Policies & Compliance

Research Related Regulations, Policies & Procedures

10.4 Property and Capital Equipment

For purposes of sponsored projects, property (capital equipment) is defined in the Uniform Guidance as non-expendable, tangible personal property with a useful life of more than one year and an acquisition cost that equals or exceeds the lesser of:

the capitalization threshold established by the University for financial statement purposes, or
$5,000 per unit.

This category also includes fabricated equipment, which consists of multiple components assembled into a single, identifiable unit that meets the capitalization threshold.

The University's Property Accounting office maintains official capital-equipment records and provides property-related information to departments, inventory controllers, sponsors, and external auditors.

Equipment Classifications

Agency-Defined Equipment
Some sponsors define equipment at a threshold lower than the University's $5,000 standard. When a sponsor-specific definition applies, an Agency-Defined Equipment account code is used to track such items.

Government-Acquired Equipment
Equipment purchased by or for the federal government for the performance of a contract, to which the government holds title, unless otherwise specified in the contract.

Government-Owned Equipment
Equipment owned by the federal government, including items acquired by the University with federal funds, where title remains with the government under the award terms.

Government-Furnished Equipment
Equipment provided to the University by the federal government or a government contractor. The title may or may not remain with the government, depending on award conditions.

10.4.1 Institutional and PI Responsibilities

The University is responsible for the custody, control, and stewardship of sponsor-funded or sponsor-owned property provided under the terms of sponsored grants or contracts.

The University delegates day-to-day control and accountability of such property to the Principal Investigator (PI) responsible for the project. While PIs may assign operational responsibilities to project staff, research coordinators, departmental property administrators, or laboratory personnel, overall accountability remains with the PI.

Strict adherence to equipment-management policies is required to ensure compliance with contractual, regulatory, and audit obligations.

10.4.2 Sponsor Title and Disposition Requirements

Federal Contracts

For federal contracts (as distinct from grants):

The title to equipment costing $5,000 or more typically remains with the federal government unless the contract provides otherwise;
This includes equipment purchased in whole or in part with matching or cost-share funds;
Equipment costing less than $5,000 generally vests in the University only if contracting officer approval is obtained prior to acquisition.

When title remains with the government, the University acts as custodian of the equipment.

Federal Grants

For federal grants, title to equipment typically vests in the University upon acquisition, unless the sponsor reserves the right to retain or later transfer title. In practice, retention of title by the government is uncommon for grant-funded equipment.

Non-Federal Awards

For non-federal sponsors, title and disposition of equipment must be determined according to the award terms. The University's preferred position is to take title upon acquisition, unless sponsor requirements dictate otherwise.

10.4.3 Acquisitions Funded by Research Grants & Contracts

Requisitions for capital equipment and significant modifications charged to sponsored projects are subject to review by Grants & Contracts Accounting (GCA) to confirm allowability under the applicable award.

Equipment not explicitly authorized in the approved budget or award terms may not be purchased until sponsor approval is obtained.
As a general practice, requisitions for capital equipment submitted within 90 days of the project end date will not be processed unless:
- the purchase is essential to accomplishing the project objectives and is approved by the Vice President for Research (or designee), or
- the award specifically supports equipment acquisition.

Requisitions for equipment or supplies may also be denied if delivery is unlikely to occur within a reasonable time before the project end date.

All purchases using federal funds must comply with applicable federal procurement regulations, sponsor requirements, and University policies. When price quotations are limited or sole-source justifications are used, price-reasonableness and cost-analysis requirements must be met prior to award.

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