The following policies and forms pertain to moveable equipment used with organized research or other sponsored activities. The policies affect how equipment costs are recognized and tracked for overhead recovery purposes and for required management of government furnished property. Departments having equipment that is not used in research or related activities are not required to follow these policies.
Harvard University has a decentralized equipment management practice under which individual schools are largely responsible for equipment management. The central Office for Sponsored Programs (OSP) provides policy and procedural guidance to the schools and complies with reporting requirements of auditors, sponsors and agencies. Such requirements are dictated in the special terms and conditions of awards and in applicable sections of federal government guidelines found in the following circulars:
OSP, on behalf of the schools, will submit required property reports to the government including DOD form 1662 and NASA form 1018 specifically when required by CFR. Details of required government reporting functions are seen below in part 3. b.
To the extent there is any inconsistency between Harvard's policies and the terms and conditions of a sponsoring agency's award under which equipment is provided, the award's terms and conditions shall govern.
For all Central equipment reporting and policy guidance, contact:
Judith A. Ryan
Director for Cost Analysis & Compliance
Office for Sponsored Programs
Holyoke Center Suite 600
1350 Massachusetts Avenue
Cambridge, MA 02138
617 495 1520 judy_ryan@harvard.edu
Marc Todesco, Senior Financial Analyst
Office for Sponsored Programs
Holyoke Center Suite 600
1350 Massachusetts Avenue
Cambridge, MA 02138
617 495-8341 marc_todesco@harvard.edu
For all equipment-related matters at the individual schools:
Faculty of Arts & Sciences:
Alan K. Long
Assistant Dean for Research Finances and Systems
1414 Massachusetts Avenue Room 430
Cambridge, MA 02138
617 496 2491 aklong@fas.harvard.edu
Harvard Medical School:
Sarah T. Axelrod
Manager of Cost Analysis
Financial Operation & Analysis
25 Shattuck St Gordon Hall 403
Boston, MA 02115
617 432 3284 sarah_axelrod@hms.harvard.edu
Harvard School of Public Health:
Deborah Carmel
Director of Cost Accounting
677 Huntington Avenue
Building 3 Room 1007
Boston, MA 02115
617 432 0990 dcarmel@sphofs.harvard.edu
For all other Harvard Schools:
Marc Todesco, Senior Financial Analyst
Office for Sponsored Programs
Holyoke Center Suite 600
1350 Massachusetts Avenue
Cambridge, MA 02138
617-495-8341 marc_todesco@harvard.edu
3.General Guidelines, Definitions, Policies and Proceduresback to top
a. Roles and Responsibilities
In addition to acquiring, using, maintaining and protecting capital equipment, the schools' general responsibilities include keeping records of capital equipment they have acquired with federal funds or that are federally-owned and are in their possession. Schools must also properly dispose of federally-funded or owned equipment according to the terms and conditions of the grants or contracts through which the equipment had been acquired. Non-federally-funded or owned equipment, including Harvard-funded, may be inventoried by schools at their discretion for use in Facility & Administrative (F&A) cost recovery calculations.
The school equipment contacts, noted above, may conduct equipment management responsibilities with the assistance of their Department Equipment Officers (DEOs). The DEOs are Harvard employees assigned by a school's Department Head or designee to conduct local equipment management activities in the departments where equipment is used.
Typical functions of school Equipment Management Offices and/or school departments may include:
Keeping records of capital equipment
Coordinating physical inventories of capital equipment
Reviewing fabrication requests for contract/grant compliance
Budgeting and transacting equipment and fabrication expenditures
Processing and filing Fabrication Request and Placement in Service forms
Notifying the Office of Fixed Asset Accounting when equipment and fabrications are to be placed in service and can be capitalized
Recording movements of federally-funded or federally-titled equipment
Processing and filing Notifications of Disposition of Equipment for trade-ins, transfers, loans, donations, and sales
Providing policy guidance on disposal requirements for equipment decommissioning and returns of equipment to sponsors or title transfer to Harvard when appropriate
Processing police reports on losses and thefts
Processing and filing documents related to receipt of government surplus or loaned equipment
Processing and filing reports from subcontractors on loss, damage, or destruction of equipment in subcontractors' possession
Processing and filing department signature authority forms
The schools may execute these and other tasks centrally or distribute some or all of them among departments as appropriate.
