2 CFR Part 200.313(d)(3) is a Federal regulation. CFR stands for the  Code of Federal Regulations which is contained in the Office of Management and Budget (OMB) Uniform Guidance manual. It is nicknamed the Green Book and contains the rules for Federal grants.

For the smallest grant recipients, one key area that has been lacking is a uniform equipment marking system (UEMS). In the following link at Grants.gov, the first word mentioned is “Uniform.”

The core regulation is as follows:
2 CFR Part 200.313 – Equipment.
(d) Management requirements.
(3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated.

Operation Identification

Operation Identification was developed in the 1960s by the police. It is the earliest attempt to use a universal identification number (UIN) which was originally the Social Security number. In the 1970s the UIN shifted to a driver’s license number and the 2-letter state abbreviation. But where does that leave small organizations? What UIN should they use? I don’t think a tax identification number (TIN) was ever even considered.

The original strategy was so popular among law enforcement professionals, that a massive five-year undertaking was executed at the Federal level. In 1979, the Department of Justice rolled out OperationID as the companion to Neighborhood Watch. Historically, the problem with Operation ID was its lack of a uniform equipment marking system (UEMS) with the result being an inability to issue unique identification numbers (UIN) that can be stored securely on a uniform identification system (UIS).

Internet-Based Equipment Marking

In the mid 1990s, strategies were developed to harness the power of the internet to finally create a management and control system for equipment and other capital assets. Operation ID was migrated to the web with capabilities complying with FAR, DFARS and NASA’s NFS requirements for labeling property and a simple web-based, secure portal for entering the make, model and serial number and any other information.

An Often Ignored Regulation

Large institutions can afford the turnkey strategy of an enterprise asset management (EAM) system. Up until the development of web-based uniform equipment marking systems (UEMS), tiny companies had to rely on throw-back, old-school strategies like ledgers, spreadsheets and databanks. Today that’s changed. A compliant, integrated, registration solution for the smallest players is just a click away.


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