For school districts & public institutions

What 2 CFR 200.313 and GASB-34 Actually Require — And Where Asset Tags Fit

If you're a business official, facilities director, or IT director at a public school district or state university, you've probably run into these two requirements even if nobody ever spelled them out clearly. Here's what they actually say, in plain terms.

2 CFR 200.313 — the federal equipment rule

This is part of the federal Uniform Guidance governing how recipients of federal funds — Title I, IDEA, E-Rate, ESSER, and virtually every other federal program that touches a public school district or public university — have to manage equipment bought with that money.

It applies to "equipment": tangible, non-expendable property with a useful life of more than one year and an acquisition cost of $5,000 or more per unit (many districts set a lower internal capitalization threshold, and track more than the federal floor requires).

For qualifying equipment, it requires:

• Accurate records for each item — description, serial number or other identification number, funding source, who holds title, acquisition date, cost, location, condition, and eventual disposition.
• A physical inventory taken and reconciled against those records at least once every two years.
• A control system adequate to prevent loss, damage, or theft.

The "identification number" piece is where physical tagging comes in directly — you can't run a reconciled inventory without a reliable way to match a physical item in a room to its record on paper.

GASB-34 — the accounting side

Governmental Accounting Standards Board Statement 34 governs how state and local governments — including public school districts and public universities — report capital assets on their financial statements.

It requires capitalizing and depreciating capital assets, which means maintaining a capital asset register accurate enough to hold up under audit, not a spreadsheet nobody's checked in years.

What asset tags actually solve — and don't

A durable, uniquely serial-numbered tag on each qualifying item is the standard way institutions satisfy the identification/control piece of both requirements — it's what turns a two-year physical inventory or an auditor's sample test into something you can do quickly and accurately, instead of a room-by-room guessing exercise.

Worth being clear about: tags alone aren't the whole compliance picture. You still need the underlying inventory records, someone responsible for maintaining them, and an actual periodic physical count. Tags are the part that makes all of that fast and reliable — not a substitute for having the system in the first place.

Quick questions

Does this apply to devices like Chromebooks and tablets?

If your district capitalizes them, yes — the same identification and tracking requirement applies. 1:1 device programs often push total values well past most internal thresholds even at a few hundred dollars per unit, so a lot of districts do tag and track them.

How often does the physical inventory actually need to happen?

At least once every two years under 2 CFR 200.313. Many districts do it annually anyway, to stay ahead of the audit cycle rather than scrambling right before one.

What if our current tags are already worn or illegible?

That's a common finding. Durable or tamper-evident tag stock costs a little more per unit but holds up on equipment that gets handled, cleaned, or moved often — worth it specifically for the items most likely to fail an audit sample otherwise.

This is a general explanation, not legal or audit advice. Your business office or auditor can confirm your institution's specific capitalization threshold and inventory policy.