Training Module III Property and Travel Office of Contract and Grants The University of Colorado at Boulder April 2, 2009 TODAY’S TOPICS • TRAVEL: • Presentation by Christian Scott, Travel Resource Coordinator, Travel Office • Travel Authorization – Ted Jobe, Travel Officer, OCG – Fly America Act & Open Skies Agreement • PROPERTY: • Sponsored Project Property – Ted Jobe, Government Property Manager, OCG • ABS Property Accounting – Greg Roers, Central Operations Manager Travel Office Topics • Traveling on fund 30’s • New mileage rate • TV’s on hold • Account Codes • Major problems on TV’s • Q&A Travel Authorizations • OCG screens Travel Authorizations (TAs) daily • Use FileMaker, PeopleSoft & Original Award – Is travel specifically related to the project? – Is the travel within the period of performance? – Are there funds to cover the travel? – Is the Authorizer different than the traveler? – Is Sponsor prior approval required? – Adequate Justification Required. (Attachment A) Travel Justification (Attachment A) • Provide Detailed Information on TA: – Purpose of travel. – How expenses benefit the project. – Specify subject title of Papers. – Specify Lecture Content. • Identify conferences and meeting by name. • No acronyms – use complete names. Fly America Act (Attachment B) • Applies to U.S. Government funded travel. • Use U.S. Flag Air Carrier Service. • Code-share agreement allows foreign carrier. • Exceptions: no U.S. carrier available; travel delay of 6 or more hours, 2 or more aircraft changes on the route, medical need. • Exception: Approved Bilateral or Multilateral Air Transportation Agreements. – Open Skies (EU), Australia, Switzerland Open Skies Agreement (Attachment B) • Travel via any EU member state air carrier allowed. • Travel Agreements with Australia and Switzerland basically the same as with the EU. • Travel: – U.S. city to any member state city. – Between any two points outside the U.S. Exceptions to Open Skies (Attachment B) • Fly America Act takes precedence: – City-pair contract exists. • U.S. Government • State of Colorado – DoD sponsored travel. OPAS Form (Attachments D & E) • When the travel budget has insufficient funds for the requested travel, and we have Expanded Authority, OCG can approve a budget deviation via an OPAS form. • Must justify the need for the travel, specify which budget categories funds are coming from to cover the travel and why they are no longer needed in that budget category. • If there is a change in scope, we will need to obtain prior approval from the sponsor. Travel that Requires Prior Approval • Check FileMaker for travel notes. • Check the terms and conditions of the agreement for prior approval requirements. – Federal contracts and foundations often have prior approval requirements for foreign travel. • Be sure to send OCG a copy of the approval before the TA is submitted. – If you need assistance with submitting your request, we can help facilitate the process. Travel Authorization on HOLD • When OCG puts a Travel Authorization on hold, travel is not delayed, the reimbursement of costs is delayed. • You are notified when an authorization is put on hold and when the hold is lifted. • Some holds require an OPAS submittal. – When submitting an OPAS please note in email subject line what TA is on hold. Property Objectives • New personnel Government Property training. • Review Government Property in: – Property Responsibilities – Government Regulations – Title to Property – Bar Coding Pilot Project – Government Fabrication Policy – Acquisitions – Maintenance – Inventory – Disposal • Discuss problems and solutions in property management – Q & A Entities Dealing with Property • Office of Contracts and Grants (OCG) • ABS Property Accounting Office • Property Services • Procurement Service Center • Principal Investigators • Department Property Manager • Department Administrators Office of Contracts and Grants • Overall administration of Government property. • Tagging Government property – LASP Pilot Project Bar coding. • Approves all equipment purchases on contract/grants. • Sponsoring agency approval. • Government property inventory reports – annual & close out. • Notify PAO of Gov’t equipment transfers to and from CU. • Approves Sponsored Proj. Equip. Disposal Requests. • Approves OPAS and CAS request forms. • Government property inventory audits. • Creates and manages OCG Government Property Manual. • Knowledge of contract and grant property terms & conditions. Property Accounting Office • Maintains inventory records database (PAS). • Tags university-owned equipment (CU tags). • Inventories department equipment. • Reports from PAS inventory records. • Property Disposition. • Property Transfers. • Maintains all Government and CU