Equipment Property Mgmt (2 CFR 200.313)

When a university or other non-federal entity purchases equipment with money from a federal grant or cooperative agreement, title to that equipment usually vests immediately in the recipient — but that ownership is conditional, not absolute. Under 2 CFR 200.313 (“Equipment”), part of the OMB Uniform Guidance, the recipient must operate a property management system that meets specific federal requirements for as long as the federal government retains an interest in the equipment, and must follow federally-prescribed rules when the equipment is eventually sold, transferred, or scrapped. Research offices that get this wrong — missing records, skipped inventories, equipment sold without disposition instructions — create real audit findings, not paperwork nitpicks.

This guide covers what a compliant property management system under 2 CFR 200.313 actually requires, what belongs in a property record, how often physical inventories must happen, the federal reporting mechanism (the SF-428 form family), and where the disposition thresholds and dollar figures currently stand.

Scope: What Counts as “Equipment” Under 2 CFR 200.313

2 CFR 200.313’s obligations attach to items that meet the Uniform Guidance definition of “equipment” at 2 CFR 200.1: tangible personal property (including information technology systems) with a useful life of more than one year and a per-unit acquisition cost equal to or exceeding the lesser of the recipient’s own capitalization threshold or $10,000. That $10,000 figure was raised from a prior $5,000 threshold, effective for federal awards issued on or after October 1, 2024, as part of OMB’s April 2024 revision to the Uniform Guidance. Items below the threshold, or with a useful life under a year, are “supplies” and fall under the much lighter 2 CFR 200.314 rules instead — don’t apply the property-management machinery below to a $2,000 lab instrument just because it was bought on a grant.

2 CFR 200.313 governs equipment the recipient purchases using award funds, where title vests in the recipient subject to conditions. That’s a different regulatory situation from equipment a federal sponsor furnishes directly to a recipient without the recipient ever purchasing it — that scenario is governed by the neighboring section, 2 CFR 200.312 (“Federally owned and exempt property”), where the federal government retains title throughout. See CASRAI’s separate guide on government-furnished property under 2 CFR 200.312 for that distinct case. The two sections share some mechanics (including the SF-428 reporting family discussed below), but the underlying title and disposition rules differ, so don’t conflate them when advising a PI or auditor.

The Six Elements of a Compliant Property Management System

2 CFR 200.313(d) specifies, at minimum, what a recipient’s (and any subrecipient’s) property management system must include:

Property records, maintained per item, containing: a description of the property; a serial number or other identification number; the source of funding for the property, including the Federal Award Identification Number (FAIN); who holds title; the acquisition date; the cost; the percentage of federal participation in the cost; the location, use, and condition of the property; and any disposition data, including the date of disposal and sale price.
A physical inventory, conducted and reconciled against the property records, at least once every two years.
A control system to prevent loss, damage, or theft of the equipment, with any loss, damage, or theft investigated and documented.
Adequate maintenance procedures to keep the equipment in good operating condition.
Sales procedures, if the recipient is authorized to sell the equipment, designed to ensure the highest possible return.
Disposition procedures that follow the rules in 2 CFR 200.313(e) once the equipment is no longer needed for the project (covered in detail below).

Property records must also be updated whenever an item’s status changes — transferred to a different project, relocated, damaged, or retired — not just created once at purchase and left static. Most research institutions run this through a centralized asset-management or capital-equipment inventory system operated by the sponsored-programs, procurement, or facilities office, with departments and PIs holding day-to-day custodial responsibility for the physical item.

Disposition: What Happens When Equipment Is No Longer Needed

2 CFR 200.313(e) sets out what a recipient must do once federally-funded equipment is no longer needed for the project or program that acquired it (or any other currently federally-supported project):

Current per-unit fair market value of $10,000 or less: the recipient may retain, sell, or otherwise dispose of the equipment with no further obligation to the federal awarding agency. If sold, the recipient may retain up to $1,000 (or 10% of the sale proceeds, whichever is less — some agency terms vary this) of the proceeds for selling and handling costs, with the remainder allocated to the federal share.
Current per-unit fair market value over $10,000: the recipient must request disposition instructions from the federal awarding agency (or pass-through entity, for a subaward). If the agency doesn’t respond within 120 days of the request, the recipient may retain or sell the equipment, but the federal government retains a right to compensation based on its percentage share of the equipment’s original cost.

The $10,000 disposition threshold, like the $10,000 equipment-definition threshold, was raised from a prior $5,000 figure in OMB’s April 2024 Uniform Guidance revision, effective for awards issued on or after October 1, 2024. Awards issued before that date may still reference the older figure in their terms — check the specific award’s effective date rather than assuming the current threshold applies retroactively. Real property and federally-owned property follow separate rules under neighboring sections of Subpart D; don’t apply the equipment threshold to land, buildings, or government-titled property.

