4209 Moveable Equipment

Policy Sections

4209.1 Acquisition of Moveable Equipment

4209.2 Moveable Equipment Capitalization

4209.3 Maintenance of the Moveable Equipment Inventory

4209.4 Useful Life and Depreciation Allowance

4209.5 Off-Campus Use of Moveable Equipment

4209.6 Transfer and Disposal of Moveable Equipment

4209.7 Government Furnished Property (“GFP”)

This policy sets forth the requirements for maintaining the University’s Moveable Equipment from acquisition to disposition and applies to all Yale community members involved in the equipment lifecycle.

This policy does not cover fixed equipment or equipment on capital projects.  For guidance on fixed equipment or equipment on capital projects, consult Policy 4202 Capitalization, Depreciation, and Disposal of Capital Assets.

Moveable Equipment is an asset of the University that must be properly classified, safeguarded, and depreciated, and used only for University programs and purposes.  Moveable Equipment must depreciate according to useful lives established by the University.  Yale community members involved in the management of Moveable Equipment must perform their responsibilities in a manner consistent with this policy and its associated procedures.

This policy establishes the rules and requirements respecting the purchase, use, management, and disposition of Moveable Equipment.  It is consistent with federal regulations (e.g., 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) in support of the terms and conditions of sponsored awards.

Accessories

Minor (valued less than the Capitalization Threshold) equipment items that are purchased as attachments or add-ons for a Moveable Equipment item and are necessary for the Moveable Equipment to be placed in service.

Capitalization Threshold

The minimum value at which a piece of Moveable Equipment may be capitalized.  Yale University’s Capitalization Threshold for equipment is $5,000.

Composite Asset

A type of Moveable Equipment composed of individual pieces of minor equipment that, when combined, form one asset and have a total purchase price equal to or greater than the University’s Capitalization Threshold.  To be a Composite Asset, all composite pieces must be needed to make the asset functional for its intended purpose.

Fabricated Equipment

A type of Moveable Equipment that is built or assembled into one identifiable unit by combining various components and/or materials.  Fabricated Equipment built or assembled using sponsored funds is not considered a true asset of the University and, therefore, will not be capitalized nor included in the Moveable Equipment Inventory.

Government Owned Equipment

Moveable Equipment purchased using federal funds for which Yale has not yet obtained the title. Generally, Government Owned Equipment becomes the property of Yale 180 days after the applicable sponsored award ends.

Government Furnished Property (“GFP”)

Equipment of any value owned by the government and loaned to Yale for a specific research project. Generally, this equipment is returned to the sponsor according to the terms and conditions of the applicable sponsored award.

Moveable Equipment

Tangible, non-expendable, University property (i.e., property other than real property) that has an estimated useful life of greater than one year and a per-unit acquisition cost equal to or greater than the University’s Capitalization Threshold.

Moveable Equipment Inventory (“MEI”)

The complete record of all Moveable Equipment.  The Capital Asset Accounting team within the Controller’s Office maintains the MEI database, which is subject to a biennial physical inventory to validate its accuracy. 

Prior to purchasing or leasing Moveable Equipment, departments must determine the need for such Moveable Equipment and avoid acquisition of unnecessary or duplicative items.  Departments evaluating whether to purchase or lease Moveable Equipment must consider the overall costs associated with each purchase or lease alternative and must work with the Procurement Department to ensure that the purchase or lease transaction conforms to all applicable procurement standards.

Principal Investigators (“PIs”) planning to purchase or lease Moveable Equipment using sponsored funds must refer to the terms and conditions of the sponsored award and contact Sponsored Projects Financial Administration (“SPFA”) for any necessary advance approvals.

Departments may purchase or lease Moveable Equipment only when there is an approved budget to cover such purchase or lease.

Departments must inform the Capital Asset Accounting team at mei.admin@yale.edu if they obtain any Moveable Equipment (as well as items that may meet the definition of Moveable Equipment) transferred to the University from another institution, donated/gifted to the University, or otherwise obtained by the University without consideration.

All Moveable Equipment acquisitions must follow the processes described in Procedure 4209 PR.01 Acquisition and Maintenance of Moveable Equipment.

Departments must, with approval from the Capital Asset Accounting team, capitalize Moveable Equipment assigned to them.  The Capital Asset Accounting team makes the final determination on whether to capitalize the Moveable Equipment. 

Moveable Equipment capitalization is subject to the following:

A. Fabricated Equipment

• Fabricated Equipment must equal or exceed the University’s Capitalization Threshold;
• Departments must expense, as incurred, all costs for the maintenance and/or repair of Fabricated Equipment that do not extend its useful life;
• Fabricated Equipment must have a useful life of more than one year; and
• Departments must not capitalize Fabricated Equipment disassembled prior to placing in service.

For a detailed description of the Fabricated Equipment process, see Procedure 4209 PR.01 Acquisition and Maintenance of Moveable Equipment.

