PROCEDURE CR2019 ACCOUNTING FOR CAPITAL AND NON-CAPITAL PROPERTY (EQUIPMENT AND FACILITIES)
Systems and Procedures
A Division of The Corporate Controller's Office
IN
Last Revision: 06/06/2022

Procedure CR2019 Accounting for Capital and Non-Capital Property (Equipment and Facilities)

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:


GENERAL:

The Pennsylvania State University (“University” or “Penn State”) Policies FN14 Use of University Tangible Non-Capital Property, Capital Property, Supplies, and University Services and RA70 Research Administration Property & Equipment requires the University maintain records for capital and non-capital property (equipment and facilities/property) acquired by:

These records are used with other information to determine the depreciation charge for capital tangible property and facility property, to assist in generating the financial statements, and to obtain insurance coverage. It is the responsibility of Property Inventory, a division of the Office of the Corporate Controller, to maintain the records of all capitalized tangible property and facility property. The College of Medicine at Hershey Medical Center follows this procedure but using different systems for recording and tracking their property. Penn State Health and all its subsidiaries, and Penn College of Technology are exempt from the requirements of this procedure as they maintain their own records on capitalized tangible property and facility property.

For tangible property and/or facility property to be capitalized, it must meet certain criteria (see the criteria section below), be assigned a unique identifying number, and assigned a business area number denoting responsibility for the item. This, and other pertinent information, is entered into System for Integrated Management, Budgeting, and Accounting (“SIMBA”) which is used to maintain the "perpetual" inventory of all capitalized tangible property and/or facility property. Any changes in the property records, such as transfer to a different location or disposal, must be reported to Property Inventory using:

Facility property is recorded as Building, Improvement other than Buildings (IOB), and Land. The criteria for these types of acquisitions can vary depending on the type of activity (purchase, construction, or renovation). If a facility asset meets the capital criteria, a seven-digit tracking number is given for Building and IOB assets. Building, IOB and Land assets are tracked through SIMBA.

NOTE: All University or government property is assigned a SIMBA Asset ID Number within the SIMBA system.

This procedure explains the criteria for capitalizing acquisitions, identification of new property, relocation of property, and disposition of tangible property and facility property at both University Park and non-University Park locations. Forms required to complete this procedure are referenced where applicable.

DEFINITIONS:

PROCEDURE:

CAPITALIZATION CRITERIA:

Capitalization Criteria for Tangible Property:

The criteria for capitalizing property are:

  1. The acquisition cost of the property must have a value of $5,000 or more including any costs necessary to put property in place (i.e., freight, installation, and training)
  2. The property must have a useful life of one (1) or more years and having continued economic value for future usage

The cost of accessory property purchased with the parent item, or added later, (i.e. upgrades) must be capitalized even if less than $5,000. However, if an item of accessory property is purchased to be used with two (2) or more items of capitalized property, it must be treated as separate property. If such an accessory item meets all the criteria of capitalized property as stated previously ($5,000/1 year), it will be treated as a separate item of capitalized property and tagged appropriately.

Additional examples for capital vs non-capital recording include:

Capitalization Criteria for Facility Property:

In order for facility expenses to be recorded as capital, the following criteria must be met:

The University also maintains records of Buildings, Improvements Other than Buildings (IOB), and Land received or acquired as gifts or built by the University with oversight by the OPP. These records are used in conjunction with other information to determine the depreciation expense for each project. It is the responsibility of Property Inventory to maintain the official records for Facility capital projects.

Capitalization Criteria for Non-Tangible Computer Software Greater than $500,000 "PSU fully-titled":

Costs associated with the acquisition of enterprise-wide systems or PSU developed systems will be capitalized at the amount paid for the software. An enterprise-wide system is defined as an “Enterprise Resource Planning” (ERP) system that is implemented campus or university-wide and represents a major outlay for the University and will be titled at PSU unconditionally. Costs prior to the preliminary pilot stage and costs incurred for testing must be treated as expenses as incurred. Accordingly, training and data conversion expenses will not be capitalized. Expenses associated with studying the need for a system, identifying the system requirements, and evaluating and selecting the software system to be purchased will not be capitalized.

Computer software that is propriety in nature and is necessary for a capital property item to be functional/operational, must be included in the capital cost of the tangible property item. Warranty and extended maintenance expenses associated with the software are to be treated as non-capital expenses subject to F&A.

