Property Management Operating Procedures Manual

Chapter 8:  Subcontractor Control

48 Code of Federal Regulations subpart 45.5, 45.106, 45.502, 45.504(c), 45.505 (a), 45.510 and 52.245.5 Office of Management and Budget Circulars A-110 and A-21

Subcontractors

Michigan Tech is responsible for all federal-funded equipment acquired by or borrowed to a subcontractor and for ensuring that a subcontractor's property control is adequate.

The subcontractor must identify the need to purchase equipment and supplies, and identify the items specifically with their original proposal.

The subcontractor must have a property management system in place in order to receive, borrow, or purchase equipment. The property management system must include procedures necessary for compliance with federal regulations.  The subcontractor is to provide either a copy of their system approval documentation from the government, or a certification letter from the subcontractor's audit/accounting firm, to be kept as record by Michigan Tech.

The subcontractor's property physical inventory procedures must meet the requirements of both Michigan Tech and the sponsor. The subcontractor is also required to comply with federal regulations in order to adequately care for and maintain such property and assure that it is used only as authorized by the contract. see subcontractor requirements

Title to equipment acquired by a non-profit subcontractor with government funds may vest in the subcontractor when permitted by the sponsor's and MTU provisions.  Title to equipment acquired by a for-profit subcontractor with government funds will vest with MTU or with the government. 

When a non-profit or for-profit subcontractor acquires equipment with non-government funds, title to the equipment is determined by MTU with the initial proposal.

When the subcontractor acquires property to be titled to the sponsor or to Michigan Tech, the subcontractor shall provide to MTU the invoice or shipping documents upon receipt of the property.  Invoicing to Michigan Tech must detail equipment purchases, along with the copy of the paid equipment invoice. 

Equipment reports are submitted to MTU for referral to the sponsoring agency, as required by the prime award and\or at contract closeout.  Federal reporting of equipment is completed by Michigan Tech.