School District Asset Tracking for Federally Funded Equipment:
A 2 CFR 200.313 Compliance Guide

Short answerEquipment bought with federal grant money falls under 2 CFR 200.313. Each item needs a property record: description, ID or serial number, funding source and FAIN, cost, federal share, location, condition and disposition data. Schools must physically count it at least every two years, reconcile the count to the records, and keep controls against loss and theft.

Key takeaways

• 2 CFR 200.313(d) sets five management requirements for federally funded equipment: complete property records, a physical inventory every two years, a loss-prevention control system, regular maintenance, and proper sales procedures.
• Since the 2024 Uniform Guidance revision (effective October 1, 2024), “equipment” means items costing at least the lesser of your capitalization level or $10,000 per unit. The previous figure was $5,000.
• Tag every record with its funding source and FAIN when the item is received. Recovering that information later, during an audit, is much harder.
• Most student laptops fall below the threshold, but districts track them anyway because they are the items most likely to go missing.
• A barcode-based asset system turns the biennial inventory into a scan-and-reconcile exercise instead of a spreadsheet hunt.

What does 2 CFR 200.313 require schools to do with federally funded equipment?

It requires you to know what you bought, where it is, what condition it is in, and what happened to it at the end of its life, and to prove all of that with records. The Uniform Guidance (2 CFR Part 200) applies to K-12 districts and colleges that receive federal awards, directly or as subrecipients through a state education agency. Section 200.313(d) says the recipient “must manage equipment (including replacement equipment) utilizing procedures that meet the following requirements”:

• Property records “must include a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property.”
• Physical inventory: “A physical inventory of the property must be conducted, and the results must be reconciled with the property records at least once every two years.”
• Control system: “A control system must be in place to ensure safeguards for preventing property loss, damage, or theft. Any loss, damage, or theft of equipment must be investigated.”
• Maintenance: “Regular maintenance procedures must be in place to ensure the property is in proper working condition.”
• Sales: if you are authorized to sell the property, “proper sales procedures must be in place to ensure the highest possible return.”

One nuance: paragraph (b) says states manage equipment under their own state laws and procedures. Districts and colleges that receive funds through a state as subrecipients follow paragraphs (c) through (e). Most school districts are in that second group. Your state education agency may also add its own inventory rules on top.

What counts as “equipment” under the current Uniform Guidance?

Under 2 CFR 200.1, equipment is “tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost that equals or exceeds the lesser of the capitalization level established by the recipient or subrecipient for financial statement purposes, or $10,000.”

The $10,000 ceiling is new. The Office of Management and Budget’s 2024 revision of the Uniform Guidance (89 FR 30046, published April 22, 2024) took effect October 1, 2024, and raised the threshold from the long-standing $5,000. Two consequences for schools:

• Your capitalization policy may now set the threshold. If your board policy capitalizes items at $5,000, your threshold is still $5,000 because the rule uses the lesser of the two.
• Older awards may carry the older threshold. The terms of the specific award govern, so check each grant’s terms and conditions before you reclassify anything.

Items under the threshold, such as most Chromebooks, projectors and document cameras, are not “equipment” under 200.313. Districts still track them for three practical reasons. They are the items most often lost or stolen. State or local policy frequently requires tracking of “sensitive” or “theft-prone” items. And auditors reviewing a federal program will ask how you safeguarded everything bought with its money, not just items over $10,000.

How do you tag assets by funding source so audits are easy?

Capture the funding source when the item is received, not afterwards. Once a device is on a cart in a classroom, nobody remembers which grant paid for it. A workable pattern:

1. Require a funding source and FAIN on every purchase order line that uses federal money.
2. When items arrive, receive them against the PO in your asset system so cost, date and funding source copy onto each asset automatically.
3. Print and apply asset tags at receiving, before items leave the warehouse or tech office.
4. Run a monthly “missing funding source” report and fix the gaps while the paperwork is still fresh.

BarCloud has written about this workflow in more depth in Funding source tracking for schools. The goal is to answer “show me everything bought with this grant, and where it is today” with one report.

How do you run the biennial physical inventory, step by step?

The regulation requires a count and a reconciliation. Counting the items is not enough; you also have to explain every difference between what you counted and what your records say. Here is a procedure that works for multi-campus districts.

1. Freeze the baseline. Export the current property records by site and room. Tell sites that moves and disposals are paused during the count window, or that they must be scanned when they happen.
2. Assign counters by room. Give each counter a room list and a scanner or phone with the mobile app. Counting room by room makes “not found” meaningful.
3. Scan everything physically present, including items with no tag. Untagged items go on an “unidentified” list for follow-up. They are often grant purchases that were never received properly.
4. Reconcile three lists: found where expected; found somewhere else (update the location); not found. Asset systems with cycle-count features produce these lists automatically. BarCloud labels them Found, To Be Found and Unidentified.
5. Investigate every “not found”. Check checkout records, repair logs and disposal paperwork. 200.313(d)(3) requires loss, damage or theft to be investigated, and reported to the federal agency or pass-through entity if it affects the program.
6. Update conditions during the count, which also supports the maintenance requirement in (d)(4).
7. Sign off and archive. Save the dated reconciliation report, the not-found investigation notes and the approver’s sign-off. This package is what you hand an auditor.

Districts that count high-risk items such as laptops, tablets and AV equipment every year find the biennial count much smaller. By the time it comes around, most discrepancies have already been cleared.

How should districts handle 1:1 laptop check-out at the start and end of the year?

Treat each student device like a library book: one scan to assign it, one scan to return it, and a condition note both times. A practical workflow:

• Before the year: tag each device and charger (a charger is often a separate, frequently lost item), and import the student roster so devices can be assigned by name or ID.
• Distribution day: scan the student ID, then the device. Record the condition and, if your policy requires it, capture the parent or student signature.
• During the year: log repairs and loaner swaps as check-ins and check-outs so the history stays complete.
• Collection day: scan returns, record the condition and run a “still checked out” report before students leave for summer.

The Okanogan School District in Washington moved from handwritten laptop check-out sheets to mobile check-out and check-in, and could track devices from anywhere without buying extra hardware (case study).

What should a school look for in asset management software?

• Custom fields for funding source, FAIN and federal share, so the 200.313 fields are first-class data, not notes.
• Check-out/check-in with due dates for student and staff devices.
• Cycle counts by room with found, not-found and unidentified results.
• Phone-based scanning, so every campus does not need dedicated scanners.
• Multi-site permissions, so each campus sees its own assets and the district office sees everything.
• Maintenance logs and a disposal status that keeps history.
• Directory integration (Active Directory or Google Workspace) so staff and student lists stay current.

BarCloud’s asset tracking system includes check-out/check-in with reservations and email/SMS alerts, cycle counts, maintenance tracking, depreciation, and iOS and Android apps that use the phone camera as a scanner. Active Directory and Google Workspace integrations are included on the Standard and Professional plans. See how districts use it on the education page.