Equipment Accountability (Grant and Contract)
Description of Property Control System Analysis (PCSA)
As a recipient of Federal grants and contracts the University of Washington is subject to an audit of its equipment inventory standards. The Office of Naval Research (ONR) administers an annual Federal property audit known as Property Control System Analysis (PCSA) for the University of Washington. The auditors:
- Examine the records and procedures maintained by the University of Washington.
- Physically inspect equipment.
- Interview University personnel.
University (Contractor) Responsibilities
In accordance with Federal Acquisition Regulation 45 - Government Property (FAR45) and clause 52.245-1 Government Property, Section (f) (1), the University must establish and implement property management plans, systems, and procedures to ensure the following ten outcomes are met (The Equipment Inventory Office currently maintains the OASIS system for this purpose):
Acquisition of Property
University departments must follow contractual provisions for the acquisition of property whether through requisition or transfer from Government sources or through purchase from an outside vendor. Granting agencies often have specific regulations and forms for equipment acquisitions. Contact the Equipment Inventory Office for assistance.
Receipt of Government Property
University departments must adequately process government property as soon as they receive it. Upon receipt of new equipment, departments must:
- Document the receipt of government property.
- Compare the shipment to what was ordered. If there is a discrepancy between what is delivered and what was ordered, the department must get the signature of a representative of the carrier (i.e. a delivery person).
- Tag the property and document the following information on OASIS or via a Property Activity Request - Form 1024 to the Equipment Inventory Office:
- UW Tag Number (contact your departmental inventory person)
- Serial Number
- Room Number
- Requisition Number
- Accountable Budget
- Total Cost
- Class Code
- Date Received
- Acquisition Method
- Properly store and protect government property during the receiving process.
The Equipment Inventory Office must account for all items purchased by reconciling the items received to the appropriate requisition documents, purchase orders, packing slips and other documents.
Records of Government Property
The Equipment Inventory Office must maintain official records that:
Show the status of all equipment purchased, fabricated or furnished by the government. (This includes equipment located on campus or in the custody of a subcontractor.)
Control the disposition of equipment. This may include location changes, changes in custodian, parts removed and recovered, or the transfer of equipment from one project to another.
- Are specific to certain kinds of equipment. For example, the University must maintain record of:
- sensitive property: must be marked as such on equipment inventory records.
- industrial plant equipment: the University must submit DD Form 1342, DoD Property Record when it acquires an item defined as industrial plant equipment.
- equipment replaced under warranty: the University must keep records for equipment returned to the manufacturer under warranty.
University departments must:
- Affix an official University of Washington bar code tag to government property upon receipt or fabrication and report the tag number to the Equipment Inventory Office through OASIS or via a Property Activity Request - Form 1024.
- Place a yellow agency tag along with the bar code tag if title vests with a federal agency. (If any portion of a fabrication vests with the federal government the department must apply a federal yellow sticker to the entire fabrication.)
The University must conduct an inventory of all items of government property in its custody both at an interval approved by Office of Naval Research and at the conclusion of a contract.
- Equipment Inventory generates an inventory of government property for each department.
- A designated department inventory contact must physically locate each asset on this inventory and mark its status on the inventory. (The inventory contact must be someone other than those maintaining records or who have equipment in their own custody.)
- The inventory contact notes any changes to the status of equipment on this inventory.
- The department returns the annotated inventory to the Equipment Inventory Office.
- The Equipment Inventory Office enters any adjustments made on the inventory into OASIS and reports them to the Office of Naval Research within a reasonable period. (The Equipment Inventory Office marks such changes in the OASIS database as inventory adjustments and includes the date of the inventory.)
The University, as a prime contractor, may loan government equipment to a subcontractor under some circumstances if they have authorization from the Office of Naval Research or other granting agency.
- If loss occurs the University must compensate the government.
- If a subcontractor has a property control system in place that is approved by the government, the subcontractor's records are accepted as being the University's inventory records. (The University is responsible for ensuring that a subcontractor's property control is adequate.)
- If the subcontractor does not have a property control system of its own the University may write a subcontract relieving the subcontractor of the risk of loss. (Name any assets provided to a subcontractor and any subcontractor responsibilities in the subcontract.)
The Equipment Inventory Office must submit Annual Property Reports and Closeout Property Reports reflecting the status of property as required by contract or regulation. The Equipment Inventory Office must:
- Base property reports on up-to-date information and must indicate the source of their data.
- Work with University departments to ensure the accuracy of this data and to fulfill contractual requirements for the submission of reports.
