Skip to main content

Real Property Acquired with External Funding

PPD-0210

PPD Number: 0210
Title: Real Property Acquired with External Funding
Responsible Office: Finance & Sponsored Programs
Effective Date: 08/01/2025
Last Updated: First Version

I. Scope

This policy and procedure document (PPD) applies to William & Mary’s Batten School of Coastal & Marine Sciences (Batten School) & Virginia Institute of Marine Science (VIMS). It applies to all members of the Batten School & VIMS community, including faculty, staff, and students. It applies to all Batten School & VIMS campuses, including the Eastern Shore Laboratory (ESL) and the Kauffman Aquaculture Center (KAC).

II. Purpose & Policy Statement

This policy outlines the responsibilities and procedures for the management of real property acquired or improved using federal funds at the Virginia Institute of Marine Science (VIMS), in accordance with 2 CFR § 200.311 of the Uniform Guidance. It ensures transparency, accountability, and compliance with applicable federal and institutional requirements.

III. Definitions

Real Property: Land and any permanent structures or improvements on it, excluding movable machinery and equipment.

Federal Interest: The federal government’s retained rights in real property purchased or developed with federal assistance.

Non-Federal Entity: For this policy, it refers specifically to VIMS as part of William & Mary.

IV. Process & Procedure

Ownership and Use

  • Title to real property acquired with federal funds shall vest in William & Mary on behalf of VIMS.
  • The property must be used for the federally authorized purpose for the duration of its useful life, regardless of whether the project remains actively funded.
  • VIMS may not mortgage, lease, or otherwise encumber federally funded property without prior written consent from the federal awarding agency or authorized pass-through entity.

Property Records

VIMS, in coordination with William & Mary’s Office of Finance and Administration, shall maintain detailed records including:

  • Description and physical location of the property
  • Property identification number
  • Federal award reference (including agency and grant number)
  • Date of acquisition and acquisition cost
  • Current use and status of the property
  • Any liens, encumbrances, or restrictions

Inventory and Inspections

A comprehensive inventory and physical inspection of all federally acquired real property will be conducted at least once every two years. The results will be reconciled with property records, and any variances will be documented and corrected.

Disposition of Property

When a real property asset is no longer needed for its original federally funded purpose, VIMS must seek written disposition instructions from the awarding federal agency or its designee. Depending on those instructions, options may include:

  • Retaining the property after reimbursing the federal share of the fair market value
  • Selling the property and remitting the federal share of the proceeds
  • Transferring title as directed by the federal agency

Maintenance and Protection

VIMS shall ensure that all real property is maintained in good condition and adequately insured. Facilities Management will oversee upkeep, conduct regular condition assessments, and coordinate necessary repairs.

Encumbrance or Transfer Restrictions

No real property acquired with federal funds may be sold, transferred, leased, or otherwise encumbered without prior written authorization from the federal awarding agency. Compliance with 2 CFR § 200.311(c) regarding compensation to the federal government is mandatory when applicable.

Record Retention

Records related to the acquisition, use, and disposition of real property must be retained for at least three years following final disposition, or longer if specified by the awarding agency or William & Mary’s retention policies.