2 CFR 200.313 Equipment: Federal Grant Property Records & Physical Inventory Requirements

What 2 CFR 200.313 is, and where it sits in the Uniform Guidance

The Uniform Guidance (2 CFR Part 200) is the government-wide rulebook for federal financial assistance. It applies to states, local and tribal governments, nonprofits, universities, and other recipients, subject to some agency-specific deviations. Within it, Subpart D — Post Federal Award Requirements governs how recipients manage property bought with grant funds, and 2 CFR 200.313 is the core equipment provision, paired with the supplies rule at 2 CFR 200.314 and the definitions at 2 CFR 200.1.

Recipients generally take title to equipment on acquisition — but that title is conditional. As long as the federal government retains an interest, the recipient carries ongoing duties to use, document, safeguard, inventory, and properly dispose of the equipment. Whether those duties are met is tested during the Single Audit under 2 CFR Part 200 Subpart F.

The five management duties under 2 CFR 200.313(d) and (e)

Subsection (d) sets out the property-management standards every recipient must meet. Together they describe, almost exactly, a professionally run fixed-asset inventory program:

• (d)(1) Property records. Maintain records for each item of equipment (the required data elements are listed in the next section).
• (d)(2) Control system. Operate a control system with adequate safeguards to prevent loss, damage, or theft — and investigate any loss that does occur.
• (d)(3) Physical inventory. Take a physical inventory of the property and reconcile the results with the property records at least once every two years.
• (d)(4) Maintenance. Keep adequate maintenance procedures so the equipment stays in good condition.
• (e) Disposition. Follow defined procedures when equipment is sold, traded, or retired, including computing the federal share of any proceeds.

The requirement most organizations underestimate: a physical inventory every two years

Of all the duties in 200.313, subsection (d)(3) is the one that catches organizations out — because it is not a paperwork exercise. It requires an actual physical inventory of the equipment, walked and verified on the floor, and a reconciliation of that count back to the property records — at least once every two years. A register that has quietly drifted out of sync with reality (missing items, relocated equipment, disposed assets still on the books) is precisely what this rule exists to catch, and precisely what an auditor looks for.

Producing that evidence well means a floor-to-book and book-to-floor pass, exception handling for items found and not found, and a documented reconciliation trail. Our fixed-asset verification checklist and guide to reconciling fixed assets walk through that process step by step. Ghost assets — items on the register that no longer physically exist — are the classic finding here; see ghost asset detection.

The property records 200.313(d)(1) requires

Subsection (d)(1) is specific about what each equipment record must contain. In practice, your register needs to carry, for every item:

• a description of the equipment;
• a serial number or other identification number;
• the source of funding, including the Federal Award Identification Number (FAIN);
• who holds title;
• the acquisition date and cost;
• the percentage of federal participation in the cost;
• the location, use, and condition of the equipment; and
• ultimate disposition data, including the date of disposal and sale price.

A durable, scannable identifier is what makes those records maintainable over a two-year cycle. That is exactly the role of asset tagging — barcode, QR, or RFID tags that tie the physical item to its record so each subsequent inventory is faster and the location and condition fields stay accurate.

The $10,000 threshold — and what the 2024 revisions changed

Whether an item falls under the equipment rules at all depends on the definition in 2 CFR 200.1. The April 2024 revisions to the Uniform Guidance raised the federal equipment threshold from $5,000 to $10,000, effective for projects starting on or after October 1, 2024. Equipment is now tangible personal property with a useful life of more than one year and a per-unit cost at or above the lesser of your organization's capitalization level or $10,000. Items below that are treated as supplies.

The same 2024 package also raised the Single Audit threshold from $750,000 to $1,000,000 in federal awards expended. Importantly for property managers, the core duties in 200.313(d) did not change — the biennial physical inventory, the property records, and the control system all remain. If your policies or templates still say "$5,000," they are out of date.

Health centers and HHS grantees: 45 CFR 75.320 and the move to 200.313

Organizations funded through the Department of Health and Human Services — including HRSA-funded FQHCs and Health Care for the Homeless programs under Section 330 of the Public Health Service Act — are subject to the same property standards. Historically those appeared at 45 CFR 75.320, an HHS-specific rule that mirrored 2 CFR 200.313. HHS is now repealing 45 CFR Part 75 and adopting 2 CFR Part 200, with a new 2 CFR Part 300 for HHS-specific deviations. During the transition, some active awards still reference 45 CFR 75.320 while newer or modified awards reference 200.313 — but the substance is the same: maintain the records, run the control system, and complete the biennial physical inventory and reconciliation. Grant-funded medical and clinical equipment is high-value and mobile, which makes health centers a particularly high-risk setting for property-management findings.

Single Audit reality: why organizations get property findings

The most common equipment findings in a Single Audit are not about misunderstanding the rule — they are about execution. Auditors repeatedly find incomplete property records, a physical inventory that was never performed or never reconciled within the two-year window, and control systems that exist on paper but not on the floor. In other words, organizations know the requirement and still receive findings because they lack the floor-level evidence the rule demands. A professionally executed, independent physical inventory closes exactly that gap.

Where CPCON fits — and the honest boundary

CPCON performs the independent physical inventory, the register reconciliation, and the asset tagging that 2 CFR 200.313 relies on. We produce the walked, verified, reconciled evidence — with a documented exception and disposition trail — that supports your compliance and stands up to Single Audit testing. We work across fixed-asset inventory and count & tagging services for asset-intensive organizations.

The honest boundary: CPCON is not your auditor and does not provide legal or audit advice. We do not issue compliance opinions or guarantee an audit outcome, and this article is general information, not legal advice — always confirm requirements against your specific award terms and cognizant federal agency. What we provide is the physical evidence base that makes meeting 200.313 straightforward.