- Submit appropriate forms/reports to granting agency.
- Conduct its own internal self-audit addressing its property control policies and procedures. (The Equipment Inventory Office works with departments to conduct our internal equipment inventory self-audit.)
Relief of Stewardship Responsibility
- Should screen contract-acquired property at the conclusion of a contract and when excess equipment exists to determine its usefulness on other contracts or other work of the University.
Should inform the Equipment Inventory Office of any excess inventory by sending a completed Property Activity Request - Form 1024 to the Equipment Inventory Office (Box # 351121).
Must comply with contractual provisions for scrap procedures. The proceeds from the sale of scrap must be credited as directed by the Federal or Agency sponsor. (If directed, they must credit proceeds from the sale of contract-acquired assets to the Federal government.)
The Equipment Inventory Office:
- Contacts the Federal or Agency sponsor to obtain permission to dispose of the government or agency property.
- After sponsor permission has been obtained, sends the department a white tag to be placed over the yellow Federal or Agency tag. This tag will say FEDERAL AGENCY PROPERTY, CLEARED FOR DISPOSAL and will indicate to Surplus Property that these items are okay to dispose of.
- If specific disposal instructions from the sponsor exist, works with Surplus Property to promptly dispose of equipment according to the those instructions and in accordance with Federal Acquisition Regulation 45.6 Reporting, Reutilization, and Disposal.
- Maintains records reflecting authority to dispose, disposal method, date of the disposal, and when the record is posted to the inventory control system.
Utilizing Government Property
University departments may only use government property for the uses they described before they received it. The department must:
- Get authorization from the Office of Naval Research before they may use federal property for non-contractual purposes.
- Establish methods to determine and allocate rental charges if they get permission to use the property for a different use
- Must maintain a screening process to determine the level of such utilization. (The degree of utilization of equipment determines whether the University retains the equipment or not.)
Equipment Inventory must report excess to the Office of Naval Research.
Consumption: University departments may use up raw materials provided by the Federal government in the process of fulfilling a contract. The Office of Naval Research must authorize the consumption of such materials. Quantities consumed by University departments must be reasonable as determined by cost, the amount called for, and established scrap rates. The department must:
- Ask the Office of Naval Research or the granting agency for authorization to use more materials than they originally planned. Accurately document their consumption of materials and any authorization by the appropriate departmental officials.
- Consume aging sensitive materials first.
- Return any unused materials to the government unless the University has been authorized to retain these materials.
- Have a screening process in order to identify excess government property in their custody.
- Report excess property during property closeouts.
Movement: University departments moving government property from one location to another on campus or to another facility must:
- Submit the proper documentation including a Property Activity Request - Form 1024 shipping documents.
- Get authorization for the move from appropriate departmental officials, including directors, deans and chairs.
- Provide adequate physical protection for the equipment during the move. This includes packing, covering, skidding prevention, the use of property handling equipment, proper procedures and techniques and safety precautions.
- Contact the Equipment Inventory Office for assistance since you may need prior approval from the granting agency.
Storage: University departments must provide an adequate government property storage facility that:
- Offers adequate physical security and protection for assets stored inside and outside.
- Protects items in storage from corrosion, humidity, temperature and aging.
- Is accessible only to authorized personnel.
- Offers additional physical security and protection for sensitive items.
University departments must provide the maintenance necessary to obtain a high quality of production and the most useful service life of government property. Departments must:
- Maintain the government property according to current technical standards.
- Schedule and complete periodic maintenance.
- Perform any unscheduled maintenance in an expeditious manner.
- Keep records of all maintenance performed.
Research departments and the Equipment Inventory Office work together to fulfill contractual provisions for handling equipment on a closing contract.
The Equipment Inventory Office:
- May ask departments to provide any necessary information about government property on a contract.
- Sends a listing of contract-acquired property to the Office of Naval Research or other granting agency at the end of a contract.
- Requests that title vest with the University for use in further, on-going research if the title remained with the government at the beginning of the contract.
- If title is given to the University, issues one special white tag per assets to the department to place over the yellow Federal / Agency tag. This tag will say PRIOR FEDERAL AGENCY ASSET, NOW UNIVERSITY PROPERTY.
- (and the department) Resolve all inventory adjustments, liability determinations, and other property issues before the contract is closed.
- Informs the Office of Naval Research or other granting agency when all pending actions on property-related matters are completed.
- Gives the Office of Naval Research or other granting agency any special tooling requirements for equipment reverting to the custody of the Federal government.