Issuance No: A18
Issuance Date: August 7, 2007; Revised 3/29/11; 12/6/16
Subject: Inventory Policy
Property means real property or personal property. Uniform Guidance 2 CFR 200.78, 2 CFR 200.85 and 2 CFR 200.311 shall be referred to for guidance on property.
Equipment, as defined in 2 CFR 200.33, consist of “tangible personal property (including information technology systems) having a useful life of more than one year and a per unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000.” In other words, equipment with per-unit fair market value of less than $5,000 shall not qualify as equipment under this definition.
Supplies, as defined at 2 CFR 200.94, consist of “all tangible personal property other than equipment.” Thus, all tangible personal property acquired with a per-unit fair market value of less than $5,000 shall be considered supplies.
The Northwest WDB will maintain a listing of all property defined as equipment as well as maintain a record of tangible supplies with a per-unit acquisition cost of $500. This is in keeping with the college’s policy on inventory which is identified in Section #6.5.00 of the NCMC Board Policy Manual.
All inventoried purchases will be tagged with a label and maintained on a listing to include: description of the item, manufacturer, serial number (if applicable), unit acquisition cost, acquisition date, location, funding source, condition at last inspection, title/ownership by percent and sale price if sold.
A physical inspection of inventoried items will be completed on an annual basis in conjunction with monitoring visits and reconciled with WDB records. During the course of the physical inspection, any property that cannot be accounted for will become the responsibility of the last custodian, based upon the location of the item(s) from the prior year inspection. If the missing property is valued at less than $100 or has exceeded its estimated life, no financial recovery will be implemented. However, the WDB may establish additional reporting expectations for the custodial vendor/subcontractor to reduce the likelihood of future loss. If the missing property is valued at $100 or more and still has an expected useful life, the custodial vendor will be asked to reimburse the value of the lost property to the Northwest Workforce Development Board.
Ownership and Authorization to Purchase:
Any equipment or tangible supplies purchased with an acquisition cost of $500 or more will become the responsibility and ownership of the NW WDB. Purchases of equipment or supplies with an acquisition cost of $500 or more by a subcontractor must be approved in advance by the WDB Director while equipment or supply purchases of $5,000 or more must have prior approval from DWD.
Equipment and inventoried supplies no longer being used will be included on a listing of surplus property to be reviewed and approved by the Board. A fair market value will be established by an independent third party. Disposition will be handled in the following manner:
- Individual items valued at $100 or less will be recycled, given away or tossed.
- Individual items with a value over $100 will be sold through public auction or disposed of by receipt of sealed bids.
In determining a method for disposition, priority will be given to cost-effectiveness, protection of confidential information, and conservation of natural resources.
The WDB will request prior approval from DWD to dispose of any “equipment” or “supplies” worth $5,000 or more.
Equipment and supplies must be utilized for the program or project for which the equipment/supplies were acquired as long as needed, whether or not the project or program continues to be supported by the WDB/DWD. Prior approval from the WDB/DWD must be obtained before any other program can encumber the property.
Uniform Guidance at 2 CFR 200.314(a) states, “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.” Equipment or supplies with a per unit fair market value of less than $5,000 may be retained, sold or otherwise disposed of with no obligation to the federal awarding agency.
While proceeds from the sale of equipment are not program income, they shall be reported to DWD in a manner similar to that of program income which will be used offset future equipment or program services.
The WDB shall ensure that DWD has a right to an amount of the proceeds in proportion to DWD’s share (percentage of participation) in the cost of the original equipment.