18 Miss. Code. R. 8-1.1-6
Overview
Uniform standards on inventory management shall ensure the effective use and control of Subgrantee property and equipment under the jurisdiction of Mississippi Department of Human Services (MDHS). Property inventory management is applicable to all non-expendable equipment and property having a useful life of one (1) year or more. All such property and equipment shall be tagged and placed on the inventory. There are other specific items also listed in this chapter that are required to be placed on MDHS' inventory regardless of price. It will be the responsibility of the MDHS Subgrant Property Officer, in collaboration with the MDHS Director of the Division of Property, to ensure proper reporting of all equipment and property and that such information is accurately recorded and maintained at the MDHS Division of Property.
If equipment or property is authorized under an MDHS subgrant, the property or equipment shall be purchased within ninety (90) days from the beginning date of the subgrant, or within thirty (30) days of the effective date of the modification which authorizes the purchase of property or equipment. If it becomes necessary to purchase other property or equipment to accomplish the purpose of the subgrant after the ninety (90) day beginning date of the Subgrant/Agreement, then this purchase will require a modification to the relevant section of the agreement. No equipment or property shall be purchased during the last thirty (30) days of the subgrant. These time limits are also applicable to property or equipment purchased with nonfederal funds or donated by third parties that is used to match funds under an MDHS subgrant.
This chapter serves as a minimum guide in the development of the MDHS inventory management system as it relates to subgrants and is meant to provide guidelines for the following:
Subgrant property management implementation shall be the responsibility of the Subgrantee, which shall be verified by MDHS Division of Property in conjunction with the Funding Divisions. The Division of Property and the Funding Division shall notify the Division of Procurement Services Subgrant Management Supervisor to address any property related issues. Property which has been stolen shall be reported by the sub-grantee/contractor to the Division of Property and the Funding Division within twenty-four (24) hours of discovery.
Failure to abide by the property requirements outlined within this chapter or any applicable Federal or State property requirements shall be grounds for MDHS to implement any of the following measures:
Policy
Subgrantees may refer to 2 C.F.R. § 200.310 through § 200.327, or applicable Federal law regulating property management for further guidance on property management standards. All property and assets purchased through MDHS subgrants shall be placed on inventory in accordance with the applicable Federal guidelines, the statutes of the State of Mississippi, and the rules set forth in the State Property Officers Manual. The State Property Officers Manual is available online through the Mississippi Office of the State Auditor's website.
Purchase Approval: All equipment purchased with subgrant monies shall be specifically authorized through the Cost Summary Support Sheet and the Budget Narrative of the subgrant agreement. Any deviation shall require a budget modification of the subgrant. The equipment needs of the Subgrantee shall be assessed by the Director of the Division of Property in conjunction with the Director of the MDHS Funding Division who will analyze all prior subgrants/contracts, and the equipment needs expressed in the Scope of Services and the Terms and Conditions of the current subgrant agreement. All means of acquiring the proposed equipment, e.g., leasing, shall be reviewed before authorization is given by MDHS.
Duplication of property or equipment purchases is prohibited by statute. A capital lease or lease purchase agreement is prohibited by statute.
The assessment criteria to be used for purchase approval shall include, but is not limited to, the following:
Note: All property or equipment purchased, in whole or in part, with funds provided by MDHS, shall be held in trust by the Subgrantee as trustee for MDHS, and shall not be encumbered without the written or signed approval of the MDHS Funding Division Director. The Subgrantee shall record liens, or other appropriate notices of record, that property or equipment has been acquired, or where applicable, improved with funds provided by MDHS.
Reference 2 C.F.R. § 200.316
Purchase of Used Property and/or Equipment
Subgrantees who wish to purchase used property and/or equipment, must submit a written request and justification to the appropriate MDHS Funding Division Director for approval, before proceeding with procurement. This is in addition to the established purchase requirements set out in Chapter 4, Procurement Standards.
Use of Property and/or Equipment under MDHS Subgrants
The Subgrantee shall use the property and/or equipment in the project or program for which it was acquired as long as needed, whether the project or program continues to be supported by Federal funds and shall not encumber the property without approval of the MDHS Funding Division Director. When no longer needed for the original project or program, the Subgrantee shall contact the MDHS Funding Division Director, and request written authorization for the Subgrantee to use the equipment in connection with the Subgrantees other federally-sponsored activities, as required under federal regulations.
Reference 2 C.F.R. § 200.439
Statement of General Policy - Property Inventory Rules
Any equipment/property purchased through an MDHS Subgrant shall be itemized by the Subgrantee on an inventory control list, regardless of price.
In conformity with State Property regulations, equipment or property items 1-12 listed below shall be included on inventory regardless of the price as required by the Office of the State Auditor. All other items not listed with a useful life of one year or more are required to be tagged by MDHS Division of Property.
NOTE: Any equipment or property item(s) purchased that contains a processor (e.g., but not limited to laptop, cell phone, iPad, etc.), regardless of purchase price, shall be included on the Inventory List and shall have an agency "Property of MDHS" sticker applied.
If authorized under an MDHS subgrant, items 1 -12 listed below shall be listed on the Budget Narrative under the budget category of Capital Outlay-Equipment regardless of the price.
