Title I, Part A
Inventory Review
Guidelines
2014 GCEL Conference
February 24-26, 2014
4/13/2015
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Agenda
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Why do an Inventory
Function of An Inventory
Definitions
Procedures for Inventory Management
Off-site Use of Equipment
Physical Inventory
Equipment Use in Targeted Assistance Program
Equipment Use in Private Schools
Disposition Policy
Loss, Damage or Theft of Equipment
Common Equipment/Inventory Findings
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Why Do An Inventory
• Education Departments General Administrative
Regulations (EDGAR)
– Sections 80.20
• Effective control and accountability must be maintained for all
grant and sub-grant cash, real and personal property, and other
assets.
• Grantees and sub-grantees must adequately safeguard all such
property and must assure that it is used solely for authorized
purpose.
• Such internal control provides reasonable assurance of the
effectiveness and efficiency of the program, reliability of reporting
and compliance with applicable laws and regulations.
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Why Do An Inventory?
• Education Departments General Administrative
Regulations (EDGAR), Section 80.32 \
• Office of Management and Budget (OMB)
guidance (Circular A-87)
– States that LEAs shall provide: “effective control over
and accountability for all funds, property, and other
assets. Recipients shall adequately safeguard all
assets and assure they are used solely for authorized
purposes”.
– Provides detailed information on requirements of
maintaining an inventory.
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Why Do An Inventory
• General Education Provisions Act (GEPA)
Section 443(a) requires each recipient of
federal funds to keep records which fully
disclose the amount and disposition of the
funds, the total costs of the activity for which
the funds are used…and such other records as
will facilitate an effective financial or
programmatic audit.
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Why Do An Inventory
• Monitoring and Audit Requirements
– EDGAR 80.40
• LEAs receiving federal funds are responsible for
managing the day-to-day operations of the grant and its
supported activities to ensure that the requirements of
the grant are met. The monitoring includes the
purchasing, use and disposal of property.
• These federal regulations also require the state
educational agency (SEA) to monitor the
implementation of program requirements and
expenditures of federal funds.
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Why Do An Inventory
• Monitoring and Audit Requirements
– OMB Circular A-133
• Grantees that expend $500,000 or more in a year in
federal awards must have a single audit or program
specific audit performed for that year in accordance
with the provisions of Circular A-133.
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Functions of An Inventory
• Serves as a needs determination to assists LEAS in
determining if additional materials and supplies need to be
purchased in order to implement the district’s Title I program.
• Surveys the property in storage to determine if it is being (a)
held for disposition, (b) in the process of production for
disposition, or (c) to be consumed/utilized in the
implementation of the district’s Title I program.
• Tracks the property undergoing repair. Procedures include a
process for repair and a work-in-process tracking system.
• Provides an inventory disposition process for the loaning and
issuing of equipment, as well as the disposal process.
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Definitions
• Equipment: of nonexpendable, tangible personal
property having a useful life of more than one year.
• Supplies: tangible personal property that is
considered consumable items.
• Pilferable Items: those items that may be easily be
lost or stolen.
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Procedures for Maintaining an
Inventory of Equipment
• Acquisition of equipment
• Method for entering information into inventory management
system
• On-site use of equipment
• Physical inventory
• Equipment disposition
• Supplies disposition
• Lose, damage or theft of equipment
• Equipment use for Title I, Part A targeted assistance programs
• Equipment use for private schools
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Requisition of Equipment
• Determine the need and use of equipment.
• Purchases made in accordance the Title I federal
regulations.
• Equipment must be reasonable and necessary.
• Follow internal control procedures for approval and
receiving of equipment.
• Proper labeling of equipment.
• Issuing equipment to proper location.
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Entry of Information into Inventory
• Title I director and principals of each school is
responsible for inventory management.
• Procedures should be in place to ensure:
– all equipment is properly tagged.
– adequate safeguards related to loss, damage or theft.
– maintenance procedures to keep equipment in good
condition.
– a physical inventory of equipment.
