Procedure # : 600.170 Date: 10 August 1998
Written By: Ralph Earhart
Director, Financial Services
OMB A-110 in its property control section (.34) says that "title to equipment acquired with federal funds shall vest in the recipient, subject to the conditions of this section." In the paragraphs relating to supplies (.35), it says, "title to supplies and other expendable property shall vest with the recipient upon acquisition". Supplies and equipment bought with any fund source through the collegeís procurement system becomes state property. Equipment transferred to The Citadel when a faculty member comes to the college becomes state property. State property cannot be disposed of or transferred without following the appropriate materials management procedures.
OMB A-110 provides for the transfer of federally funded equipment from one college to another, however the project must be on going or it must be within 120 days of the close-out of the project. The procedures relating to property transfers are included in the appropriate section. Bottom line, if a project is on-going or just completed, the principal investigator needs to ask the granting agency for approval in writing to move the equipment away from The Citadel.
If equipment is purchased on a non federal grant, the sponsor would generally want the equipment to transfer with the principal investigator (PI) since they are funding the PIís particular work and would expect that they would only have to buy a piece of equipment once for the person, no matter how many times the PI might change institutions. In order for PI to have this flexibility, the initial contract with the college must indicate that any equipment and supplies bought with the grant funds are to go with the principal investigator, should he go to another institution. In that manner, it becomes a requirement of the collegeís acceptance of the grant that it will permit the equipment and supplies to move. Without this requirement in the contract or grant, non federally funded equipment will not be able to transfer to another institution.
2. General Definition of Responsibility
The Principal Investigator of each grant is responsible for contacting the Director, Financial Services and Procurement Director when a move from The Citadel is contemplated in order that the appropriate support can be confirmed so that the property can be legally moved.
Principal Investigators reporting to the Citadel who are bringing equipment and supplies from another college or university are required to contact the Controller and Director of Procurement so that their grant (non personal ) equipment may be entered into the property system, appropriately insured, and properly safeguarded and accounted for. Equipment being transferred to the Citadel becomes state property.
Departmental Property liaisons are required to inventory the equipment annually. The liaisons should not permit the equipment to be taken from the college without proper authorization from the Director of Procurement and the Director, Financial Services.
The College Property Manager is required to notify the property manager of the
institution to which a principal investigator may be moving , of the grant funded equipment being transferred with that person.
With appropriate documentation and timing, equipment and supplies can be transferred from the Citadel to another non profit organization or college or university.
All equipment or supplies bought on a grant are property of The Citadel. They cannot be moved to another entity without following federal and state rules. A summary of these rules are:
Written approval to transfer equipment and supplies purchased on a federal grant must be received while the grant is on going or within 120 days after the termination of the grant. Without this written authorization, federal equipment cannot be moved.
For non federal equipment and supplies, the granting or contracting documents awarding the grant to the college must indicate that, as a condition of accepting the grant or contract, the college must permit the principal investigator to take the equipment or supplies at such time as they might leave the college.
Without this documentation, equipment and supplies purchased on grants will remain at The Citadel and used on appropriate programs, or else they will be disposed of through the state procurement process as surplus equipment and supplies.