Inventory Management Requirements

1. Inventory Management Requirements FY16 Georgia Educational Leaders Conference Savannah Riverfront Marriott February 22-24, 2016

2. Presenters Grace McElveen Title I Education Program Specialist Georgia Department of Education School Improvement – Federal Programs gmcelveen@doe.k12.ga.us (912) 334-0802 Kathy Pruett Title I Education Program Specialist Georgia Department of Education School Improvement – Federal Programs kpruett @doe.k12.ga.us (706) 540-8959 Cathy Buescher Education Program SpecialistRural Education Achievement Program, Title VI, Part Bcbuesche@doe.k12.ga.us (229)561-4499

3. SCHOOL IMPROVEMENT & DISTRICT EFFECTIVENESS

4. Agenda • Why do an Inventory • Function of An Inventory • Definitions • Procedures for Inventory Management • Off-site Use of Equipment • Physical Inventory • Equipment Use in Targeted Assistance Program • Equipment Use in Private Schools • Disposition Policy • Loss, Damage or Theft of Equipment • Common Equipment/Inventory Findings

5. Why Do an Inventory 2 C.F.R. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Rewards • Section 200.313 – Equipment (d)(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, who holds title, the acquisition date, and cost of the property, the 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 sale price of the property.

6. Why Do an Inventory 2 C.F.R. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Rewards • Section 200.313 – Equipment (d)(2) • A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (Georgia requires inventory checks annually!) • Section 200.313 – Equipment (d)(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.

7. Functions of an Inventory Serves as a needs determination to assists LEAS in determining if additional materials and supplies need to be purchased in order to implement the district’s educational programs. Surveys the property in storage to determine if it is being (a) held for disposition, (b) in the process of production for disposition, or (c) to be consumed/utilized in the implementation of the district’s educational programs.

8. Functions of an Inventory Tracks the property undergoing repair.  Procedures include a process for repair and a work-in-process tracking system. Provides an inventory disposition process for the loaning and issuing of equipment, as well as the disposal process. 

9. Definitions Equipment: of nonexpendable, tangible personal property having a useful life of more than one year. Supplies: tangible personal property that is considered consumable items. Pilferable (Walkable) Items: those items that may be easily be lost or stolen.

10. Definition - Equipment 200.33 (pg99) Equipment: tangible, nonexpendible, personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit. Grantee may also use its own definition of equipment as long as the definition would at least include all equipment defined above. BRUSTEIN & MANASEVIT, PLLC

11. Definition - Supplies 200.94 (pg106) • All tangible personal property other than equipment • Computing devices are supplies is less than $5,000 • Computing devices 200.20 (pg97) • Machines used to acquire, store, analyze, process, public data and other information electronically • Includes accessories for printing, transmitting and receiving or storing electronic information BRUSTEIN & MANASEVIT, PLLC

12. Internal Controls 200.302(b)(4) (pg119) Regardless of cost, grantee must maintain effective control and “safeguard all assets and assure that they are used solely for authorized purposes.” BRUSTEIN & MANASEVIT, PLLC

13. Equipment200.313(a) and (c)(4) (pg127) Conditional Title vests with the non-Federal entity. Cannot encumberthe property without approval of federal agency or pass-through agency But When acquiring replacement equipment, may use the equipment to be replaced as a trade-in or sell the property and use the proceeds to offset the cost of the replacement property. BRUSTEIN & MANASEVIT, PLLC

14. Procedures for Maintaining an Inventory of Equipment • Acquisition of equipment • Method for entering information into inventory management system • Off-site use of equipment • Physical inventory • Equipment disposition • Supplies disposition • Lose, damage or theft of equipment • Equipment use for Title I, Part A targeted assistance programs • Equipment use for private schools

15. Requisition of Equipment • Determine the need and use of equipment. • Purchases made in accordance the Title I federal regulations. • Equipment must be reasonable and necessary. • Follow internal control proceduresfor approval and receiving of equipment. • Proper labeling of equipment. • Issuing equipment to proper location.

16. Entry of Information into Inventory Records • Title I director and principal of each school is responsible for inventory management. • Procedures should be in place to ensure: • all equipment is properly tagged. • adequate safeguards related to loss, damage or theft. • maintenance procedures to keep equipment in good condition. • a physical inventory of equipment.

17. Entry of Information into Inventory Records • Inventory Records should include: [2 C.F.R. Part 200.313(d)(1)] • Description • Serial Number/Identification Number • Funding Source and Percentage of Source (including FAIN) • Title • Vendor • Acquisition Date and Unit Cost • Location • Use (Student Instruction, Professional Development, Parent Involvement, etc.) • Condition • Disposition (including sale price, if applicable)

18. Off-Site Use of Equipment • Written procedures to ensure effective tracking system for equipment used off-site. • Possible components of the procedures: • date signed out, • purpose of use, • person responsible, and • condition of equipment upon return.

