Equipment Requirements: Proposal through Disposition
"Equipment," in the context of research or other BMC sponsored programs (SPs), is a term of art used to identify a "tool" that is needed and sponsor-approved for the conduct of the SP and meets the following conditions: it is not consumed by use and has both a per-unit acquisition cost of ≥$5000* and a useful life of more than one year. SP equipment usually is employed to obtain, measure, and or analyze data relevant to the SP for which it is employed and, subject to sponsor requirements, may be proposed and charged to the sponsor.
Because the federal government is BMC's greatest source of SP funding, and the National Institutes of Health (NIH), the single greatest funder, BMC has set its requirements to meet NIH and more general federal standards. The above defining conditions are from the NIH Grants Policy Statement, 1.2 Definition of Terms, and the BMC SP equipment policy.
Equipment requirements are parsed into four categories that, together, are comprehensive – procurement, management, transfer, and disposition – and a shared accountability among key SP roles: the principal investigator/program director (PI/PD), department administrator (DA), and Sponsor Programs Finance (SPF).
Please also consult the sections below for relevant details, including general and information technology (IT) considerations.
*The NIH definition adds ta proviso, rarely employed: the cost threshold is the capitalization value on BMC's financial statements whenever that stated value is <$5K.
General Considerations
Before turning to the specificities of IT equipment or multiple phases of equipment compliance, consider familiarizing or refreshing yourself on equipment basics.
- Unlike most SP provisions, equipment responsibilities may range beyond closeout or publication to subsequent equipment use and disposition, requiring long-term oversight to meet compliance requirements
- Federally funded equipment purchases require prior written approval from the relevant funding agency
- Non-federal equipment purchases typically require prior approval but may occasionally be more flexible
- Careful PI/PD/DA analysis of agreement or award terms and conditions prior to proposal submission or agreement finalization may prevent downstream non-compliance and/or operational complexity
- BMC policy may supersede sponsor requirement and should be consulted prior to proposal submission or clinical trial agreement negotiation
- Components that, by themselves, do not meet the capital threshold but do so collectively, as part of a single system/device, may be categorized as equipment
- The acquisitions cost, nearly always set at the $5,000 threshold, is figured as the net invoice unit price of the property, including any costs of modification, attachments, accessories or auxiliary apparatus needed to use the property for its intended purpose (see 6 above)
Information Technology as Equipment
As with so many SP requirements, rules guiding SP equipment compliance are many. Below we outline equipment rules as applied to information technology (IT) products.
- IT systems may be considered SPs, if they are needed specifically for completion of SP work, and are mentioned in the NIH definition of equipment
- Computer software is standardly not categorized as equipment.
- Computing devices that do not meet 1, above, are considered supply costs, inapplicable to equipment designation.
Roles and Responsibilities
Adhering to federal regulation and other sponsor requirements requires diligence and mutual accountability. Those responsible for the procurement, management, transfer, and disposition of equipment include the PI/PD, the DA, and SPF.
The PI/PD:
- identifies the need for equipment
- determines if the requisite equipment is available on campus and arranges use or, if unavailable, budgets the necessary equipment in the SP proposal or agreement
- ensures that equipment under their jurisdiction is properly used and maintained
- supports biannual* physical inventory of equipment
- notifies the SPF equipment manager of any changes in equipment location or proposal or decision to sell or dispose of equipment
The DA:
- ensures that SP equipment in their department or division is both accounted for and optimally utilized
- supports biannual* physical equipment inventory
- notifies the SPF equipment manager of any changes in equipment location or any intention or request to sell to sell or dispose of equipment
SPF:
- oversees inventory of equipment via tagging and monitoring inventory records for satisfaction of federal, other sponsor, and BMC policy requirements
- conducts biannual* physical equipment inventory
- approves equipment sale and disposal forms
*Whenever "biannual" is indicated, "every other year" is intended.
Procurement and Title
Purchasing Equipment
SP equipment requires three price quotes prior to the necessary purchase order (PO) requisition. If fewer than three quotes are obtained and/or the lowest quote is not accepted, a written, satisfactory justification is required. Perfunctory explanation shall be returned.
The PO requisition and accompanying quotes/documents need to be approved by SPF before equipment is purchased. Please contact the SPF equipment manager for questions or support.
Title to Equipment
Title to equipment purchased with SP funds is retained by the funding agency or granted permanently to BMC. Additional information concerning title to equipment may be contained in sponsors' policies or in property clauses of SP agreements or notices of award.
Management
The PI/PD is responsible for the custody, care, and maintenance of SP-acquired or -furnished equipment.
Tagging upon Receipt
Upon equipment receipt, the PI/PD/DA or designee must contact the SPF equipment manager to request that a laminated tag with adhesive backing be affixed to each item. This tag shows the property control number (Tag #).
Inventory Documentation
A current and accurate inventory listing of all SP equipment must be maintained, including physical inventory no later than biannually. The PI/PD/DA or designee(s) are responsible for reporting significant changes to SPF in equipment location, condition, transfer, or disposition.
Disposition: Movement, Transfer, Sale, or Disposal
Per BMC's Sponsored Program Equipment Management Policy, sponsor-owned research equipment must be reported to SPF if it:
- is moved to a new location
- becomes unserviceable, or
- is no longer needed in the conduct of the SP work.
Please read the descriptions below and, as needed, email the SPF equipment manager, attaching the completed Equipment Transfer/Disposal Form.
Movement or Transfer
Equipment is considered to be moved if it is either physically moved to a new location within BMC or transferred interdepartmentally without being physically moved.
Equipment that is permanently moved from BMC to another entity is considered to be transferred. Before a transfer may occur, a departing PI/PD/DA or designee must contact the SPF equipment manager in advance to request the transfer. The decision to transfer equipment to another institution, apart from legitimate sponsor requirements, is at the discretion of Research Operations.
Sale or Disposal
In all cases, reasonable efforts must be made to locate another BMC SP use for the equipment before SPF may authorize disposal. If a sponsor authorizes or requires BMC to sell a piece of equipment, the PI/PD/DA or designee must make reasonable efforts to ensure the highest possible return and satisfactorily document those efforts.