4.9 Property Management Standards

4.9.2 Equipment and Supplies

Effective date: July 1, 2025

Equipment is tangible personal property (including information technology systems) that has a useful life of more than one year and a per unit acquisition cost that equals or exceeds the lesser of the capitalization level established by the recipient for financial statement purposes, or $10,000.¹

Supplies are all tangible personal property other than those described in the definition of equipment above and having an acquisition cost 5below the lesser of the capitalization level established by the recipient for financial statement purposes or $10,000, regardless of the length of its useful life.²

1. Use
   Equipment acquired under a grant agreement must be used for its originally authorized purpose until funding ceases or it's no longer needed for the project. Equipment may be retained as long as needed for the program, regardless of whether the program continues to be supported by the federal award. Equipment no longer needed for its originally authorized purpose may be used in the following order of priority: (1) for other DOL funded activities or (2) other federally funded activities.³
   
   The subrecipient must make equipment available for use on other federally funded programs if such use does not interfere with the purpose for which it was originally acquired. First preference should be given for other DOL funded activities, followed by other federally funded activities. While using the equipment for non-federally funded projects is allowable, it must not interfere with the purpose for which it was originally acquired, and user fees should be considered, as appropriate.⁴ However, equipment acquired with grant funds must not be used to provide such services for a fee that is less than a private company would charge for similar services unless specifically authorized by law.⁵
   
   When acquiring replacement equipment, the equipment to be replaced may be used as a trade-in or may be sold. If sold, the proceeds should be used to offset the cost of the replacement equipment.⁶
2. Management Requirements
   Subrecipients must meet the following requirements for all DWD-DET purchased equipment, whether acquired in part or its entirety with federal funds:⁷
   1. Equipment records or register that reflect:
      • Description of equipment;
      • Serial number or other identification number;
      • Funding source, including the Federal Award Identification Number(FAIN);
      • Titleholder;
      • Acquisition cost and date;
      • Percentage of federal contribution to the purchase;
      • Current use, condition, and location;
      • Any disposition data, such as the date of disposal and sale price.
   2. A physical inventory of equipment must be taken at least once every two years, with the results reconciled with the equipment records.
   3. Equipment must be maintained in good, working order and condition.
   4. Subrecipient must have a control system in place to ensure safeguards for preventing property loss, damage or theft. Any loss, damage, or theft of equipment must be investigated. The subrecipient must notify DWD-DET of any loss, damage, or theft of equipment that will have an impact on the program.
   5. Insurance for equipment purchased or improved with federal funds is required.⁸ Such costs are chargeable to the grant.⁹
   6. If the subrecipient is authorized or required to sell the equipment, the subrecipient must have proper sales procedures in place to ensure the highest possible return.
3. Disposition
   Disposition is the act of selling or otherwise disposing of equipment. When original or replacement equipment is no longer needed for the original program or for other activities currently or previously supported by DWD-DET, equipment disposition instructions must be requested from DWD-DET if required by the terms and conditions of the federal award. Otherwise, equipment disposition will be made as follows:¹⁰
   1. Equipment with a current per unit fair market value of $10,000 or less may be retained, sold, or otherwise disposed of with no further responsibility to DWD-DET.
   2. Equipment with a current per unit fair market value more than $10,000 requires DWD-DET approval for disposition. This includes both equipment purchased with DWD-DET funds or equipment transferred from other programs. This requirement applies to such equipment whenever the subrecipient discontinues operation of a DWD-DET program, has no further use for the equipment, intends to use it for a purpose other than a DWD-DET program, wants to trade the equipment, or needs to dispose of unusable equipment. Before any such equipment is disposed of, the subrecipient must comply with the following requirements:
      1. Ensure all relevant records are up to date.
      2. Submit the following information in writing to the appropriate DWD-DET program manager for all equipment to be disposed of:
         1. Description
         2. Acquisition source
         3. Per unit acquisition cost
         4. Quantity
         5. Condition
         6. Funding source under which equipment was acquired
         7. Reason for the disposition
         8. Proposed disposition, including what will be done with any money resulting from the disposition.
      3. Written authorization from DWD-DET must be obtained.
      4. The sale of equipment that is no longer needed shall be an action of last resort. Before a sale is made, the subrecipient shall take the following steps, listed in order of priority ranking:
         1. Transfer the equipment to other DWD-DET funded programs of the subrecipient.
         2. Transfer the equipment to similar DWD-DET funded programs of other subrecipients within the state. In transferring equipment to similar programs, equipment should first be offered to other Workforce Development Boards (WDB), then to non-WDB grantees within the Workforce Development Area (WDA). Any departures from this order must be justified in writing.
         3. If no such program is found, the equipment may be sold.
      5. For equipment that cost $10,000 or more that was only partly purchased using DWD-DET funds, the disposition standards outlined above will apply. The amount of reimbursement to DWD-DET shall be computed by multiplying the percentage of DWD-DET funding towards the original purchase by the current market value or proceeds from the sale.
   3. Any proceeds received from the sale of DWD-DET funded equipment are considered program income and shall be subject to requirements of program income in §4.6 of this chapter.
   4. The disposition of all DWD-DET equipment and equipment transferred from other programs must be fully documented.
   5. The subrecipient may transfer title to the property to DWD-DET or to an eligible third party provided that the subrecipient must be entitled to compensation for its attributable percentage of the current fair market value of the property.
   6. If the subrecipient fails to take appropriate disposition actions, DWD-DET may direct the subrecipient to take disposition actions.
4. Retention. When included in the terms and conditions of a Federal award, DWD-DET may be authorized to permit the subrecipient to retain equipment, with no further obligation to DWD-DET or the federal government, unless prohibited by law.

