Page of 1 of 9 POLICY STATEMENT The Coalition shall adhere to Federal and state laws, regulations, and rules requiring the implementation of proper controls related to the management, maintenance, reporting, and disposition of Tangible Personal Property equipment purchased with state and federal funds. PROCEDURE A. AUTHORITY Legislative authority outlining the specifying requirements for property management include: 1. 45 CFR Part 75 Code of Federal Regulations 2. Section 1002.84(11), Florida Statute - Complying with Tangible Personal Property Requirements 3. Chapter 274, Florida Statutes Tangible Personal Property Owned by Local Governments 4. Rule 69I-73, Florida Administrative Code - Tangible Personal Property Owned by Local Governments 5. OEL-FG-0004-14, Office of Early Learning Fiscal Guidance Tangible Personal Property B. COALITION RESPONSIBILITIES 1. It is the Coalition s responsibility to be knowledgeable about and appropriately implement federal, state, and local requirements, as well as applicable regulations, rules, policies, and procedures, to ensure that all laws, regulations, and rules are appropriately adhered to. 2. Failure to abide by these federal and state requirements can result in auditing or monitoring exceptions, and it may negatively impact the ability of the Coalition to meet its program goals and objectives. C. IDENTIFICATION OF FUNDING REGULATIONS 1. State Funding a. Program VPK b. Purchase - Tangible, personal properties purchased solely with state funds (e.g., PK funds) c. All Applicable Requirements - Chapter 274, F.S., and Rule 69I-73, F.A.C. 2. Federal Funding a. Program - School Readiness b. Purchase - Tangible personal properties purchased solely with federal funds (e.g., SR funds) c. All Applicable Requirements - 45 CFR Part 75, Chapter 274, F.S., and Rule 69I-73, F.A.C. 3. Combined Funding a. Program VPK AND School Readiness b. Purchase Tangible personal properties c. All Applicable Requirements - When entities combine funding for the purchase of tangible property, the more restrictive requirements apply. D. BACKGROUND 1. The federal Child Care and Development Fund (CCDF) and Temporary Assistance for Needy Families (TANF) block grants provide a substantial part of the funds allocated and awarded to the Coalition or its contractor for the Coalition 's SR program.
Page of 2 of 9 2. The U.S. Department of Health and Human Services (HHS) administers both grants. 3. Federal regulations governing grant funds that HHS provides require recipients of the federal grant funds to follow certain requirements for the management, disposition, and utilization of property purchased with the federal grant funds (45 C.F.R. Part 75). 4. These requirements include maintaining certain records of property purchased with the federal grant funds and performing a physical inventory of the property, at least once every two years. These federal regulations are limited to "tangible nonexpendable personal property charged directly to the award and having a useful life of more than one year and an acquisition costs of $5000 per unit (45 CFR Part 75). Federal regulations also allow a state to establish lower limits for these requirements. Because Florida Early Learning Programs draw down federal funds from the State Treasury, Coalitions and applicable contractors must also follow applicable state laws and rules. 5. State requirements relative to the management and disposition of tangible personal property are sometimes more restrictive than the federal regulations applied to tangible personal property. 6. The Coalition is required to inventory all tangible personal property with value or cost of $1,000.00 or more and the normal expected life of one year or more. 7. The Coalition is also required to conduct this inventory of its property annually. E. OPERATIONAL DEFINITIONS 1. Tangible Personal Property Chapter 274, F.S., and Chapter 691-73, F.A.C., defines Tangible Personal Property as an item of a non-consumable and non-expendable nature, the value or cost of which is $1000 or more and the normal expected life of which is one year or more. 2. Custodian The person/agency responsible for lawful custody of Tangible Personal Property. The Coalition s Chief Executive Officer shall act as custodian as required by OEL. 3. Custodian Delegate The person acting under the supervision of the Custodian to whom the Custodian has delegated the custody of property and from whom the custodian receives custody receipts. The Coalition s Finance Director shall act in this capacity 4. Disposition Disposition is the final status of tangible personal property (e.g., sale, scrap, donation, transfer, etc.) when the Coalition removes it from the Master Personal Property Inventory List 5. Early Learning Coalition Early Learning Coalitions are not-for-profit organizations authorized to administer the state's early educational programs at the local level in accordance with Parts V & VI, 1002. F.S. 6. Equipment Equipment is defined as tangible, personal property,with a value or cost of $1000 or more, and having a projected useful life of one (1) year or more, as well as any hardback-bound book with a value or cost of $250 or more that is not circulated. 7. Office of Early Learning Department of Education OEL is a division of the Florida Department of Education designated as the lead agency for administration of the Federal Child Care and Development Fund. This includes the School Readiness
