Funny you should bring this up--I was just about to bring the subject up.

We manage grants and contracts for the New York State Department of Health
and we are one of those "others" that retains title  (please wait to
commence the stoning --I'm actually on your side!)

We are coming from a very different perspective in that much of the funding
we administer is for community based demonstration projects (AIDS outreach,
Maternal and Child Health education initiatives, etc.).  As such, we deal
with many small community based organizations--many of whom were/are new
to receiving federal grant funding.  I believe that this is part of the
reason we decide to retain title (the decision pre-dates my arrival here)
We were unsure as to whether they
had the administrative ability to track equipment and more importantly
we concerned that if they ended up "defaulting" (i.e. unable to perform)
we would be in a better position to recoup the equipment.

So, for ease of administration our boilerplate contract has us retaining
equipment title with the contractor having the right to request transfer to
them at the end of the contract (a request that we would rarely refuse).

Suprisingly, even with our subcontractors under "traditional" NIH
grants and the like, few have questioned our retaining title.  For those
that do, we will change the clause--it is very clear that PHS and
NSF allow, and even encourage, pass through of title to subrecipients.
We ALWAYS try to get it on subcontracts we receive from other organizations.
(I guess that makes us REEEEELY obnoxious in light of our boilerplate!)

With the advent of A-133, most of our subcontractors, even the smaller
community based organizations, have passed audit under A-133 and we are
more confident in their abilities--both programmatic and administrative.
We are considering going to a standard whereby we pass title to
subrecipients--as in my view, this then puts the job of tracking
on the sub.  In my view, Michelle, I can't imagine why anyone would
"want" title to subrecipients equipment --my reading of A-110 is that
if you hold title, you have to track and inventory, etc.  Its difficult
enough to track our own stuff!

* Elizabeth (Liz) Mazzella             xxxxxx@ALBNYDH2.BITNET  *
* Asst. Dir. Technology Transfer & Sponsored Pgms.            *
* Health Research, Inc. (A Non-Profit Corp.) Albany NY 12209  *
* Voice: (518) 431-1200                    Fax: (518)431-1234 *