The central Office for Sponsored Programs, noted above, shall provide policy and procedural guidance to the schools pertaining to all equipment management matters. OSP shall also respond to requests for reports and information from sponsors, auditors and other parties.
b. Government Furnished Property (GFP) requirements back to top
1. GFP Overview. Agencies of the federal government will on occasion furnish equipment or other property under a grant or contract for use in sponsored activities. GFP remains owned by and titled to the federal government while in Harvard’s possession and until it is properly disposed of. All items of GFP no matter how small, old or inexpensive have no threshold dollar value for capitalization or other purposes. Any property received from the federal government regardless of original value or date when received must be properly and continuously identified, maintained, protected, controlled, and inventoried while in the possession of Harvard or its subcontractors. GFP must be disposed of when no longer needed as approved by the federal agency that furnished the equipment. Disposal may involve returning the property to the government, transferring its title of ownership to Harvard, or distributing to a third party.
Because GFP is provided to Harvard at no cost yet remains the property of the federal government, it is neither recorded as an expense transaction in the General Ledger nor recorded as a capital asset in a school’s balance sheet. As such, no depreciation expense or other transactional information will be recorded for GFP in Harvard’s financial systems of record. Due to its not appearing in the General Ledger, customary methods of cost recognition will not identify GFP. Nevertheless, GFP has value, remains the property of the federal government and must be carefully managed by departments and faculty at Harvard.
Property owned by the federal government and used by Harvard must be clearly identified to indicate federal ownership. School Equipment Management Offices must account for the following aspects of all GFP in their departments’ possession:
A description of the equipment
Manufacturer's serial number, model number, federal stock number, national stock number, or other identification number(s)
Source of the equipment, including the award number and the award’s ending date
Clear acknowledgment that ownership and title vests with the federal government
Date property was received from the federal government
Location and condition of the GFP and the date the information was reported
Original cost or value of each item of GFP
Ultimate disposition data, including date and status of disposal
In order to clearly identify and locate government furnished property, schools should use uniquely numbered identification tags affixed to property if items are taggable. Numbered tags will facilitate a school's equipment inventory control by enabling them to match individual pieces of GFP under their control with associated information as required above. Department Equipment Officers or Principal Investigators must inform their respective school’s Equipment Management Office whenever GFP is received, changes location or condition, or its source award has ended at which time disposition options will be discussed with the federal agency that had provided the GFP.
2. Notification procedures. When the Office for Sponsored Programs is notified via sponsor correspondence of an award receiving government-furnished equipment, an Action Memo will be generated and distributed to the PI, pre- and post-award administrators, department administrator, and the Department Equipment Officer. In GMAS, Harvard’s sponsored research system of record, the “Special Equipment Terms” radio button will be selected and the Action Memo will include, in the Revision Comment section, a statement on the government-furnished equipment. This will alert schools and departments to tag the equipment and enter the requisite information into their inventory control system.
3. Reports. OSP shall submit all required GFP reports, including specific forms for GFP disposal, to the federal government on behalf of the schools. The primary government agency to receive Harvard’s required GFP reports and its address for correspondence is:
Department of the Navy
Office of Naval Research (ONR)
Boston Regional Office
495 Summer Street, Room 627
Boston , MA 02210-2109
Attn. Ms. Linda Rowe, Property Administrator
Specific GFP reports to be submitted by OSP to the federal government include but are not restricted to:
Procurement Instrument
Format
Distribution
Notes
DOD
Contract
DOD Property In The Custody Of Contractors DD Form 1662
Negative Reports Not Required
(unless a positive balance was reported last year)
Due 10/15 of each year for preceding year
ending 9/30.
If there are any questions on the requirements for annual government furnished property reporting, contact the ONR Property Systems Manager at (617) 753 - 4598.
c. Equipment Costs and Capitalization Threshold (back to top)
Under Harvard financial policy, an item is considered capital equipment when it has a unit cost of $5,000 or more, Harvard's capitalization threshold value for non-GFP, and has a useful life of at least one year. The capitalized unit costs consist of the allowable costs noted below. Because the government owns our GFP, it will not be capitalized or depreciated as a Harvard-owned asset in our balance sheet accounts.
d. Allowable Costs that may be Capitalized as Equipment (back to top)
The total cost of a single (non-GFP) item ($5,000 or more having a useful life of at least one year) less any discounts, plus delivery charges, insurance while in transit, and cost of installation may be accumulated as capitalized equipment costs. Government furnished property, which has no threshold value, will not be capitalized.
