Designation Renewal System (DRS) – the Implied Requirements on Equipment Management for Head Start Program Awardees
In the end of 2011, the Department of Health and Human Services (HHS) issued a new regulation. 45 C.F.R. Part 1307, Policies and Procedures for Designation Renewal of Head Start and Early Head Start Programs, became final. This regulation includes a provision that Head Start and Early Head Start grants change from indefinite project periods to five year project periods.
All Head Start grants, regardless of competition status, are undergoing closeout as indefinite project periods are phased out and five year project periods begin.
The impact of this regulation on the equipment management operation in many non profit organizations is big. Many recipients of the Head Start programs didn’t immediately feel the impact, but they started to feel the pressure NOW, as they prepare to close out the indefinite project periods. They have found that meeting the inventory audit requirements from ACF (Administration of Children and Families, a division in the Department of HHS that administers the Head Start grants) is more challenging than expected.
According to the new regulation,
The Administration for Children and Families (ACF) requires a comprehensive inventory as part of the Designation Renewal (DRS) process and in advance of the completion of the indefinite project period. (See 45 C.F.R. Part 74.33-35 or 45 C.F.R. Part 92.33(b).) Inventories of Head Start and Early Head Start property, equipment and supplies must be submitted to the responsible awarding agency (ACF). Report all covered property, equipment and supplies used in grantee operations, including property, equipment and supplies in use by contracted service providers and delegate agencies.
So what does the Designation Renewal System (DRS) mean for the equipment management policies and procedures?
- Grantees need to provide an up to date inventory list of assets, what they are and where they are (in which building, offices, etc.).
- Grantees need to prove that they have audited the assets.
- Grantees need to account for all the equipment and supplies purchased with each grant and funding source.
At E-ISG Asset Intelligence, we help non profit organizations to put in place the system and processes to manage their grant funded equipment. If you would like to find out more about the eQuip! solution, you call 1-866-845-2416, ext. 2 to speak with one of our asset management experts.