Page of 3 of 9 program (FS 2156) and the Voluntary Prekindergarten Program, in accordance with Chapter 1002. 8. Grant Purchased Property Grant Purchased Property is an item defined as equipment stipulated in 45 CFR Part 75 and defined as "property" in s.274, FS., and Rule 691-73, F.A.C., which a Coalition or its contractor purchased, using state or federal funds allocated and awarded by the office of Early Learning. 9. Inventory Management Inventory Management includes all functions related to the recording, tracking, and safeguarding of equipment, to include the monitoring/management of equipment moved to and from various locations within the Coalition s locations or offices. 10. Material Service Organizations Material Service Organizations are those subrecipients or other entities contracted by the Coalition, to administer or manage grant program (s). Coalitions may contract with other entities to perform and/or manage portions of the services for the School Readiness and/or the VPK programs This type of organization may have a subrecipients contract relationship with the Coalition and is often called a "material service organization.'' 11. Pass-through Entity A pass-through entity is a non-federal entity that provides a federal award to other entities to carry out a federal program. Pass-through entities are also known as recipients/subrecipients. The Office of Early Learning is a subrecipient and receives grant program funds directly from the federal awarding agencies. The Coalition receives grant program funds from the Office of Early Learning and are subrecipients of Office of Early Learning since they perform/manage operations material to the School Readiness and VPK programs. When the Coalition awards federal funds to other entities to carry out program activities, those programs are considered the Coalition s subrecipients, with the exception of private providers who are not required to meet subrecipient requirements established in legislation. 12. Program The term program is defined as a grant, appropriation, or other designated funds, and approved costs. Coalitions must accumulate and report to the funding sources. 13. Property Recording Threshold An entity must record in its financial system as property for inventory purposes all property with a value or cost of $1000 or more and with a projected useful life of one year or more. If a Coalition or contractor has a more restrictive threshold level, the Coalition or contractor will follow the most restrictive threshold level. 14. Equipment Title According to federal regulations, any equipment title acquired with HHS funds must vest with the Coalition. 15. Vendor Vendor is defined as a dealer, distributor, merchant or other seller providing goods or services to implement a federal program. These goods or services may be for an organization's own use or for the use of beneficiaries of the federal program 16. Voluntary Pre-kindergarten Program (VPK)
Page of 4 of 9 The Voluntary Pre kindergarten Program offers free prekindergarten to all eligible 4-year-old children in Florida. Private Pre-Kindergarten providers and school-based sites comprise the delivery system for VPK and General Revenue (GR) funds the program. F. STATE GUIDANCE 1. Chapter 274, F.S. and Rule 69I-73, F.A.C. provide the minimum standards necessary to adequately control, safeguard, and account for tangible personal property. 2. To reasonably assure compliance with Chapter 274, F.S. and rules of the Chief Financial Officer, the Coalition s internal controls shall include appropriate measures to ensure that all tangible personal property acquisitions are identified, appropriately marked, and accurately recorded in the appropriate records. 3. An annual physical inventory shall be conducted and reconciled to related property records by persons who do not have asset custody responsibilities. G. EQUIPMENT MANAGEMENT 1. Recording of Property Federal regulations, State statutes, and State rules require the Coalition to maintain adequate records of property in its custody. Each property record entered at the time of the purchase transaction shall include the following information: a. Award Number b. Funding Source c. Identification number d. Description of item or items e. Physical location (the city, county, address or building name, and room number therein) f. Name of custodian delegate with assigned responsibility for the item(s) g. In the case of a property group, the number and description of the component items comprising the group h. Name, make, or manufacturer, if applicable i. Year and/or model(s), if applicable j. Manufacturer s serial number(s), if any, and if an automobile, vehicle identification number (VIN) and title certificate number, if applicable k. Date acquired l. Cost or value at the date of acquisition for the item m. Method of acquisition n. Voucher or Purchase Order Number o. Check or warrant number p. Date the item was last physically inventoried q. Condition of the item at time of inventory r. Percentage of Federal Participation s. If disposed of, use or refer to the information prescribed in Rule 69I-73.005, F.A.C. 2. Identification/Marking of Property a. Within thirty (30) days of receipt, a decal or tag shall be affixed to the item of grantpurchased property to identify the property.