Penn States defines a Subscription agreement as a subscription-based pricing model as a payment structure that allows a customer or organization to purchase or subscribe to a vendor's IT services for a specific period of time for a set price. Subscribers typically commit to the services on a monthly or annual basis. The software will be hosted by the vendor, with PSU only having the right to use the application(s) listed in the agreement.

TYPES OF ACQUISITIONS:

Tangible property, facility property, and non-tangible software acquisitions must be reported to Property Inventory to ensure proper record keeping.

The University acquires or financially tracks tangible and/or facility property by the following methods:

OPP Project Work Orders and Direct Billing:

OPP billing documents and IO’s are reviewed monthly and/or quarterly to ensure only facility property are being procured. If tangible property items, meeting the capital criteria, are procured under an OPP project or work order number, those costs are moved to an appropriate general ledger account.

Acquisition by Construction:

Initial capitalization includes initial construction costs of the building structure, including all internal components within the building. The cost must also include architect fees, inspection fees and permits, bid advertising, interest expense, and insurance costs incurred during the construction period and legal fees and excludes costs of landscaping, sidewalks, parking lots, utility tunnels, or furnishings, which are to be capitalized in other fixed asset accounts, (IOB). Special purpose movable machinery and property (such as x-ray, sterilizers, presses) installed in the building or structure at the time of construction, which relates to the activity to be conducted in the building or structure, must be capitalized in property general ledger account rather than the building general ledger account. Fixed (such as fume hoods, HVAC chillers, alarm systems, video systems) installed/bolted to structure will be recorded in the facility SIMBA system.

Building Renovations:

Building projects or portions of projects, must be added to the capitalized value of an existing building. However, any renovation project of less than $500,000 must be charged to expense or capitalization reporting required by bond or lease purchase covenants.

Capitalized renovations and remodeling projects are recorded in SIMBA by assigning a separate asset number. Each component life is assigned a sub-asset number.

Landscaping and IOB:

New IOB projects will be capitalized if the cost is $5,000 or more. New IOB renovation projects will be capitalized if the cost is $500,000 or more.

Costs to build new infrastructure projects owned or used by the University (excluding buildings) will be capitalized as Land Improvements/Infrastructure (IOB). It is the practice of the University to capitalize such improvements. However, the nature of many improvements (i.e., walks and driveways) are such that it is impractical to inventory such improvements. Repair, maintenance, partial replacement, and resurfacing projects must be charged to expense. It shall also be the practice to capitalize all costs in this category, which are incurred in conjunction with a major building project even if the amount is less than stated in the succeeding sections of this document for various classifications of improvements.

Construction (Work) in Progress:

Construction (Work) in Progress (CIP) is designed to accumulate all costs incurred in connection with projects undertaken for the construction or renovation of capital property that will extend over a period of time. Costs will remain in the Asset Under Construction (AUC) /CIP general ledger account until the project is placed in service, contractors paid, and/or invoices received. After discussions with OPP Project Leaders or review of project financials to determine the AUC/CIP completion status, the property will be placed in the appropriate category.

Departments Other Than OPP:

Departmental (other than OPP) billing documents and IO’s are reviewed monthly and/or quarterly to ensure property being procured are accurately charged. If tangible property items, meeting the capital criteria, are procured on 31, 34, 37, and/or 52 IOs, those costs are moved to an appropriate general ledger account.

Purchases:

Purchases of Tangible Property:

Property valued at $5,000 or more that is requested by a department, including the Applied Research Lab (ARL) through Procurement Services using Lion Marketplace or a purchase order (PO) will be reviewed by Property Inventory. Previously recorded capital property purchased from Lion Surplus or between departments cannot be recapitalized. Non-Capital general ledger accounts must be used no matter what the purchase price of the item. Items that were previously procured by federal monies will need to have agreement terms reviewed prior to resale.

Uniform Guidance 200.318 requires that federal funds not be used to acquire certain capital property unless it is first determined, through a preacquisition screening process, that similar property is not available for use. See Procedure CR2055 Preacquisition Screening of Federally-Funded Capital Property before procuring property.

NOTE: Use of the correct general ledger account for Property acquisitions must be enforced when source documents are prepared to ensure proper recording of capitalized property and reduce the amount of time spent by Property Inventory to review and adjust discrepancies via Journal Entry (JE).

Refer to SIMBA General Ledger Accounts/Payment Decision Matrix for a complete listing of general ledger accounts and their intended use.

Purchases of Facility Property:

New buildings acquired by outright purchase will be capitalized if costing $5,000 or more. New building renovation projects will be capitalized if costing $500,000 or more.

Buildings acquired by outright purchase will be capitalized at acquisition cost with proportionate allocation of the purchase price and associated closing costs allocated to land based on current appraised values. University Real Estate Services obtains the appraisal values. Additional costs incurred for the purpose of renovating or modifying the building structure to place it in service will also be capitalized if that cost meets established renovation criteria.

The Commonwealth of Pennsylvania Department of General Services (DGS):

DGS will procure and deliver capital property under legislation appropriations. DGS will assign project number (ex. 800-xxx) for each legislation and the University Procurement Services department and Office of Physical Plant will assist and monitor these projects.

Two types of DGS projects are awarded:

Government or Sponsor Provided Property:

Property provided to the University for the purpose of utilization on a particular award or for the overall Research and Development at the University. This property may be:

See the Consignment or Loan Agreements section for reporting requirements.

Private Industry:

Property provided to the University, by private industry, for the purpose of utilization on a particular award or for the overall Research and Development at the University. This property may be:

See the Consignment or Loan Agreements section for reporting requirements.

University Departments:

Gifts:

Gifts-in-kind are another source of property to the University.

Property received by the University as a gift is initially identified to Property Inventory by the Office of University Development (OUD). Further information for special handling is provided (when appropriate) by the Assistant Treasurer's Office. OUD provides a copy of their electronic Gift Reporting and Transmittal Form, appraisal or other official document verifying fair market value (FMV), and any additional information identifying the property, to Property Inventory when it is processed through the gift reporting system. In determining fair market value (FMV), the University shall rely on either of the following:

OUD forwards a copy of the Appraisal Summary (IRS Form 8283) to Property Inventory to initiate an internal "tracking" procedure in order to comply with IRS regulations if disposal occurs within the time period specified by the IRS. Items disposed within three years of receipt could require IRS form 8283 be completed by the Director, Tax Services.

Consignment or Loan Agreements:

Property valued at $5,000 or more obtained by consignment or loan must be report to Property Inventory to ensure adequate insurance coverage is provided. The Report of Tangible Property Obtained by Consignment or Loan Form must be completed.

All property consigned or loaned by a governmental agency, no matter the value, must be reported to Property Inventory to ensure adequate insurance coverage and contractual reporting requirements. The Report of Tangible Property Obtained by Consignment or Loan Form must be completed.

Finance and Operating Lease Agreements (which may or may not be considered purchases):

Property leases will be initiated using the Shop OnLion module and facility leases will be recorded by University Real Estate Services (URES) using a third-party lease system and reported to Property Inventory. For all property leases, having a lease term longer than one year, with the tangible item’s present value of lease payment of $5,000 or greater will be analyzed by Property Inventory to determine if the lease will be recorded as a Finance or Operating lease. If the lease is determined to be finance lease it will be recorded at the present value based on the lease analysis. Procurement Services submits a Lease Fact Sheet to Property Inventory with all applicable data elements to support the analysis. If the lease is deemed a finance lease, the shopping cart will be approved, and the general ledger GL number will be changed to 52120760. Once the items are received, the leased item(s) will be recorded in the SIMBA Property module.

Real Estate leases having a base lease term longer than one (1) year and base lease value of $1,000,000 or more will be analyzed by Property Inventory and recorded in SIMBA.

Analysis must meet FASB accounting standard 842-10-25:

NOTE: Financial Accounting Standards Board (FASB) lease reporting requirement will be generated from the third-party (AMT) system. JEs for operating leases and any adjusting JEs for finance leases will be posted in SIMBA by Financial Reporting as part of the year-end process.

See the SIMBA General Ledger Accounts and Payment Decision Matrix for the appropriate general ledger account to be used.

Office of Physical Plant - Facilities Resources and Planning (FRP):

The Office of Space Management is responsible for the following:

They use LionSpace, a third-party system, to track the above.

Land:

Land acquisitions are recorded at purchase price and all recording and legal fees are capitalized with purchase cost. Land is not depreciated. Any structures included in the purchase are recorded in the building system.

University Internal Fabrications:

See Procedure CR2020 Property Fabrication for complete details on property fabrication, approval processes, and establishing IO's and Work Breakdown Structures Elements (WBSE) cost collectors.

Property fabricated by a department is considered an acquisition. The amount capitalized includes the actual cost of materials and any special engineering services.

Miscellaneous Additions

Miscellaneous additions will be added to SIMBA for property located during a physical inventory or when incorrect general ledger accounts were used to purchase the original item.

Capitalized Interest

Bond funded capital improvement projects will have interest costs added to the total value of the property until the project is complete. Financial Reporting assists with monitoring projects having capital interest and provides that information to Property Inventory.

IDENTIFICATION OF NEW TANGIBLE PROPERTY OR FACILITY PROPERTY:

Identifying Tangible Property:

Movable or fixed property acquired with University or grant funding, that is University titled, is identified during the Shop OnLion process. Departments place their tangible property requisition with applicable supporting documents. If the order exceeds $5,000. and the item(s) product category maps to a tangible commodity code, the shopping cart will then be placed in a special workflow that will route the shopping cart to asset approvers.

Asset approvers will analyze the shopping cart, and if the item(s) are deemed an asset, the shopping cart will be assigned a SIMBA virtual asset number(s) and the asset clearing general ledger number 17599999 will be assigned for financial reporting needs. The assignment of GL 17599999 will automatically place all payments on the Property, Plant and Equipment (PP&E), category – Asset Under Construction (AUC).

Property Inventory staff or their delegates will assign each SIMBA Asset number a physical inventory tag to the item(s) after the PO is paid in full and enter all missing key information required for inventory or federal reporting requirements, such as serial and model numbers, building and room numbers etc.

For Grant funded items that will be sponsored titled, the process is the same as mentioned above but a sponsor asset class will be assigned to the item so to avoid any financial values being reported to the balance sheet.

Property received by the University as a gift is initially identified to Property Inventory by the Office of University Development (OUD). OUD provides a copy of their electronic Gift Reporting and Transmittal Form. If the tangible item has met the Federal Standards, the gift will be manually entered in SIMBA asset module.

Property Fabrication acquisitions are tracked by using IO’s or WBS numbers. Additional details on this process can be found in Procedure CR2020 Property Fabrication.

Hershey College of Medicine property to be capitalized is identified at the point of the completion of an electronic requisition created in the Penn State Health purchasing system. Requests for capital property are routed to the College of Medicine’s Controller’s office and reviewed/approved before a PO is issued. Once the asset has been received and the corresponding invoice paid, the asset is added to SIMBA manually by College of Medicine Controller’s office staff.

Federal Government or Sponsored furnished property is to be reported to the Property Inventory by completing a Report of Tangible Property Obtained by Consignment or Loan form. If items are received with an appropriate federal form that lists all the applicable information, (i.e., serial and model numbers, dollar value for each item, etc.) that form may be used in lieu of the Report of Tangible Property Obtained by Consignment or Loan form. Information must be sent to CCOpropertyInv@psu.edu attention Government property associate.

NOTE: Fixed property that is purchased while a building is being built or under renovation, will be capitalized as fixed property in the University’s facility property system, if the overall project meets our capital definitions.

During the Property Inventory reviews, the source documents warranted for review are examined to ensure the assigned general ledger accounts were properly utilized. Discrepancies are investigated and resolved as encountered. In determining the value of property, the inventory Administrative Support Assistant (ASA) adds actual cost, plus shipping and installation charges, excluding extended warranty/maintenance. If the property is received by gift, lease purchase, fabrication, or if the property is found while inventorying, the amount recorded for capitalization is either fair market value, present value, or actual cost from the original source document. Procurement Services provides Property Inventory a detail sheet for all lease purchases.

See Procedure CR2068 Property Inventory: Recording, Tracking, and Depreciation for the types of Property Inventory tags assigned.

Identifying New Facility Property:

Property Inventory reviews IO numbers beginning with a 31, 32, 33, and 34 for projects meeting the University’s capital thresholds. If they meet the thresholds, the IO is given an AUC designation profile. The IO’s profile is changed to YPS003. By setting this designation, all expenditures are posted automatically to the balance sheet. A reconciliation of all expenditures is completed prior to removing cost from AUC and posted to an asset general ledger account number and assigned a SIMBA asset number for depreciation.

OPP billing documents are reviewed monthly or quarterly to ensure that only facility property is being procured. If OPP project meets the capital criteria and are procured under an OPP project number, those expenditures will be capitalized accordingly.

