Comments throughout. Sorry for the long-winded background; you sound like you know your way around A-110, but it does take all the bricks to make the wall! If there is some justifiable reason for this audit requirement, which seems on the surface completely erroneous, will you share it with the list? Chuck At 01:23 PM 4/5/2004, you wrote: >We were recently required by auditors to provide a listing of federally >funded property... not equipment, not real estate, but "property." A-110, --.2, (aa) "Property means, unless otherwise stated, real property, equipment, intangible property and debt instruments." >We were required to inventory items such as a fax machine, a palm pilot, >and other sundry items which don't meet the equipment threshold for either >A-110 or my organization. I've never been required to inventory such >property before and I don't see where I'm required to do so. I can think of no reason to do so, unless the specific property was federally owned. A-110 ___.30 allows use of the institution's own property management standards (e.g., what is tracked and what is not) so long as ___.31 through ___.37 are observed. Equipment is subject to ___.33. The definition is at ___.2. (l)., >$5000 and life > 1 year, unless institution has lower standard. Property management is required for "equipment", at ___.33.f.; it is not required for property of a lower standard. ___.35 refers to "supplies and other expendable property" and specifies that title vests in grantee; "supplies" are defined at ___.2. (HH) as "all personal property excluding equipment...", and there is no property management required. ___.2 (n) states: "Exempt property means tangible personal property acquired in whole or in part with Federal funds, where the Federal awarding agency has statutory authority to vest title in the recipient without further obligation to the Federal Government. An example of exempt property authority is contained in the Federal Grant and Cooperative Agreement Act (31 U.S.C. 6306), for property acquired under an award to conduct basic or applied research by a non-profit institution of higher education or non-profit organization whose principal purpose is conducting scientific research." Exempt property vests in the recipient. >That said, in reading a-110 & 28CFR70.33 (this is a DOJ grant) I find the >following, which I thought only related to federally provided property: > >A-110 Subpart C .33 a 1 states "Title to federally-owned property remains >vested in the Federal Government. Recipients shall submit annually an >inventory listing of federally-owned property in their custody to the >Federal awarding agency." > >28CFR70.33 says nearly the same thing. Federally owned property IS NOT property bought with grant funds. You need to track it. But you did not indicate that this was federally owned property. I cannot see any reason for requiring tracking the supplies and expendable property that the auditor was requesting. I believe that they have reached too far. Are they experienced auditors that understand A-133 standards? Do they understand A-110, and that it applies on the basis of the type of organization the grantee is? Or do you have a grant with really unusual (i.e., non a-110 compliant) standards? Sorry for the long-winded background; you sound like you know your way around A-110, but it does take all the bricks to make the wall! If there is some justifiable reason for this audit requirement, which seems on the surface completely erroneous, will you share it with the list? >Does this apply to federally funded property? > >Have you ever been required to perform such an inventory? > >Can you cite any sources either way (for or against inventorying such >property)? > >Linda Ward >Sr. Accountant >Research Administration 35-123A >Children's Hospitals and Clinics >2910 Centre Pointe Dr. >Roseville, MN 55113 >651-855-2603 >651-855-2690 Fax >email: xxxxxx@childrenshc.org >__________________________________ > >Confidentiality Statement: >This email/fax, including attachments, may include confidential and/or >proprietary information and may be used only by the person or entity to >which it is addressed. If the reader of this email/fax is not the intended >recipient or his or her agent, the reader is hereby notified that any >dissemination, distribution or copying of this email/fax is prohibited. If >you have received this email/fax in error, please notify the sender by >replying to this message and deleting this email or destroying this >facsimile immediately. > > >====================================================================== > Instructions on how to use the RESADM-L Mailing List, including > subscription information and a web-searchable archive, are available > via our web site at http://www.hrinet.org (click on "Listserv Lists") >====================================================================== Herbert B. Chermside, CRA Virginia Commonwealth University PO BOX 980568 Richmond, VA 23298-0568 Voice: 804-827-6036 Fax 804-828-2051 e-mail xxxxxx@vcu.edu ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