B. Composite Assets

Departments that purchase MEI components with individual purchase prices less than the University’s Capitalization Threshold must capitalize the costs of the Composite Asset and add the asset to the MEI System when all of the following criteria are met:

• the total cost of a Composite Asset must equal or exceed the University’s Capitalization Threshold;
• the Composite Asset must have a useful life of more than one year; and
• all component parts are purchased at the same time.

For detailed procedures regarding the capitalization of Composite Assets, see Procedure 4209 PR.02 Capitalization of Moveable Equipment Accessories and Composite Assets.

C. Accessories

Departments that purchase Accessories costing less than the University’s Capitalization Threshold must capitalize them if both of the following criteria are met:

• the Accessories are purchased at the same time as the original piece of Moveable Equipment; and
• the Moveable Equipment requires the Accessories for its intended purpose in order to place the equipment in service.

For detailed procedures regarding the capitalization of Accessories, see Procedure 4209 PR.02 Capitalization of Moveable Equipment Accessories and Composite Assets.

Departments with Moveable Equipment are responsible for safeguarding their Moveable Equipment by maintaining an accurate inventory of the Moveable Equipment assigned to them and reporting any changes in the inventory to the Capital Asset Accounting team at mei.admin@yale.edu.  An accurate inventory includes properly tagging, documenting the location, and assigning the jurisdiction of equipment (i.e. the asset is “Issued To” the responsible individual in Workday).

Departments must assist the Capital Asset Accounting team in completing a biennial physical inventory to verify the existence of Moveable Equipment assigned to their department.

The Capital Asset Accounting team is responsible for tagging equipment, maintaining an accurate record of the University’s MEI, and for completing a biennial physical inventory of the MEI.

Departments are responsible for maintaining the Moveable Equipment assigned to them in accordance with Procedure 4209 PR.01 Acquisition and Maintenance of Moveable Equipment.   

The Capital Asset Accounting team is responsible for calculating the depreciation expense for all physical assets, including for the Moveable Equipment that comprises the University’s MEI. 

Depreciation is calculated on a straight-line basis over the useful life of the Moveable Equipment and is calculated on a half-year convention, beginning in the year the asset is placed into service.

For a list of useful lives by Moveable Equipment class, contact the Capital Asset Accounting team at: mei.admin@yale.edu.

Any proposed use of Moveable Equipment in non-University space must first receive approval from the appropriate department chair or lead administrator.  Use of Government Owned Moveable Equipment in non-University space is also subject to the terms and conditions of the applicable agreement.

Any Moveable Equipment being used in non-University space must be affixed with a Yale asset tag (unless otherwise noted in Procedure 4209 PR.01 Acquisition and Maintenance of Moveable Equipment).  Moveable Equipment assigned to a location other than the main Yale campus in New Haven or West Campus, and not accessible via the Yale University Shuttle Service, will be issued a non-RFID tag, as applicable. The lead administrator (or designee) must maintain a record of the location of such Moveable Equipment in an official Moveable Equipment inventory. If any Moveable Equipment will be off-campus for more than thirty (30) consecutive days, the lead administrator (or designee) must notify the Capital Asset Accounting team (mei.admin@yale.edu) and the Office of Enterprise Risk Management.

Individuals using Moveable Equipment in non-University space are responsible for the care and proper use of such Moveable Equipment, as well as for first obtaining appropriate approval for such use.

With advance approval of off-campus use of Moveable Equipment, and provided the individual uses the Moveable Equipment in accordance with instructions for proper use, the University’s insurance may pay for any loss of, or damage to, the equipment, and any injuries to others or their property.  In such event, the department assumes the Office of Enterprise Risk Management’s deductible allocation.

Without advance approval of off-campus use of Moveable Equipment, the individual is personally responsible for the full cost of repair or replacement of damaged, destroyed, or lost Moveable Equipment and for any injuries to others, or damage to the property of others, resulting from the off-campus use of Moveable Equipment.

Under no circumstances will the University be liable for any loss or damage to the Moveable Equipment, property of others, or for any injuries to any persons, if such loss, damage, or injury resulted from the failure of the user to use the Moveable Equipment in the manner in which it was intended, or to follow all instructions for proper use.  See Policy 1110 Personal and Off-Campus Use of University Property Including Vehicles for further information.

When Moveable Equipment (or any other University property, including materials and supplies) needs to be taken outside the United States, individuals should first consult with the Director of Export Controls to determine if a special export license is required.  

Note: Both civil and criminal penalties may apply for transporting certain items outside the U.S. without proper approval.

The transfer of Moveable Equipment comprises all methods of transfer, including but not limited to, sale and release.  Disposal of Moveable Equipment refers to the final disposition (e.g., dismantling, destruction) of Moveable Equipment.