During the Property Inventory reviews, the source documents warranted for review are examined to ensure the assigned general ledger accounts were properly utilized. Discrepancies are investigated and resolved as encountered. If the property is received by gift, lease purchase, or if the property is found while inventorying, the amount recorded for capitalization is either fair market value, present value, or actual cost from the original source document.

The Office of Naval Research (ONR) auditors, Deloitte & Touche, LLP (D&T) auditors, and Penn State's internal auditing departments perform periodic reviews of the Property Inventory Department to ensure compliance with University policies and procedures and Federal regulations for proper record keeping. The University periodically contracts a third-party vendor to perform Property self-assessment audits.

The Property Inventory Department notifies the person in charge of the administrative area to be inventoried as to the date the inventory will start and the approximate time it will end. The department head should, in turn, notify the college/area liaison of the above information.

RELOCATION OF PROPERTY:

Permanent Transfers:

Property permanently transferred to another department is reported on Asset Transfer and Retirement Form in SIMBA, which routes to Property Inventory.

Permanent transfers require updating of the information on the property database such as business area, location custodian and other information as applicable. If the administrative business area does changes and the property is tagged with an old tag (other than a bar-code tag), the property will be re-tagged according to current procedures.

See Procedure CR2024 Using University Tangible Property Away from the University regarding the care and custody of University property used at employee’s homes or other off-campus locations. Use of the Request for Authorization to Use University Tangible Property at Non-University Locations is required when using University tangible property away from the University.

Temporary Transfers:

In the case of a temporary transfer of property to another University location (between locations within the same campus or transferred to another Penn State campus), an Asset Transfer and Retirement form is completed in SIMBA and routes to Property Inventory if the relocation of property will exceed 30 days. "Temporary" is defined as the relocation of property for a period of 30 days or more, up to and including one year.

Per University Policy FN14 Use of University Tangible Non-Capital Property, Capital Property, Supplies and University Services, transfer of University or governmental property to a non-University location for the purpose of University business is reported to Property Inventory when tagged property is transferred, no matter the length of transfer time. The Request For Authorization to Use University Tangible Property at Non-University Locations is used for the transfer of University-owned property. Department of Defense forms may be used when transferring government property. Each of these types of request must be submitted to Central Property Inventory for record updating. Forms may be submitted to Central Property Inventory by emailing CCOpropertyInv@psu.edu.

Do NOT use the Accountability Transfer Form to transfer property or equipment. The Accountability Transfer Form is only used to transfer currency and documents. See Procedure CR2004 Accountability for Transfers of Items of Value (except equipment) for the process of transferring currency and documents.

Traveling with University Tangible (capital and non-capital) Property:

The United States Government has established certain laws and implemented certain regulations and guidelines to restrict, prevent, and/or inhibit access to or provision of certain information, materials, equipment, services and/or financial resources by, to, or for the benefit of unauthorized foreign governments, companies, or persons. These laws, regulations, and guidelines are often collectively referred to as "U.S. Export Controls." All University Affiliated Travelers must comply with these U.S. laws and regulations when traveling internationally on University business, including all U.S. laws and regulations governing the export of controlled materials, software, technology, data, and services. It is required, therefore, that an export review be obtained prior to commencement of any international travel for University business regardless of the funding source for such travel. The required export review for international travel is an included component of the required enrollment of University Affiliated International Travel in the Travel Safety Network system. For more information about the TSN, please visit the TSN website.

ACCOUNTING ADJUSTMENTS

If an area determines that a different cost collector should have been used for the purchase of capital property or a sponsor-titled property, the following must occur:

METHOD OF TRACKING AND ACCOUNTING FOR FACILITY PROPERTY:

OPP Department conducts on site audits of University Park and Commonwealth Campus locations to ensure structures still exist. OPP Program Leaders also inform Property Inventory when structures are being razed in preparation for a new structure.

SIMBA maintains the records of all capitalized property acquisitions. This information is used in determining the depreciation charge, to assist in generating the financial statements and in determining the amount of insurance coverage required for property.

MAINTENANCE OF CAPITAL AND NON-CAPITAL PROPERTY

Policy FN14 Use of University Tangible Non-Capital Property, Capital Property, Supplies, and University Services and Policy RA70 Research Administration Property & Equipment requires departments to provide reasonable maintenance of property to ensure continued functionality (including cost of parts and labor), as well as protection from theft and/or damage.

