Notes on Property Management Policy

Sections 200.310-200.316 of 2 CFR 200 are devoted to defining the standards for property management by recipient organizations.

Note on real property (defined at 2 CFR 200.85): The regulation governing real property is found at 2 CFR 200.311. The balance of this page deals only with personal property.

Much of the personal property (defined at 2 CFR 200.78) that your organization buys will have a useful life of more than a year, with title vesting with you (the recipient). However, even when title vests with the recipient, the USG funder retains an interest in property purchased using federal funds, at least until it is fully consumed or its fair market value (FMV) drops below your organization's capitalization threshold. See Property Management Issues for a more in-depth discussion of federal interest, capitalization threshold, useful life of property, unused supplies, etc., and how these issues affect your property management policy.

2 CFR 200's property management sections put most of their energy into differentiating among types of property (real, personal, intangible, computing devices, "equipment" vs. "supplies"), defining how title is held, and providing instructions for the disposition of property that is no longer needed.

However, Section 200.313, paragraph(d), defines specific points that the recipient must include in its property management policy. Here are some brief notes on what an NGO's property management policy must cover.


  • Provide for maintaining Property Records that include the following:
    • description of the property;
    • a number that uniquely identifies the property;
    • source of funding (including the FAIN - Federal Award Identification Number);
    • who holds title to the property;
    • acquisition date;
    • acquisition cost;
    • percentage of federal participation in the acquisition cost (as the percentage of federal participation in the total project costs of the project under which the property was acquired);
    • location of the property;
    • use of the property;
    • condition of the property;
    • ultimate disposition (disposal, sale, donation, etc.); and
    • date of final disposition.
  • Conduct a Physical Inventory that is reconciled to the property records, at least once every two years.
  • Maintain a Control System that ensures adequate safeguards to prevent loss, damage or theft of the property and that requires the investigation of any such loss, damage or theft.
  • Provide for Maintenance Procedures that assure the property is kept in good condition.
  • Establish proper Sales Procedures to ensure highest possible return, when the recipient is authorized or required to sell the property.

That's what's required. But given that your obligation to the federal funder regarding disposition of personal property at the end of an award depends on the current fair market value (FMV) of the property (see 2 CFR 200.313 paragraph (e) and 2 CFR 200.314 paragraph (a)), your policy should also provide for methods of estimating FMV, guidance for determining the useful life of durable items, requirement for inventory management of durable supplies (property with unit value below your capitalization threshold and with useful life of one year or more) and rules for managing consumable supplies when quantities on hand exceed what you would reasonably expect to consume within 30 days of acquisition. See Property Management Issues for a more in-depth exploration of these topics.

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