Equipment Compliance

Stay Compliant...

• If equipment costs are shared across multiple projects, document how the cost is divided and why each project benefits
• Indicate equipment purchases in the budget and budget justification during proposal stage
• Obtain written approval prior to the purchase (if required by the sponsor)

Also Consider...

• Equipment must directly benefit the project to be allowable
• In most cases, title of the equipment will vest to the University. However, Federal sponsors may require that title vests with the Federal sponsor 
  • *For example, when equipment is purchased on Department of Energy National Lab awards, the title typically vests with the lab and/or funding agency.  Departments are responsible for identifying these situations and contacting SPA to obtain a Federal Property tag 
• Federally titled equipment must be completely funded by the sponsor and cannot be allocated between different awards or funding sources 
• Equipment titled to the University may be purchased on split funding (funding from non-sponsored funds and Federal sponsor funds) 
  • The cost allocated to the Federal project should be based on the relative benefit 
  • Documentation to support the methodology should be maintained by the department

Equipment Title Tool

Equipment compliance should be considered during all phases of the award lifecycle, including detailed justifications during the budgeting and budget justification phase, obtaining prior approvals when necessary, following terms and conditions during the award period of performance, and fulfilling any reporting responsibilities, including closeout. Equipment purchased or fabricated must be properly tracked and inventoried in the property accounting system. The University’s single audit engagement occurs annually and includes equipment observations and testing. Additionally, other sponsors may conduct equipment and inventory audits throughout the lifecycle of an award.

To ensure compliance, departments should…

• Determine if any prior approval requirements exist and ensure documentation is maintained.
• Follow award terms and conditions and reach out to SPA Award Management for clarification as needed.
• Confirm the equipment is properly recorded in Banner property accounting records (Banner Fixed Asset).
• Make sure a Ptag is affixed to all equipment purchased with Federal funds.
• If the sponsor retains title, a Federal (or Private Sponsor) inventory tag should be affixed, as applicable. This tag is in addition to the assigned Ptag.
• Know the location of the equipment; a physical inventory inspection should be conducted at least every two years (BusFin Section 12.2.1).
• Ensure proper documentation and logging in Banner Fixed Asset is completed for disposition statuses such as:
  • Transfers of equipment
  • Loans of equipment
  • Disposal of equipment
  • Unlocatable or stolen equipment
  • Surplus equipment
• Comply with reporting requirements as detailed in the award.

For additional details and assistance, please visit BusFin Equipment Management .