• ¹ 2 CFR 200.1 "Equipment"
• ² 2 CFR 200.1 "Supplies"
• ³ 2 CFR 200.313(c)(1)
• ⁴ 2 CFR 200.313(c)(2)
• ⁵ 2 CFR 200.313(c)(3)
• ⁶ 2 CFR 200.313(c)(4)
• ⁷ 2 CFR 200.313(d)
• ⁸ 2 CFR 200.310
• ⁹ 2 CFR 200.447(a)
• ¹⁰ 2 CFR 200.313(e)

4.9.3 Real Property

Effective date: July 1, 2025

Real property is defined as a parcel of land and everything that is permanently attached to the land, including land improvements, structures, and subrecipientsappurtenances thereto, and legal interests in land, including fee interest, licenses, rights of way, and easements Real property does not include moveable machinery and equipment.¹ Subrecipients are not allowed to purchase real property for grant purposes, unless specifically authorized by the federal award. The following provisions shall apply:

1. Subrecipients must obtain written approval from DWD-DET and DOL prior to purchasing real property.
2. Title to real property acquired or improved with federal grant funding shall vest in the subrecipient upon acquisition.
3. Real property must be used for the originally authorized purpose as long as it is needed for that purpose. While the property is being used for the originally authorized purpose, the subrecipient must not dispose of or encumber its title or other interests except as provided by DOL. Easements for utility, cable and similar services that benefit the real property and are consistent with the authorized use are not considered an encumbrance.
4. Subrecipients must provide DWD-DET with the location of the real property and the federal share of the acquisition cost.
5. Allowable costs relating to real property must be in accordance with limitations in current federal standards.
6. Disposition of real property shall follow written instructions from DWD-DET. DWD-DET must specify one of the following disposition methods²:
   1. Retain title after compensating DOL;
   2. Sell the property and compensate DOL;
   3. Transfer title to DOL or a third party designated and approved by DOL.

• ¹ 2 CFR 200.1 "Real property"
• ² 2 CFR 200.311(d)

4.9.4 Intangible Property

Effective date: July 1, 2025

Intangible property is any type of property that represents something of value but is not physical in nature. Examples of intangible property include, but are not limited to, trademarks, copyrights, patents, investments and ownership interests, goodwill, and life insurance contracts.¹ The following provisions shall apply:²

1. Title to intangible property shall vest in the subrecipient upon acquisition.
2. The subrecipient must use that intangible property for the originally authorized purpose and must not encumber the property without the approval of DWD-DET.
3. To the extent permitted by law, the subrecipient may copyright any work that is subject to copyright and was developed, or for which ownership was acquired, using federal funding. DOL and DWD-DET reserve a royalty-free, nonexclusive, and irrevocable right to reproduce, publish, or otherwise use the work for federal purposes and to authorize others to do so.
4. The subrecipient is subject to applicable regulations governing patents and inventions, including government-wide regulations in 37 CFR part 401.³
5. Disposition occurs in the same manner as for equipment purchased with WIOA funds. See subsection 4.9.2(C) in this chapter.

• ¹ 2 CFR 200.1 "Intangible property"
• ² 2 CFR 200.315
• ³ 37 CFR part 401