Policy Steward: 
Manager of Analytical Ops
Format Updated: 
University Policy & Standards Converted: 
Revision Date: 
Wednesday, April 13, 2016

* This information replaces PRO 901 Accountability of Equipment on Sponsored Awards & 902 Principal Investigator Responsibilities & 903 Reporting and Inventory of Federal Property & 905 Property in Hands of Subcontractors


Accountability of Equipment on Sponsored Awards

  • The federal government specifies tagging, use, maintenance, reporting and disposal requirements for property accountable to federal grants and contracts.  See PRO-Ex11: Types of Federal Property.

    Property acquired from a research sponsor or purchased with sponsored research funds is accountable to the grant or contract.  Contract authority must exist for the acquisition of facilities, special test equipment and other capital equipment on sponsored research funds. Equipment budgeted in the grant or contract award is assumed to be approved by the award sponsor.  Additional acquisitions of capital equipment on award funds must be pre-approved in writing by the sponsor when required by the regulations of that sponsor.

    There may be additional management procedures and restrictions required by an award sponsor.  In the case of federally sponsored research, procedures and restrictions are specified in Uniform Guidance 2 CFR 200, the Federal Acquisition Regulations (FAR) Part 45-Government Property, and within the terms of the individual contract or grant. 

    Principal Investigators acquiring equipment for sponsored research are held accountable for following the Sponsor's requirements regarding receiving, acquisition, tagging, use, maintenance, storage, physical inventories, record keeping, reporting and disposition of property.


Principal Investigator Responsibilities

  • Departments will order, receive, and tag equipment as required by the contract or grant, Uniform Guidance 2 CFR 200 and the Federal Acquisition Regulations (FAR) Part 45 Government Property.



    Acquisition documents should be detailed with accurate descriptions of assets and properly coded with the contract or grant index or identifier. Items and quantities requisitioned, purchased or fabricated should be reasonable, contractually authorized, based on firm requirements, and not available from existing stocks.

    Orders for supplies and assets should be processed in a timely manner to minimize emergency acquisitions or requisitions. Economic ordering practices should be applied, when applicable. Outstanding orders should be monitored until received, and cancelled or amended promptly when contract modification or other events change requirements.


    Government furnished property (GFP) and contractor-acquired property received for sponsored research must be reviewed immediately upon arrival. If overages, shortages, or damages are discovered, the PI should provide a statement of the condition and apparent causes to the sponsor's property administrator within 48 hours unless the shipment has moved by Government bill of lading and carrier liability is indicated. Then, the PI should report the discrepancy to the sponsor's property administrator within five working days. Note: A copy of all correspondence with the sponsor's property administrator should be sent to the Office of Sponsored Research and Award Administration (OSRAA).

    Packing slips, bills of lading, reports of discrepancies and related documentation must be returned to the department's Business Center and filed with other related grant and contract information. Packing slips for capital equipment should be kept with a copy of the invoice and filed electronically in Nolij as supporting documentation. The receiving process should also include the proper identification of the new equipment.


    Refer to PRO 302 Tagging. When required for Federally-owned equipment, a "Property of U.S. Government" tag may be acquired from Fixed Assets Property Management.

    Equipment with Federal and\or sponsoring organization tags may not be cannibalized or disposed of without written authorization from the sponsoring agency. Request for this authorization needs to be coordinated with Fixed Assets Property Management and OSRAA.


Reporting and Inventory of Federal Property

  • The reporting of equipment and taking of physical inventory will be accomplished as required by the grant or contract, OSU policy, OMB Uniform Guidance, and the Federal Acquisition Regulations (FAR) Part 45-Government Property.

    When federally owned property is no longer needed to perform the contract, the Principal Investigator (PI) is responsible for informing Fixed Assets Property Management.

    When a sponsor requests special reports and/or a physical inventory outside of the biennial inventory contact the Office of Sponsored Research and Award Administration (OSRAA).

    Follow PRO 801 for the Reporting of Lost, Damaged or Destroyed Property.


Property in Hands of Subcontractors

  • Subcontracts are predicated on the prime award, and a copy of the prime award is always attached to the subcontract agreement.  The terms of the prime award flow down to the subcontractor.  However, such terms are not automatic in the area of federally owned property.

    In order to receive federally owned equipment a subcontractor must have an approved property system which includes procedures for the care and maintenance of the equipment.  The subcontractor is required to adequately care for and maintain such property as required by federal regulations per OMB Uniform Guidance and Federal Acquisition Regulation (FAR) Part 45-Government Property. The subcontractor must assure that the equipment is used only as authorized by the contract.  Equipment reports must be submitted to OSU for referral to the sponsoring agency, as required by the prime award and\or at contract closeout.

    A subcontractor will assume full risk for loss, damage, or destruction of federal property in the subcontractor's possession or control except to the extent that the subcontract relieves the subcontractor from such liability.  If there are unusual property requirements, they will be stated in a special conditions attachment to the subcontract. These will include title restrictions and reporting requirements.