DISPOSITION OF PROPERTY

General Information:

Capitalized property which is disposed of in any manner must be properly recorded on the Asset Transfer and Retirement Form in SIMBA. The tag must also be removed and returned to Property Inventory.

Government/Sponsored property tagged with a red or yellow tag may not be disposed of until Property Inventory is notified. Any item with a red tag is government-owned and cannot be disposed of without specific permission from the government. All government markings must also be removed from the property before returned to the government or when abandoned to the University. Any item with a yellow tag is sponsor-owned or placed by consignment or loan with the University. Disposal of a gift item so tagged must be reported to the donor and the Internal Revenue Service (IRS) (IRS Form 8283) if disposal occurs within three years of the date of receipt of the gift (refer to the Associate Treasurer's Office and to IRS Regulations for more information).

Types of Disposals:

There are nine (9) ways in which the disposal of property is categorized by Property Inventory. Each category is represented on the data base by a specific Disposal Code as follows:

  1. TYP1 Disposal sent to salvage - Disposals that are reported by department on the Asset Transfer and Retirement form within SIMBA and sent to LION Surplus. Refer to University Policy BS15 Disposal and Purchase of Obsolete, Surplus or Scrap University-Owned Equipment, Supplies and/or Materials and University Procedure BS2011 Lion Surplus Operation Including Sales Store.
  2. TYP2 Disposal Cannibalized - Disposals that are reported by department on the Asset Transfer and Retirement form in SIMBA that have been cannibalized (used for parts and need to be removed from the asset record).
  3. TYP3 Disposal Recycled - Disposals that are reported by department on the Asset Transfer and Retirement Form in SIMBA that is to be sold for scrap.
  4. TYP4 Write Off –Used to retire an asset that has been missing from inventory for two (2) cycles.
  5. TYP5 Prior Year Correction – Used to make prior year corrections and to delete a record from the database.
  6. TYP6 Trade In – Used to dispose of property that has been traded in.
  7. TYP7 Returned to Sponsor – Used to dispose of property that has been returned to the sponsor.
  8. TYP8 Sold – Used to indicate property that has been sold outside of being sent to Lion Surplus.
  9. TYP9 Returned to Vendor – Used to dispose of property that has been returned to the vendor.

When facility property is sold, razed, or partially demolished, the SIMBA asset record and any sub-asset numbers will be deactivated by using one of the same Disposal codes.

The Corporate Controller’s Office and departments must utilize IO’s 31 and 34 for major capital projects.

VIOLATIONS:

Violation of 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. When those resources are inadequate, you may choose to make an anonymous report through the Penn State University hotline by calling 1-800-560-1637.

AUDIT COORDINATION - FINANCIAL AND PROCEDURAL:

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 office related to these procedures.

UNIVERSITY RECORDS RETENTION AND DISPOSITION:

University Records must be retained and managed in accordance with Policy AD35 University Archives and Records Management and the University’s Records Retention Schedules that have been approved by the Records Management Advisory Committee (RMAC), the Office of General Counsel, and Vice President for Administration. These Records Retention Schedules are derived from - or based upon - federal, state, and local statutes or regulations (i.e.; Federal Acquisition Regulations, the OMB Uniform Guidance, Internal Revenue Service, and other regulations governing the auditability and retention of financial records), 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.

University Records and Transitory/Disposable Records are defined below. See Policy AD35, Definition of Terms for additional information.

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. In many cases, retention periods and disposition methods may be generally determined by comparing the type of record (i.e., reports, correspondence, etc.) to similar records series with known retention periods listed on the Records Retention Schedule. If the disposition method for University Records states “Review by Archives” on the Records Retention Schedule, the Unit 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 (IRC).

Exceptions to the disposition process are as follows:

To safeguard the privacy of individuals, records that contain Personally Identifiable Information (PII), as defined in University Policy AD53 Privacy Policy, or student records, as defined in University Policy AD11 Confidentiality of Student Records, must be securely destroyed beyond recovery. For additional information regarding privacy and the protection of an individual's personal information, see Policy AD53 Privacy Policy.

Additional questions may be directed to the Office of Records Management.

EXHIBITS:

No associated exhibits

CONTACT INFORMATION:

For questions, additional details, or to request changes to this procedure, please contact Property Inventory.

CROSS REFERENCES:


PROCEDURE STATUS:

Date Approved:

June 6, 2022

Most recent changes:

Revision History: