Administrative Regulation 6.08-01

ADMINISTRATIVE REGULATION:   AR: 6.08-01 DATE APPROVED: February 23, 2021
SUBJECT: Asset Management ORIGINATING DEPARTMENT: County Administrator

PURPOSE:

The Board of County Commissioners (Board) is required by Chapter 274, Florida Statutes, to maintain capital asset records on tangible personal property of a non-consumable nature, in accordance with Chapter 69I-73, Florida Administrative Code, except for land which will always be capitalized at amount expended. Additionally, when the capital asset is acquired with federal/state grant monies, compliance by the Department with federal/state regulations, identified in the grant contract, must be maintained.

In order to comply with the Florida Administrative Code, the Board in conjunction with the Clerk of Court has established a capital assets system. The Clerk of Court’s Finance Department (Clerks’ Finance) has developed a record keeping system to comply with the Florida Administrative Code and to maintain adequate capital assets records for control and financial statement purposes.

The purpose of the Asset Management Administrative Regulation is to ensure adequate control and accountability of capital assets and to provide direction for County employees who are responsible for marking, recording, and/or safeguarding County owned and Government owned capital assets.

POLICY:

These policies and procedures are intended to define County-wide capital assets and to establish guidelines for accountability, budgeting, purchasing, transferring, disposing, and financial reporting of capital assets. If a Division/ Office/ Department elects to institute a more restrictive practice for purposes of budgetary control, the County Administrator will entertain a request of this nature. All County employees are expected to comply with these policies and procedures.

1.  DEFINITIONS

Account –a five-digit number assigned to a particular class of assets and is used when purchasing capital assets. When using these accounts, the expenditures must meet the capitalization threshold set by the Board. When an asset is capitalized, the asset costs are converted to an asset account on the balance sheet by Clerk’s Finance.

Asset Identification (Asset ID Number
) - a unique number which is assigned to each capital asset by Clerk’s Finance.

Attractive Items
- tangible personal property with purchase prices of at least $1,000 but less than $5,000 that are not capitalized but require special attention to ensure legal compliance, protect sensitive data, and avoid potential liability, or to compensate for a heightened risk of theft.

Buildings
– All enclosed structures, capital and permanent, used by the County in its operations, including, but not limited to, office buildings, firehouses, garages, jails, equipment storage facilities, and recreation facilities.

Building Renovations and Remodeling
– Any improvement to a building that increases its value or utility.

Cannibalizing Equipment
–the removal of components for reuse, rendering the parent unit unusable.

Capital Assets
– (also called fixed assets) Real or personal, tangible or intangible property that has a cost equal to or greater than the capitalization threshold provided in Rule 69I-73.002, Florida Administrative Code, ($5,000) and has an estimated useful life extending beyond one year. Examples include land, buildings and equipment.

Capitalization Threshold
– defines the criteria (dollar amount, life of the asset) that determines the proper financial reporting of the asset. Asset acquisition costs that meet the criteria are to be capitalized on the balance sheet and depreciated over the asset’s useful life (excluding land).

Construction in Progress
– The construction, including materials and services, which creates or modifies real or personal property.

Custodian
–person responsible for proper use, maintenance, and control of assigned property; will assist Clerk’s Finance with annual asset inventory.

Custodian Delegate
–person acting under the supervision of the custodian to whom the custody of property has been delegated by the custodian.

Depreciation –
The accounting method used to match the use of the asset over time to the multiple reporting periods the asset serves.

Easement
– The right to use the land of another for the specific purpose(s) stated therein.

Equipment
– All moveable furniture, machinery, and apparatus, including, but not limited to, computer hardware, communications equipment, vehicles, boats, trucks, and heavy equipment. Equipment is categorized as a Capital Asset (acquisition cost of $5,000 or more with a normal expected life of one year or more).

Improvements
– Property or equipment which is an integral part of a larger item of property or equipment; the addition of which either increases the cost or useful life of the larger item; e.g., fencing or parking lots.

Infrastructure
– Long-lived assets that are both stationary in nature and capable of being preserved for a significantly greater number of years than most Capital Assets (roads, bridges, curbs, gutters, docks, parking areas, storm drains, sidewalks, water and sewer lines), and that have a cost of acquisition or construction of $50,000. An exception to the rule is Utility projects. Utility “infill” infrastructure projects are capitalized, no matter the cost, as each project ultimately hooks into the overall system.

Intangible assets
- Capital assets to be used over the long-term; but lack physical existence. Examples of intangible assets include computer software, patents, water rights and mineral use rights, copyrights, trademarks, and intellectual property.

Inventory
– Tangible property or goods held for sale or consumption concurrent with the normal activity of a governmental entity or enterprise.

Land
– Real property, excluding Buildings and depletable resources, whose fee title is owned solely or jointly by the County. Land is characterized as having an inexhaustible life. All expenditures made to acquire land and prepare it for its intended use are considered part of the land cost.

Library Resources
– Collection of books and other informational materials made available to the public for reading, study or reference.

Lease
– A contract that conveys control of the right to use another entity’s nonfinancial asset (the underlying asset) as specified in the contract for a period of time in an exchange or exchange-like transaction. Examples of non-financial assets include buildings, land, vehicles, and equipment.

Regulatory Conservation Easement
– Land use rights conveyed to the County at no cost through the permitting process.

Software
– Purchased, licensed, or internally generated intangible assets.

Spare Parts
– Parts removed from Surplus Property for reuse as repair or replacement parts to existing property.

Subcontractor Acquired Property
– Property provided by the County or purchased from County-provided funds for the performance of a contract or grant. Title to property will vest with the County or the original federal sponsoring agency.

Supplies –
General purpose consumable items which have a short life span (less than one year) and are stocked for recurring use. Office supplies, paper towels, and cleaning materials are examples of supplies.

Surplus Property
– Property that is obsolete, serves no useful function, is uneconomical or inefficient for continued use, or has exceeded its useful service life.

Tag (Property or Decal) Number
– Number assigned to an asset by Clerk’s Finance. The tag number is printed on a decal that is placed on moveable equipment. Once the decal has been placed, it is not to be removed. The asset ID numbers that Fleet affixes on the vehicles and equipment in the large black numbers should coincide with the asset ID number for the item.

Tangible assets
– Assets that have a physical substance, are moveable and non- consumable in nature, and are valued over $5,000 dollars with an estimated life of at least one year.

Title (Ownership) of Property
– The County owns all property acquired with funds administered by or under the control of the County. Title to assets purchased with federal funds may reside with the granting agency during the life of the contract or grant. Once a contract or grant has expired and if the granting agency no longer has a need for the property, title will revert to the County. Assets meeting the capitalization threshold will be decaled regardless of funding source.

PROCEDURE:
  1. PURCHASING, CLASSIFYING, IDENTIFYING, AND RECORDING OF CAPITAL ASSETS

(a)  Purchasing

  1. When purchasing a capital asset through a Purchasing Requisition, the requisition must reference the applicable Department and expenditure account to confirm it is a budgeted
  2. Tangible assets (other than Library materials) should not be purchased with a Purchasing card (P-card). Systems Management may purchase Capital Assets within the P-card policies and procedures.
  3. When purchasing a capital asset from contract or grant funds, specific provisions may vary. Before assets are charged to a contract or grant, Directors or designees must review the terms and conditions of the agreement and identify any limitations and/or reporting requirements.
  4. Leased Assets – per GASB 87, Leases, lease agreements that meet the definition of a lease will be classified as finance leases and recognized in the financial All leases will be reported as capital leases unless the lease is a short-term, defined as 12 months or less.
   (b) Classifying

  1. Accurate and consistent identification and classification of high value Capital Assets is critical to meaningful internal and external financial reporting of the County. To properly report an asset and ensure it will be recorded in County records, items meeting the criteria of a Capital Asset will be charged to the appropriate capital outlay object code (6000 series).
    • Land                                                                                                             56100
    • Buildings                                                                                                   56200
    • Infrastructure & Improvements Other than Buildings               56300
    • Equipment                                                                                                  56400
    • Intangible Assets                                                                                      56800

(c)  Identifying

  1. All Equipment that is a Capital Asset will be permanently marked with the identification number assigned to that item to establish its identity and County ownership by Clerk’s Finance. When physical marking would significantly impair the asset, an alternative means of identification may be used. However, County records must contain sufficient descriptive data to permit positive identification. Clerk’s Finance will record capital outlay expenditures in the general ledger. Clerk’s Finance must periodically reconcile and maintain these records in an audit file for the Capital Asset.
  2. A County Property Record will be prepared by Clerk’s Finance and distributed to each Custodian. The Custodian will review the record and advise Clerk’s Finance of any discrepancies.

(d)   Recording

  1. If the original cost of a Capital Asset (other than Land and Easements) meets or exceeds the capitalization threshold for its classification, the asset is reported on the County’s statement of net assets and depreciated over its estimated useful life. Acquisitions that do not meet the capitalization thresholds are reported as expenses in the year purchased. Failure to meet the threshold requirements for asset capitalization does not relieve the County of its custodial responsibility over the asset.
  2. Depreciation Schedule. Buildings, Infrastructure, Software, and Machinery and Equipment of the County are depreciated using the straight-line method over the following estimated useful lives:
  3. Land and Easements have indefinite useful lives and as such are not considered depreciable Capital Assets. Construction in progress is not depreciable until the project is complete or substantially complete and transferred to a depreciable Capital Asset, such as, Buildings, Infrastructure, Machinery and Equipment or other depreciable assets.
  4. Cost of Land. Costs incurred for surveys, mapping, legal fees, environmental assessments, and appraisals of Land should be included as part of the Land’s original cost.
  5. Cost of Capital Assets Other than Land. The cost of Capital Assets, other than Land, is calculated by taking the invoice price plus freight, labor, and installation, less any discounts and/or trade-ins.
CAPITAL ASSET TYPE
CAPITALIZATION THRESHOLD USEFUL LIFE IN YEARS
Land Capitalize All N/A
Buildings $5,000 10-50
*Infrastructure $50,000 10-30
Improvement Other Than Buildings $50,000 10-30
Improvement - Water/Sewer Lines $5,000 30
Machinery and Equipment $5,000 5-20
Software $50,000 7-20
*All Utility "infill" infrastructure projects are capitalized as considered part of the overall system.

  1. Attractive Items include but are not limited to: tools, equipment, computers, laptops, cameras, televisions, sound /video equipment, and other electronic-type items that may be considered portable must be tagged and tracked for inventory purposes.
    1. In coordination with the County’s, Chief Information Officer, and Clerk’s Finance, each Division will be responsible for maintaining a complete list of Attractive Items and to develop and implement inventory control procedures.
    2. For computer-related items, the County’s Systems Management Department will periodically verify the data, on Attractive Items, is on file and processes are performed to ensure the reliability and completeness of the data.
    3. For non-computer-related items, the Department which purchased the item will periodically perform the review.
  2. All Capital Assets donated to the County will be rendered on the County-wide financial statement in the appropriate asset category and as contribution revenue in an amount equal to the estimated fair market value of the donated asset as of the date of donation. The donor will provide the proper justification and fair market value of the donation per Citrus County Administrative Regulation 2.20 Donation Program.

2.  CONSTRUCTION IN PROGRESS/ MODIFICATION OF CAPITAL ASSETS.

Clerk’s Finance tracks projects using project numbers assigned by the County Departments. Assigned project numbers are included on purchase orders, journal vouchers, invoices, and P- card charges. Upon completion of the project, all costs accumulated under each project will be reconciled to the project number and appropriate Capital Asset number(s) will be established.

3.  SAFEGUARDING AND CARE
(a)   It is the Custodian’s responsibility to ensure that the County’s assets assigned to them are adequately protected against loss, damage, or theft.

This includes:

  1. Placing the asset (including attractive items) in a secured location.
  2. Performing adequate maintenance and upkeep of the asset.
  3. Continuous and consistent maintenance of the asset.
  4. Training staff on procedures for properly handling the asset (i.e., moving, transferring, and cannibalizing equipment).

4.    ANNUAL PHYSICAL INVENTORY

  1. A physical inventory of all tangible personal property (Equipment that is a Capital Asset) must be conducted each fiscal year. The inventory will be conducted under the direction of Clerk’s Finance and Custodians. Clerk’s Finance will notify the Custodians prior to such inventory so that a mutually satisfactory inventory date may be established, and that all property is available for visual inspection.
  2. Each Custodian must check all property item(s) against the County Property Report. Discrepancies must be traced, reconciled, and an inventory report must be dated and signed by Clerk’s Finance representative and the respective Custodian.
  3. The original inventory report must be filed and maintained by Clerk’s Finance. A copy of the final report must be sent to the Director, Clerk’s Finance, and each Custodian.
  4. All missing property discovered through this process must be reported pursuant to the missing Capital Assets procedures.
  5. Custodians shall track and monitor capital assets assigned to them. Custodians shall develop and implement controls to properly safeguard these items such as ensuring the asset is securely locked when not in use.

5.  MISSING CAPITAL ASSETS

Property may be removed from County Property Records pursuant to the following procedures:

  1. The Custodian must promptly report all lost, stolen, destroyed or missing Capital Assets to Clerk’s Finance.
  2. The Custodian must make a reasonable effort to locate the Capital Asset and determine if it has been misplaced, lost, stolen, or destroyed.
  3. If the Capital Asset cannot be located, the appropriate Custodian shall provide his or her office or Division director with a report on the missing property. The report must contain the following:
    1. Property identification number
    2. Manufacturer’s name
    3. Description of the property
    4. Year and/or model number
    5. Serial number
    6. Last official location of the property
    7. Last known location of the property
    8. Recorded value of the property
    9. Name of Custodian
    10. Details of the investigation to locate the property
d.  If the Capital Asset or Equipment is declared missing after two consecutive inventories, the Department Director will recommend the property’s removal from the County Property Records.in accordance with County Policy

6.   TRANSFER OF CAPITAL ASSETS
  1. Real Property Capital Assets. When transferring real property, the County will follow the procedures set forth per Administrative Regulation 03-2 Acquisition and Sale of Property (Real Estate).
  2. All Other Capital Assets. The Custodian transferring the Capital Assets must submit to Clerk’s Finance a completed Asset Activity Form. Approvals will be received from both the transferring and receiving custodians.
  3. If a Capital Asset is moved from its official location, the Custodian must complete Asset Activity Form and file it with Clerk’s Finance for updating the property records.
  4. If an asset is purchased from a contract or grant, the Custodian, and Grant Manager, when applicable, will verify the appropriateness of the transfer. Terms and conditions of the granting agency may prevent the equipment from being used for activities other than the original project’s objective.

7.    LEASE OF PROPERTY

  1. The leasing of public lands, real property and capital assets is to be governed by Florida Statutes 125.031, 253.71 and 255.2501.

8.  TRADE-IN PROPERTY

  1. As provided in section 274.04, Florida Statutes, non-consumable tangible personal property may be traded-in, and the amount allowed by a vendor for a trade-in may be subtracted from the cost to be paid by the County.
    1. Property to be traded-in, excluding vehicles and equipment approved for replacement during the budget process, must be presented to the Board which may declare the item surplus and dispose of it by trade-in.
            b. To dispose of such property by trade-in, the following procedures must be followed:
    1. The Director of the Department or Division to which the property is assigned must prepare an agenda item requesting to dispose of the property by trade-in.
    2. Once the Board approves the request, the Director or designee requesting the trade-in must:
      1. Complete an Asset Activity Form. All County decals must be removed from the asset before the property is traded in. The Asset Activity Form will be forwarded to Clerk’s Finance. The custodian is responsible for destroying the old asset tag/decal.
      2. Property containing sensitive information, such as a copier, must have all sensitive data removed prior to trade in.

9.  SURPLUS, DISPOSAL OF PROPERTY

  1. Real Property Capital Assets. The surplus of County-owned real property is governed by sections 125.35 and 274.05 Florida Statutes and Citrus County Administrative Regulation 8.03- 2, Acquisition and Disposition of Property (Real Estate).
  2. Other Capital Assets and Non-Capital Assets
  1. The Division or Department responsible for the Capital Asset must request disposal of the property from the Board, with the exception of vehicles and equipment approved by the Board through the budget process, by auction, recycling, donating to another organization/agency, landfill disposal, trade-in, cannibalizing, or other means (lost/missing, stolen, improperly disposed i.e., thrown away).   The terms and conditions of a contract or grant may stipulate how and when an asset is allowed to be disposed. Therefore, all equipment accountable to a contract or grant must be approved by the Grant Project Manager and custodian before an asset can be disposed.
  1. Administrative Regulation 16.23 Disposal of Computer Equipment and Software Media, addresses the disposal of an IT asset, regardless of its classification (capital asset, attractive item, equipment).
  2. When equipment has been deemed lost or stolen, the Department must initiate a request through an Asset Activity Form. When theft is discovered, the County Sheriff’s Office (or local authority) must be notified immediately. A copy of the police report must accompany the form when applicable. In the case of loss of property that is covered by insurance, the Custodian must notify the Risk Manager.
  3. When vehicles or equipment have been approved by the Board during the budget process, additional Board approval is not required for the vehicles or equipment being replaced, to be surplused, once the new vehicles or equipment have been issued an asset number by the Clerk of Courts Financial Services Department.
  4. After the Board declares property surplus and all necessary disposal documentation is received, Clerk’s Finance will remove the capital asset from the record.

