Government Equipment

Overview

A series of standards and regulations set forth in the OMB Uniform Guidance and Federal Acquisition Regulation have been established to maintain controls on government-sponsored equipment for all institutions that receive funds for federally sponsored programs. These institutions are required to maintain a database of equipment that must comply with the federal regulations and the government has the right to approve institutional policies and to audit their systems.

Boston University’s responsibility extends from the initial acquisition and receipt of equipment, through stewardship, custody, and use until formally relieved of responsibility by authorized means, including delivery, consumption, expending, sale (as surplus equipment), or other disposition, or via a completed investigation, evaluation, and final determination for lost, stolen, damaged, or destroyed equipment.

The Property Management team, department administrators and custodians are responsible for compliance.

Government Regulations

OMB  2CFR 200 (Uniform Guidance) 

https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200

Federal Acquisition Regulations (FAR)

https://www.acquisition.gov/browse/index/far

Defense Federal Acquisition Regulations (DFARS)

https://www.acquisition.gov/dfars

NASA Grant & Cooperative Agreement Manual

https://www.nasa.gov/wp-content/uploads/2025/03/gcam-mar-2025.pdf?emrc=982b64

 

Equipment Definitions

Capitalization Threshold for Equipment

Moveable Capital Equipment is defined as any article of non-expendable tangible property (e.g., automobile, centrifuge, microscope, projector, network server) that meets the following capitalization criteria.

  • The purchased item has a useful life of one year or greater.
  • The cost of the item is $5,000 or greater, including delivery and installation costs, and including the cost of attachments required to operate the item when those attachments are acquired as part of the original equipment purchase.
  • Boston University has title to, is the custodian of or is held responsible to account for the item.

Contractor Acquired Property (CAP)

Equipment purchased by Boston University with award funds from a federal contract to which the government holds title.  It is the responsibility of the department to document the receipt of government equipment and take all actions necessary to adjust for overages, shortages, damage and/or other discrepancies discovered upon receipt. Records shall be created and maintained for all government equipment accountable to the contract.

Government Furnished Property (GFP)

Equipment may be made available for use by the University by a government agency to fulfill research required on a sponsored award. All equipment furnished by the federal government must be tagged and documented within the Asset Accounting Module, regardless of its price. Government equipment may be shipped to Boston University directly from federal installations or other government contractors. The receiving department at BU shall become responsible for the equipment upon delivery into the department’s custody or control. It is the department’s responsibility to notify Property Management in a timely manner as to the arrival and location of this equipment. The equipment will be tagged and entered in the Asset Accounting Module to ensure appropriate coverage for this type of equipment.  At the end of the award, disposal instructions from the sponsor are required.

Title to Equipment

Title to equipment purchased with federal funds will vest in accordance with the terms and conditions of the award agreement.

Roles & Responsibilities

Principal Investigator (PI)

A Principal Investigator has full responsibility for the oversight of a sponsored project, including the design, development, and implementation of the technical plan; as well as all administrative aspects, and financial and non-financial compliance aspects of the project. The PI is fully responsible for the academic quality of the project and for ensuring compliance with the terms, conditions, and policies of the sponsor and the university.

Property Management

The central administration team that develops and implements policies, procedures, and a system that enables effective management of equipment for Boston University. Property Management provides support for all matters regarding moveable capital equipment-related issues from pre-purchase considerations through the retirement of assets. Property Management staff is responsible for capturing purchases of capital equipment and creating and maintaining assets records as well as equipment tagging, inventory, audit management and Property reporting.

Department Property Administrator (DPA)

The person or team in the department that manages the award used to purchase the equipment. The role of the department is outlined below:

  • To safeguard moveable capital equipment assigned to the department and ensure equipment is in proper use and maintenance.
    • Departments are fully liable for equipment within their custody and are responsible for all repair and maintenance costs.
  • To uphold compliance policies regarding moveable capital equipment set forth by Boston University and government agencies.
  • To ensure custodians, principal investigators, and users of moveable capital equipment titled to the federal government are aware of the rules and regulations governing the equipment.
  • To Maintain a requisition and packing slip for each item received.
  • To work with Property Management on any moveable capital equipment issues:
    • Report any acquisitions not processed through Ariba (PCard, Donations, Loans)
    • Follow up on returns or trade-ins
    • Report equipment that is ready to be tagged
    • Consult regarding discharged equipment, disposals, transfers, and movements of capital equipment
    • Participate and/or assist in physical inventories on an as-needed basis

 

Equipment Management Process

Acquisition

Department Administrators work with the Principal Investigators to place an order of Equipment. Purchase requisitions with totals greater than (or equal to) the capitalization level using the appropriate product category codes are routed to Property Management for approval. Those that meet the capitalization criteria, will be entered into the accounting system as a moveable capital equipment asset. Each asset record includes descriptive information as well as location information and purchase documents.

