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
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