Contents
Policy Statement
Reason for Policy/Purpose
Applies To
Roles and Responsibilities
Procedure
Contacts
Definitions
Who Approved this Policy
History / Revisions
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RESEARCH EQUIPMENT MANAGEMENT POLICY
Policy Statement
Partners HealthCare (Partners) is responsible for the proper procurement, use, tracking,
cataloging, storage and disposition of all equipment purchases acquired under federal and nonfederal sponsored projects. In addition, this oversight must adhere to any and all regulations or
mandates as determined by the sponsoring institution and indicated in the executed agreement.
Partners will follow federal guidelines that require uniform standards governing the management
of property furnished by the federal government or purchased on a federal grant or other
agreement. Federal guidelines require that Partners maintain accurate property records and
conduct a physical inventory, as well as properly tag and catalogue all equipment.
Reason for Policy/Purpose
All equipment whose unit cost is $5,000 or more with a minimum useful life of two years is
considered capital equipment in accordance with Federal regulations. The equipment cost
includes the cost of the item, less any applicable discounts, plus any delivery charges and cost
of installation. The cost also includes any modifications, attachments, or accessories that are
acquired with the item and are necessary to make the item usable for its intended use.
In addition, some Partners affiliated institutions will maintain an inventory of equipment with a
cost of $1,500 to $4,999.99 and a useful life of greater than one year for the purposes of
facilities management, relocations, or otherwise. Please contact the Research Space
Management Group at your institution for additional information concerning the threshold for
research equipment and additional questions concerning this policy.
Occasionally equipment must be fabricated on-site to suit the unique needs of the research
project. Fabricated equipment consists of tangible personal property, physically constructed by
a Partners employee/department, which has a total acquisition cost of $5,000 or more, is freestanding, does not lose its identity when affixed to or installed in other property, and has a
useful life of at least two years. When fabrication is complete, the acquisition value consists of
the direct costs of employee time, services purchased from outside vendors and the costs of the
component parts purchased. Parts alone are not considered fabricated equipment. Typically,
these types of costs are incurred within the institution’s research area.
The overall management of equipment for use and in support of sponsored projects must be
consistent with the purpose and goals of the project while also conforming to institutional,
federal and non-federal guidance. Additionally, these standards require that the acquisition of
equipment meet certain threshold limits and be screened against an up-to-date inventory record
that provides for the shared use of equipment and lowers the risk of unnecessary purchases.
This policy describes how property management and the shared use of equipment should be
handled according to the following guidelines.
45 CFR PART 74—UNIFORM ADMINISTRATIVE REQUIREMENTS FOR AWARDS AND
SUBAWARDS TO INSTITUTIONS OF HIGHER EDUCATION, HOSPITALS, OTHER
NONPROFIT ORGANIZATIONS, AND COMMERCIAL ORGANIZATIONS; AND CERTAIN
GRANTS AND AGREEMENTS WITH STATES, LOCAL GOVERNMENTS AND INDIAN
TRIBAL GOVERNMENTS
Property Standards
§74.30 Purpose of property standards
Sections 74.31 through 74.37 set forth uniform standards governing management and
disposition of property furnished by HHS or whose cost was charged directly to a project
supported by an HHS award. The HHS awarding agency may not impose additional
requirements, unless specifically required to do so by Federal statute. The recipient may use its
own property management standards and procedures provided they meet the provisions of
§§74.31 through 74.37.
§74.34 Equipment
(a) Title to equipment acquired by a recipient with HHS funds shall vest in the recipient, subject
to the conditions of this section.
(b)(1) The recipient shall not use equipment acquired with HHS funds to provide services to
non-Federal organizations for a fee that is less than private companies charge for equivalent
services, unless specifically authorized by Federal statute, for so long as the Federal
Government retains an interest in the equipment.
(2) If the equipment is owned by the Federal Government, use on other activities not
sponsored by the Federal Government shall be permissible if authorized by the HHS awarding
agency.
