Purpose ....................................................................................................................................2

Equipment Title/Ownership ....................................................................................................2

Responsibilities .......................................................................................................................3

Equipment Management Department ...............................................................................3

Custodial Departments…………………………………………………………………..4

Principal Investigator ........................................................................................................4

Types of Identification Tags ...........................................................................................10

Reassignment of Identification Tags ..............................................................................10

Maintenance of Records .......................................................................................................11

Storage and Movement .........................................................................................................14

Physical Inventory ................................................................................................................15

Reports ..................................................................................................................................16

Equipment Usage ..................................................................................................................16

Care and Maintenance...........................................................................................................16

Subcontractor Control ...........................................................................................................17

Disposal.................................................................................................................................17

Property Closeouts ................................................................................................................19

Capitalization ........................................................................................................................20

Depreciation of Equipment ...................................................................................................20

Definitions.............................................................................................................................21

USC has adopted the Office of Management and Budget (OMB) costing regulations under

Circular A-21 for equipment capitalization at $5,000. The equipment definition is as follows:

acquired by, the government and subsequently made available to the university for usage

in the performance of a contract or grant. These items must be inventoried as mandated

Asset Management System (CAMS) under object code 17013.

equipment with title vesting with the Government/Sponsor and an acquisition cost of less

than $5,000. This equipment must be inventoried as mandated by the sponsoring agency.

These items are treated as an expense that is subject to indirect cost (F&A) burden under

burden under object codes 17011, 17012.

The following policies and procedures apply to the acquisition of equipment regardless of the

source of funding and are in compliance with:

 OMB Circulars A-21, A-110, and A-81,

 Federal Acquisition Regulations,

 California state and local government restrictions, and

 The university’s negotiated indirect cost (facilities and administration costs - F&A) Rate

Agreement with DHHS (Department of Health and Human Services).

held by the university. These procedures are established to comply with federal regulations with

respect to government equipment for which the university is responsible and accountable.

Title or ownership of university equipment acquired with university funds is vested with the

university at the time of acquisition. Title to equipment acquired or fabricated with sponsored

project funds or with funds provided by a sponsor is determined by the type of agreement and the

specific terms and conditions of the contract or grant. Title to equipment received as a donation

or gift to USC will vest with the university; it does not vest with an individual.

The university is responsible and accountable for all equipment to which it holds title. Custodial

university “Capital Asset Management System” (hereafter referred to as CAMS). CAMS adheres

to the screening and reporting requirements of sponsoring agencies, promotes control and

accountability of equipment, assists in calculating depreciation for indirect cost recovery,

provides data for adequate insurance coverage, and serves as the official equipment record at the

university. In addition, the Equipment Management Department:

responsibility for the care, maintenance, physical inventory, and control of the equipment in their

custody. In addition, custodial departments:

(c) Software is purchased for use in a Fabrication/Cluster.

GFP is recorded in CAMS at the time of receipt: Equipment Management scans and retains all

documentation.

the asset eDoc. These records are referred to as “supporting documents” and are used for audit

purposes. A typical file should include the following:

Equipment Management electronically by logging in to CAMS and making adjustments to the

equipment record.

any loaned equipment. The accountability for this type of loans rests with the department

receiving the equipment.

Equipment that is being used as a trade-in for a new piece of equipment must be identified on the

new requisition. The tag number of the old piece of equipment must be noted on eMarket by

filling in the “Capital Asset Management” tab to ensure that the equipment being traded in is

retired from CAMS.

A department must notify Equipment Management via email at [email protected] regarding

any equipment that has been tagged and is now being exchanged or returned to the vendor

(without cost) for a new piece of equipment.

