Effective Date: July 1, 2007
Effective December 26th, 2014, OMB Circulars A-21, A-110 and A-133 will be replaced by regulations under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (also known as the Uniform Guidance). Please refer to the University’s Uniform Guidance website http://spa.columbia.edu/uniform-guidance for further details that may supersede information outlined in this policy. Revised policies will be posted once they are available.
To establish a policy on the management, control and accounting for moveable capital equipment* (herein referred to as equipment) owned by Columbia (CU) including equipment purchased under grants and contracts where title is vested in CU; or equipment owned by government agencies (i.e. equipment funded by the government under grants or contracts where title is not vested in CU and for which CU is accountable.
Reason for the Policy
To provide the CU community guidance on the management, control and accounting of CU owned or government owned equipment in order to ensure compliance with applicable Federal regulations, as well as to provide conformity with Generally Accepted Accounting Principles (GAAP)
Primary Guidance to Which this Policy Responds
Office of Management and Budget (OMB) Circular A-21, "Cost Principles for Educational Institutions"
OMB Circular A-110, "Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations"
Federal Acquisition Regulation (FAR), Parts 35, 45, and 52
OMB Circular A-133, "Audits of States, Local Governments, and Non-Profit Organizations"
* Purchase price of $5,000 or greater and a useful life of 2 or more years.
CU has contracted an independent asset management firm to provide management oversight for the identification, tagging, recording and reporting of equipment assets. The vendor will be responsible to ensure that CU's policies and procedures applicable to the accounting for equipment are compliant with Federal regulations and conform to GAAP.
An on-site property representative position will be established (herein referred to as "CU Property Coordinator") for the purpose of providing the CU community guidance on the management, control and accounting for CU owned and government owned equipment.
The CU Property Coordinator will:
The asset management vendor will:
Who is Responsible?
CU Controller's office is responsible to account for all equipment purchased using grant or contract funds, including equipment which may be in the possession of a subcontractor.
CU Controller's office is responsible to account for all government owned equipment until such time as the award is finalized and closed, and disposition of equipment is completed.
The Custodial department will be responsible to manage the department's equipment inventory.
Principal Investigators will be responsible to monitor and control equipment purchased on their respective government grants and contracts.
Any inconsistency between this policy and the terms of the grant or contract under which equipment was funded, the terms of the grant or contract shall govern.
What is Considered Equipment?
Note: The custodial department and/or principal investigator are responsible to ensure that government equipment is used only on the award from which the equipment was funded. Use of the equipment for any other purpose must be approved in writing by the government contracting officer.
Annually, CU must file a report on all government equipment having a unit cost of $5,000 or more.
What is CU's Equipment Capitalization Threshold?
CU's equipment capitalization threshold is defined as equipment with a unit cost of $5,000 or more and having a useful life of 2 or more years. Capital equipment purchases should be charged to subcode 61xx. The amount charged to subcode 61xx may include the cost of shipping, installation, modifications, attachments, accessories or auxiliary apparatus necessary to make the property usable for the purchase for which it was acquired. Cost of maintenance contracts or service agreements should be segregated and charged to subcode 3300.
Equipment items costing less than $5,000 will be considered disposable and expensed as current operating costs.
When fabricating or constructing a special purpose apparatus or system, the costs of labor and component parts will be used in determining the asset cost. The CU Property Coordinator will set up the special accounting necessary for tracking and monitoring fabrication costs.
How do you Purchase Equipment?
A purchase order (PO), EZ purchase order (EZPO), or procurement card (P-card) may be used to purchase equipment items. Refer to CU's Purchasing website for guidance on how to purchase equipment at: http://www.columbia.edu/cu/purchasing/policies.html
How do you Identify and Account for Equipment Items to be Tagged?
When an equipment item is received (CU acquired and owned, or CU acquired and government owned) the department will complete the on-line "receiving form" and electronically route the completed form to CU Accounts Payable and the CU Property Coordinator. The CU Property Coordinator will use the receiving form to schedule the tagging.
Capital equipment items will be identified in the accounting system using CU account sub code 61xx.
Requests to fabricate capital equipment must be forwarded to the CU Property Coordinator. The CU Property coordinator will set up an equipment fabrication control to track purchased parts and other components used in the fabrication. The equipment fabrication will be identified in the accounting system using CU account sub code 63xx. When the fabrication is completed the item will be tagged and recorded under sub code 61xx.
Capital leases will be recorded at the time of acquisition using CU account sub code 6117. In order to ensure proper accountability, the CU Property Coordinator should be notified when any changes are made to a capital lease agreement.
Non-capital equipment items (items that do not meet the $5,000 or above cost threshold) will be recorded in the accounting system using sub code 62xx.