Equipment costs may also include any modifications, attachments, accessories, or auxiliary apparatus that are necessary to make an item of capital equipment useable for its acquired purpose.
Equipment that is part of a fabrication project is also considered capital equipment, regardless of the dollar amount of the component items, provided that the total cost is $5,000 or more and the final fabricated asset will have a useful life of at least one year.
Equipment repair costs may not be included in capitalized equipment costs unless the department which requests the repairs states on a repair invoice or other documentation that the repair will add at least two years to the item's assigned useful life, or the repair is an enhancement of the item.
e. Costs that may not be Capitalized as Equipment (back to top)
Demolishing or dismantling equipment.
Rearrangement, transfer, or moving of equipment from one University location to another, including the costs incurred in dismantling, transporting, reassembling and reinstalling such items in a new location.
Government furnished property
Separate warranty costs of maintenance contracts.
Items for which periodic invoices are received either monthly or annually such as software, licensing fees, etc.
Lease or rental costs; government regulations may permit lease or rental costs to be recovered through indirect cost recovery rates, but not capitalized, if:
rates are reasonable at the time of decision to lease or rent, and
the cost recovered does not exceed the purchase price on the date equipment was leased or rented; and,
the monthly charges for such items are transacted using equipment rental expense object codes rather than using equipment acquisition object codes.
Once the determination to lease has been made, but prior to commitment, departments should send the lease agreement (unsigned) to Harvard's Office of General Counsel. The Office of General Counsel reviews lease agreements for legal and contractual liabilities.
Financial transactions in the General Ledger pertaining to equipment acquisition are executed by using equipment-related object codes seen below. The object codes used for purchasing equipment are associated with useful life values (expressed in years) for specific types of capital equipment. The useful lives affect deprecation accounting, thus it is important that all capital equipment transactions use correct object codes for the type of equipment acquired. All other items with individual costs of less than $5,000 are considered supplies and their transactions use object codes for supplies in the 6500-6620 range.
When non-GFP capital equipment is acquired and placed in service, its value is depreciated annually, in whole -year increments, using the straight-line method over its useful life. A typical capital equipment depreciation expense scenario could follow this example:
an electron microscope valued at $80,000 is placed in service on March 1;
its annual depreciation expense will be $10,000 given its useful life of 8 years;
there is no pro-rating or calculating of partial-year depreciation, it is recorded in whole year increments on June 30th beginning with the year in which it was placed in service;
if this microscope was sold at any time in the following fiscal year after its initial fiscal year of placement in service, it would have net book value of $70,000, i.e. one of its eight years of useful life had passed and one-eighth of its original value had depreciated. The asset would continue to lose one-eighth of its original value after every fiscal year has passed, eventually fully depreciating to $0.
For further advice on depreciation accounting or asset valuation, please contact Devin Advani, Financial Manager, in the Office of Fixed Asset Accounting, at 617 495 3766.
Upon receipt of a federally-funded or owned (titled) capital equipment item, schools should maintain positive identification and awareness of equipment location. Federally-funded or owned equipment is subject to annual A-133 audits during which Harvard's compliance with federal equipment requirements in OMB Circular A-110 section 34 is tested. Thus, schools must maintain records of federally-funded or owned equipment and include all of the following information for each item of capital property.
A description of the equipment.
Manufacturer's serial number, model number, federal stock number, national stock number, or other identification number.
Source of the equipment, including the award number.
Whether title vests in the recipient or the federal government.
Acquisition date (or date received, if the equipment was furnished by the federal government) and cost.
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).
Location and condition of the equipment and the date the information was reported.
Unit acquisition cost.
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 federal awarding agency for its share.
Equipment owned by the federal government shall be identified to indicate federal ownership.