Fabricated equipment projects require an application to Property Management. An asset tag number is assigned to the project and acquisition costs are tracked in a separate account. When the project is complete, the asset is entered into the moveable capital equipment database.

Asset Tracking

The Property Management team maintains a list of newly acquired assets and works with PIs to get access to the equipment for tagging.  Each piece of equipment is tagged with a BU Property tag.  The labels are barcoded and list an individual identification number.  Government titled equipment will also receive a government property label. The asset record in SAP will include identifying information, the location and, if possible, an image of the asset.

Every two years, the Property Management Team conducts a physical inventory where all assets not previously deactivated in the equipment database are investigated.

 Record Retainment

Department Property Administrators are responsible for organizing and storing records related to capital equipment assets as these supporting documents are used for reconciliation and audit purposes. It is recommended to establish an individual file for each piece of equipment and a typical file should include the following:

Acquisition Documents

  • Approval of purchase, if sponsor requires it
  • Any maintenance or warranty agreements
  • External screening, if sponsor requires, (i.e., Certificate of Non-Availability [CNA])
  • Shipping records (for example, vendor packing lists)
  • If donated equipment, ensure Property Management has copies of all documents prior to purging the file
  • Assigned BU-Property Tag Number
  • Location and custodian

 For federally owned equipment, in addition to the above, please retain:

  • Shipping Document: Bill of Lading or letter of transfer
  • Department of Defense Form 1149 (for used equipment) or any other government form provided.

 For disposal of government equipment and government furnished equipment, please retain:

  • Approval letters from the sponsor
  • Repair, maintenance, and calibration records
  • Financial and property records, supporting data, statistical records, or any document pertinent to an agreement should be retained for a period of three years after submission of the final payment, or three years after disposition of the property, whichever is later.
  • Note: If any litigation, claim or audit is started before the three-year expiration period, the records must be retained until all litigation, claims, or audit findings have been resolved.

Audits

All assets are subject to audits and must be accounted for accurately and on a timely basis. Boston University is subject to annual audits conducted by the University’s external auditing company or the Office of Naval Research (ONR), biennial audits by Property Management, and audits at will by Boston University Internal Audit.

Disposition of Federally Owned Equipment

Upon completion of an award, or completion of the equipment’s use, the University shall report the equipment to the awarding agency for further utilization. If the agency has no further need for the equipment, the agency has statutory authority to dispose of the equipment by alternative methods. Appropriate instructions shall be issued to the University by the federal awarding agency.

Federally owned equipment requires written permission for disposal and is accomplished generally through the contracting office of the award. Dismantling or cannibalizing of any federally titled equipment is unlawful.

Relief of stewardship responsibility and liability
The department accountable for the equipment must promptly recognize, investigate, and disclose the reporting of loss of government owned equipment. Loss is defined as equipment that is missing, stolen, damaged, or destroyed.

Unless otherwise directed by the contracting agency, the department shall report all incidents of loss, as soon as the facts become known, by submitting a completed and signed Movable Capital Equipment Management Form to Property Management. Such reports shall, at a minimum, contain the following information:

  • Date of incident (if known)
  • Accountable contract number
  • A statement indicating current or future need of equipment
  • Unit acquisition cost, or if applicable, estimated sales proceeds, estimated repair or replacement costs
  • All known interests in commingled material of which includes Government material
  • Cause and corrective action taken or to be taken to prevent recurrence
  • A statement that the government will receive compensation covering the loss of equipment
  • Copies of all supporting documentation
  • Last known location
  • A statement that the equipment did or did not contain sensitive, export controlled, hazardous, or toxic material, and that the appropriate agencies and authorities were notified.

Unless the contract provides otherwise, Boston University shall be relieved of stewardship responsibility and liability for the government equipment when:

  • Such equipment is consumed or expended, reasonably and properly, or otherwise accounted for, in the performance of the contract.
  • The contracting agency grants relief of responsibility and liability for loss of the equipment.
  • Equipment is shipped from Boston University, under government instructions, except
    when shipment is to a subcontractor or other off-campus location.
  • Equipment is disposed of in accordance with the government regulations.

It is also the responsibility of Boston University to notify, in writing, the federal agency when federally owned equipment is lost, damaged, destroyed, or consumed. Failure to inform the agency may result in University liability to the government with subsequent appropriate reimbursement.

Failure to follow procedures on this type of equipment can result in penalties and fines for the custodian/department of the equipment. Equipment titled to the federal government remains at the acquisition value and does not depreciate regardless of its age or condition.

Retention by the University of federally owned equipment may occur when a contract is completed or terminated, provided that the government has approved the transfer of title in writing to the University.