Q. Is it allowable for the Migrant Education Program (MEP) to lend old, but usable laptop computers to the College Assistance Migrant Program (CAMP) indefinitely, to use in student computer laboratories? The laptop computers have exceeded their lifespan, are no longer needed by MEP regional staff, and have been replaced with updated models. If transferred from the MEP to CAMP, CAMP would manage their usage by students.
Assuming that the per unit purchase price for the computers was less than $5,000 (therefore classifying them as supplies rather than equipment), and that they were purchased with MEP funds, the answer to your question about transferring the computers to CAMP, is either (1) or (2) below, depending on the current aggregate value of the computers.
1. If the current total aggregate value of the computers is less than $5,000, then:
The non-Federal entity may retain, sell, or otherwise dispose of them without any further obligation to the Federal awarding agency (U.S. Department of Education).
2. If the current total aggregate value exceeds $5,000 and the supplies are not needed for any other Federal award, then:
The Uniform Guidance requires that the non-Federal entity must either retain the computers for use in other activities or sell them (see 2 CFR 200.314). In either case, the non-Federal entity must compensate the Federal awarding agency (U.S. Department of Education) for its share. This is calculated the same way that it is calculated for equipment under 2 CFR 200.313(e)(2). The Federal agency is entitled to an amount calculated by multiplying the current market value or proceeds from sale by the Federal agency’s percentage of participation in the cost of the original purchase. If the computers are sold, the Federal agency may allow the non-Federal entity to deduct and retain either $500 or 10% of the proceeds, whichever is less, for selling and handling expenses.
In other words, if the total aggregate value of the computers is now less than $5,000, you are allowed to transfer them to CAMP, where the program would manage their usage by students. If not, you must either retain them or sell them, following the procedure outlined above.