Disposal of Equipment on Federal Awards

Proper Disposition of Equipment Governed by the Code of Federal Regulations (CFR)/Uniform Guidance

Section 200.313 (e) of the CFR, also known as the Uniform Guidance, details proper disposition of equipment governed under these regulations.

If the equipment is Federally owned or funded on current awards, the department must work with the Equipment Inventory Office to obtain written instructions from the sponsor before the item can be surplused, moved, transferred, or disposed.  This documentation must be complete and contain:

• The Federal agency's written authorization,
• Appropriate disposal action, which could: 
  • Relieve the University of further federal accountability by transferring title to the University.  When this occurs the equipment falls under State policies and procedures.
  • Request the University return the equipment to the federal agency.
  • Request the University sell the equipment and return the proceeds to the federal agency less $500 or 10% of the proceeds, whichever is less, to cover the administrative costs associated of selling and handling of the equipment.
  • Request the University transfer the equipment usage to another award funded by the same sponsoring agency (e.g., NIH to NIH, NASA to NASA) in which case title of the equipment is retained by the Federal Government.
• Date of disposal

When instructions have been received from the sponsor, proceed as directed. 

• If the sponsor transfers title to the University, work with the Equipment Inventory Office to obtain a special white tag to place over the yellow Federal or Agency tag.  This tag states "PRIOR FEDERAL OR AGENCY ASSET, NOW UNIVERSITY ASSET". 
• If the sponsor approves disposal, work with the Equipment Inventory Office to obtain a special white tag to place over the yellow Federal or Agency tag.  This tag will state "FEDERAL AGENCY PROPERTY, CLEARED FOR DISPOSAL". 

Disposal of Federal or Agency Equipment via Internal Transfer, Trade In, Items Cannibalized/Consumed

If the equipment is federally owned or funded on current awards,

• Gets written approval from the sponsor before the item can be surplussed, moved, transferred, or disposed of.  This documentation must be complete and contain:
  • Date of disposal.
  • Appropriate disposal action, which could:
    • Relieve the University of further federal accountability by giving the title to the University at which point it falls under state policies and procedures.
    • Request the University to return the equipment to the agency.
    • Request the University sell the equipment and return the proceeds to the agency less $500 or 10% of the proceeds, whichever is less, for selling and handling expenses.
    • Transfer the equipment usage to another award by the same sponsoring agency (e.g., NIH to NIH, NASA to NASA) and leave the title with the federal government
  • Agency's written authorization.
    

    Note:

    • Equipment Title is only completely vested with the UW (the government does not have conditional title) if the Award specifically states that the recipient has unconditional title (example terminology:  “without further obligation to the government” or “exempt”) and therefore there is no obligation to the federal government at the end of the award.  This means that the equipment is “exempt” from the standard regulation; In this case, the government may still require transfer of the item either back to government or another entity such as when a PI moves to another institution and takes their award with them;
    • Equipment Title is generally vested with the UW (not the department but the UW as UW is the recipient) as a “conditional title”.   This means the government retains rights to the equipment and, for example, is entitled to reimbursement of the cost of the item if the UW wants to keep or sell it. In this case, the equipment is “non-exempt” from the standard regulation.
• Sends written approval to Equipment Inventory so that the transaction can be recorded.

Disposal of Federal or Agency Equipment via External Transfer (an outside entity)

If Federal or Agency Titled, department requests written sponsor approval (email is sufficient) from the sponsor (specific to the award and/or budget number) and sends to EIO upon receipt.

If sponsor:

• Approves, EIO obtains written sponsor approval from the department and approves the item(s) to leave the UW.  NOTE:  After EIO approves, the department cannot deny the transfer.  However, the researcher can choose to leave the item(s) behind.
• Does not approve, EIO notifies the department that the item(s) cannot leave the UW.  When equipment is no longer needed, it should be returned to the Federal government or agency or the department can work with EIO to request disposition instructions.  Disposition instructions could relieve the University of further federal accountability by giving the title to the University (at which point it falls under state policies and procedures), request the University sell the equipment and return the proceeds to the agency (less $5000 or 10% of the proceeds, whichever is less, for selling and handling expenses), transfer the equipment usage to another award by the same sponsoring agency and leave title with the federal government.

Please visit the Post Award Fiscal Compliance page for more information on this.

Disposals With An Unidentifiable Federal Sponsor

This usually happens with awards that are quite old and have been closed for a period longer than our records retention period. On some very old awards where equipment was purchased with a Federal or Agency title, we may or may not be able to identify who the sponsor is.

The following steps are taken to attempt to determine a sponsor contact. EIO will document that this process was followed for each asset:

1. Check the following for any information regarding the original sponsor: Sera, Grant Tracker, OSP Status and check with Research Central to see if it’s still at records center.
2. Check Equipment Inventory’s Closeout records.
3. If sponsor is identified, we would contact the sponsor and request permission to dispose of the equipment.
4. If none of the above produce a clear record of who should be contact for disposal requests, the Department would be contacted to see if they have any information on the sponsor.
5. After all avenues have been exhausted, the information is forwarded to the Assistant Director of EIO for review. If approved, the Equipment Inventory Office would then issue a surplus disposal authorization to the Department.