To maintain effective inventory control of equipment, schools should use uniquely numbered identification tags affixed to equipment. Tags and tag numbers may facilitate the schools' equipment inventory control by enabling them to match individual pieces of equipment in their control with their associated information as required above.
A "fabrication" is equipment that is being constructed or developed for Harvard by combining components or materials into one identifiable unit. All components must work as one unit to be considered a fabrication; parts alone are not considered a fabrication.
Individual components acquired during a fabrication project are considered equipment regardless of their unit costs. For example, three parts of a robotic arm each costing $2,500 would accumulate to a $7,500 capital asset. When fabrications are sufficiently developed and useful, and meet capital equipment thresholds, they should be placed in service to initiate depreciation of the whole asset. A Notification of Placement in Service of Capital Equipment Fabrication form should be completed, retained locally and a copy should be sent to the University's Office of Fixed Asset Accounting. The original component costs of fabrications are excluded from the direct cost base and are not subject to overhead if all costs are accumulated under a single item identification number.
There are several steps involved in creating fabrications and placing them in service as whole units of capital equipment.
Acquiring components for a fabrication. Developing fabrications may require numerous purchases of components. Also, transfers of property between sponsored agreements, and even from sponsors to Harvard, can provide property for fabrications.
Using the Fabrication Request Form. A Fabrication Request Form is completed by the department administrator or Principal Investigator at the beginning of each fabrication project. The fabrication-initiating form may be retained locally or sent to the school's Equipment Management office, depending on local practice. Either the department or the school's Equipment Management Office may then issue an identifying tag number and record the fabrication's information in an equipment inventory system. All subsequent invoices for components of each fabrication should refer to the fabrication's identification number in order to accumulate component costs into a single fabrication account.
The Fabrication Request Form should include:
description of the fabricated item
sponsor/government agency (or non-sponsored fund source)
award number
Principal Investigator
33-digit account codes
beginning and ending dates of the award
location of fabrication
estimated total cost of fabrication
estimated placement in service date
useful life of fabricated item, depending on its ultimate asset category, e.g. scientific equipment
person responsible for monitoring/developing the fabrication
Accounting for fabrication costs. When fabrication projects are consistent with funding contract or grant terms and have begun their development, their component costs may be charged to each project using capital equipment object codes 6811-6812.
Upgrading fabrications. Subsequent additions to an existing fabrication are charged to the original fabrication's account and new components are given the original fabrication's tag number. Using consistent accounts and tag numbers for all subsequent upgrades to fabrications will enable schools to accumulate costs accordingly to assess changes in asset values and depreciation expense.
Fabrications may be subject to special terms and conditions of the sponsoring agency and award. Certain awards, for example from the U.S. Department of Energy, will state that capital equipment funds must be reported separately from operating funds. Only costs that are described initially in the budget as necessary for the completion of the fabricated item are considered appropriate and allowable. If additional costs other than those approved in the budget are needed during fabrication, a revised budget must be submitted for approval.
Placing the fabrication in service. When useful results have been obtained from a fabrication, it is ready to be placed in service even if additional components will be added at a later date. Departments should ensure that the fabrication is recorded properly in the school's equipment inventory system. A Notification of Placement in Service of Capital Equipment Fabrication form should be signed by the Department Administrator and either sent to the school's Equipment Management Office or retained locally, depending on local practice. The department or school's Equipment Management Office will also inform the University's Office of Fixed Asset Accounting of the fabrication's placement in service.
Disposal of fabrications. A fabricated item may be disposed of in whole, as may all other capital equipment, or partially reused with the permission of the funding sponsor or owning agency if such requirements are stated in funding contract or grants terms. Departments or school Equipment Management offices must ensure accurate accounting of the disposal of any item of equipment by submitting a Notification of Disposition of Equipment Form and recording the disposal in the school's equipment inventory system.
For each item of inventoried equipment that is located at Harvard, at off-campus sites, or at any of its affiliates, and is moved from its most recently recorded location, the school's equipment inventory system should be updated to indicate a change of building and/or room location(s). As well, during each biennial inventory, departments may indicate a new location of previously inventoried equipment.
Capital equipment remains identified as Harvard-owned or sponsor/government-owned equipment as long as it is in the custody, possession, or control of Harvard. Identification tags or numbers are removed from the equipment only when the equipment is scrapped or otherwise physically removed from Harvard's possession.