Page of 5 of 9 b. The decal or tag shall contain at least, the name of the Coalition and a unique identification number. c. The Coalition shall record the property tag identification number (which may include an electronic scanning code [ barcode ] to facilitate electronic inventory procedures) on the OEL Property Tag Assignment Form or a form the Coalition adopts that is substantially similar. 3. Location of Marking a. The Coalition shall mark items of a similar nature in a similar manner to facilitate identification. In determining a marking location, the Coalition shall give careful consideration to the intended use of the items; the probability that wear, vandalism, or routine maintenance functions could obliterate the marking; and the appropriateness of the marking method chosen. b. The location of the marking and the marking method chosen must not mar the appearance of the item. 4. Inventory of Grant-Purchased Property a. In accordance with Rule 69I-73, F.A.C., the Coalition shall conduct a physical inventory of equipment, at least annually, and whenever there is a change of custodian or change of custodian s delegate. b. The Custodian delegate shall not personally inventory items for which they are responsible. The Office Administrator or other staff designee shall inventory all applicable items to maintain separation of duties and proper internal control processes. c. The Coalition shall provide its updated Master Property Inventory List to the Office of Early Learning no later than October 1 of each year or within thirty (30) days of a change in custodian or Custodian s delegate. (The Office of Early Learning Master Property Inventory Form is a sample format for the inventory report.) d. For the inventory of an item physically present and properly described on the Master Property Inventory List, the Coalition shall: i. Physically inspect the item ii. Match the property tag identification number and description of the item against the Master Property Inventory List iii. Verify the current condition of the item against the condition described on the Master Property Inventory List iv. Record the initials of the person taking the inventory next to the item on the Master Property Inventory Form, indicating that the person inventoried the item v. Record the date the Inventory was performed d. For the inventory of an item physically present with incorrect or missing information: 1. If an item s property tag identification number matches the Master Property Inventory List but the description of the item does not match, the custodian shall investigate and correct the description as appropriate. a. The custodian shall draw a line through the incorrect description, record the correct description immediately above or after the incorrect entry, and follow the steps described above. 2. If an item s property tag identification number does not appear on the Master Property Inventory List, the custodian shall investigate and correct the inventory as appropriate.
Page of 6 of 9 a. The custodian shall add the item to the Master Property Inventory List and follow the steps described in subparagraph above. 3. If an item does not have a property tag identification number, the custodian must investigate and correct the inventory as appropriate. a. The custodian shall determine whether the item appears on the Master Property Inventory List and then determine the identification number of the original property tag. b. The custodian shall place a replacement tag with the original property tag identification number on the item, and follow the steps described above. 4. If the item does not appear on the Master Property Inventory List, a new property tag shall be placed on the item, the item will be added to the Master Property Inventory List, and steps described above shall be followed. 5. If the manufacturer s serial number on the item does not match the serial number on the Master Property Inventory List, a line shall be drawn through the incorrect serial number, the correct serial number will be recorded immediately above or after the incorrect entry, and the steps listed above shall be followed. e. For the inventory of an item on the Master Property Inventory List that is no longer physically present, a line shall be drawn through the entry and the appropriate notation shall be made as follows: 1. Transferred : The Coalition transferred the item to another location or entity (i.e., Note the change of location on the Master Property Inventory List and Property Tag Assignment Form. 2. Stolen : Someone stole or may have stolen the item. Note on the Master Property Inventory List the date the item was reported stolen. Attach a copy of a police offense report. 3. Lost : The item is missing and determined lost. Note on the Master Property Inventory List the date the custodian determined the item to be lost. 4. Surplus : The item is surplus and reported on the Surplus Property Form along with a signed Surplus Property Affidavit f. Enter the date, required certification signatures, and other requested information on the last page of the Master Property Inventory List. g. The Coalition shall submit a copy of the Master Property Inventory List to the Office of Early Learning no later than October 1 of each fiscal year. H. USE OF EQUIPMENT Equipment purchased with grant or sub-grant dollars may only be used in the following manner: 1. Equipment shall be used by the funding program/project as long as needed. 2. If there s extra capacity available, the equipment may be used for other partnering programs/projects; 3. If used for other programs/projects any related usage fees must equal those charged by other private companies for the same equipment; and 4. If new equipment is needed, current equipment may be sold or used for trade-in negotiations to offset newer equipment costs (subject to OEL prior approval).
