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Section 12: Property Management

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This section outlines the subgrantee’s property management responsibilities for equipment and supplies purchased through the Texas Behavioral Traffic Safety Program.

Subgrantees must establish and administer a system to procure, control, protect, preserve, use, maintain, and dispose of property furnished to them by TxDOT, or purchased through a grant, subgrant, or other agreement in accordance with their own property management procedures, provided the subgrantee’s procedures are not in conflict with the standards contained in this section, or federal property management standards.

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Buy America Act

The Buy America Act, 23 U.S.C. §313, prohibits states from using highway grant funds under 23 U.S.C. Chapter 4 to purchase products, unless they are produced in the United States.

For information concerning the Buy America Act, see the NHTSA Buy America Act Guidance and the NHTSA Buy America Act Questions and Answers.

Both documents are located on the eGrants Help Page.

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The following definitions apply in regard to property management:

Acquisition Cost: The net invoice unit price of an item of purchased equipment, including the cost of modifications, attachments, accessories, or auxiliary apparatus necessary to make the property usable for the purpose for which it was acquired. Other charges, such as the cost of installation, transportation, taxes, duty, or protective in-transit insurance, must be included or excluded from the unit acquisition cost in accordance with the subgrantee’s regular accounting practices.

Controlled Assets: Assets that qualify as personal property but do not meet the equipment threshold of $5,000, but must be secured and tracked due to the nature of the items. Currently, Traffic Safety Controlled Inventory Assets include, but are not limited to:

Equipment: Tangible, non-expendable, personal property having a useful life of more than one year and an acquisition cost of $1,000 or more per unit.

Excess Property: Property under the control of any federal awarding agency that is no longer required for the agency’s needs or the discharge of its responsibilities, as determined by the head of the agency.

Exempt Property: Tangible personal property acquired in whole or in part with federal funds and where the federal awarding agency has statutory authority to vest title in the recipient without further obligation to the federal government.

Federally-Owned Personal Property: Property furnished by the federal government and whose title remains vested in the federal government. Federally-owned property does not include property purchased through traffic safety grants and agreements.

NOTE: Subgrantees must manage the equipment in accordance with federal agency rules and procedures, and submit an annual inventory list of federally-owned property in their custody to the federal agency that furnished the property.

Federal Share (of real property, equipment, or supplies): The percentage of the property’s acquisition costs and any improvement expenditures paid with federal funds.

Major Equipment: Tangible, non-expendable, personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit (as defined by the NHTSA Highway Safety Grants Program Resources Guide).

Personal Property: Property of any kind except real property. Personal property may be tangible (having physical existence) or intangible (having no physical existence), such as copyrights, patents, or securities.

Real Property: Land, including land improvements, structures, and appurtenances thereto, excluding movable machinery and equipment.

Supplies: Personal property having a useful life of less than one year or an acquisition cost of less than $1,000 per unit.

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Acquisition of Equipment

The Texas Behavioral Traffic Safety Program generally prohibits the acquisition of Major Equipment ($5,000 or more). However, there are exceptions when TRF-BTS may determine that a requested acquisition would benefit the program.

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Requesting Prior Approval

A major equipment purchase may occur only if both of the following conditions are met:

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  • The purchase is specifically authorized in the grant agreement, and
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  • TxDOT and the NHTSA have approved the purchase, determining it to be in the best interest of the program.

Before initiating the acquisition of equipment, the intended purchaser must obtain written notice from the TRF-BTS Director stating that both TxDOT and the NHTSA Regional Administrator have formally approved the equipment purchase. (This procedure is required by 23 C.F.R. §1300.31(d) and NHTSA Highway Safety Grants Program Resources Guide. The approval may be part of the approval of the Highway Safety Plan (HSP) or part of a separate written request describing how the equipment would support the State’s Highway Safety Program.

To request approval for equipment (unit acquisition cost of $5,000 or greater) a subgrantee must:

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  1. Ensure that the grant contains necessary provisions and that there are sufficient funds to cover the cost of the equipment.
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  3. Submit an Equipment Request through eGrants for approval to the Project Manager. The Equipment Request is located under “Supplemental Approvals,” and can be found under “Examine Related Items.”
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  5. Select “Create New” under “Supplemental.” Select “I Agree” when prompted “Are you sure you want to create a Supplemental Report?”
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  7. Click on “View, Edit and Complete Forms” and choose “Equipment.”
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  9. Complete and save the form.
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  11. Complete the checklist request process by changing the status of the form (found under “Change the Status”) to “SR Submitted.” Once the status of the request has been changed to “SR Submitted,” the request will be electronically forwarded to the appropriate project manager for review.

NOTE: When making the equipment purchase, the purchaser should also obtain the expected service life and warranty of the equipment from the vendor or the manufacturer.

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Property Procurement

The subgrantee’s procurement of property under a grant will follow the same policies and procedures used for procurement with its non-federal funds, provided their procurement procedures conform to the standards specified in 2 C.F.R. §200.313.

Any property purchased, regardless of the unit cost, must be specifically authorized in the grant agreement.