For all transfers and disposals of Moveable Equipment funded by sponsored awards, any requirements of the sponsor concerning the transfer of Moveable Equipment, if more stringent, supersede University policy.

The transfer and disposal of safety-critical Moveable Equipment is not only subject to this policy, but also Policy 3220 Purchase of Restricted Items.  Departments should consult Environmental Health & Safety prior to the transfer or disposal of any safety-critical Moveable Equipment within or outside the University.  Note: This includes transfers for the repair, service, or disposal of the Moveable Equipment.

Transfer and disposal of Moveable Equipment installed in buildings as a permanent fixture and removed for upgrading or renovation purposes requires advance approval by the Vice President for Facilities and Campus Development (or designee).  For guidance on Fixed Equipment, please consult Policy 4202 Capitalization, Depreciation, and Disposal of Capital Assets.

A. Transfer of Moveable Equipment Between University Departments

Yale permits the transfer of University-owned Moveable Equipment from one department to another, upon approval from both the transferring and receiving cost center managers, subject to the following:   

• to avoid charging a sponsor twice for the same piece of Moveable Equipment, University departments may not sell Moveable Equipment funded by a sponsored award to another University department; and
• if a principal investigator (“PI”) is no longer using a piece of Moveable Equipment funded by a sponsored award, they should first offer the equipment to another investigator or department of the University at no cost. They may do this by posting the piece of equipment to the Eli Surplus Exchange. Note: The transferring department may charge the receiving department for any costs incurred to disconnect and/or move the Moveable Equipment.

B. Transfer of Moveable Equipment to External Parties

The University may transfer Moveable Equipment it owns and no longer has a use for to another institution or third party with the approval of the assigned department’s dean or chair, and the University Provost, subject to specific rules. Any transfer of Moveable Equipment to external parties must follow the procedures detailed in Procedure 4209 PR.03 Transfer, Sale, Disposal, or Release of Moveable Equipment.

C. Moveable Equipment Under Departing Principal Investigator (“PI”) Jurisdiction

Prior to the departure of any principal investigator (“PI”), a review of all Moveable Equipment under the jurisdiction of the PI must be performed to ensure the MEI system accurately reflects the Moveable Equipment assigned to the PI, and that the release, or transfer, of equipment is properly recorded.

Detailed steps on the proper review of equipment under departing PIs can be found in Procedure 4209 PR.03 Transfer, Sale, Disposal, or Release of Moveable Equipment.

D. Moveable Equipment Not Owned by the University

Moveable Equipment to which Yale does not have legal title may not be transferred to another institution or third-party or disposed without the written approval of the owner.

Proper procedures for handling the sale, transfer, or release of equipment not owned by the University can be found in Procedure 4209 PR.03 Transfer, Sale, Disposal, or Release of Moveable Equipment.

E. Disposal of Moveable Equipment

The department must properly dispose of Moveable Equipment to ensure accurate maintenance of the University’s MEI. 

Proper disposal of Moveable Equipment must follow the procedures detailed in Procedure 4209 PR.03 Transfer, Sale, Disposal, or Release of Moveable Equipment.

Departments are responsible for identifying when a sponsored award in their department includes GFP. Departments are also responsible for, upon obtaining any GFP, informing the Capital Asset Accounting team by submitting Form 4209 FR.01 Government Furnished Property Information. Departments are further responsible for tracking and maintaining the GFP in accordance with section 5 of Procedure 4209 PR.01 Acquisition and Maintenance of Moveable Equipment.

The University must return Government Furnished Property (“GFP”) to the sponsor in accordance with the sponsored award terms and conditions.

Schools/Departments

• Responsible for the safeguarding of all Moveable Equipment assigned to their school, unit, and/or department.
• Responsible for ensuring any changes to their Moveable Equipment inventory are reported to the Capital Asset Accounting team, including the transfer, disposal, or impairment of any Moveable Equipment under their jurisdiction.
• Responsible for assisting the Capital Asset Accounting team in completing the biennial physical inventory of the University’s MEI and tagging all newly acquired Moveable Equipment.
• Responsible for identifying GFP in sponsored awards, completing Form 4209 FR.01 Government Furnished Property Information, and accurately tracking and maintaining GFP in accordance with Procedure 4209 PR.01 Acquisition and Maintenance of Moveable Equipment.

Deans/Chairs

• Responsible for approving the transfer of Moveable Equipment no longer being used by the University to another institution or third party after certifying that the Moveable Equipment is not needed by any other investigator at the University.  Note: Provost’s Office approval is also required.

Capital Asset Accounting Team

• Responsible for tagging Moveable Equipment.
• Responsible for maintaining an accurate record of the University’s MEI and for the completion of the biennial physical inventory.
• Responsible for calculating and recording depreciation expense and establishing and assigning useful lives for all Moveable Equipment.

Provost’s Office

• Authorizes the transfer of Moveable Equipment to other institutions or third parties.