Finding 544347 (2024-001)

2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.313(d) which requires that: Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: 1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. 2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every 2 years. 3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. 4. Adequate maintenance procedures must be developed to keep the property in good condition. 5. If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. The School purchased a forklift simulator desk and controls in the amount of $29,995 using Education Stabilization Fund grant funds and due to deficiencies in inventory controls, failed to add the assets to the School inventory system. The lack of maintaining the required property records not only violates federal grant requirements but also increases the risk of noncompliance with grant requirements going undetected in a timely manner. The School should ensure all federally procured equipment be included on property records and property records should include the information documented under item 1. above.