The Property Records Federal Grants Require: Every Data Element Under 2 CFR 200.313(d)(1)

Why property records are the backbone of 200.313

The property standards in 2 CFR 200.313 — the Equipment section of the federal Uniform Guidance — rest on one foundation: an accurate property record for every item of equipment bought with federal funds. The control system, the physical inventory every two years, the disposition procedures — all of them reference back to what the record says an asset is, where it is, and what award paid for it. If the record is incomplete, the rest of the program has nothing to reconcile against.

That is why subsection (d)(1) is specific about content. It does not simply ask you to "keep records"; it enumerates the data elements each record must contain. Getting that list right is the difference between a register that supports a clean review and one that generates findings the moment it is tested. For the full set of management duties around these records, see our pillar on 2 CFR 200.313 equipment requirements.

The full 200.313(d)(1) data-element list

Subsection (d)(1) requires that equipment records include, for each item, all of the following:

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

Every one of these is mandatory. A register that carries only a description, a cost, and a location — a common shortcut — is missing more than half of what the rule requires.

The fields organizations most often miss: FAIN and federal share

In practice, two elements are omitted far more often than the rest: the source of funding, including the FAIN, and the percentage of federal participation in the project costs. Both trace an asset back to the specific award that paid for it and record how much of that cost was federal. They feel like accounting metadata rather than asset attributes, so they are the first fields to fall off a register that was built for internal tracking rather than grant compliance.

They matter most at the end of an asset's life. When grant-funded equipment is sold or otherwise disposed of, the federal share of the proceeds generally has to be computed — and you cannot compute it without knowing the award and the percentage of federal participation. A register missing those fields turns disposition into a reconstruction exercise, often years after the purchase, when the source documentation is hardest to find.

Keeping records accurate across the two-year cycle

Property records are not a one-time build. 200.313 requires a physical inventory reconciled to the records at least once every two years, and the location, use, and condition fields drift the fastest — equipment moves, gets reassigned, and wears out between counts. Keeping those fields honest is what makes each biennial inventory a verification rather than a rebuild.

A durable, scannable identifier is what holds the record and the physical item together over that cycle. Barcode, QR, or RFID asset tags let each item be located and confirmed by a scan, so location and condition stay current and the next inventory is faster because verification is a read, not a manual match. The reconciliation step itself — comparing the walked count back to the register — is covered in our guide to reconciling fixed assets.

Disposition data and the federal share

The last data element — ultimate disposition data, including the date of disposal and sale price — closes the loop on each asset. It is also where the two most-missed fields come back into play. Because the federal share of any sale proceeds must be computed, the disposition record only works if the FAIN and the percentage of federal participation were captured up front and carried through the asset's life. Recording disposition well means the sale price, the disposal date, and the federal-share calculation all sit in the same register entry, traceable back to the original award.

Where CPCON fits — and the honest boundary

CPCON performs the physical inventory, the asset tagging, and the register reconciliation that populate and maintain a property record meeting the 200.313(d)(1) data elements. We work across fixed-asset inventory and count & tagging services to build the walked, verified, tagged register grant recipients rely on.

The honest boundary: CPCON supports your compliance and audit readiness but is not your auditor. We do not audit, certify, or issue compliance opinions, and this article is general information, not legal advice — always confirm the required data elements against your specific award terms and cognizant federal agency. What we provide is the physical evidence base and the maintained property record that make meeting 200.313(d)(1) straightforward.