Section 9 - Equipment (Capital Assets)

This section describes purchases, inventory controls, and proper disposal of secondary and postsecondary equipment acquired with federal funds.

Federal and State Requirements

Equipment purchases must be permissible according to Perkins V, Section 135(b). Consortia must also follow policies set forth by Minnesota State Board policy 7.3.6 for postsecondary and MDE UFARS policy Chapter 5, section 500 for secondary. Allowable use, disposition, and record-keeping requirements as defined by the Education Department General Administrative Regulations (EDGAR) must be followed.

2 CFR 200.1 defines equipment as tangible, nonexpendable property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost that equals or exceeds the lesser of the capitalization level established by the recipient or subrecipient for financial statement purposes, or $10,000. “Sensitive equipment,” such as computers and specialized tools, may be less than $10,000, but follow the same property management standards.

Equipment must be necessary, reasonable, and allocable, and used to support CTE instruction. Perkins V funds may not supplant local or state funding, and purchases must reflect current industry standards and improve program quality.

Approval of the annual consortium plan establishes a fiduciary relationship between the consortium, Minnesota State, and MDE. Because of this relationship, all equipment purchases of $10,000 or more require pre-approval, and requests must be submitted by and approved through the consortium coordinator.

Federal Equipment Management Requirements

In accordance with 2 CFR 200.313(d)(1), the recipient’s (consortium’s) property management standards for equipment acquired with federal funds must include the following:

Equipment Inventory Records
Accurate inventory records must be maintained and must include:
- Description of the equipment
- Manufacturer’s serial number, model number, or other identifying information
- Acquisition date and cost
- Documentation sufficient to calculate the percentage of federal participation in the equipment cost
- Current location and condition of the equipment, including the date this information was last verified
- Ultimate disposition data, including the date of disposal, method used to determine fair market value, and sales price (if applicable)
Physical Inventory Requirements
A physical inventory of equipment must be conducted at least once every two years. Inventory results must be reconciled with equipment records. Any discrepancies between physical counts and recorded quantities must be investigated to determine the cause. As part of the inventory process, the recipient must verify the existence of the equipment, its current use, and its continued need.
Control System and Safeguards
A control system must be in place to ensure adequate safeguards against loss, damage, or theft of equipment. Any loss, damage, or theft must be fully investigated, documented, and reported.
Notification Requirements
Pursuant to 2 CFR 200.313(d)(3), the recipient or subrecipient must notify the Federal agency or pass-through entity of any loss, damage, or theft of equipment that affects the program. Notification must be provided to Minnesota State Colleges and Universities and to the Minnesota Department of Education (MDE).
Equipment Maintenance
Adequate maintenance procedures must be implemented to ensure equipment is kept in good working condition.
Sale or Disposition of Equipment
If the recipient sells equipment, proper sales procedures must be established that provide for competition to the extent practicable and result in the highest possible return.

Minnesota Inventory Control

Minnesota established that equipment purchases of $5,000 or more and equipment classified as sensitive (such as computers) must be tracked in the combined inventory. Consortia might find it useful to track all equipment purchased with Perkins funds.

Consortium Responsibilities

Maintaining a single consolidated consortium inventory of secondary and postsecondary equipment that includes the information specified in item #1 above.
Validating and reconciling the inventory at least every two years.
Establishing a process to update inventory if equipment is reassigned or disposed of.
Labeling equipment as property of Perkins CTE. Asset tags should identify the Perkins Federal Grant as the source of funding. Add other relevant details deemed necessary.

Asset Tag Requirements

Permanent Identification: A physical tag must be permanently fastened to, or stamped on, each item.
Visibility: The tag must clearly indicate that the item was funded by Perkins.
Unique Identifiers: Each tag must have a unique number that corresponds directly to the entity's inventory records.
Timing: Items must typically be tagged immediately upon receipt.

Example asset tag language provided by the Saint Paul Perkins Consortium:

Purchased with Perkins Federal Grant Dollars. By law, this must remain with a licensed CTE teacher. Do not recycle or remove from this classroom without notifying the SPPS CTE department.

Equipment Disposal

When equipment purchased with Perkins funds is no longer needed for the original project, programs, or other activities supported by the grant, the consortium must request disposition instructions from Minnesota State and MDE (2 CFR 200.313). Follow the college’s procedure based on the Minnesota State policy and the MDE policy for equipment disposition, along with the following stipulations for equipment purchased with Perkins funds:

Before equipment is disposed of, the consortium must make an effort to repurpose the equipment to support a CTE program in another member district or college program. Technical support for these efforts will be available through Minnesota State and MDE.
Equipment with a current fair market value of $10,000 or less (per unit) may be retained, sold, or otherwise disposed of with no further responsibility to the Federal agency or pass-through entity
When equipment purchased with Perkins funds has a current fair market value in excess of $10,000, it may be retained or sold. However, the Federal agency is entitled to an amount calculated by multiplying the percentage of the Federal agency’s contribution towards the original purchase by the current fair market value.
Selling equipment purchased with Perkins funding to another consortium is not allowed.
Document equipment disposed of in the combined consortium inventory, including date and disposal method.

Equipment Purchase Guidelines

Unallowable Expenses:

Equipment not directly supporting an approved CTE program or not used primarily for CTE instruction.
Purchases that duplicate existing equipment available for the same instructional purpose (supplanting).
Equipment used for general district/college purposes, extracurricular activities, or personal use.
Ongoing or long-term costs that are not sustainable under Perkins V (e.g., extended software licenses beyond initial implementation).
Any costs that are not reasonable, necessary, or allocable to the Perkins grant.

Allowable Expenses:

Equipment and sensitive equipment required for CTE instruction and aligned with approved program curriculum and industry standards.
Curriculum-related software or licenses that support CTE instruction, typically limited to short-term implementation (1–2 years).
Costs associated with equipment tracking and compliance, including asset tagging, inventory systems, and required reporting.

Policy & Procedure History
Date of Implementation: 07/01/2026
Date of Last Review: 0/0/0