The SF-428 Form Family: How Property Gets Reported to the Federal Government

When a federal awarding agency requires formal property reporting — typically specified in the award’s terms and conditions, and routine at closeout for awards that acquired reportable equipment — recipients use the SF-428, “Tangible Personal Property Report,” and its attachments (OMB control number 4040-0018). The base SF-428 establishes the reporting relationship; which attachment gets filed depends on when and why the report is being made:

SF-428-A (Annual Report): used when an award’s terms require periodic reporting on property status during the period of performance, rather than only at the end.
SF-428-B (Final Report): used at award closeout, to provide a final accounting of property (both federally-owned property and award-acquired equipment) as the award ends.
SF-428-C (Disposition Request/Report): used at any point other than closeout — during the award period or after closeout, as long as the federal government still retains an interest in the item — to request disposition instructions or report a disposal, corresponding to the over-$10,000 disposition scenario above.
SF-428-S (Supplemental Sheet): used alongside any of the above to list individual item detail when more rows are needed than the base form provides.

Not every award requires an SF-428 filing. If no reportable property was acquired, or if all equipment on the award falls under the $10,000 no-further-obligation threshold and the award’s terms don’t independently require periodic reporting, there may be nothing to report at closeout beyond noting that fact. Always check the specific award’s terms and conditions and the awarding agency’s own closeout instructions rather than assuming the SF-428 suite is or isn’t required — requirements vary by agency and by award.

Setting Up a Property Management System That Holds Up to Audit

Tag and record at acquisition, not later. Assign an asset ID/barcode and create the property record the moment equipment is received, capturing all the required 200.313(d) data elements while the purchase documentation (PO, invoice, funding source) is still readily on hand.
Calendar the biennial inventory. A two-year physical-inventory cycle is easy to let slide without a standing recurring process; institutional research-equipment inventories are frequently flagged in Single Audit findings when reconciliation lapses.
Capture the federal percentage of participation at the item level. If equipment was cost-shared or purchased partly with non-federal funds, the property record needs the federal share percentage on file — it directly determines the government’s compensation right at disposition.
Route disposition requests before selling, not after. For equipment over the $10,000 threshold, request agency disposition instructions and document the 120-day window; selling first and reporting later inverts the required sequence and is a common audit finding.
Flow the same requirements down to subrecipients. A subaward that purchases equipment with pass-through federal funds is still subject to 2 CFR 200.313 — the pass-through entity’s monitoring plan should confirm the subrecipient maintains equivalent property records and inventory practices.
Don’t let insurance/maintenance obligations get lost. Some award terms or institutional policy layer additional insurance or preventive-maintenance requirements on top of the federal baseline — check both the award terms and institutional equipment policy, not just 2 CFR 200.313 alone.

Frequently Asked Questions

What equipment is subject to 2 CFR 200.313’s property management requirements?

Tangible personal property with a per-unit acquisition cost at or above the lesser of the institution’s capitalization threshold or $10,000, and a useful life of more than one year, purchased in whole or in part with federal award funds. Items below that threshold are “supplies” under 2 CFR 200.314, not “equipment,” and don’t carry the same property-management obligations.

Do I have to file an SF-428 for every piece of grant-funded equipment?

No. Whether an SF-428 filing is required depends on the specific award’s terms and the awarding agency’s closeout instructions — not every award requires it, and equipment at or below the $10,000 disposition threshold generally carries no further reporting obligation once the recipient disposes of it. Check the award terms and the agency’s own guidance before assuming a filing is or isn’t needed.

How often must a physical inventory of federally-funded equipment be conducted?

At least once every two years, reconciled against the property records, per 2 CFR 200.313(d)(2).

Who owns equipment purchased with federal grant funds?

Title generally vests in the recipient (the university or other non-federal entity) upon acquisition, but that title is conditional: the recipient must use the equipment for the authorized purpose, maintain a compliant property management system, and follow the federal disposition rules when the equipment is no longer needed. This is different from federally-owned property under 2 CFR 200.312, where the federal government retains title throughout.

What’s the difference between 2 CFR 200.312 and 2 CFR 200.313?

200.312 covers property the federal government itself owns and furnishes to a recipient (title stays with the government); 200.313 covers equipment the recipient purchases with award funds (title vests in the recipient, subject to federal conditions). See CASRAI’s guide on government-furnished property under 2 CFR 200.312 for the federally-owned-property case.

Property Management System Requirements for Federally-Funded Equipment (2 CFR 200.313)