Inventory.
- Policy AD11 Confidentiality of Student Records
- Policy AD35 University Archives and Records Management
- Policy FN14 Use of University Tangible Non-Capital Property, Capital Property, Supplies, and University Services
- Policy FN18 University Approval Authorization
- Policy FN27 Establishing and Billing Service Center User Rates
- Capital Property Shared Use Agreement
- Federally-Funded Property Preacquisition Screening Certification
- Purchase Order Change Form
- Uniform Guidance 2 CFR 200.313
- Uniform Guidance 2 CFR 200.318
- Blue/White Shredding Program
January 31, 2022
- Revision 4 - January 31, 2022 - revised to reflect system-wide changes dues to the implementation of SIMBA
- Revision 3 - 5/2015 - revised to include Uniform Guidance verbiage
- Revision 2 - 05/18/11 - revised to eliminate reference to "Deputy Controller" and minor text clarifications
- Revision 1a - 03/05/92 - (KSB initialed)
- Revision 1 - 05/18/88