Replacement parts, regardless of cost, are not considered to be equipment, rather supplies and materials since the purpose of the acquisition is to restore an equipment item(s) to its original working condition. CU account sub code 21xx should be used to record purchase of replacement parts.
All journal entry requests, FAS account changes and other corrections regarding the accounting for equipment will be routed to the CU Property Coordinator for review. The CU Property Coordinator will forward recommendation for final approval to the Director, Research Policy and Indirect Cost Group. The director's approval is necessary before any equipment journal entry is entered into the University's accounting system.
How are Equipment Items Tagged?
Each equipment item will be tagged with a bar-coded label. If the item is too small or if the application of the label would adversely effect the operation of the item a virtual tag will be assigned.
Government owned equipment will be identified in the same manner as CU equipment, however, the item will be prominently marked with a "Property of the U.S. Government" decal.
The CU Property Coordinator will review each asset record for completeness and accuracy.
What is Equipment Utilization and Screening?
CU equipment will be considered excess when the item becomes idle, or no longer meets the intended need. An internal screening will be conducted to determine whether there is a need for the item within the CU community. The custodial department should contact the CU Property Coordinator for assistance in the screening process.
The "Columbia Equipment Re-Use Program" can be useful to advertise equipment available to the University community. The web link is:
How do you Report Changes in Status of Equipment?
Periodically, the custodial department is expected to review its equipment assets to determine need and/or serviceability.
When deemed appropriate, the department chairperson or designee may request a change in the status of an equipment item by submitting a completed "Equipment Inventory Adjustment Form" to the CU Property Coordinator for disposition instructions.
Disposition of government equipment must be coordinated and approved by the government contracting officer.
When final disposition of an equipment item has taken place, the custodial department must notify the CU Property Coordinator and request that the asset record be retired from the department's active equipment inventory.
In accordance with CU's commitment to protect the environment, Attachment 1 provides guidance on the disposal of computers and other electronic devices.
Excess CU equipment may be offered for sale or trade, or may be donated.
Disposal of equipment damaged or destroyed beyond economical repair must be approved by the CU Property Coordinator.
Any item of equipment (government or non-government) which is lost or stolen should be reported to the CU Property Coordinator for handling instructions. Stolen equipment should also be reported to the campus security office.
When equipment is gifted to CU, the custodial department should contact the CU Property Coordinator for valuation, tagging and recording.
When a custodial department requests the transfer of non-government owned (CU) equipment to another institution an Equipment Inventory Adjustment Form will be completed and sent to the CU Property Coordinator. The CU Property Coordinator will validate the equipment and send a copy of the listing to the receiving institution. Before the equipment is set up for shipment, the receiving institution must provide CU a written acknowledgement that the equipment will be accepted. The CU Property Coordinator will ensure that all CU identification is removed from the equipment prior to shipping.
When government or non-government owned equipment is transferred to Columbia from another institution the custodial department must complete the Equipment Inventory Adjustment Form and forward the form together with any equipment documents received from the sending institution to the CU Property Coordinator. The CU Property Coordinator will schedule the equipment for tagging.
The Equipment Inventory Adjustment Form will be used to request the transfer of government or non-government owned equipment to another institution. The CU Property Coordinator will provide the receiving institution a listing of the equipment. The receiving institution must send the CU Property Coordinator a written statement accepting responsibility for the equipment. The CU Property Coordinator will request approval of the transfer from the sponsor. Before shipment, all government and CU identification will be removed from the item(s). The transferee will be responsible for all transportation costs.
The custodial department must notify the CU Property Coordinator of any permanent change in equipment location. This is necessary in order to maintain control of all moveable capital equipment.
The custodial department must notify the CU Property Coordinator when equipment is moved to an off-campus location. The name of the borrower must be provided in order to annotate the equipment record. The CU Property Coordinator should be notified by email whenever an item of equipment is temporarily relocated off-campus and when the item is returned to the campus.
CU provides limited insurance coverage. Home users of equipment, especially computers and other electronic devices, are responsible for the equipment borrowed. Responsibility for theft, damage or loss liability should be established with the custodial department before equipment is borrowed for home use.
Why is a Physical Inventory of Equipment Necessary?
Conducting physical inventories are necessary in order to validate existing equipment assets and to comply with internal and external audit requirements.
Federal regulations require that a physical inventory of equipment be taken at least every two years. The CU Property Coordinator will be responsible to ensure CU's compliance with Federal requirements. Policy and procedures for conducting a physical inventory can be found at:
A "Physical Inventory Policy and Procedures" document is in the process of being written. When completed, the document will be posted to the University's Policies Library.