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. Minnesota requires pre-approval for secondary and postsecondary equipment purchases of $10,000 or more with Perkins funds.
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.
In accordance with 2 CFR 200.313(d)(1), the recipient's (consortium's) property management standards for equipment acquired with federal funds and federally-owned equipment shall include all of the following:
- Equipment inventory records shall be maintained accurately and shall include the following information:
- A description of the equipment.
- Manufacturer's serial number, model number, federal stock number, national stock number, or other identification numbers
- Source of the equipment, including the award number.
- Whether title vests in the recipient or the Federal Government.
- Acquisition date (or date received, if the equipment was furnished by the Federal Government) and cost.
- Information from which one can calculate the percentage of federal participation in the cost of the equipment (not applicable to equipment furnished by the Federal Government).
- Location and condition of the equipment and the date the information was reported.
- Unit acquisition cost.
- Ultimate disposition data, including date of disposal and sales price or the method used to determine current fair market value where a recipient compensates ED for its share.
- Equipment owned by the Federal Government must be identified to indicate federal ownership.
- A physical inventory of equipment must be taken, and the results reconciled with the equipment records at least once every two years. Any differences between quantities determined by the physical inspection and those shown in the accounting records must be investigated to determine the causes of the difference. The recipient shall, in connection with the inventory, verify the existence, current utilization, and continued need for the equipment.
- A control system must be in effect to ensure adequate safeguards to prevent loss, damage, or theft of the equipment. Any loss, damage, or theft of equipment shall be investigated, fully documented, and reported.
In accordance with 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 will have an effect on the program. Notification must be made to Minnesota State Colleges & Universities and MDE.
- Adequate maintenance procedures must be implemented to keep the equipment in good condition.
- Where the recipient is authorized or required to sell the equipment, proper sales procedures must be established which provide for competition to the extent practicable and result in the highest possible return.
Inventory Control
Minnesota established that equipment purchases of $5,000 or more and equipment classified as sensitive (e.g., 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.
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