Federal regulations have required that federal funds not be used to acquire certain capital equipment unless it is first determined, through a pre-acquisition screening process, that similar equipment 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 equipment promotes availability of equipment on college and university campuses, reduces unnecessary duplication of equipment, and consequently, frees up federal funds to be used in other categories of expenditure or for other projects.
This procedure requires that a screening for availability be undertaken prior to the purchase of federally-funded equipment items costing $50,000 or more. The screening will be confined to the College and/or administrative unit level for equipment items costing at least $50,000 but less than $100,000. The screening will be extended University-wide for equipment items costing $100,000 or more.
Should the screening procedure fail to identify like, or substantially similar, available equipment, the procurement file will be documented appropriately and the requisition(s) will be processed. However, should the screening procedure identify like, or substantially similar, equipment 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 to inspect the equipment. Outcomes of the inspection could be: (1) a certification from the principal investigator that the equipment is not satisfactory for his or her use (in which event the procurement file will be documented and the requisition(s) will be processed), or (2) a signed shared-use agreement or transfer of equipment in the event the identified equipment is satisfactory for the principal investigator’s needs and available for shared use or reassignment. Forms for documenting these actions are discussed in this procedure.
Purchase Orders and eBuy+ requisitions (here after referred to as Purchase Orders) received for processing by Financial Officers for federally-funded capital equipment purchases of $50,000 or more must show evidence of having been screened against the appropriate inventory system, according to the dollar limits cited below, to determine if similar equipment already exists. The search will be documented by a Federally-Funded Capital Equipment Pre-Acquisition Screening Certification appropriately signed in accordance with the requirements set forth below. Purchase Orders not accompanied by a completed Certification Form cannot be processed by the Financial Officer.
Pre-Acquisition screening for equipment costing at least $50,000 but less than $100,000 will be conducted at the College and/or administrative unit level. 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 Equipment Pre-Acquisition Screening Certification. The budget executive shall sign the Certification Form attesting to the results. A photocopy of the completed Certification Form should be placed in the department’s procurement file. (A photocopy of the Purchase Order may also be placed in the file if the budget executive chooses to do so.)
Pre-Acquisition screening for equipment costing $100,000 or more will be conducted first at the College and/or administrative unit level by the respective budget executive. The results of the search for existing equipment at this level will be noted on the Certification Form and signed by the budget executive. Both the Certification Form and the Purchase Order are forwarded to the Controller, regardless of the outcome of the search by the budget executive for equipment costing $100,000 or more.
Purchase Orders for equipment costing $100,000 or more, accompanied by a Federally-Funded Capital Equipment Pre-Acquisition Screening Certification will be screened by the Controller (or designee) through University-wide Property Inventory records if the search was unsuccessful at the College and/or administrative unit inventory level. The Controller (or designee) will certify to the search by signing the Certification Form.
If no similar equipment is located to satisfy the principal investigators needs, the Certification Form is attached to the Purchase Order and both are forwarded to the respective Financial Officer for normal processing.
If similar equipment is located, at either the College and/or administrative unit level or as a result of the University-wide search, the principal investigator will inspect the existing equipment to determine if it is satisfactory to meet his/her needs. If the equipment is deemed acceptable, a determination must also be made whether the equipment is available for shared use or able to be reassigned to the new project. Copies of the Certification Form are forwarded to both the proposed borrower and lender/custodian of the equipment for preparation of a Shared-Use Agreement. The original Certification Form is forwarded to Property Inventory in order to maintain accurate inventory records.
Individuals involved in the preparation and/or approval of the Purchase Order prior to the point of cancellation should be notified that the order has been canceled since existing equipment is available.
If it is determined that apparently similar equipment is available for shared use, a Capital Equipment Shared-Use Agreement must be prepared and 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 equipment is to be shared. Any subsequent revisions to this agreement should be documented and approved by all parties involved. Copies of the Shared-Use Agreement (and any such revisions) should be maintained by both the borrower and lender. The original Agreement should be forwarded to Property Inventory in order to maintain accurate inventory records.
Per Uniform Guidance 2 CFR 200.313: Equipment shared use should be allowed in the following order:
- On project or program for which item was acquired on.
- On other Federal government awards (1st preference to other programs supported by acquiring agency.
- Other Federal government programs.
- Last – Use for non-federally-funded programs or projects is also permissible. Users fees should be considered if appropriate.
If it is determined that the apparently similar equipment can be reassigned to the new project, a Report of Disposition or Permanent Transfer of Tangible Assets should be completed. If the period of reassignment/relocation will be for less than one year, a Report of Temporary Relocation of Tangible Assets should be completed. Both forms and instructions are available on GURU.
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, as well as performing an annual audit that is submitted to the Assistant Controller.
Record retention must be managed in accordance with Policy AD35 - University Archives and Records Management, and records schedules approved by the Records Management Advisory Committee, Office of General Counsel, and Office of the President. These retention requirements are the University's retention criteria, either derived or based upon federal, state, and local statute or regulations, industry standards, and business needs. Retention beyond recommended time periods require justifiable reasons and warrant review by the Records Management Officer or designee. All documents must be maintained in such a manner so as to provide ease of access for review, and to provide a suitable audit trail for all transactions.
- Documents 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.
- Documents under audit or review, either internally or externally. The retention period extends until released by the Corporate Controller's Office. The Financial Officer will be notified regarding any accounts which are under audit; the Financial Officer will be responsible for contacting the department.
Additional questions may be directed to the University Archivist or the Records Management Officer.
For questions, additional detail, or to request changes to this procedures, please contact the Associate Controller.
Date Approved: 05/31/15
Most recent changes:
- Revision 3 - Dated 5/2015 - revised to include Uniform Guidance verbiage
Revision History (and effective dates:)
- Revision 2 - Dated 05/18/11 - revised to eliminate reference to "Deputy Controller" and minor text clarifications
- Revision 1a - Dated 03/05/92 - (KSB initialed)
- Revision 1 - Dated 05/18/88