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Both Columbia University and the U.S. government have policies and procedures for property management. For USG-funded projects, the applicable provisions are in the Code of Federal Regulations (CFR) in Sections 45 CFR 74.31 through 74.37. These provisions set forth uniform standards governing management and disposition of property furnished by the U.S. government or whose cost was charged directly to a project supported by a USG award.
PIs and Country/Project Directors are responsible for the safekeeping of all Columbia University and USG assets used in their international projects, regardless of dollar value. This includes the maintenance, secure storage, proper use, and appropriate tracking of assets. Examples of systems and procedures that PIs or Country/Project Directors could establish may be found in Section 6.13 of the ICAP SOPs. The following highlights the key requirements.
Columbia University’s policy is to record all equipment and any other property that would not normally be consumed throughout the course of a project. In line with prudent financial management, Columbia University policy, and U.S. government regulations, international projects must maintain a property log (inventory) of all non-expendable property with an expected service life of 1 year or more and with a unit cost of more than US$500, including taxes, shipping, duties, installation, and related charges.
In addition, the Property Log must include expendable equipment, supplies, or commodities with a total transaction cost of more than US$2,000 including taxes, shipping, duties, installation, and related charges.
Note that the stricter Columbia University standard, which uses a lower acquisition amount than USG funding agencies, is the one that international projects must follow.
The log must contain data as specified by the University and the funding agency and must be updated regularly as assets are purchased and disposed of. At the end of the fiscal year (June 30), the project must complete an up-to-date version of the property log and submit it to the Department Administrator by July 15.
Often more than one property log is required:
Since the University does not provide coverage for loss or damage to property outside of North America, it is the PI’s or Country/Project Director’s responsibility to procure the types and levels of insurance coverage that an international project will obtain against loss, damage, or theft of real property and equipment. In making this decision, the PI or Country/Project Director might consider:
In the event of property loss through theft or any other means, the PI or Country/Project Director should report the loss to New York and/or the funding agency if appropriate for that type and level of loss, and in accordance with University and funding agency guidelines. It is usually important to obtain documentation of the loss in the form of a report from an independent party such as the police. Note that funding agencies may require the University to obtain their approval before using grant/contract funds to replace a lost asset.
If the aggregate value of property owned or leased in conjunction with any individual research project is substantial (e.g., greater than US$500,000), University central administration, through the Office of Risk Management, is available to assist with the procurement of necessary insurance coverages.
Disposition of major assets must be done in accordance with the procedure and conditions specified in the funding award. Prior funding agency approval may be required to sell or donate an asset. For smaller items not classified as major equipment, these may be disposed of in an appropriate manner as determined by the PI or Country/Project Director in consultation with the Department Administrator.
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