Property

Unless otherwise stated in Federal statute, program regulations, and terms and conditions, recipients and pass-through entities are responsible and accountable for, but not limited to, the following:

• Maintaining effective property management for the full property life cycle of property acquired and/or used under a Federal award.
• Monitoring and ensuring that subrecipients also have effective controls in place for property.
• Maintaining written policies and procedures for the full property life cycle (acquisition, improvements, maintenance, through disposal). Recipients may use their own property management standards and procedures so long as it meets the property standard provisions at 45 CFR §§75.316 - 75.323 (effective on or after 10/1/2025: 2 CFR §§200.310 - 200.316).
• Submitting recipient (and on behalf of subrecipients) prior approval requests and applicable reports on property that has federal interest.
• Maintaining clear and accurate property/asset records containing content such as description of property, dates, amount, location, purpose, depreciation, documentation (request, approval, reports (SF-429, SF-428), liens, finance/refinance documents, agreement, lease, appraisal, etc.), procurement process, funding source (non-Federal and Federal amounts and percentages), and so on.
• Recording a notice of federal interest (NFI) in the appropriate official records for the jurisdiction in which the real property is located. (ACF is aware that some jurisdictions do not allow the recording of NFIs on modular units, as such please post the NFI, in a clearly visible location, on the exterior of the modular unit and inside the modular unit.) A copy of the NFI must be provided to ACF.
• Maintaining equivalent insurance coverage for real property and equipment.
• When a property is no longer needed for the original authorized purpose, the recipient (and on behalf of the subrecipient) must submit a disposition request according to the federal regulations and guidance contained within these pages.
• At closeout (if applicable) of a Federal award, recipients (and on behalf of subrecipient) must account for any real and personal property acquired with Federal funds.
• The closeout of a Federal award does not affect property management and disposition requirements. However, please note that federal interest does not expire until formal disposition; therefore, recipients (and on behalf of subrecipients) are responsible for ongoing reporting and prior approval requirements.
• Records for real property and equipment must be retained for 3 years after final disposition.

While acquisition and maintenance of equipment, generally, is an allowable cost, acquisition, construction, and renovation of real property is unallowable in the absence of specific statutory authority and prior approval.