(3) User charges shall be treated as program income, in keeping with the provisions of §74.24.
(c) The recipient shall use the equipment in the project or program for which it was acquired as
long as needed, whether or not the project or program continues to be supported by Federal
funds and shall not encumber the property without approval of the HHS awarding agency. When
no longer needed for the original project or program, the recipient shall use the equipment in
connection with its other federally-sponsored activities, if any, in the following order of priority:
(1) Programs, projects, or activities sponsored by the HHS awarding agency;
(2) Programs, projects, or activities sponsored by other HHS awarding agencies; then
(3) Programs, project, or activities sponsored by other Federal agencies.
(d) During the time that equipment is used on the program, project, or activity for which it was
acquired, the recipient shall make it available for use on other projects or programs if such other
Partners HealthCare Research Equipment Management Policy, 2
use will not interfere with the work on the program, project, or activity for which the equipment
was originally acquired. First preference for such other use shall be given to other programs,
projects, or activities sponsored by the HHS awarding agency. Second preference shall be
given to programs, projects, or activities sponsored by other HHS awarding agencies. Third
preference shall be given to programs, projects, or activities sponsored by other Federal
agencies.
(e) When acquiring replacement equipment, the recipient may use the equipment to be replaced
as trade-in or sell the equipment and use the proceeds to offset the costs of the replacement
equipment subject to the approval of the HHS awarding agency.
(f) The recipient's property management standards for equipment acquired with Federal funds
and federally-owned equipment shall include all of the following:
(1) Equipment records shall be maintained accurately and shall include the following
information:
(i) A description of the equipment;
(ii) Manufacturer's serial number, model number, Federal stock number, national stock
number, or other identification number;
(iii) Source of the equipment, including the award number;
(iv) Whether title vests in the recipient or the Federal Government;
(v) Acquisition date (or date received, if the equipment was furnished by the Federal
Government) and cost;
(vi) Information from which one can calculate the percentage of HHS's share in the cost of the
equipment (not applicable to equipment furnished by the Federal Government);
(vii) Location and condition of the equipment and the date the information was reported;
(viii) Unit acquisition cost; and
(ix) Ultimate disposition data, including date of disposal and sales price or the method used to
determine current fair market value where a recipient compensates the HHS awarding agency
for its share.
(2) Equipment owned by the Federal Government shall be identified to indicate Federal
ownership.
(3) The recipient shall take a physical inventory of equipment and the results reconciled with
the equipment records at least once every two years. Any differences between quantities
determined by the physical inspection and those shown in the accounting records shall be
investigated to determine the causes of the difference. The recipient shall, in connection with
the inventory, verify the existence, current utilization, and continued need for the equipment.
(4) Recipient shall maintain a control system to insure adequate safeguards to prevent loss,
damage, or theft of the equipment. Any loss, damage, or theft of equipment shall be
investigated and fully documented; if the equipment was owned by the Federal Government, the
recipient shall promptly notify the HHS awarding agency.
(5) The recipient shall implement adequate maintenance procedures to keep the equipment in
good condition.
(6) Where the recipient is authorized or required to sell the equipment, proper sales
procedures shall be established which provide for competition to the extent practicable and
result in the highest possible return.
(g) When the recipient no longer needs the equipment, it may use the equipment for other
activities in accordance with the following standards. For equipment with a current per unit fair
market value of $5000 or more, the recipient may retain the equipment for other uses provided
that compensation is made to the original HHS awarding agency or its successor. The amount
of compensation shall be computed by applying the percentage of HHS's share in the cost of
the original project or program to the current fair market value of the equipment. If the recipient
has no need for the equipment, the recipient shall request disposition instructions from the HHS
Partners HealthCare Research Equipment Management Policy, 3
awarding agency; such instructions must be issued to the recipient no later than 120 calendar
days after the recipient's request and the following procedures shall govern:
(1) If so instructed or if disposition instructions are not issued within 120 calendar days after
the recipient's request, the recipient shall sell the equipment and reimburse the HHS awarding
agency an amount computed by applying to the sales proceeds the percentage of HHS share in
the cost of the original project or program. However, the recipient shall be permitted to deduct
and retain from the HHS share $500 or ten percent of the proceeds, whichever is less, for the
recipient's selling and handling expenses.
(2) If the recipient is instructed to ship the equipment elsewhere, the recipient shall be
reimbursed by the HHS awarding agency by an amount which is computed by applying the
percentage of the recipient's share in the cost of the original project or program to the current
fair market value of the equipment, plus any reasonable shipping or interim storage costs
incurred.
(3) If the recipient is instructed to otherwise dispose of the equipment, the recipient will be
reimbursed by the HHS awarding agency for such costs incurred in its disposition.
(4) If the recipient's project or program for which or under which the equipment was acquired is
still receiving support from the same HHS program, and if the HHS awarding agency approves,
the net amount due may be used for allowable costs of that project or program. Otherwise the
net amount must be remitted to the HHS awarding agency by check.
(h) The HHS awarding agency reserves the right to order the transfer of title to the Federal
Government or to a third party named by the awarding agency when such third party is
otherwise eligible under existing statutes. Such transfer shall be subject to the following
standards:
(1) The equipment shall be appropriately identified in the award or otherwise made known to
the recipient in writing.
(2) The HHS awarding agency may require submission of a final inventory that lists all
equipment acquired with HHS funds and federally-owned equipment.
(3) If the HHS awarding agency fails to issue disposition instructions within 120 calendar days
after receipt of the inventory, the recipient shall apply the standards of paragraph (g)(1) of this
section as appropriate.
(4) When the HHS awarding agency exercises its right to order the transfer of title to the
federal Government, the equipment shall be subject to the rules for federally-owned equipment.
(See §74.34(g)).
[59 FR 43760, Aug. 25, 1994, as amended at 61 FR 11747, Mar. 22, 1996]
FEDERAL ACQUISITION REGULATIONS (FAR) - Part 45
This part prescribes policies and procedures for providing Government property to contractors,
contractors’ use and management of Government property, and reporting, redistributing, and
disposing of contractor inventory. It does not apply to providing property under any statutory
leasing authority, except as to non-Government use of plant equipment under 45.407; to
property to which the Government has acquired a lien or title solely because of partial, advance,
or progress payments; or to disposal of real property
Subpart 45.5 - Management of Government Property in the Possession of Contractors
This subpart prescribes the minimum requirements contractors must meet in establishing and
maintaining control over Government property. It applies to contractors organized for profit and,
except as otherwise noted, to non-profit organizations. In order for the special requirements in
this subpart governing nonprofit organizations to apply, the contract must identify the contractor
as a nonprofit organization. If there is any inconsistency between this subpart and the terms of
Partners HealthCare Research Equipment Management Policy, 4
the contract under which the Government property is provided, the terms of the contract shall
govern.
Subpart 45.6 - Reporting, Reutilization, and Disposal
This subpart establishes policies and procedures for the reporting, reutilization, and disposal of
Government property excess to contracts and of property that forms the basis of a claim against
the Government (e.g., termination inventory under fixed-price contracts). This subpart does not
apply to the disposal of real property or to property for which the Government has a lien or title
solely as a result of advance or progress payments that have been liquidated.
Note: To the extent that there is inconsistency between Partners Policy, federal
guidance (FAR, OMB, CFR, etc.) and the terms and conditions of the award under
which the equipment was purchased, the more restrictive terms and conditions
shall govern.
For further information, please see the Policies and Procedures for the Management, Control
and Disposition of Research Capital Equipment, revised 08/24/2006.
Applies To
All Partners HealthCare Entities, Employees and Agents (“Partners HealthCare”) who are
involved with the performance, oversight, or administration of sponsored projects.
Roles and Responsibilities
Research space management group (RSMG) is responsible for the oversight and tracking of
equipment purchased with sponsored and non-sponsored funds within Partners.
Its
responsibilities include:
Work with PI and department to tag and catalog research capital equipment
Trace equipment received via a PI new to Partners from an outside institution
Maintain the RSMG Research Equipment Inventory database and update records to
reflect changes in location of research equipment; periodically conduct statistical audits
to validate equipment-specific records maintained in the Research Asset Inventory
database
Conduct a physical inventory of equipment associated with federal projects every two
years
Principal Investigator (PI) has responsibilities that include:
Identify the need for research equipment, determine if such equipment is available, and
(if appropriate) initiate the purchase of new equipment
Maintain physical control of all equipment acquired under an award and safeguard it
against loss, damage, or unauthorized use
Make sure that equipment under their jurisdiction is properly maintained and kept in the
assigned locations indicated on the inventory record
Partners HealthCare Research Equipment Management Policy, 5
Report to RSMG any relocation of research equipment for which they are responsible
prior to its relocation
Inform RSMG of any loss or damage of equipment
Coordinate disposition and disposal activities with RSMG
Coordinate the loan of equipment purchased with contract and grant funds to
organizations or institutions participating jointly in a sponsored project (when necessary
or applicable)
Advise subcontractors of their responsibility to comply with Partners HealthCare’s
Research Capital equipment management policies and procedures where applicable
and receive reports in all instances of loss, damage, or destruction of equipment in
subcontractor’s possession or control; submit copies of these reports to RSMG
Department administration has equipment responsibilities that include:
Assist the PI/Partners in conducting a physical inventory of all equipment and checking
that it is accounted for and properly maintained
Periodically review inventory levels of equipment and other tangible assets
Assist the PI to complete administrative actions or required reports associated with the
equipment
Research Management has equipment responsibilities that include:
Provide assistance to the PI and department in determining the need for and allowability
of equipment purchased during the proposal process
Assist the PI/department in determining:
Sponsor approval for the purchase of equipment using project funds
Whether or not Partners retains title to equipment purchased with project funds
Disposition instructions for equipment at the end of the project
Submission of inventory of equipment reports if required by the sponsor
Procedure
Proposal Preparation
Proposal budgets and accompanying narratives should specify the type, unit cost, and
quantities along with the anticipated maintenance costs of the equipment. In general, they
should not request approval to purchase general office equipment like desks, chairs, office
furnishings, cellular phones, etc. Before including equipment in the proposal, the PI should
determine that existing equipment is either not available for use when required or fails to meet
the project's needs. When equipment is available, whether within the institution or furnished by
the sponsor, the costs associated with using and maintaining the equipment should be included
in the proposal budget (i.e., use fee, preventative maintenance and service, project specific
modifications or repairs, additional security measures, etc.)
Award Documents
The award documents will identify equipment pre-approval, acquisition, use, maintenance and
disposal responsibilities associated with the project. They will also identify who will retain title to
the equipment at the end of the project. If the item is provided by the sponsor as Government
Partners HealthCare Research Equipment Management Policy, 6
Furnished Equipment (GFE), the award will contain additional instructions regarding the receipt,
use, care and future disposition of the equipment.
Purchasing Equipment
The inclusion of equipment in the proposal may not grant authorization to purchase the item
once an award is made by the sponsor. Pre-approval may be required. Institutional procurement
policies may mandate additional approval (Please refer to Partners Purchasing Central –
Materials Management Policy).
Title to Research Equipment
Title to equipment purchased with grant or contract funds may be retained by the funding
agency (sponsor-owned) or granted to Partners (Partners-owned) upon acquisition. Title to
equipment acquired by a Partners entity typically vests in the entity (i.e., BWH, MGH, etc.)
except in special circumstances; for example, if funds independently generated by the hospital
are involved in purchasing research equipment (i.e., matching funds), Partners retains title to
the equipment. Due to the complex nature of claiming loss reimbursement from the federal
government, federally-titled equipment is insured under the entity’s general insurance policy. If
a piece of Partners equipment is in use at another institution, it should be added to that
institution’s insurance policy and a certificate of insurance, with Partners being named as
beneficiary, should be provided to the home department and RSMG.
Additional information concerning title to research equipment may be contained in the terms and
conditions of the award. If there are additional questions concerning title to research equipment
please contact RSMG.
Unless Partners retains title to the equipment, the sponsor must approve the disposal and/or
disposition of surplus property in writing.
Shared Use Priorities
Federal regulations require that during the time nonexpendable property is held for use on
government sponsored projects or programs funded through grants and other agreements, the
recipient shall make that equipment available for use by other projects or programs if such use
will not interfere with the work on the project for which the property was originally acquired. In
accordance with these guidelines, the priority for this shared use shall be:
Other projects/programs of the same federal agency
Projects/programs of other federal agencies
Activities not sponsored by federal agencies (however, if the property is owned by the
federal government, authorization of the federal agency concerned is required)
Management and Disposition of Research Equipment
Information regarding equipment is maintained in the RSMG Research Equipment Inventory
database. Each piece of qualifying equipment is assigned a unique identifying number and a
property tag displaying this identifying number will be affixed to the equipment in a prominent
position. This identifying tag may not be removed for any reason, other than by a representative
of RSMG.
Partners HealthCare Research Equipment Management Policy, 7
PIs are responsible for the custody, care, use, and maintenance of all research equipment
acquired through or furnished to their grants, contracts, and other agreements. The department
is responsible for reporting significant changes in the use, location, condition, transfer, and
disposition of research equipment to RSMG. Equipment owned by the Sponsor (title has not
been granted to Partners) shall be identified to indicate sponsor ownership.
A current and accurate inventory listing of research equipment must be maintained. Partners will
conduct a physical inventory of equipment and reconcile the results with its equipment records
at least once every two years. In connection with the inventory, each Partners entity will verify
the existence, current utilization, and continued need for the equipment. Additionally, larger
entities will inventory a statistical sample of equipment.
Partners must maintain a control system with safeguards to prevent loss, damage, or theft of the
equipment. Differences between the physical inspection and those shown in the inventory
records shall be investigated. Any loss, damage, or theft of equipment shall be fully
documented. If title to the equipment does not vest with Partners, the sponsor will be notified of
the status.
The Research Capital Equipment Inventory database will, when available, include the following
information for each item of capital property:
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
M.
N.
O.
P.
Q.
R.
S.
T.
U.
V.
W.
X.
Y.
Acquisition Cost
Acquisition Date
Actual User Name
Approximate Exterior Size
Approximate Weight
Delivery Location
Depreciation/Useful Life (based on Capital Asset Accounting guidelines)
Equipment Alarm Number
Equipment Description
Equipment Function
Equipment Status Code
Inventory Tag Number
Manufacturer’s serial number, model number, or other identification number
Physical Location (Campus, Building, Floor, Room)
Principal Investigator Name
Project Grant Number
Purchase Order Number
Purchased By Name
Research Site Location (Group, Unit, Unit-Site, PI Unit-Site)
Partners SMG Equipment Description
Sponsor Name
Ultimate Disposition Data, Including Date of Disposal and Sales Price, if applicable
Utility Requirements
Whether Title Rests with Partners, the Federal Government, or other sponsoring
agency
Information from which one can calculate the percentage of federal participation in
the cost of the equipment (not applicable to equipment furnished by the federal
government
Partners HealthCare Research Equipment Management Policy, 8
Transfer of Research Equipment
Equipment owned by the Federal government or other sponsors is subject to transfer to another
institution where approved and directed by the sponsoring agency. A request for transfer of
such property can originate with a researcher transferring to another institution and requiring
such property in the pursuit of continuing research or with the sponsoring agency itself.
Subsequent to a researcher's decision to transfer to another institution, equipment purchases
should be limited to those necessary to complete research at Partners. The acquisition of
additional equipment, necessary to continue research, should take place at the new institution.