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Entry of Information into
Inventory Records
• Inventory Records should include:
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Description
Serial Number/Identification Number
Funding Source and Percentage of Source
Vendor
Acquisition Date and Unit Cost
Location and Use
Condition
Title
Disposition
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Off-Site Use of Equipment
• Written procedures to ensure effective
tracking system for equipment used off-site.
• Possible Components of the procedures:
– date Signed Out,
– purpose of Use,
– person Responsible, and
– condition of Equipment Upon Return.
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Physical Inventory
• Physical Inventory shall be taken and results
reconciled at least once every two years.
• Purpose of physical inventory is to verify
– the existence of equipment.
– current utilization of equipment – is equipment being used
for intended purpose.
– the continued need of equipment.
– the condition of the equipment.
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Physical Inventory
• If an LEA cannot locate an item purchased with
federal funds, it is difficult to demonstrate the item
was necessary for the performance or administration
of the grant, reasonable, or benefitted the program
that paid for the item.
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Equipment Use in
Targeted Assistance Programs
• Equipment purchase for TA program must be
reasonable and necessary to implement a properly
designed program for Title I, Part A participants.
– Used with targeted assistance students, based on needs
assessment.
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Equipment Use in
Targeted Assistance Programs
• If used on a less than full-time basis the equipment
could be made available for other educational uses
without interfering with its use in the Title I, Part A
program.
• Equipment could be used on other projects or
programs currently or previously supported by the
Federal Government, “providing such use will not
interfere with the work on the projects or programs
for which it was originally acquired.”
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Equipment Use in
Targeted Assistance Programs
• The standards will have been presumed to be met
and the use of Title I, Part A equipment in non-Title I,
Part A activities is proper if use does not exceed 10
percent of the time the equipment is used in Title I,
Part A activities.
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Equipment Use for Participating
Private Schools
• Section 1120(d)(1) of the ESEA requires that the
control of the Title I funds, and the ownership of
the materials and equipment, purchased with Title I
funds for private schools shall be in the LEA, and the
LEA shall administer the funds, materials, equipment
and property. This is an LEA responsibility rather
than the responsibility of the private school.
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Equipment Use for Participating
Private Schools
District officials will:
• complete the requisitions forms for ordering materials
and/or equipment.
• have the materials and equipment delivered to the LEA.
• sign for the delivery of the materials and/or equipment.
• label the equipment as Title I to include the fiscal year of
purchase and property of the respective school district.
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Equipment Use for Participating
Private Schools
District officials will:
• deliver the materials and/or equipment to the private
school.
• store materials and equipment in a secure location
when not in use.
• maintain an inventory of all materials, equipment,
and property purchased with Title I funds for use with
eligible Title I students at private schools. The
inventory shall contain the same requirements for
any equipment purchased with Title I, Part A funds.
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Equipment Use for Participating
Private Schools
• Inventory must be updated as equipment items are purged
or new purchases are made.
• Equipment items purchased with federal funds are to be
identified and physically marked as such.
• Adequate safeguards must be in place related to the loss,
damage, or theft of the equipment. Any loss, damage, or
theft should be investigated and fully documented.
• Adequate maintenance procedures should be implemented
to keep the equipment in good condition.
• A physical inventory of equipment items must be taken and
the results reconciled with the inventory records at least
once every two years.
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Disposition of Equipment
• Establish accounting for lifecycle of goods
(Depreciation Methodology).
• When original or replacement equipment acquired
with federal funds is no longer needed for the
original project or program, the equipment may be
retained, sold or disposed, if it is not needed in any
other Title I, Part A like or federally funded project or
program.
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Disposition of Equipment
• Procedures to eliminate any equipment item from
the inventory
1. Equipment items with an acquisition cost/current
per unit fair market (explanation is provided in
Definitions section) value of less than $5,000 and
are more than three years old may be retained, sold
or disposed, with no further obligation to the
GaDOE. The disposition of such items should be so
noted on the equipment inventory maintained by
the LEA.
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Disposition of Equipment
• Procedures to eliminate any equipment item from
the inventory, continued
2. Equipment items with an acquisition cost of
$5,000 or more may be retained or sold and the
awarding agency (GaDOE) shall have a right to
amount calculated by multiplying the current market
value or proceeds from sale by the awarding agency
(GaDOE’s) share of the equipment.
