UNO Subcontractor Property Management Instructions
These procedures supplement the University Property Control Operating Procedures and all procedures must be strictly adhered to by all subcontractors. This includes but is not limited to the control, care and disposition of Government property: OMB Circular A-110 and FAR Part 45.510 apply to each agreement entered into by the University whereby government property may come under the control of a subcontractor. Whenever a subcontractor is in possession of Government property, the University will ensure that the subcontractor has a federally approved property system that is in compliance with these regulations. However, the University of New Orleans is responsible and accountable for all Government property in the possession of the subcontractor. It is imperative that the subcontractor adheres to all the appropriate provisions in its subcontracts providing for Government property.
Should the subcontract allow for the subcontractor to acquire material on behalf of the University as Government property, it must ensure the University has obtained all necessary approvals as stipulated in the contract between the University and Government. Upon receipt, title to this equipment will vest with the Government.
When equipment is ordered by the subcontractor, equipment/material should be shipped directly to the subcontractors location. All shipments should be inspected and the receiving date should be noted on the applicable invoice for future reference. If there are any discrepancies or damage in the shipment it should be handled immediately. Upon receipt, title to the equipment will vest in the Government and as such all procedures related to the handling, care, inventory, utilization and disposition, etc. will be done in accordance with federal regulations.
All subcontractors will be issued a block of University and Government tags to be affixed to Government equipment by the University's Property Control Office. The subcontractor will be responsible for accounting for all used and any unused tags given to them at the time of award. Both tags will be affixed to equipment in a visible location so as not to interfere with the operation of the equipment when the equipment is received. If a tag cannot be affixed because the equipment is to small, the subcontractor will so annotate a copy of the purchase order as "Untaggable". The tag can then be affixed to a copy of the purchase order for further reference.
The University will maintain the official property records for all government property. The subcontractor’s records will be used as a secondary locator record. The subcontractor must maintain the same data as the University’s system (see Property Control Operating Procedures section VI A2). For subcontractors with large amounts of government property and unless the Government authorizes otherwise, on-site review of records and inventory of all Government property in the possession of the subcontractor must be done periodically.
Government property should not be removed from the site of the subcontractor without prior written permission from UNO Property Control.
Government property in the possession of the subcontractor should be easily locatable, easily identifiable, and stored in such a way to ensure that it is always protected. If equipment becomes idle at any time the subcontractor should immediately, in writing, request disposition instructions from UNO's Property Control. Property Control will coordinate the request and final disposition. It is reasonable to expect that the subcontractor be able to quickly distinguish their own property from that of the government.
Because an inventory report must be submitted annually to the state (due approximately at the end of May) and also to the Government (due by September 30) the University requires that all subcontractors inventory all government property and report it semi-annually. The reports will be due to UNO Property Control on March 1 and again on September 1. This will allow time for all records to be reviewed accordingly. At the termination or completion of the subcontract, a final inventory will be conducted and submitted within 30 days so UNO's Property Control can coordinate final disposition.
(As it relates to Fabrication) – When equipment is fabricated and the total acquisition cost exceeds $5000 it will be immediately added to the subcontractor’s equipment records and the information on this item will be transmitted simultaneously to UNO Property Control.
Utilization of Equipment
Government property in the possession of the subcontractor may only be utilized for the purpose of the contract.
The subcontractor is responsible for preventative maintenance on all government equipment. Should any major repairs be necessary, written approval from UNO Property Control is required.
Should surplus property be identified by the subcontractor, it shall be reported to UNO Property Control. Instructions will be given on disposing of the equipment and making any necessary records adjustments. Prior to any Government property being scrapped, traded-in, dismantled for parts or transferred, the subcontractor must request written authority from UNO Property Control who will coordinate final disposition. Additionally, the subcontractor must immediately report to UNO Property Control all cases of loss, damage or destroyed government property. Do not remove Government property from the records until instructions are received.
Contract Property Closeout
The subcontractor must complete a final inventory at the completion or termination of the subcontract. Disposition instructions will be given to the subcontractor of all Government property in these situations by UNO Property Control.