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Policy statement and procedures Adopted September 2012
The University requires principal investigators to identify and document program income on projects from both federal and nonfederal sponsors. The nature of this income must be appropriately documented and the resulting revenue properly recorded. This income must be brought to the attention of the Finance Office for deposit into the appropriate account. This policy and its procedures address the definition, management, reporting and monitoring of program income in accordance with federal and University requirements.
Sponsors provide funding to cover costs of conducting research, training and public service-related activities. Program income may be generated as a result of these activities and in some cases must be reported to the sponsor. Federal sponsors have documented in Office of Management and Budget (OMB) the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, known as the Uniform Guidance or 2 CFR 200 explicit requirements for identifying, recording, reporting and monitoring income generated during the project period. The requirements can be found in the Uniform Guidance Subpart D §200.307. This policy was implemented to comply with sponsor and University policies and to ensure that program income is managed in a manner consistent with the University's overall missions and goals.
A receipt register for tracking receipts; and
A periodic reconciliation of the receipt register to the record of deposits.
Program income awards are subject to the same sponsor rules, regulations and limitations applicable to the primary award and, accordingly, only those expenses that are allowable and allocable to the award may be charged directly to the program income award.
Program Income from Federal FundsNormally, program income earned on federally-funded research awards must be added to funds committed to the project by the federal awarding agency and used to further eligible project or program objectives. Program income earned from other federally-funded non-research awards must be deducted from the total project or program allowable cost in determining the net allowable costs on which the federal share of costs is based. Under special circumstances, program income earned on federally-funded non-research awards may be used to finance the non-federal share of the project or program (i.e., used to fulfill cost sharing requirements. See also the university's Cost Sharing on Sponsored Agreements Policy).
The OSP and Finance Office will assist the PI in reviewing sponsor regulation and/or specific award terms to identify which options are available for using the program income that is generated throughout the life of the award.
The PI must contact the department Chair who, in consultation with the Finance Office, will determine the appropriate accounting treatment for program income earned after the end of the federal project. The OSP and Finance Office can provide specific information on award terms regarding program income earned after the end of the project. The Finance Office can provide information on setting up relevant accounts for the deposit of program income earned after the end of the project, as well as any restrictions on the expenditures from such accounts. Unless the federal award or Federal awarding agency regulations specify otherwise, the university has no obligation to the federal government regarding program income earned after the project period. The Finance Office is responsible for determining the taxability of any program income.
Program Income from Non-Federal Funds
Program income earned from non-federal funds during the project period may be used in one or more of the following ways unless the sponsored agreement specifies otherwise:
The PI must contact the Finance Office to determine the appropriate accounting treatment for program income earned after the end of the non-federal project. The Finance Office is responsible for determining the taxability of any program income.
Appendix A - Guide to Identifying Revenue Generating Activities and Program Income
Origination date: September 2012 Last amended date: May 2020Next review date:
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