FQHC & Health Center Equipment Management: Meeting HRSA and Uniform Guidance Property Standards

Which property rules apply to FQHCs

Federally Qualified Health Centers and Health Care for the Homeless programs are funded under Section 330 of the Public Health Service Act and administered by the Health Resources and Services Administration (HRSA), an agency of the Department of Health and Human Services (HHS). Because that money is federal financial assistance, the equipment a health center buys with it is subject to federal property and equipment standards — the same family of rules that govern any grant-funded equipment.

In practice that means three things every recipient must do: maintain detailed property records, operate a control system that safeguards equipment against loss, damage, or theft, and take a physical inventory reconciled to those records at least once every two years — plus the disposition rules that apply when equipment is retired. For the full text of the underlying equipment rule, see our pillar guide to 2 CFR 200.313 equipment requirements.

45 CFR 75.320 and the move to 2 CFR 200.313

Historically, HHS grantees followed 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 to carry any HHS-specific deviations. This matters for health centers because it changes the citation you will see on your award — not the underlying duties.

During the transition, expect both to be live at once:

• Some active awards still reference 45 CFR 75.320 — the HHS rule most FQHCs have operated under for years.
• Newer or modified awards reference 2 CFR 200.313 — the government-wide Uniform Guidance equipment rule that HHS is adopting.

The honest read is to present both, dated, and confirm against your specific award — but the substance is the same under either citation: property records, a control system, a physical inventory reconciled with the records at least once every two years, and defined disposition rules. If your policies still cite only 45 CFR 75.320, they are not wrong for older awards — but they should also account for 200.313 on anything new.

Why health-center equipment is high-risk

Grant-funded medical and clinical equipment is a difficult population to keep accurate. It is high-value — often well above the equipment threshold — and it is highly mobile: infusion pumps, portable ultrasound, dental and diagnostic equipment move between exam rooms, between clinic sites, and out onto mobile units that deliver care in the community. Every one of those moves is a chance for the property register to drift out of sync with reality.

That combination — expensive, portable, spread across multiple locations — is exactly what makes health centers a high-risk setting for property-management findings. Equipment that is on the register but no longer where the record says (or no longer there at all) is the classic exception, and it accumulates quietly between inventory cycles. Note too that the 2024 Uniform Guidance revisions raised the equipment threshold to $10,000 and the Single Audit threshold to $1,000,000 (effective for projects starting on or after October 1, 2024) — thresholds that apply to health centers as much as to any other recipient.

The biennial physical inventory in a clinical setting

The requirement that catches organizations out is the physical inventory every two years. It is not a paperwork exercise — it requires an actual physical inventory, walked and verified on the floor, and a reconciliation of that count back to the property records. In a clinical setting that means working around care delivery: pulling together equipment that is scattered across exam rooms, back-of-house, satellite sites, and mobile units, and accounting for items that were in use, in storage, or out for service at the moment of the count.

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. A durable, scannable asset tag on each item is what makes this maintainable across a two-year cycle — it ties the physical equipment to its record so location and condition stay accurate and each subsequent inventory is faster. Our fixed-asset verification checklist walks through that process step by step.

Getting HRSA-audit-ready

Most equipment findings 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. For a multi-site health center, the practical path to readiness is a single, independent physical inventory that covers every site and mobile unit, tags the equipment, and reconciles the result to the register with a documented exception and disposition trail.

That work sits squarely within our fixed-asset inventory and count & tagging services. It produces the walked-and-verified evidence base that HRSA and Uniform Guidance property standards rely on — the property records, the biennial reconciliation, and the control-system trail a Single Audit tests.

Where CPCON fits — and the honest boundary

CPCON performs the independent physical inventory, the asset tagging, and the register reconciliation across every site and mobile unit — producing the evidence that supports your compliance and audit readiness under 45 CFR 75.320 or 2 CFR 200.313.

The honest boundary: CPCON is not your auditor and does not certify, issue compliance opinions, or provide legal advice. We support compliance and readiness; this article is general information, not legal advice. Because the HHS transition means both 45 CFR 75.320 and 2 CFR 200.313 can be in play, always confirm the applicable requirements against your specific award and HRSA/HHS terms. What we provide is the physical evidence base that makes meeting those standards straightforward.