property records on the CU Campus. Property Services • Property disposals – pick up. • Approve cannibalization or trade-in of old equipment. • Donations to nonprofit organizations. • Selling equipment to off-campus buyer. • Approves equipment transfers to universities. Procurement Service Center • Makes equipment procurements approved by OCG. • Verifies Sole Source Suppliers. – Current requirement set at $4,500 and more per item. Principal Investigator • Initiates equipment purchase requests. • Responsible for proper use, maintenance and security of assigned property. • Notifies OCG of shortage, damage loss or theft of Government property. Department Property Manager or Designated Personnel • Custodians of Government-owned property in his or her department. • Coordinates with OCG Property Officer on inventories and audits. • Works with OCG Property Officer to retag Government Property to CU tagged. Department Administrators • Handle property Purchase Requests (PRs), OPAS and CAS submittals to OCG. • Submit JE’s for property account code changes. REGULATIONS – Source of Federal Guidelines • OMB Circular A-21: Cost Principals for Educational Institutions. Defines “Allowable Costs” – What are allowable as direct costs on contract and grants. • General requirements for allowable costs – Reasonable: prudent person principal. – Allocable: Benefits the particular project. – Consistent: Treated consistently as direct or indirect cost. REGULATIONS – Source of Federal Guidelines • OMB Circular A-110: Defines requirements for adequate management systems on grants. – Purchasing Systems. – Property Control Systems. – Accounting and Financial Control Systems. • FAR – Federal Acquisition Regulations on Federal contracts. – DFAR, NFS, DEAR. – FAR PART 45 – Government Property (June 2007). FAR 52.245-1 ALT II (June 2007) • Required for Educational Institutions. Contracts only. • Title to property <$5,000 vests with CU with Contracting Officers Approval (not Technical Officer). – DD1419 – Sponsor screening sometimes required. – Some sponsors consider inclusion in the approved budget as sponsor approval – no screening necessary. • Title to property $5,000 or more must be defined in the contract. This requirement is sometimes not met requiring a contract modification. Types of Property • Government Property – All property owned or leased by the Federal Government. – Government-Furnished Property (GFP). • Any value. – Contractor-Acquired Government Property. • Purchased by University titled to Government. – $5,000 or more (verify in contract terms) – All Government Property is tagged with a Government tag by OCG. Types of Property • CU-Owned Property – Mostly capital equipment and non-capital departments wish to control. • CU-Owned Property is tagged with an orange tag. • Managed by PAO. Types of Capital Property $5k and Over • Equipment - tangible asset that is functionally complete for its intended purpose, durable, and nonexpendable. Equipment does not ordinarily lose its identity or become a component part of another article when put into use. It has a useful life of one year and an acquisition cost of $5,000. • Use account codes 810100: CU-owned; 810200: Gov’t-owned Types of Capital Equipment (Attachments J, H) • Fabrication is the transformation of material, supplies, and hardware into a one-of-a-kind item of equipment that meets unique research or testing requirements. – One-of-a-kind item, fabricated at CU. – Meets unique research specifications. – Aggregated cost $5,000 or more. – Useful life of 1 year, 2 years for NASA. – Will not be affixed permanently to a building or structure. • Use account codes 810700: CU-owned; 810800 Gov’t-owned. CU Fabrication Process (Attachment H & I) • PI informs Susan Wyn in PAO about new fabrication. • PI completes and returns a Fabrication Tag Request Form (Attachment I) to Susan. • PI notifies Jeanne Connely in PAO when the fabrication is complete – usually at time of first use. – CU tags are sent out by Jeanne; Gov’t tags are placed in the department by Ted Jobe in OCG. • Changes to fabrications after fabrication completed require a new tag (new type of tag – a child tag – associated with the main fabrication w/same capitalization requirements. Government Contract Fabrications (Attachment J) • Included in the OCG Government Property Manual. – Required by 2008 Government Property Audit. – Applicable to some Government contracts starting April 1, 2009. • CU must capture cost of materials, components, and labor at completion of fabrications for first use. – Both for deliverables (fabrications sent into space) and fabrications staying at CU. Government Contract Fabrications (continued) • CU won’t capitalize labor and travel cost. • Labor and travel cost