10.      SURPLUS PROPERTY DISPOSAL PROCEDURES.

Surplus Property, other than real property, may be disposed by the following procedures:

  1. The Surplus Property may be exchanged or traded for new property, provided the value of the new property is not less than the current estimated value of the Surplus Property.
  2. The Surplus Property may be retained for Spare Parts, provided:
  1. The item is removed from the County Property Record by Commission approval.
  2. The item should be disassembled, if practicable. The parts must be maintained and used, as needed, by the requesting director. When the item is no longer useful for Spare Parts, such item must be disposed of, as any other Surplus Property item, either in whole or part, by Clerk’s Finance. 
 c. Surplus Property may be sold, donated, or destroyed as follows:
    1. Surplus Property may be offered, pursuant to section 274.05, Florida Statutes, for sale by best bid or donation to other governmental units within the County or to private non-profit agencies, as defined in section 273.01(3), Florida Statutes. The cost of transferring the Surplus Property shall be paid by the receiving governmental unit or non-profit agency.
    2. Alternatively, Surplus Property may be disposed of for value without bids to the State, any governmental unit, or political Surplus Property may also be disposed of for value to any person or entity in the following ways:
      1. Surplus Property with an estimated value of $7,500 or more will be sold only to the highest responsible bidder or by public auction after advertised notice to the general public. All surplus items not otherwise disposed of by donation or sale may be carried over to the next surplus
      2. Surplus Property with an estimated value less than $7,500 may be disposed of by the most efficient and cost-effective means.
3. Surplus Property without commercial value may be donated, destroyed, or abandoned.

d. A record of the final disposition of all Surplus Property must be provided to Clerk’s Finance.

11.      INVENTORY PROCEDURE - SUPPLIES

  1. Inventory is a complete list of items such as property, goods in stock, or the contents of a building. Supplies and raw materials shall be considered to be inventory only to the extent that they are acquired for sale or lease to customers in the ordinary course of business or will physically become a part of merchandise intended for sale or lease to customers in the ordinary course of business. Partially finished products which when completed will be held for sale or lease to customers in the ordinary course of business shall be deemed items of inventory. For the purposes of this section, fuels on hand shall be considered inventory.
  2. Many Divisions will have both supplies and inventory on hand at any given time. However, Supplies are ultimately an expenditure, while inventory is generally sold/billed to another Division/agency.
  3. Accounting for Supplies:  Supplies appear on the County's balance sheet as an asset at year end. The amount shown is equal to the cost of the items that the County has on hand. The supplies expense category is listed as a cost to the County; this is the total value of the supplies used during the period of the financial statement.
  4. Accounting for Inventory: Inventory is listed on a balance sheet as an asset. As inventory leaves the County, another asset category, accounts receivable, rises. If customers are invoiced for the sale, the amount is listed in the accounts receivable category until it is paid; the amount is then listed as cash.
  5. Any supplies with a unit cost of $1.00 or less shall not be counted, unless directed otherwise by management (i.e., needles at Animal Services, screws, and nails at Facilities Management). Supply stock that is inventoried must be coded and parts numbers documented. Partial pieces of supplies and/or inventory should be considered fully utilized and “scrap” for items that are counted by piece (e.g., PVC pipe).
  6. All inventoried Divisions must document periodic review/counts/reconciliations/audits of items on Division count sheets. Random and/or sporadic reviews are more successful in identifying intentional inventory or supply loss. Count sheets should be location specific. Updates to the count sheets to correct items that may need to be added or deleted (if an asset, this must be processed with an Asset Activity Form) or consistency of count (volume vs. piece) should be done prior to the annual inventory process.
  7. The Department is responsible for locating missing assets that were not found during the first inventory pass.
  8. Some Departments (Utilities, Jail, Systems Management, Supervisor of Elections) use a custodian delegate for asset inventory purposes and the County will continue to allow this to be used as needed throughout the County.

