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CSFP Section 7

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CSFP Procedures Manual Section 7: Property Management

7.1 Procurement Requirements

  1. Procurement of Capital Assets.
    1. Procurement of capital assets (equipment, equipment repairs, and capital improvements) supported by Food Assistance (FA) funding must comply with this guidance. All procurement of capital assets using CSFP funds, regardless of percentage require prior approval from WSDA FA and USDA FNS. If the participating agency has internal equipment repair and procurement or capital improvement policies that are more restrictive, the stricter of the two policies should be followed.
    2. Allowable equipment purchases:
      1. Equipment is defined as any tangible nonexpendable personal property with a useful life of more than one year and costs $10,000 or more. The purchase of equipment to be used in CSFP is an allowable expenditure. See the Equipment and Equipment Repairs Procurement Guidelines (AGR-454).
      2. Equipment costing $10,000 or more per unit must be approved prior to purchasing, using the Equipment Procurement Request/Approval Form (AGR-2204).
      3. Equipment costing $30,000 or more or $40,000 (as applicable) per unit (see the Equipment and Equipment Repairs Procurement Guidelines (AGR-454)) requires three bids in writing which must be submitted with the Equipment Procurement Request/Approval Form (AGR-2204) and approved by FA prior to purchasing.
      4. Lead Agencies must have written procurement and inventory policies for equipment and procedures for disposing of equipment that at a minimum meet the FA standards. If an agency’s internal equipment procurement policies are more restrictive, the stricter of the two policies should be followed.
      5. If the Lead Agency allows equipment purchases under their CSFP Agreement with a Sub Agency, then the Lead Agency submits the Equipment Procurement Request/Approval Form (AGR-2204) to FA on behalf of the Sub Agency.
      6. Additional reporting requirements may apply.
    3. Allowable equipment repairs:
      1. Equipment repairs with a cost of $10,000 or more are defined as a Capital Expenditure and should be capitalized when they prolong the useful life of the equipment being repaired. Equipment Repair costs which equal or exceed the lesser of the capitalization level established by the non-federal entity for financial statement purposes, or $10,000 will be capitalized. Equipment repairs funded in part or entirely with FA funds must be pre-approved by FA. See the Equipment and Equipment Repairs Procurement Guidelines (AGR-454).
      2. Equipment repairs costing $10,000 or more per unit must be approved by FA prior to work beginning, using the Equipment Repair Request/Approval Form (AGR-2615).
      3. Equipment repairs costing more than $30,000 or more or $40,000 (as applicable) per unit (see the Equipment and Equipment Repairs Procurement Guidelines (AGR-454)) requires three bids in writing and must be submitted with and approved by FA prior to purchasing using the Equipment Repair Request/Approval Form (AGR-2615).
      4. Lead Agencies must have written procurement and inventory policies for equipment repairs and procedures for disposing of repaired equipment using FA funding that at a minimum meet FA standards. If an agency’s internal equipment repair policies are more restrictive, the stricter of the two policies should be followed.
      5. If the Lead Agency allows equipment repairs under their CSFP Agreement with a Sub Agency, then the Lead Agency submits the Equipment Repair Request/Approval Form (AGR-2615) to FA on behalf of the Sub Agency.
      6. Additional reporting requirements may apply.
    4. Allowable capital improvements:
      1. Capital improvement means expenditures to acquire permanently located capital assets, or expenditures to make additions, improvements, modifications, replacements, rearrangements, reinstallations, renovations, or alterations to capital assets that are permanently located that materially increase their value or useful life. See the Capital Improvement Procurement Guidelines (AGR-898).
      2. The purchase of buildings and/or land is not allowable.
      3. Capital improvements costing $10,000 or more require prior approval. Lead Agencies should reach out to their regional representatives to make sure they understand what will be required of them before beginning the project and bid process.
      4. Capital improvements are most easily approved for buildings that are owned by the Lead Agency or Sub Agency. Capital improvements may be approved if a building is leased under certain circumstances. Be advised that a lease term minimum may apply.
      5. Procurement and bid process requirements for capital improvements will vary depending on the cost of the capacity project and/or funding sources.
      6. Lead Agencies must have written procurement and inventory policies for capital improvements that at a minimum meet FA standard. If an agency’s internal capital improvement policies are more restrictive, the stricter of the two policies should be followed.
      7. If the Lead Agency allows capital improvement purchases under their CSFP Agreement with a Sub Agency, then the Lead Agency submits the Capital Improvement Procurement Request/Approval Form (AGR-2308) to FA on behalf of the Sub Agency.
      8. Additional reporting requirements may apply. Lead Agencies and Sub Agencies shall establish written procurement procedures, which should include at least the following:
        1. All procurement transactions shall be conducted in a manner to provide, to the maximum extent practical, open and free competition.
        2. Where appropriate, an analysis is made of lease and purchase alternatives to determine which would be the most economical and practical procurement method when using FA funds, and to assure the avoidance of purchasing unnecessary or duplicative items.
        3. Solicitations for goods and services shall provide a clear and accurate description of the technical requirements for the material, product, or service to be procured.
        4. Procurement records for purchases shall include the following at a minimum:
          1. Basis for Lead Agency selection;
          2. Justification for lack of competition when competitive bids or offers are not obtained; and
          3. Basis for award cost or price.
        5. Purchasing agreements shall be made only with responsible vendors under the terms and conditions of the proposed procurement. Consideration shall be given to such matters as the vendors’ integrity, record of past performance, financial and technical resources, or accessibility to other necessary resources. Vendors shall not be suspended or debarred.
        6. Sub Agencies must submit to the Lead Agency any related procurement documents, justification for non-competitive procurement, if applicable, in order to receive reimbursement from FA funds.
        7. Real property (land, land improvements, structures and appurtenances/fixtures) is considered an unallowable cost.

7.2 Property Management and Inventory

  1. For the sake of clarity, “personal property” means property of any kind except real property. “Equipment” means tangible nonexpendable personal property having a useful life of more than one year with an original purchase price of $5,000 or more per unit prior to October 1, 2024, or of $10,000 or more per unit on October 1, 2024, or after.
  2. The Washington State Administrative and Accounting Manual (SAAM) defines the state’s capitalization policy as assets with a unit cost (including ancillary costs) of $10,000 or greater, or collections with a total cost of $10,000 or greater. Consequently, components valued less than $10,000 but are pieces of a larger system valued over $10,000 are determined to be equipment (refer to SAAM 30.20.20). Property management and inventory practices must also comply with requirements from 2 CFR §200 Subpart D.
  3. A Capital Asset Inventory Policy is Required for All Lead Agencies.
    1. Lead Agencies must have an inventory policy in place for capital assets that adequately address how to track all capital asset inventories. This policy must be no less restrictive than the Food Assistance (FA) procurement guidelines (Equipment and Equipment Repairs Procurement Guidelines (AGR-454) and Capital Improvement Procurement Guidelines (AGR-898)).
    2. Note: The Lead Agency must ensure that all Sub Agencies in possession of capital assets purchased with FA funds at a minimum adopt FA inventory policy or the Lead Agency’s if more restrictive.
    3. This inventory should include equipment, equipment repairs, and capital improvements purchased in part or in whole with FA funding.
    4. Lead Agencies must have a method for tracking inventory purchased or repaired by their Sub Agencies with FA funds to ensure that all appropriate capital assets are listed on the Annual Equipment Inventory (AGR-2201) each year.
    5. Sub Agencies must adopt a method for tracking capital assets purchased with FA funds.
    6. A physical inventory of the property purchased with FA funds must be taken and the results reconciled with the property records at least once every two years.
    7. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of capital assets. Any loss, damage, or theft must be investigated.
    8. Adequate insurance and maintenance procedures must be in place for all capital assets.
  4. Annual Reporting of Capital Assets.
    1. All Lead Agencies must annually report all capital assets (equipment and equipment repairs on the Annual Equipment Inventory (AGR-2201) and all capital improvements on the Annual Capital Improvement Inventory (AGR-2614)) with an acquisition cost of $10,000 or more per unit that was purchased with FA funds, regardless of the percentage of FA funding used.
    2. Lead Agencies are responsible for reporting Sub Agencies’ applicable capital asset inventory on the Annual Equipment Inventory (AGR-2201).
    3. Capital asset reporting is based on the acquisition date and has no ending date for the Annual Equipment Inventory (AGR-2201) until disposition occurs.
    4. Upon approval, the disposition status must be updated on the Annual Equipment Inventory (AGR-2201) and Annual Capital Improvement Inventory (AGR-2614) that the Lead Agency maintains and provides to FA annually.
    5. Records must be maintained and updated.
  5. Disposition of Personal Property and Equipment.
    1. If a Lead Agency or their Sub Agency has no further need for the equipment, with an original purchase price of $5,000 or more per unit prior to October 1, 2024, or of $10,000 or more per unit on October 1, 2024, or after, then the Equipment Disposition Request/Approval Form (AGR-2203) must be completed and sent to FA for prior approval. Additional instructions can be found in the Equipment Disposition Guidelines (AGR-452).
    2. Once approved, the following applies:
      1. Please reference the Equipment Disposition Guidelines (AGR-452) and the Capital Improvement Disposition Guidelines (AGR-978).
      2. For equipment with an original purchase price of $10,000 or more per unit, the Lead Agency (and on behalf of their Sub Agencies) must submit the Equipment Disposition Request/Approval Form (AGR-2203) to FA for prior approval. Disposition may not occur until authorization is obtained from FA.
      3. This policy also applies to equipment repairs of $10,000 or more funded by CSFP, occurring within the required use period.
      4. For capital improvements with an original purchase price of $10,000 or more per unit, the Lead Agency (and on behalf of their Sub Agencies) must submit the Capital Improvement Disposition Request/Approval Form (AGR-2613) to FA for prior approval. Disposition may not occur until authorization is obtained from FA.
      5. Upon approval, the disposition status must be updated on the Annual Equipment Inventory (AGR-2201) and/or the Annual Capital Improvement Inventory (AGR-2614) that the Lead Agency maintains and provides to FA annually.
      6. Be advised that reimbursement may be required for a portion of the sales. This is determined on a case-by-case basis, please contact FA for specific instructions.
      7. Disposition status must be updated on the Annual Equipment Inventory (AGR-2201) and provided to WSDA annually.
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CSFP Procedures Manual Table of Contents
Section 6 Section 8
Revision History
Section 7 Revision 2025-04-23