Equipment is "disposed of" when it is:
no longer under the control and responsibility of Harvard University,
no longer an identifiable piece of equipment; or,
no longer part of the inventory of active items.
Equipment disposal may be effected through the following actions:
Trade-ins. When trading in equipment, enter applicable information on the Notification of Disposition of Equipment Form, attach the form to the invoice of the new item and submit all paperwork to Accounts Payable. This form requires department approval and should be filed locally. The paperwork will be scanned into the A/P imaging system and can be made available to schools and their departments. Update the appropriate record(s) in the school's equipment inventory system when disposing of equipment through trade-ins.
Selling or transferring equipment between departments. Departments selling equipment should prepare a Journal Voucher for both the debit and the credit, using appropriate equipment Object Codes. Include an identification number of the equipment to be sold or transferred in a description field of the Journal Voucher. Departments should also fill out a Notification of Disposition of Equipment Form noting the identification number, the amount of the sale, the department receiving the equipment and the new location, if known. The form may be retained locally or sent to the school's Equipment Management Office, depending on local practice. Update the appropriate record(s) in the school's equipment inventory system when disposing of equipment through sale or transfer.
Loaned equipment. For equipment that is loaned by one department to another department or entity, donor departments must maintain records of the location of the equipment. If the equipment will be off-campus, departments should complete an "Authorization for Off-Campus Use of Equipment Form" and either retain it locally or send it to the school's Equipment Management Office. This form requires the complete address of equipment location and requires the signature of the user of the equipment and department authorization. Update the appropriate record(s) in the school's equipment inventory system when disposing of equipment through lending.
Equipment given to another department. If an item is being given to another department, the donor department should fill out a Notification of Disposition of Equipment Form and send a copy to the school's Equipment Management Office depending on local practice. This form should have a department-authorized signature. Update the appropriate record(s) in the school's equipment inventory system when disposing of equipment by giving equipment to another department.
Selling or donating equipment to a party outside of Harvard. When selling a piece of equipment to an external party, items should be sold for the net book value. Enter the applicable information in the Notification of Disposition of Equipment Form. Complete the Disposal portion of the form and provide copies to the acquiring party and the school's Equipment Management Office. The dollar amount received should be recorded as income to object code 5770. If the sale is for $10,000 or more, a "Notification of Significant External Sale of Capital Equipment Form" should be completed and sent to the Office of Fixed Asset Accounting. Update the appropriate record(s) in the school's equipment inventory system when disposing of equipment through selling or donating. For further guidance when selling capital equipment contact Judith A. Ryan (in OSP for property management concerns) at judy_ryan@harvard.edu , 617-495-1520 or Devin Advani (in the Office of Fixed Asset Accounting for equipment sales accounting procedures) at devin_advani@harvard.edu , 617-495-3766.
Equipment transfers to/from Harvard and other institutions. If a Principal Investigator is leaving Harvard to join another institution and will be taking capital equipment from Harvard, the following procedures should be followed:
obtain sponsoring agency's approval
prepare an Equipment Transfer Notification Form (If the award is a Public Health Service Research Grant, and the PHS Relinquishing form is applicable, reference the Equipment Transfer Notification form in the Equipment portion of the PHS form. Show the details concerning the equipment being transferred only on the Equipment Transfer Notification Form)
contact the schools' Equipment Management Office for any disposal regulations and obtain Department Head's signed approval for the release of listed items.
update the appropriate record(s) in the school's equipment inventory system and/or
send a copy of the form(s) and a list of items to the school's Equipment Management Office, depending on local practice
Equipment having no value and no longer being used:
enter applicable information in the Notification of Disposition of Equipment Form. This form requires department approval, and
obtain disposal instructions from the school's Equipment Management Office and note regulations in the remarks section of Notification of Disposition of Equipment form if applicable, and,
update the appropriate record(s) in the school's equipment inventory system and/or
subject to these disposal regulations, dispose of the item and send a copy of Notification of Disposition form to the school's Equipment Management Office, depending on local practice.