1.  Periodic review/counts/reconciliations/audits by Division:

A.  Animal Services

  1. Management implemented an inventory log to document cost of goods sold (COGS). The inventory log reflects the date of each item sold. When restocking is required, the inventory log reflects supplies that are logged out from the safe room and logged into the items for sale cabinet. The inventory log should be reconciled monthly.
  2. Maintain a log sheet for cleaning supply items as well as pet food. The log is used to maintain control of supplies and to assist with usage of particular items and ordering frequency. Items are logged out when utilized with assigned staff monitoring usage and when orders should be placed.
  3. Periodic review/counts/reconciliations/audits by Division should be conducted for inventory, controlled substances, and supplies.

B.  Fire Services

Periodic review/counts/reconciliations/audits by Division should be conducted for inventory and supplies.

C.  Solid Waste

Periodic review/counts/reconciliations/audits by Division should be conducted for inventory and supplies.

D.  Utilities

  1. Inventory sign-out sheets should be reviewed periodically to ensure compliance with
  2. Periodic review/counts/reconciliations/audits by Division should be conducted for inventory and supplies, including all assets off-site at utility facilities and landfill.

E.  Grounds Maintenance

Periodic review/counts/reconciliations/audits by Division should be conducted for inventory and supplies.

F.  Facilities Management

Periodic review/counts/reconciliations/audits by Division should be conducted for inventory and supplies.

G.    Fleet Management - NAPA

  1. Management has implemented an inventory system to track COGS. The volume of parts inventory makes counting each piece unreasonable and costly. The County accepts the policy to count items by weight and will tolerate the risk of minor discrepancies due to the nature of the “count”.
  2. Periodic review/counts/reconciliations/audits by Division should be conducted for inventory and supplies.

H.   Aquatic Services

Periodic review/counts/reconciliations/audits by Division should be conducted for inventory and supplies.

12.       ANNUAL INVENTORY PROCEDURES - SUPPLIES

  1. Any County Department that maintains an inventory of parts, supplies, chemicals, etc. are required to conduct an annual inventory on those items as close to the end of the fiscal year as possible.
    1. It is the role of Clerk’s Finance to audit/spot check those inventories for accuracy of count, consistency in counting methodology, strength in counting and inventory storage process, and susceptibility to fraud or theft.
    2. Divisions that currently participate in the end of fiscal year inventories are Animal Services, Fire Services, Solid Waste, Utilities, Grounds Maintenance, Facilities Management, Fleet Management, and Aquatic Services.
B.  Clerk's Finance will create and inventory schedule.
    1. Departments will conduct their inventory as close to September 30th as
    2. Clerk’s Finance will schedule to arrive on site as soon as the Department inventory is completed or sufficiently completed that the inventory would be finalized before the spot check audit process was completed.
    3. Aquatics inventory of chemicals is completed by the Department at the end of the business day on September 30th and the Clerk’s Finance audit will be completed the morning of October 1st before the chemicals are checked out for the day.
    4. Clerk’s Finance will conduct the audit of the Department count sheets based on the above information. A memo will be sent to the Division, management, and County Administrator. Adjustments will be made to correct the financial impact of the audited inventory by Clerk’s Finance.
    5. Attractive Items
A.  An Attractive Items require special attention to ensure legal compliance, protect sensitive data, and avoid potential liability, or to compensate for a heightened risk of theft. The County or the Department wishes to track the property due to various reasons, including:

  1. Property contains sensitive data
  2. Property is prone to theft or loss
  3. The Department is required to track the property
B.   An Attractive Item that is required to be tracked must be charged to expenditure account 55125, unless another expenditure account is specific for that purpose (hardware, etc.). Attractive Items include items used in mobile computing and storage devices (i.e., laptops, tablets, cameras, computer peripherals, equipment to be loaned out to other Departments and smart phones).

13.       Other

The following forms are available on the Citrus County Intranet to assist users with the management of Capital Assets:

Asset Activity Form
Asset Decision Tree determination of an asset
Fixed Asset and CIP PowerPoint training
This Administrative Regulation supersedes any previous policy, whether oral or written concerning the disposal of surplus property.


FOOTNOTES & REFERENCES TO RELATED A.R.’s: Supersedes AR 6.08 dated April 10, 2018