19. Use of Equipment 200.313(c)(1) and (2) (pg127) • Equipment must be used by the non-federal entity in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award. • When no longer needed, may be used in other activities with the following priority: • Projects supported by federal awarding agency • Project funded by other federal agencies • When used it may be shared (according to the above priorities) provided such use will not interfere with work on the original projects/programs. • Exception – Private Schools 76.661 (page 61) BRUSTEIN & MANASEVIT, PLLC

20. Physical Inventory • Physical Inventory shall be taken and results reconciled at least once every two years. • States may require standards above and beyond federal law – thus Georgia requires annual inventory checks • Purpose of physical inventory is to verify • the existence of equipment. • current utilization of equipment – is equipment being used for intended purpose. • the continued need of equipment. • the condition of the equipment.

21. Physical Inventory If an LEA cannot locate an item purchased with federal funds, it is difficult to demonstrate the item was necessary for the performance or administration of the grant, reasonable, or benefitted the program that paid for the item.

22. Equipment Use in Targeted Assistance Programs • Equipment purchase for TA program must be reasonable and necessary to implement a properly designed program for Title I, Part A participants. • Used with targeted assistance students, based on needs assessment. • The standards will have been presumed to be met and the use of Title I, Part A equipment in non-Title I, Part A activities is proper if use does not exceed 10-percent of the time the equipment is used in Title I, Part A activities.

23. Equipment Use in Targeted Assistance Programs If used on a less than full-time basis the equipment could be made available for other educational uses without interfering with its use in the Title I, Part A program. Equipment could be used on other projects or programs currently or previously supported by the Federal Government, “providing such use will not interfere with the work on the projects or programs for which it was originally acquired.”

24. Equipment Use in Participating Private Schools Section 1120(d)(1) of the ESEA requires that the control of the Title I funds, and the ownership of the  materials and equipment, purchased with Title I funds for private schools shall be in the LEA, and the LEA shall administer the funds, materials, equipment and property.  This is an LEA responsibility rather than the responsibility of the private school.

25. Equipment Use in Participating Private Schools District officials will: • complete the requisitions forms for ordering materials and/or equipment. • have the materials and equipment delivered to the LEA. • sign for the delivery of the materials and/or equipment. • label the equipment according to funding source to include the fiscal year of purchase and property of the respective school district.

26. Equipment Use in Participating Private Schools District officials will: • deliver the materials and/or equipment to the private school. • store materials and equipment in a secure location when not in use.   • maintain an inventory of all materials, equipment, and property purchased with Title I funds for use with eligible Title I students at private schools. The inventory shall contain the same requirements for any equipment purchased with Title I, Part A funds. 

27. Equipment Use in Participating Private Schools • Inventory must be updated as equipment items are purged or new purchases are made. • Equipment items purchased with federal funds are to be identified and physically marked as such. • Adequate safeguards must be in place related to the loss, damage, or theft of the equipment. Any loss, damage, or theft should be investigated and fully documented. • Adequate maintenance procedures should be implemented to keep the equipment in good condition.

28. Disposition of Equipment 200.313(e) (pg127) • When property is no longer needed in any current or previously Federally-funded supported activity, must follow disposition rules: • Nonfederal entity must request disposition instructions from the federal awarding agency if required by the terms of the grant. BRUSTEIN & MANASEVIT, PLLC

29. Disposition of Equipment 200.313(e) (pg 127) • Otherwise, may be retained, sold or otherwise disposed as follows: • Over $5,000 – pay federal share • If equipment is sold: federal awarding agency may permit non-federal entity to deduct and retain $500 or 10-percent of the proceeds for selling and handling instructions. • Under $5,000 – no accountability (still must formally dispose

30. Disposition of Supplies200.314 (pg128) If there is a residual inventory of unused supplies exceeding $5,000 in total aggregate value upon termination or completion of the project or program and the supplies are not needed for any other federal award, must compensate the federal government for its share. BRUSTEIN & MANASEVIT, PLLC

31. Disposition of Equipment • Establish accounting for lifecycle of goods (Depreciation Methodology). • When original or replacement equipment acquired with federal funds is no longer needed for the original project or program, the equipment may be retained, sold or disposed, if it is not needed in any other Title I, Part A like or federally funded project or program.