Equipment returned to vendor or sponsor. When returning an item to either a sponsor or a vendor after purchasing:
enter applicable information in the Notification of Disposition of Equipment form, and
obtain disposal instructions from the school's Equipment Management Office and note regulations in Remarks section of the Notification of Disposition of Equipment form, and
complete the Disposal portion of the Notification of Disposition of Equipment form, if applicable, and
update the appropriate record(s) in the school's equipment inventory system when disposing of equipment through sale or transfer.
provide copies of this form to the acquiring party and send a copy to school's Equipment Management Office, depending on local practice, and,
credit the dollar amount received to the appropriate object code(s) used in the original transaction.
Idle equipment. When equipment is not currently used either in active research or as part of a fabrication project, fill out the Notification of Disposition of Equipment form and either send a copy of this form to the school's Equipment Management Office or retain in department files, depending on local practice. Update the appropriate record(s) in the school's equipment inventory system when equipment is not currently being used.
Equipment that is lost or stolen. When reporting lost or stolen items, contact the Harvard University Police Department which will prepare a report. Send a copy of this report to the school's Equipment Management Office or retain in department files, depending on local practice. Update the appropriate record(s) in the school's equipment inventory system when equipment has become lost or stolen.
m. Use, Maintenance and Protection of Equipment back to top
Departments should return any warranty cards to the manufacturer and conduct any periodic maintenance such as lubrication, cleaning and/or calibration. Departments should also maintain records of any deficiencies discovered as a result of inspections, as well as any maintenance actions performed.
Departments should advise subcontractors of their responsibility to comply with Harvard's Equipment Management policies and procedures where applicable, unless the subcontractors have approved systems of their own.
Subcontractors should report to the PI all instances of loss, damage, or destruction of government equipment in the subcontractor's possession or control, which is accountable under a grant or contract, and submit copies of these reports to the department or the school's Equipment Management Office, depending on local practice.
Harvard conducts a physical inventory of federally-funded or owned capital equipment every two years in accordance with the regulations outlined in OMB Circulars A-133 and A-110. Outlined above in the Inventory Control section of this policy are the information items to be maintained in inventory records and refreshed every two years. To maintain compliance with federal auditing guidelines, inventory sheets must be signed by a Department Head or designee, dated and returned to the school's Equipment Management Office. Copies of the updated physical inventory records should be on file for two consecutive biennial physical inventories.
Harvard departments should control equipment movements by approvals of authorized staff only. For matters of equipment disposals, transfers, physical inventories, etc., the Department Head would authorize such movements with her/his signature. If the Department Head wishes to delegate this responsibility to another person, that designation should be declared on the Signature Authority form which should be kept in department files and a copy sent to the school's Equipment Management Office.
When departments use capital equipment that is owned by (titled to) the federal government, and the project through which the federally-titled equipment was furnished is sufficiently completed, they may initiate transferring ownership to Harvard. Contact the Office for Sponsored Programs Equipment Management contact, noted above, for further assistance with federal equipment title transfer.
Authorization for Off-campus Use of Equipment
Indicates off-campus location of equipment; departments must complete and retain locally and/or forward to their school's Equipment Management Office.
a href="http://able.harvard.edu/forms/em_tagging.pdf">Equipment Tagging Form
Initiates identification of capital equipment. Departments may complete and retain locally and/or forward to their school's Equipment Management Office.
Equipment Transfer Notification
Indicates transfers of equipment between departments. Information should be used to update location records in inventory databases.
Fabrication Project or Multiple Invoicing Request Form
Initiates a fabrication and its initial identification number. Departments may complete and retain locally and/or forward to their school's Equipment Management Office.
Notification of Placement in Service of Capital Equipment Fabrication form Indicates completion or placement in service of fabrication. Departments must complete and retain locally and/or forward to their school's Equipment Management Office which will in turn inform the University's Office of Fixed Asset Accounting.
Notification of Disposition of Equipment
Indicates disposal status of capital equipment. Departments must complete and retain locally and/or forward to their school's Equipment Management Office which will in turn inform the University's Office of Fixed Asset Accounting if the disposal removes the asset from Harvard control or ownership.
Signature Authorization Form
Gives department staff signature authority so that the PI or Department Head does not have to sign all forms. Signature Authority Forms are kept in the department and/or schools' Equipment Management Offices, depending on local practice.