Special care should be taken to ensure the proper assignment of object codes. The responsibility

begins with the department that initiates a requisition for the purchase of equipment and non-

capital equipment. The department and Purchasing Services will ensure that the appropriate

object code is used based on the following criteria:

 Equipment purchases of $5,000 or greater use the applicable object codes within object

code 17xxx, and

 Non-capital equipment purchases use object code 170xx if units must be inventoried as

mandated by the sponsoring agency and if acquisition is less than $5,000. The object

code 170xx should only be used on sponsored (‘5’) accounts.

less than $5,000 that is agency awarded to be budgeted/purchased as equipment,

(Equipment Management not required to submit a Final Equipment Report)

 17100 for the purchase of general equipment

 17200 for the purchase of computer or computerized equipment only

 17300 for the purchase of photocopy equipment only

 17500 for vehicles charged against non-CIP (‘69’) accounts

 17900 for the purchase of scientific equipment and

 07490 for equipment bought and passed through to non-university locations

The following is a list of equipment object codes for use acquiring equipment with Construction

In-Progress (‘69’ CIP) Accounts

 44821 for moveable equipment - general

 44850 for scientific equipment

Upon receipt, the department will thoroughly inspect all equipment to ensure that it is as ordered

and undamaged. If the shipment is complete and is in good order, the receiving department

should log in to eMarket and complete a receiving document which will authorize payment.

When the quantity or description of the equipment received differs from the shipping document,

only that quantity or description of equipment actually received is recorded on the official

receiving document, and the department must rectify any discrepancy with the supplier.

In the case of GFP, the receiving department becomes responsible for such equipment upon

delivery and must immediately notify the Equipment Management Department so the equipment

can be properly tagged and recorded.

Equipment Management staff is responsible for identifying and affixing an identification tag to

equipment. Once staff has located and identified the equipment, they will attach either a

university or a government tag in a position which is visible and will not interfere with the

operation of the equipment. A government tag ("G" tag) will be assigned to equipment when the

Sponsoring Agency retains title or if the equipment is government furnished. If a tag cannot be

applied to the equipment, Equipment Management staff will identify the equipment as

untaggable ("X" tag) and all pertinent information will be entered into CAMS. For untaggable

equipment, the actual identification tag will be affixed to the tag log and maintained in the file.

Equipment Management staff will scan the assigned tag, location, room, manufacture, model,

and serial number. This information will be transferred to CAMS through an upload process

once the staff has returned to the office.

awards administered by the Office of Naval Research (ONR) are submitted to the administrative

contracting officer at ONR San Diego.

Subcontractors are not required to submit NASA 1018 Forms, but must submit all necessary data

to the university. The university as the Prime Contractor is responsible for incorporating the

subcontractor's data into the NASA 1018 Form.

The PI should restrict usage of equipment acquired under a specific contract or grant to the

purposes of that contract or grant unless otherwise noted on the award agreement. Unless a

contract provides authorization to use government equipment on other contracts or grants, the PI

must obtain written approval for use from the Administrative Contracting Officer.

statute, for as long as the Federal Government retains an interest in the equipment."

The custodian must provide the care necessary to maintain all equipment in the condition

received, to ensure equipment’s maximum useful life.

In addition, for government-owned property, the PI or PI designee must provide a preventive

maintenance program (e.g., lubrication, cleaning, calibration, and inspection on a regular

schedule). Maintenance records must provide description and date of maintenance actions

performed, and details of inspection and deficiencies discovered or corrected, as well as the

condition of the equipment. The PI must indicate this condition during the physical inventory.

Prior to performing any major repair or rehabilitation at cost to the government, the PI must

compliance with the requirements of FAR 45.510, OMB Circular A-110, and other applicable

federal regulations. Each subcontractor must submit equipment reports to the university in such a

manner and frequency as to allow the university to properly complete all required reporting. The

subcontractor will assume responsibility and obligations of the equipment, including university-

imposed reporting requirements, title transfers and final property closeouts.

Excess university-owned equipment in working condition but no longer required by a department

should be sold through Surplus Sales in accordance with the university policy.

Procedures for dealing with university-owned equipment that has been damaged beyond repair,

lost, or stolen are available at http://fbs.usc.edu/depts/eqp/page/8990/pol-and-proc-home/.

When government-owned property becomes excess to the contract or grant for which it was

When government-owned property becomes excess to the contract or grant, the PI or PI designee

must contact Equipment Management for disposition instructions. The equipment cannot be

disposed of until the sponsoring agency has provided approval.

The PI is responsible for notifying Equipment Management of all cases involving loss, damage,

or destruction of government/sponsor-owned property as soon as the facts become known.