Page of 7 of 9 I. PROPERTY MAINTENANCE Federal regulations require the Coalition to ensure the implementation of adequate maintenance procedures designed to maintain equipment in functional condition and safeguards are in place to prevent loss, damage, or theft of the property. The Office of Early Learning staff or independent contracted auditors/monitors may review support documentation to ensure compliance with this requirement. 1. Maintenance Purpose a. Maintenance is not intended to alter or change the asset or to increase the useful life of the asset, but rather to sustain the asset in its present condition. b. Maintenance recurs on an ongoing basis (scheduled maintenance) addressing normal wear and tear associated with the use of an asset and keeps the asset in a useable condition. 2. Maintenance Costs a. Maintenance costs incurred to keep a fixed asset in normal operating condition will be expensed. b. Maintenance costs are not capitalized and are not recorded as part of the associated asset in the fixed asset record. 3. Maintenance Responsibility a. Custodian Delegates are responsible for tracking assets sent for repair to vendors and for maintaining appropriate documentation. b. Maintenance on laptops, computers, etc., will be completed by the Coalition s contracted IT vendor or other vendor as identified in accordance with the identified schedule. 4. Maintenance Condition a. The Coalition and designated staff shall rate the condition of the equipment using the following guidelines: i. Date of Acquisition (amount of time lapsed) ii. Manufacturer s Recommended Usage Information/Shelf Life, if applicable iii. Usage Volume (how often and how much is item used, what is the intensity level of usage) iv. Number of Maintenance Requirements (number of repairs/fix/recalibrate, etc ) in order to maintain item in functional condition v. Performance (statement from user related to how well the item performs within designated timeframe) vi. Other Relevant Information b. Condition Ratings follow Coalition determined definitions of the following: i. GOOD Rating = Each of the designated condition elements meets minimum status ii. FAIR Rating = Majority of designated condition elements meets average status iii. POOR Rating = Majority of designated condition elements meet high status iv. Once an asset has been determined as poor, decisions shall be made related to disposal requirements. v. Surplus materials shall be publicized for use by other entities as required c. Equipment designated as IT and/or Attractive shall be rated based on the Service Rotation Plan
Page of 8 of 9 H. TRANSFERING PROPERTY WITHIN THE COALITION 1. The Coalition shall document the transfer of grant-purchased property from one office and/or location to another, within the Coalition if the Coalition ever opens a second office. 2. The Master Property Inventory List and the Property Tag Assignment Form shall be updated, noting the new physical location, as applicable. I. LOST OR STOLEN GRANT-PURCHASED PROPERTY 1. Upon completion of a physical inventory or other discovery, the Coalition/custodian shall reconcile inventory records as appropriate. 2. The Master Inventory List will be compared to the information on the individual inventory forms. 3. The Coalition/Custodian shall investigate noted differences such as location, condition, and Custodian/Custodian Delegate and correct as appropriate and relocate the item to its assigned location and custodian in the individual property record. 4. The Coalition/custodian shall promptly report to management items not located during the inventory process in order to implement thorough investigation. 5. If the investigation determines that someone stole or may have stolen the item, the Coalition/custodian shall update the individual property record at the time of determination, and file a report with the appropriate law enforcement agency describing the missing item and circumstances surrounding its disappearance. J. DISPOSITION OF EQUIPMENT 1. If the Coalition has no need for the equipment, the following tasks will be performed: a. All equipment items in excess of $5,000 proposed to be disposed must obtain OEL written prior approval [45 CFR Part 75.320(e)(2). b. The Coalition shall dispose of equipment consistent with Sections 274.05, 274.06, and 274.07, F.S. and Rule 69I-73.005, F.A.C. b. The Coalition shall determine the need to dispose of designated equipment based on the written condition status document in year s physical inventory c. A draft Disposition Listing shall be brought before the Board for approval PRIOR to the disposition of any item. The draft Disposition Listing shall include the following: 1. Date of disposition (draft) 2. Authority for disposition (resolution of the governing body properly recorded in the minutes as Section 274.07, F.S., requires) 3. Manner of disposition (sold, donated, transferred, cannibalized, scrapped, destroyed, traded) 4. Identity of the employee(s) witnessing the disposition If cannibalized (e.g., the process of dismantling portions or components of a property item to repair, replace, upgrade, or extend the useful life of other property items), scrapped, or destroyed; 5. A notation identifying any related transactions for items disposed of (e.g., receipt for sale of the item, insurance recovery, and trade-in) 6. Surplus Property - reference to documentation evidencing that the Coalition disposed of such property in the manner required in Section 274.05 or 274.06, F.S.
Page of 9 of 9 K. PRIORITY OF DISPOSITION 1. When original or replacement tangible personal property acquired under a grant or sub-grant is no longer needed for the original project or program, the Coalition shall use the tangible personal property in connection with its other federally-sponsored activities, if applicable, in the following order of priority: a. Programs, projects, or activities the HHS awarding agency sponsors; b. Programs, projects, or activities other HHS awarding agencies sponsor; then c. Programs, projects, or activities other federal agencies sponsor. L. TRANSFER OF PROPERTY RECORDS 1. Upon disposition of a designated tangible personal property, the Coalition shall transfer the individual property record for each item disposed of to the Coalition s Disposed Property File. M. RETENTION OF RECORDS 1. Documents relating to the acquisition and disposal of tangible personal property shall be retained throughout the life of the property and for a minimum of five (5) years following final disposition. 2. If any litigation, audit or claim remains unresolved at the expiration of the aforementioned periods, then such records shall be retained until all outstanding issues have been resolved. PARTIES AFFECTED Finance Director, Chief Executive Officer and Coalition Board Members ASSOCIATED DOCUMENTS / FORMS Master Property Inventory List, Master Property Inventory Form, Property Tag Assignment Form, Property Label, Draft Disposition List, Disposition List