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4.9 Property Management Standards


Chapter 4.9.1 Resources

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Chapter 4.9.2 Resources

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Chapter 4.9.3 Resources

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Chapter 4.9.4 Resources

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4.9.1 Background

Effective date: TBD

This policy outlines procedures governing the acquisition, management, and disposition of property procured in whole or in part under all reimbursement contracts with federal funds administered by DWD-DET.

4.9.2 Equipment

Effective date: TBD

Equipment is tangible personal property (including information technology systems) that has a useful life of more than one year and a per unit acquisition cost that equals or exceeds $5,000.1

Supplies are tangible personal property other than those described in the definition of equipment above having a per unit acquisition cost less than $5,000.2

  1. Use
    Equipment acquired under a grant agreement must be used for its originally authorized purpose until funding ceases or it's no longer needed for the project. Equipment may be retained as long as needed for the program, regardless of whether the program continues to be supported by the federal award. Equipment no longer needed for its originally authorize purpose may be used in the following order or priority: for other DOL funded activities or other federally funded activities.3

    The recipient must make equipment available for use on currently or previously federally funded program if such use does not interfere with the program for which it was originally acquired. First preference should be given for other DOL funded activities, followed by other federally funded activities. While using the equipment for non-federally funded projects is allowable, user fees should be considered, as appropriate.4 However, equipment acquired with grant funds must not be used to provide such services to unfairly compete with private companies providing equivalent services.5

    When acquiring replacement equipment, the equipment to be replaced may be used as a trade-in or may be sold. If sold, the proceeds should be used to offset the cost of the replacement equipment.6
  2. Property Management
    Each recipient must establish procedures to adequately safeguard all equipment. Recipients must meet the following requirements for all DWD-DET purchased equipment:7
    1. Equipment records or register that reflect:
      • Description of equipment;
      • Serial number or other identification number;
      • Funding source, including the Federal Award Identification Number(FAIN);
      • Titleholder;
      • Acquisition cost and date;
      • Percentage of federal participation in the purchase;
      • Current use, condition, and location;
      • Any ultimate disposition data, such as the date of disposal and sale price.
    2. A physical inventory of equipment must be taken at least once every two years, with the results reconciled to the equipment records.
    3. Equipment should be maintained in good, working order.
    4. Insurance for equipment purchased or improved with federal funds is required. Such costs are chargeable to the grant.
  3. Disposition
    Disposition is the act of selling or otherwise disposing of equipment. When original or replacement equipment is no longer needed for the original program or for other activities currently or previously supported by DWD-DET, equipment disposition instructions must be requested from DWD-DET if required by the terms and conditions of the federal award. Otherwise, equipment disposition will be made as follows:8
    1. Equipment with a current per unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further responsibility to DWD-DET.9
    2. Equipment with a current per unit fair market value more than $5,000 requires DWD-DET approval for disposition. This includes both equipment purchased with DWD-DET funds or equipment transferred from other programs. This requirement applies to such equipment whenever the recipient discontinues operation of a DWD-DET program, has no further use for the equipment, intends to use it for a purpose other than a DWD-DET program, wants to trade the equipment, or needs to dispose of unusable equipment. Before any such equipment is disposed of, the recipient must comply with the following requirements:
      1. Ensure all relevant records are up to date.
      2. Submit the following information in writing to the appropriate DWD-DET program manager for all equipment to be disposed of:
        1. Description
        2. Acquisition source
        3. Per unit acquisition cost
        4. Quantity
        5. Condition
        6. Funding source under which equipment was acquired
        7. Reason for the disposition
        8. Proposed disposition, including what will be done with any money resulting from the disposition.
      3. Written authorization from DWD-DET must be obtained.
      4. The sale of equipment that is no longer needed shall be an action of last resort. Before a sale is made, the recipient shall take the following steps, listed in order of priority ranking:
        1. Transfer the equipment to other DWD-DET funded programs of the recipient.
        2. Transfer the equipment to similar DWD-DET funded programs of other recipients within the state. In transferring equipment to similar programs, equipment should first be offered to other Workforce Development Boards (WDB), then to non-WDB grantees within the Workforce Development Area (WDA). Any departures from this order must be justified in writing.
        3. If no such program is found, the equipment may be sold.
      5. For equipment that cost $5,000 or more that was only partly purchased using DWD-DET funds, the disposition standards outlined above will apply. The amount of reimbursement to DWD-DET shall be computed by applying the sales proceeds with the percentage of DWD-DET funding in the original cost.
    3. Any proceeds received from the sale of DWD-DET funded equipment are considered program income and shall be subject to requirements of program income in §4.6 of this chapter.
    4. The disposition of all DWD-DET equipment and equipment transferred from other programs must be fully documented.

4.9.3 Real Property

Effective date: TBD

Real property is defined as a parcel of land and everything that is permanently attached to the land, including land improvements, structures, and additions such as a driveway or fence.1 Recipients and subrecipients are not allowed to purchase real property for grant purposes, unless specifically authorized by that funding source. The following provisions shall apply:

  1. Recipients must obtain written approval from DWD-DET and DOL prior to purchasing real property.
  2. Title to real property shall vest in the recipient.
  3. Recipients must provide DWD-DET with the location of the real property and the federal share of the acquisition cost.
  4. Allowable costs relating to real property must be in accordance with limitations in current federal standards.
  5. Disposition of real property shall follow written instructions of DWD-DET.

4.9.4 Intangible Property

Effective date: TBD

Intangible property is any type of property that represents something of value but is not physical in nature. Examples of intangible property include trademarks, copyrights, patents, investments and ownership interests, goodwill, and life insurance contracts.1 The following provisions shall apply:

  1. Title to real property shall vest in the recipient.
  2. Disposition occurs in the same manner as for equipment purchased with WIOA funds. See subsection 4.9.2(C) in this chapter.

The recipient may copyright any work that is subject to copyright that was developed, or for which ownership was acquired, under a federal award. However, DWD-DET and DOL reserve a royalty free, permanent right to reproduce, publish, or otherwise use the work, and to authorize others to do the same.


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