Equipment Management will immediately notify the Administrative Contracting Officer by mail

and report all factual data as to circumstances surrounding the loss, damage or destruction, in

accordance with FAR 45.504 and the DOD Property Manual 4161.2-M.

(a) Date of incident;

(b) Description of equipment and identification tag number(s);

agency to the university, which is done at the time of the terminated Award Property Close-out.

A letter, along with the final property list, will be submitted to the sponsoring agency requesting

transfer of title or disposition instructions.

Transfers of equipment where title vests with the government require that the PI must contact

Equipment Management to process the transfer and work with Equipment Management to

prepare the "DD1149 Form" which must be approved by the sponsor project manager before the

asset may be permanently transferred to another entity. Upon approval, CAMS will be updated to

reflect changes.

Prior to transferring any equipment to another institution, regardless of equipment ownership, the

a list of the equipment to the appropriate dean for approval to transfer the equipment. Once dean

approval is granted, the PI or custodial department must forward the list of equipment to

Equipment Management for removal (retired as transfer in CAMS).

When university-owned equipment is transferred between departments, the department

responsibility can be made in CAMS. No change will be made to the recorded value of the

equipment.

When contractor-acquired equipment is transferred within the university from one contract to

another and the title vests with the sponsor, it becomes GFP. Equipment Management must

document all transfers to ensure accuracy of equipment records and completion of all reporting

Equipment Management will submit a Final Property Report to the Property Administrator or the

Administrative Contracting Officer within 60-90 days upon termination or completion of a

contract or grant. This report will include a complete equipment list and certification as to the

quality and quantity of all items in the final inventory. All items which have already been

directed or authorized for disposition by the Administrative Contracting Officer will be excluded

from the equipment list. The university will request disposition instructions or relief of

accountability via the following:

(a) Reasonable and proper consumption of property in the performance of the contract or

grant;

(b) Retention of the equipment for which the government received consideration with

The Administrative Contracting Officer may waive the closeout requirements if the equipment

applicable to the completed contract or grant is authorized for use on a follow-on contract or

grant. In those instances, Equipment Management will provide a complete inventory list of all

equipment to the Administrative Contracting Officer along with a letter indicating that record

balances have been transferred and that the university accepts responsibility and accountability

for the equipment under the terms of the follow-on contract or grant.

accessories, or auxiliary apparatus necessary to make it usable for its intended purpose. In

addition, acquisition cost may include ancillary charges, such as taxes, duty, freight, installation

and protective in-transit insurance.

 Donations from corporations (e.g., Hewlett Packard, IBM) are recorded at a fair market

price list.

 Donations by private individuals are recorded at the fair market value indicated by the

development costs, as well as all labor costs.

For indirect cost purposes, equipment is classified into six categories with depreciation as

indicated:

 Computers – 4 years

 Scientific equipment – 7 years

 General equipment – 10 years

 Vehicles – 9 years

 Fixed equipment – 10 years

not essential for its purpose.

the federal government or sponsoring agency.

with external sponsors.

property having a useful life of more than one year and an acquisition cost of $5,000 or greater

per unit. Items that cost less than $5,000 or have a useful life of less than one year are considered

materials and supplies.

reasonable spoilage and/or scrap.

ordering agreements, letter contracts, orders (such as purchase orders), under which the contract

becomes effective by written acceptance or performance, and bilateral contract modifications.

Contracts do not include grants and cooperative agreements.

that performs its own purchasing. For purposes of this document, the university is the contractor.

performing a contract and to which the government has title (FAR 45.101).

equipment assigned to the unit.

life of more than one year and an acquisition cost of $5,000 or greater.

government and subsequently delivered or made available to the university (FAR 45.101).

the government under the terms of the contract. It includes government-furnished property and

contractor-acquired property (FAR 45.101).

agency such as Jet Propulsion Laboratory, or loaned by the university to an external agency or

individual.

conducting extramurally funded research, training or a public service project. The individual may

also be known as Project Director or Project Administrator.

Officer assigned to administer the contract requirements and obligations relating to the

the performance of a prime contract or subcontract. It includes but is not limited to purchase

orders, and changes and modifications to purchase orders.

or for a prime contractor or another subcontractor.