information are collected and available for sponsor reporting and property management records only. • Affected departments will provide OCG monthly with an total cost report – both direct costs and labor and travel costs included. Title to Property • Grants – CU has title unless Government Furnished. • Contracts – Read contract terms. – Under $5,000 and contracting officer’s advanced approval – title vests in CU. – $5,000 or over – defined in contract. Possibilities: • CU Titled – Unconditional title (no further Government involvement.) • CU Titled – Conditional title. Government has right to claim equipment at contract close out. • Government Titled Before Acquisition • Department is responsible for project cost. • PI authorizes expenses. • Know whether funds exist in the budget for equipment. • If not – submit an OPAS or CAS form before doing a Property Purchase Request (PR). • Obtain required sponsor approvals. – Contracting or Grants Officer approval. – DD1419s or email approval. OPAS Form (Attachments D & E) • Organizational Prior Approval System • Federal Government grants CU the right to act in its place in determining movement of direct cost within the project. • Unbudgeted items $5,000 or more – sent by PI, signed by dept. chair or Institute Director. • Six criteria. • Grants only. • Property or Travel OPAS to Ted Jobe. Other direct cost movements or continued spending contact Contract & Grant Administrator on award. CAS Form (Attachment F & G) • Requests exception to Cost Accounting Standards (A-21). Make what is usually an indirect cost (paid by department) into a direct cost (paid by the project). • Page 2, Section II – General Purpose Box – Fill in all three parts. – Six criteria. • CAS Requirements Checklist (Attachment G) General Purpose Equipment Defined in OMB A-21 • General Purpose Equipment is equipment not limited to research, medical, scientific or other technical activities. – Computers – Office equipment – IT equipment and systems • A-21 disallows General Purpose Equipment as a direct cost to a project unless Sponsor approved. – In approved budget – CAS submitted and approved by OCG Acquisition • Government-owned property may be purchased or sent by the agency. • Property Purchase Requisitions are approved in PeopleSoft by OCG. – Insufficient funds – OPAS – Not in approved budget – CAS • Agency approval sometimes needed – rebudgeting, unbudgeted equip. over $5,000. – Agency approval negates need for OPAS or CAS. • Check FileMaker for property budget notes. Acquisition (Attachment K) • Contract may require DD1419 Form. • Equipment $10,001 - $24,999 – Dept. screens it’s inventory before submitting a PR. • Equipment over $25,000 internal screen of CU inventory or sole-source. • New Rule (2009) requires departments provide sole- source justification to the Procurement Service Center for property items $4,500 and over. OCG Procedures for Approving Equipment Purchase Requisitions • Adequate description. • Review budget if funds exist in equip. category. • Review budget if funds exist in overall budget. • Determine if equip. is in approved budget. • Determine if OPAS approval is needed. • Determine if CAS approval is needed. • Determine if agency approval in needed. • Approve PR or HOLD for needed actions. Account Codes OCG Approves (Attachment L) • 500800 – Computers bundled, less than $5,000 • 501900 – IT equip. less than $5,000. • 500200 – IT equip. less $5,000 (never used). • 537600 – Non-IT equip. less than $5,000. • 537601 - Non-IT equip. less than $5,000. • 537602 - Non-IT equip. less $5,000 (never used) • 810100 – Fixed Asset, $5,000 or more • 810200 - Fixed Asset, $5,000 or more, Gov’t tag • 810700 – Fabrication, $5,000 or more • 810800 - Fabrication, $5,000 or more, Gov’t tag. Maintenance • Capital equipment or Government-owned entered into PAS and monitored. • Government tags issued by OCG. • Unable to tag - keep in a log book. • Fund 30 equipment in PAS require OCG approval for disposal or transfer. • JEs to move sponsored project costs are reviewed and approved by OCG. • Off-campus forms to PAO or OCG. On-site Inventory • OCG conducts a physical inventory for Government Property at least every two years. • PAO conducts a physical inventory for CU property every two years. Disposals & Transfers (Attachments M & N) • Government Property can’t be disposed of without agency approval. – OCG requests abandon-in-place from Sponsor. – Metal tags changed to CU tags before disposal. • OCG approves disposal/transfers of fund 30 equip. • OCG disposal form sent to Ted Jobe. Property Services disposal form sent to Jack Brubaker. • Approved OCG disposal form sent to PAO, Property Services and the requesting department. • PAO sends letter to University receiving transfer.