32. Disposition of Equipment • Procedures to eliminate any equipment item from the inventory • Equipment items with an acquisition cost/current per unit fair market (explanation is provided in Definitions section) value of less than $5,000 and are more than three years old may be retained, sold or disposed, with no further obligation to the GaDOE. The disposition of such items should be so noted on the equipment inventory maintained by the LEA.

33. Disposition of Equipment • Procedures to eliminate any equipment item from the inventory, continued • Equipment items with an acquisition cost of $5,000 or more may be retained or sold and the awarding agency (GaDOE) shall have a right to amount calculated by multiplying the current market value or proceeds from sale by the awarding agency (GaDOE’s) share of the equipment.

34. Disposition of Equipment • Procedures to eliminate any equipment item from the inventory, continued • If the current per unit fair market value is $5,000 or more, the equipment may be retained or sold and the awarding agency (GaDOE) shall have a right to an amount calculated by multiplying the current market value or proceeds from the sale by the state’s share of the equipment. The entity is permitted to deduct and retain from the state’s share $500 or 10-percent of the sales proceeds, whichever is less, for the entity’s selling and handling expenses.

35. Disposition of Equipment • Procedures to eliminate any equipment item from the inventory, continued • Forward a check made payable to the GaDOE in the amount of the state’s share. The amount is then returned to the state’s Title I LEA allocations fund. • The disposition of such items should be so noted on the equipment inventory maintained by the recipient. The recipient should include the date of disposal and sales price or the method used to determine current fair market value if the recipient compensates the state.

36. Loss, Damage or Theft of Equipment • Control system for adequate safeguards to prevent loss, damage, or theft • Process for investigation of any loss, damage or theft. • Indicate the proper documentation needed to notify and report loss, damage or theft.

37. Loss, Damage or Theft of Equipment • Types of Controls • Locks or security camera (for particularly valuable or vulnerable items). • Access controls to warehouses to limit entry by unauthorized personnel. • Use of logs or sign-in sheets for certain items of property; for example iPads, laptops, cameras, projectors. • Procedures for promptly entering items received into the inventory management system.

38. Title I, Part A Monitoring Considerations • Is equipment purchased allowable for Title I purchase? • Is equipment purchased reasonable and necessary? • What accountability in is place for purchasing equipment and keeping an inventory?

39. Title I, Part A Monitoring Considerations • Does the equipment policy/procedures address the following: • Definition of equipment • Purchasing procedures • Use of equipment • Maintenance of equipment and inventory • Physical inventory • Safeguard of inventory • Disposal of equipment

40. Title I, Part A Monitoring of Equipment • LEAs may be scheduled to have an on-site monitoring of inventory between September and December (mainly based on equipment expenditures) • Scheduling does not necessarily follow Cross-Functional Monitoring schedule – Notification provided in August • Monitoring conducted by your Title I Program Area Specialist • LEAs will provide • Inventory Management Procedures • Actual inventories for Selected Schools • Physical Inventories for Selected School

41. Title I, Part A Monitoring of Equipment • Common Findings • Failure to maintain an equipment inventory • No physical inventory conducted • If no signature and date – Inventory essentially not conducted! • Insufficient, outdated or no inventory management procedures • Disposition Procedures • Theft/Loss Reporting Procedures • Transfer/Repurposing of Equipment Procedures

42. Title I, Part A Monitoring of Equipment • Common Findings (continued) • Lack of sufficient documentation to support purchases • Alignment of purchases with school’s needs assessment • Quantities purchased deemed reasonable/necessary • Mobile computer carts in storage/no record of check-out • Unopened cases of equipment (some with ¼” of dust!) • Alternate use of equipment • “Repurposing” due to various factors is possible • Equipment transfer must be documented

43. Title I, Part A Monitoring of Equipment • Common Findings (continued) • Instances of fraud, waste and abuse • Allowable purchases used in unallowable ways • Missing items unaccounted for

44. Title I, Part A Program Specialists’ Contact Information

45. Title I, Part A Program Specialists’ Contact Information

46. Presenters Grace McElveen Title I Education Program Specialist Georgia Department of Education School Improvement – Federal Programs gmcelveen@doe.k12.ga.us (912) 334-0802 Kathy Pruett Title I Education Program Specialist Georgia Department of Education School Improvement – Federal Programs kpruett @doe.k12.ga.us (706) 540-8959 Cathy Buescher Education Program SpecialistRural Education Achievement Program, Title VI, Part Bcbuesche@doe.k12.ga.us (229)561-4499

47. Inventory Management Requirements FY16 Georgia Educational Leaders Conference Savannah Riverfront Marriott February 22-24, 2016