A transfer request originated by the PI requires the advance written approval of the appropriate
department head, Chief, Research Management, Senior VP, and, in some instances, the
Federal or sponsoring agency. Agency-originated disposition or transfer instructions do not
require this approval. However, if agency-directed or contemplated transfers are likely to impair
existing research projects, these considerations should be promptly brought to the attention of
the agency, through Research Management, in an attempt to dissuade the agency from making
the transfer.
Disposition and Disposal
Capital equipment remains identified as Partners’ owned or sponsor/government owned
equipment as long as it is in the custody, possession, or control of a Partners entity.
Identification tags are removed from the equipment only when the equipment is scrapped or
when authorization is provided to physically remove the equipment from Partners’ possession.
Equipment is disposed of when it has no value, is no longer under Partners’ control and
responsibility, and can no longer be utilized as originally built. Once an item is disposed all
Partners identification shall be removed.
Disposition of the equipment is also warranted once a project has ended. If title remains with
the sponsor or is undetermined, Partners must request disposition instructions from the
sponsor. These instructions generally result in the following scenarios:
Sponsor transfers title to Partners
Sponsor retains title and equipment remains at Partners
Sponsor retains title and equipment is moved to another institution
Sponsor abandons the equipment with or without disposal instructions
Please contact RSMG for additional information on the proper disposal of equipment via tradeins, resale or donations.
Partners HealthCare Research Equipment Management Policy, 9
Contacts
BWH
Barbara E. Bierer, M.D.
Senior Vice President, Research
bbierer@partners.org
617-732-8990
MGH
F. Richard Bringhurst, M.D.
Senior Vice President,
Medicine and Research Management
McLean
rbringhurst@partners.org
617-724-8549
Peter Paskevich
Vice President, Research Administration
ppasekevich@partners.org 617-855-2922
Spaulding
Roberta Nary
Director, Research Administration
rnary@partners.org
617-573-2365
adchase@partners.org
617-954-9681
Robin Cyr
Director, Training and Policy
rcyr@partners.org
617-954-9682
Mary Mitchell
Director, Research Compliance
mmitchell14@partners.org 617-954-9597
Partners Research Management
Andrew Chase
Corporate Director, Research Management and
Finance
Definitions
Equipment
All moveable items whose unit cost is $5,000 or
more with a minimum useful life of 2 years is
capitalized. Original cost includes the cost of
the item, less any applicable discounts, plus any
delivery charges and cost of installation. The
cost
also
includes
any
modifications,
attachments,
accessories,
or
auxiliary
apparatus (accessories) that are acquired with
Partners HealthCare Research Equipment Management Policy, 10
General purpose equipment
Special purpose equipment
Useful Lives
the item and are necessary to make the item
usable for its intended use.
Equipment that is not limited to research,
medical, scientific or other technical activities.
Examples include office equipment and
furnishings,
modular
offices,
telephone
networks, information technology equipment
and systems, air conditioning equipment,
reproduction and printing equipment, and motor
vehicles.
Equipment that is used only for research,
medical, scientific, or other technical activities.
Examples of special purpose equipment include
microscopes,
x-ray
machines,
surgical
instruments, and spectrometers.
The American Hospital Association publishes
useful guidelines for classifications and
estimated useful lives for property and
equipment used by hospitals.
Where
applicable, Partners assigns useful lives in
accordance with these guidelines. Estimated
Useful Lives, 2004 edition provides estimates
of the useful life span of hundreds of capital
items commonly acquired for the delivery of
health care services and offers reference tables
with data for nine primary categories of capital
investments: Buildings, Building components,
Fixed equipment, Building services equipment,
Administrative
departments,
Nursing
departments, Diagnostic equipment, Treatment
equipment, and Support departments.
Partners HealthCare Research Equipment Management Policy, 11
Who Approved This Policy
Partners HealthCare Senior Leadership
History/Revision Dates
Effective Date: 3/12/07 (revised July 2009)
Partners HealthCare Research Equipment Management Policy, 12