Inventory Control List
All non-expendable equipment or property purchased with (or used to match) federal and/or state funds shall be listed on an Inventory Control List (MDHS-PROP-SE01). The Inventory Control List must be submitted to the MDHS Subgrant Property Officer for any new and/or additional equipment purchased once the equipment or property has been received and paid for by the Subgrantee. Both the Subgrantee and the MDHS Subgrantee Property Officer shall maintain a complete and up-to-date list of all equipment or property purchased with Subgrant funds.
Information for the Inventory Control List shall include:
Changes in status, such as, but not limited to, location and person responsible, require that the Subgrantee complete the Subgrantee Inventory Transfer Form (MDHS-PROP-114B).
Property Identification
All Subgrantee equipment and/or property purchased with Federal and/or State funds or provided as match for Federal and/or State funds, shall have permanent identification numbers assigned by the MDHS Property Division after submitting the Inventory Control List (MDHS-PROP-SE01). Permanent identification shall be made by using metal tags, vinyl tags, etching, or other appropriate means of identification. The equipment or property purchased through subgrants/agreements awarded by MDHS shall be tagged and accounted for by the MDHS Property Division. The Division of Monitoring will verify equipment and/or property purchases and whether or not they are tagged during the monitoring review process.
Physical Inventory
A periodic physical inventory shall be performed by all Subgrantees at least twice yearly and submit any discrepancies found to the appropriate Funding Division and the Subgrant Property Officer. The physical inventory shall consist of an actual accounting of all Subgrantee/lower-tier subrecipient equipment or property on the Subgrantee location listing and/or Inventory Control List, acquired with (or used to match) Federal and/or State monies under an MDHS subgrant. Property records pertaining to the purchase of equipment and/or property shall be inspected for correctness before items are identified and tagged for inventory control.
Location and use of equipment and/or property shall be verified by the authorized and designated MDHS Subgrant Property Officer who is in the MDHS Division of Property. Subgrantees must contact the MDHS subgrant Property Officer and the MDHS Funding Division to report any property and/or equipment that is not being utilized or managed under the terms of the subgrants. Any such property and/or equipment not being utilized or managed under the terms of the subgrants shall be recovered and/or redistributed with approval by the MDHS Property Officer in conjunction with the Director of Property.
Should a subgrant be terminated or not renewed, any equipment and/or property purchased under the subgrant with public funds or MDHS funds shall neither be transferred to another location nor remain at the present location under a new subgrant with a different Subgrantee, without the prior written approval from MDHS Funding Division Director. The Subgrantee Inventory Transfer Form (MDHS-PROP-114B) shall be completed and submitted to the MDHS Property Division to the attention of the MDHS Subgrant Property Officer.
Lost, Stolen, or Damaged Equipment or Property
A Subgrantee shall submit in writing to the MDHS Division of Property and the MDHS Funding Division, within twenty-four (24) hours of discovery, a detailed explanation of any stolen, misused or unaccounted for equipment and/or property. Subgrantees can utilize the Subgrantee Lost or Stolen Packet to account for property purchased with Federal and/or State funds or provided as match for Federal and/or State funds when the item has been lost or stolen. The MDHS Division of Property may initiate an investigation to determine the cause and culpability of the matter as necessary. In case of theft, robbery or mysterious disappearance, the local police or sheriff's department should be notified. If so notified, the name of local police or sheriff's department official and the date of the loss shall be included in the agency report. If such was not reported to a local police or sheriff's department at the time of the discovery, a complete explanation of such failure shall be provided. A copy of the police or sheriff's department report shall be forwarded with a letter of explanation to the MDHS Director of Property and the MDHS Funding Division, the Subgrant Property Officer, and the Director of Administrative Services. Additionally, if equipment loss occurs at the home of an employee of the Subgrantee, the employee shall provide a written statement from his/her insurance carrier indicating whether or not the stolen or lost item was paid for under his/her homeowner's or car insurance policy. The MDHS Subgrant Property Officer and Director of Property Division shall review the information and provide the MDHS Funding Division Director a recommendation of action to be taken, if appropriate.
Liability
The Subgrantee is required to maintain enough insurance coverage for real property and equipment acquired or improved with Federal funds that is at least equivalent to insurance maintained on non-Federally funded real property or equipment. The Subgrantee is not responsible for insuring Federally-owned property or equipment unless required by the terms and conditions of the Federal award. (Refer to 2 C.F.R. § 200.310 for guidance).
MDHS has the authority to recover the value of any missing property. If property is determined to be missing, an MDHS investigation may be initiated to determine the cause and culpability. If an investigation leads to negligence or misconduct with regards to the missing property, a demand may be made against the head of the Subgrantee agency, the agency's property officer and/or the appropriate supervisor/director or employee.
Property Disposal
Subgrantees shall send a completed Subgrantee Disposition Report Form (MDHS-PROP-114A) to the MDHS Subgrantee Property Division requesting authorization for disposal when an item is either at end of useful life or no longer needed. The MDHS Funding Divisions is ultimately responsible for the approval and/or denial of the disposal request.
18 Miss. Code. R. 8-1.1-6