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Disposition of Equipment
• Procedures to eliminate any equipment item from the
inventory, continued
a. If the current per unit fair market value is $5,000 or more,
the equipment may be retained or sold and the awarding
agency(GaDOE) shall have a right to an amount calculated by
multiplying the current market value or proceeds from the
sale by the State’s share of the equipment. The entity is
permitted to deduct and retain from the State’s share $500
or 10 percent of the sales proceeds, whichever is less, for the
entity’s selling and handling expenses.
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Disposition of Equipment
• Procedures to eliminate any equipment item from the
inventory, continued
b. Forward a check made payable to the Georgia
Department of Education in the amount of the State’s
share. The amount is then returned to the State’s Title I
LEA allocations fund.
c. The disposition of such items should be so noted on
the equipment inventory maintained by the recipient.
The recipient should include the date of disposal and
sales price or the method used to determine current fair
market value if the recipient compensates the State.
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Disposition of Supplies
• Procedures in place for disposition of supplies if
there is a residual inventory of unused supplies that:
– exceeds $5000 fair market value.
– are not needed for any other federally sponsored
program.
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Loss, Damage or Theft of Equipment
• Control system for adequate safeguards to prevent
loss, damage, or theft
– Process for investigation of any loss, damage or theft.
– Indicate the proper documentation needed to notify and report loss,
damage or theft.
• Types of Controls
– Locks or security camera (for particularly valuable or vulnerable
items).
– Access controls to warehouses to limit entry by unauthorized
personnel.
– Use of logs or sign-in sheets for certain items of property; for example
iPads, laptops, cameras, projectors.
– Procedures for promptly entering items received into the inventory
management system.
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Monitoring Considerations
• Is equipment purchased allowable for Title I
purchase?
• Is equipment purchased reasonable and
necessary?
• What accountability in is place for purchasing
equipment and keeping an inventory?
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Monitoring Considerations
• Does the equipment policy/procedures address the
following:
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Definition of equipment
Purchasing procedures
Use of equipment
Maintenance of equipment and inventory
Physical inventory
Safeguard of inventory
Disposal of Equipment
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Monitoring of Equipment
• Common Findings
– Inability to account for property and equipment
– Failure to maintain an equipment inventory
– Lack of sufficient documentation to support
purchases
– Insufficient, outdated or no inventory
management procedures
– No physical inventory conducted
– Alternate use of equipment
– Instances of fraud, waste and abuse
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Title I Program Specialist
Contact Information
Area
Name
Office Telephone
Email
1
Robyn Planchard
(404) 463-3467
rplanchard@doe.k12.ga.us
2
Randy Phillips
(770) 334-8390
rphillips@doe.k12.ga.us
3
Anthony Threat
(706) 615-0367
athreat@doe.k12.ga.us
4
Evelyn Maddox
(404) 656-2045
emaddox@doe.k12.ga.us
5
Judy Alger
(229) 838-6037
julager@doe.k12.ga.us
6
Grace McElveen
(912) 334-0802
gmcelveen@doe.k12.ga.us
7
Jimmy Everson
(229) 723-2664
jeverson@doe.k12.ga.us
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Marijo Pitts-Sheffield
(912) 269-1216
mpitts@doe.k12.ga.us
9
Kathy Pruett
(706) 540-8959
kpruett@doe.k12.ga.us
10
Elaine Dawsey
(478) 971-0114
edawsey@doe.k12.ga.us
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Olufunke Osunkoya
(678) 704-3557
oosunkoya@doe.k12.ga.us
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Bobby Trawick
(229) 246-1976
btrawick@doe.k12.ga.us
CONTACT INFORMATION
Grace McElveen
Georgia Department of Education
Title I Education Program Specialist
gmcelveen@doe.k12.ga.us
(912) 334-0802
Elaine Dawsey
Georgia Department of Education
Title I Education Program Specialist
edawsey@doe.k12.ga.us
(478) 971-0114