Technically you could sell it because title to supplies stays with the institution, though I would recommend keeping it within the institution because the last
thing we all want to see is a news article that talks about the obscene “profits” universities are making by selling residual supplies, and using that money to buy yachts (and of course the taxpayers are paying for it). The part about compensating the Federal
government for their share is only if you have residual supplies with an aggregate value of over $5,000, so since you didn’t have over $5k in your example, the institution has title to it and may do what they want with it. Generally residual supplies just
stay in the same labs that the original work was being performed in and get used up.
At the for-profit defense contractor I used to work for, we had to track supplies at a fine level (i.e. I purchased a box of 50 screws and used 38 of them and
have 12 remaining) and had log books to track what had been used. At the end of the contract we had to tally up all of our unused supplies, and we could either buy them ourselves (DoD always told me 10% of the cost was reasonable for our purchase), or post
the list of residual supplies on a DoD site for all other defense contractors to be able to purchase it. If nobody purchased it and we didn’t want them, we’d have to have someone from DCMA (Defense Contract Management Agency) come out and watch us destroy
and dispose (throw everything in our dumpster) of the residual supplies. I can’t imagine how large of a burden this would be at our university, but I’d be concerned that if universities were in the practice of selling off residual supplies on Federal awards
that it could be the next hot button item that draws more scrutiny towards our community (as if the indirect cost rates weren’t enough), and would lead for new regulations that have us start tracking supplies as I just described.
I hope this helps.
Sincerely,
Jason Guilbeault, CRA
Director, Post Award Services
Sponsored Program Administration
Augusta University (formerly Georgia Regents University)
1120 15th St. CJ-3301
Augusta, GA 30912
706-721-0007
Georgia Regents University is now Augusta University. Effective immediately, my email address has changed to
xxxxxx@augusta.edu. Please update your address book accordingly.
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of dougm (Doug Mounce)
Sent: Friday, April 21, 2017 6:17 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] [EXTERNAL] Re: [RESADM-L] from the equipment-and-supplies dept.
If I buy a laptop for $5,001, and a limited edition Montblanc Omas 1453 The Conquest of Istanbul fountain pen for $3,995 (both directly benefitting the project),
then, after the grant has expired, the tagged piece of laptop equipment can be disposed of for, let’s say, about $50. The Pen is still worth $1,000 or more, but I can’t sell it, right?
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Guilbeault, Jason
Sent: Friday, April 21, 2017 1:49 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] [EXTERNAL] Re: [RESADM-L] from the equipment-and-supplies dept.
I’ve seen several university policies that will state something to the effect of what’s in 2 CFR 200.314a (see below) and state that if there are supplies in
excess of $5k to contact your sponsored programs/research office, however I haven’t seen anyone that actually tracks their supplies inventory. The way an auditor would look for non-compliance in this area is to look for large dollar amounts of supplies purchased
near the end of an award, which may indicate you have a surplus of supplies (I believe I’ve seen this in a few NSF and NIH OIG Audit Reports), however in the Compliance Supplement (for Single Audits), I haven’t seen any guidance to instruct auditors on how
to check (or to check, period) for residual supplies.
Note that the supplies threshold is “$5,000 in total aggregate value” and not based on the purchase price, so if you bought a few $3,000 laptops at the beginning
of a 3 year award, this doesn’t necessarily mean that you have over $5k in residual supplies inventory at the end of the project, since those laptops are no longer worth $3k a piece. Also keep in mind that now computing devices under $5k (or whatever your
institution’s depreciation threshold is) are considered a supply (see 2 CFR 200.453).
2 CFR 200.314a - If there is a residual inventory of unused supplies exceeding $5,000 in total aggregate value upon termination or completion of the project or program and the supplies are not needed for any other Federal award, the non-Federal
entity must retain the supplies for use on other activities or sell them, but must, in either case, compensate the Federal Government for its share.
Jason Guilbeault, CRA
Director, Post Award Services
Sponsored Program Administration
Augusta University (formerly Georgia Regents University)
1120 15th St. CJ-3301
Augusta, GA 30912
706-721-0007
Georgia Regents University is now Augusta University. Effective immediately, my email address has changed to
xxxxxx@augusta.edu. Please update your address book accordingly.
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Kristina Duryea
Sent: Friday, April 21, 2017 4:15 PM
To: xxxxxx@lists.healthresearch.org
Subject: [EXTERNAL] Re: [RESADM-L] from the equipment-and-supplies dept.
This is an external email. Use caution responding, opening attachments and following links.
Does anyone do an inventory at the end of a grant? How else would we know if more than $5k of inventory remains?
Kris
Kristina Duryea, MA, GCRA, CRA
Sr. Finance and Grants Administration Manager
Center for Biotechnology
Bioengineering Bldg, Room 201
Stony Brook University
Stony Brook, NY 11794-5280
631-632-8468
On Fri, Apr 21, 2017 at 3:22 PM, Megan Roth <xxxxxx@acu.edu> wrote: