UNIVERSITY OF WASHINGTON PROPERTY CONTROL  SELF-ASSESSMENT 

As prescribed by Federal Acquisition Regulations (FAR) 52.245-1(b), the University of Washington (UW) is required to have a system of internal controls to manage, use, preserve, protect, repair, and maintain Government property in its possession.  To ensure the UW is compliant with the standards and practices defined by the Federal Government for the stewardship of this property while under the control of the UW the process must include periodic internal reviews, surveillances, self-assessments, and/or audits.  The UW will meet these requirements through an annual random sampling of department property management processes to examine current practices and determine potential deficiencies.  Please note however that while this will be based on the principle of random sampling, consideration will be given to the quantity, value and funding sources, e.g., federal, of each department's inventory. 

The assessments will be conducted by either the Equipment Inventory Office (EIO) or by the Internal Audit Office as a component of their routine departmental reviews.  Additionally, units having past findings, resulting either from external audits or Internal Audit Office reviews noted above or EIO, will be deemed as ‘high risk’ areas and require a review.  Note, high risk areas may experience more frequent monitoring until the area in question has satisfactorily resolved the issues that were found.

To complete the annual self-assessment EIO will facilitate a sample physical inventory and administer a questionnaire with departments selected for the sample that targets their property management practices.  The self-assessment will focus on, but not necessarily be limited to, departments that have Government titled property (equipment and non-equipment) or have contracts governed by FAR 52.245-1.  All units will be required to have written procedural documentation and will be tested on the processes noted below.  The written documentation may be on an individual unit basis, such as by division or department, or be more broadly applied such as a single process applicable to all units within a school or college.  The written property management plan shall be based on the following requirements:

  1. Acquisition - Process used to acquire equipment and materials

    1. Prior approvals obtained (when required)

    2. Required  to meet the project objectives if funded under a sponsored award

    3. Properly allocated to the funding source(s)

  2. Receiving – Process by which equipment or material is physically received by department

    1. Promptly recorded in the property management system

    2. Properly identified as government property (as applicable)

    3. Managed properly when discrepancies related to shipment occur

  3. Records – Assurance records of property are created and maintained

    1. Timeliness, completeness, and accuracy of property records

    2. Property movements, transfers, retirements, and necessary storage of equipment has been authorized and documented

  4. Physical Inventory – Assurance physical inventories are performed

    1. Conducted on time in accordance with UW’s policies and procedures

    2. Accuracy of physical inventory

    3. Timely reporting of results disclosed to internal and external stakeholders

  5. Maintenance – Performing normal and routine preventative maintenance and repair on property

  6. Subaward Control - Establishing and managing the guidelines and regulations projecting UW and sponsors  interests when a scope of work within a subaward has been delegated to another institution/subrecipient

    1. Adequacy of subrecipient’s property management processes.  Secured via the Office of Sponsored Programs “Subrecipient Certification Form” (project specific) and the “Subrecipient Entity Certification Form”.  

    2. Annual property inventory reports per the award’s  terms and conditions are being completed and documented

    3. Accuracy of property records by data element including quantity and dollar values

    4. Prior approvals obtained, if needed, before purchase of government owned property

    5. Timely reports of equipment lost, damaged, destroyed or stolen and transfers, movements, and dispositions have occurred

  7. Utilization  - Assurance property has been:

    1. Used only as authorized under the award

    2. Properly consumed in the performance of the award

    3. Updated to reflect proper location if movement has occurred

    4. Properly stored and secured

    5. Promptly reported and disclosed to the sponsor when it is excess (surplus) to the award needs

  8. Disposition and Closeout

    1. Timeliness of closeouts (both standard and early termination) the timeliness of each action

    2. Accuracy of records to reflect relief of stewardships

    3. Assure proper and complete coordination of closeout requirements with all subrecipients

To minimize the impact on department resources the self-assessment will be conducted during the annual inventory of Government owned/titled property.  For departments that do not have Government owned/titled property, a separate sampling will be conducted by either Internal Audit’s individual department audits or EIO.  Walkthroughs with department personnel may be requested to examine locations where the property is being used to ensure safeguards are in place. The department’s property management plan, property records, maintenance records, and general department procedures will need to be provided for review. Interviews with the department property manager and any other administrative staff who have responsibility of asset management tasks may be conducted as well.  If any deficiencies are identified, the EIO Property Compliance Coordinator will work with the department to rectify the areas needing improvement. It is the responsibility of the Assistant Director, MAA Compliance to ensure all deficiencies have been addressed and resolved by each department, including those identified within EIO. 

Additionally, the UW is required to ensure Government or sponsor owned property in the possession of a subcontractor is used and cared for in accordance with the terms and conditions of the applicable agreement. The principal method for accomplishing this is to request sufficient information from the subcontractor when finalizing the subcontract agreement. This will be accomplished by the Office of Sponsored Programs using the “Subrecipient Certification Form” (project specific) and the “Subrecipient Entity Certification Form”.  These forms incorporate the most critical questions concerning the subrecipient’s property management processes.  When the subcontractor response is insufficient to ensure adequate property control an alternative method of confirmation must be used.  It is important to note that the principal investigator is ultimately responsible for any loss, damage or destruction of property under the control of the subcontractor.

Results of the annual self-assessment will be retained by the assessed unit as well as EIO. In addition, EIO will forward a copy of the assessment to the respective dean’s office or VP’s office and, upon request, made available to the UW’s cognizant Administrative Contracting Officer.  In addition, the results will be reported to the UW’s Internal Audit Office.