The NHTSA Highway Safety Grants Program Resources Guide states that costs for construction, rehabilitation, or remodeling of any buildings or structures or for purchase of office furnishings and fixtures are unallowable. The following are some examples of unallowable items:

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  • desks
  • chairs
  • tables
  • shelving
  • coat racks
  • credenzas
  • bookcases
  • filing cabinets
  • floor covering
  • office planters
  • storage cabinets
  • portable partitions
  • picture or wall clocks
  • draperies & hardware
  • fixed lighting or lamps

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Notification of Property Purchase

When any personal property is purchased, subgrantees must notify TRF-BTS by completing the “Equipment” (400) page of the RFR forms with the subgrantee’s monthly RFR.

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Property Management Standards

Each subgrantee receiving traffic safety funds for the purchase of property must maintain procedures for managing property that comply with 2 C.F.R. §200.313. The subgrantee’s written property records must ensure that:

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  • Property records are maintained that include:
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    • A description of the property.
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    • The manufacturer’s serial number, model number, federal stock number, national stock number, or other identification number.
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    • The inventory number.
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    • The source of the property (including grant or agreement number).
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    • Indication of with whom title is vested (generally vests with the subgrantee).
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    • The acquisition date.
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    • The percentage (at the end of the budget year) of federal participation in the cost of the project.
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    • The location, use, and condition of the property and the date the information was reported.
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    • The unit acquisition cost.
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    • The ultimate disposition date (including the date of disposal and sales price or the method used to determine the current fair market value).
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  • A physical inventory of the property is taken and the results reconciled with the subgrantee’s property records on an annual basis (an employee other than the one to whom the equipment is assigned should take the physical inventory and record the physical count).
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  • An inventory control system is maintained to ensure adequate safeguards to prevent loss, damage, or theft of the property.
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  • Any loss, damage, or theft of the property is investigated.
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  • Maintenance procedures are adequate to keep the property in good condition.
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  • Proper sales procedures are established to ensure the highest return in the event the subgrantee is authorized or required to sell the property.

NOTE: Subgrantees must provide a copy of their inventory policies and procedures to the Project Manager.

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Certification of Subgrantee Property

A database of all Texas Behavioral Highway Safety Program equipment and controlled assets is maintained by TRF-BTS. Entries of federally funded equipment and controlled assets are performed by the TRF-BTS Policy and Procedures Coordinator, based on the information submitted on the “Equipment” (400) page of the monthly RFR. Inventory items are then grouped according to the agency in possession (for example, Texas Department of Public Safety, Texas A&M Transportation Institute, TxDOT, Austin District, etc.).

Once every two years, the TRF-BTS Policy and Procedures Coordinator sends a Certification of Existence and Condition for Traffic Safety Program Inventory Form listing all reported traffic safety personal property to all agencies receiving grants. The form must be completed and returned to TRF-BTS and verifies the status of property condition, current and future usage for traffic safety activities, and date of the last physical inventory.

When the completed inventory certification forms are returned, TRF reviews them to verify that:

TxDOT project managers physically verify the existence and traffic-safety use of each item. This verification is typically completed during on-site monitoring.

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Property Insurance

Subgrantees must, at a minimum, provide the equivalent insurance coverage for equipment acquired with federal funds, provided the property is owned by the subgrantee.

NOTE: Federally-owned property need not be insured unless required by the terms and conditions of the grant.

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Equipment and controlled assets, purchased in whole or in part with traffic safety funds, must be tagged to indicate the item was acquired with traffic safety funds. Traffic safety subgrantees are responsible for developing tagging procedures and for the purchase of tags. In addition, for cross-reference audit purposes, the ID tag number is to be noted on the invoice for each piece of equipment and controlled asset item.

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Upon completion or termination of a traffic safety grant or subcontract, or if it is determined by TRF-BTS that equipment and supplies are no longer needed for the purpose for which they were acquired, the equipment and supplies will, at the option of TRF-BTS, become the property of TRF-BTS. Therefore, permission for disposition must be obtained from TRF-BTS before any action can be taken regarding the equipment. Some of the possible disposition actions include, but are not limited to:

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  • Transfer from federal inventory to state inventory.
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  • Declaration of inoperability and relegation to salvage or sale at auction.
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  • Return to TRF-BTS from the subgrantee.
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  • Declaration that equipment is damaged beyond repair or salvage.
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  • Sale at auction and return of proceeds to TxDOT for reconciliation with federal funding.
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  • Allowing the organization to use the equipment and/or supplies for other than traffic safety activities provided compensation is made to the Traffic Safety Program, based on fair market value.

NOTE: See the “Useful Life and Residual Value” section and accompanying table on Pages 3 and 4 of the of the Department of Information Resources publication “Guidelines for Lease vs. Purchase” to assist in determining the useful life of equipment.

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Fair Market Value (FMV)

Fair Market Value (FMV) may be determined in several ways.

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  1. The first and preferred method is to have property appraised by a licensed appraiser.
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  3. Kelly Blue Book can be used to determine the FMV for passenger vehicles. TRF-BTS will accept “low” Blue Book value as reimbursement for the vehicle.
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  5. For personal property, such as computer systems or office equipment, written quotes from two local vendors will be acceptable.
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  7. FMV, established through a fair market value website, is acceptable.
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