KUMC Program Income Policy
To set forth the requirements for disclosure of program income as a result of sponsored project activities to the KUMC Research Institute.
The University of Kansas Medical Center (KUMC), the KU Medical Center Research Institute, Inc., (KUMCRI), and each of their affiliated entities engaged in the conduct or administration of research supported by KUMC and KUMCRI.
Program income generated as a result of sponsored projects activities is required to be disclosed to the KUMCRI by the Principal Investigator.
Income generated on sponsored projects during the project period is reportable per the Office of Management and Budget Uniform Guidance (2 CFR 200). Certain income may not be required to be reported to federal sponsors, but all program income is required to be reported to KUMCRI’s financial officers. This policy is applicable to both federal and nonfederal projects for consistency in reporting.
Program income includes, but is not limited to:
- Conference or workshop fees;
- Fees for services, such as laboratory fees;
- Sale of supplies or equipment purchased or fabricated with project funds;
- Funds generated from the use, sale, or rental of equipment purchased with project funds;
- Sale of software, tapes or publications;
- Royalties from copyrights and patents;
- Charges for research resources.
1. Requirements to report program income to sponsors
Reportable: Program income that is generated while a project is active, to be reported on the Financial Status Report of the primary grant or contract.
Not reportable: Program income that is generated after the time period of the award does not need to be reported to the sponsor unless otherwise specified; program income generated as a result of royalties or other income earned from a copyrighted work, patents, or from inventions.
Sale of Equipment: If authorized by the sponsor, grantees may use the income from the sale of equipment to pay for allowable costs of the project. There are no reporting requirements for the authorized sale of equipment.
Sale of Property: The guidelines of KUMC shall be followed regarding the dispensation of funds upon the sale of property.
2. Use of Program Income
Per 2 CFR 200 Uniform Guidance, program income earned during the project period shall be retained by the recipient and, in accordance with the Federal awarding agency regulations or the terms and conditions of the award, shall be used in one or more of the ways listed in the following:
- Additive: Added to the funds committed to the projected by the Federal awarding agency and recipient and used to further eligible project or program objective.
- Matching: Used to finance the non-Federal share of the project or program.
- Deductive: Deducted from the total project or program allowable cost in determining the net allowable costs on which the Federal share of costs is based.
If an alternative use of the above is desired, then approval from the sponsor is required.
3. Roles and Responsibilities
- Disclose in the proposal whether program income may result from the project;
- If multiple grants are involved, provide the approximate percent of the costs associated with the income generation paid for by each grant;
- Identify any non-federal source of funds used to produce the income;
- Identify the fee structure or basis for the expected or actual amount of income;
- Disclose program income received during the course of the project if not accounted for in the proposal;
- Detail how program income will be used;
- Track and confirm program income on financial reports;
- Inform Sponsored Programs Administration if income is expected after the end of the project.
- Assist PI in monitoring program income on financial reports;
- Assist PI in administrative duties, such as invoicing, receiving funds, and recording program income.
Post Award Administrator:
- Confirm that program income has been recorded properly and correctly in financial reports;
- Set up program income accounts;
- Determine if program income should be reported to the sponsor and report if required;
- Monitor departments on invoicing, receiving funds, and recording;
- Determine if use for program income is allowable;
- At close out, confirm that any outstanding program income issues have been addressed and resolved.
- If the program income is determined to not be accountable under the Uniform Guidance, then the income may be deposited in a restricted fee account established through the University Budget Office.
- Based on the federal regulations, the KUMCRI will provide instructions to the departmental grant administrator (DGA) on the process to be implemented for the management of any amounts determined to be program income.
This policy does not apply to funds generated through programs from non-sponsored programs. Unless federal agencies or sponsors indicate otherwise, this policy does not include non-reportable program income.
Associate Vice Chancellor for Research Administration: 913-588-5436
Director of Sponsored Programs Administration: 913-588-1261
Uniform Guidance: The Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Chapter I, Chapter II, Part 200, addressing the administrative requirements for grants and agreements with institutions of higher education, hospitals, and non-profit organizations.
Program Income: Per the Uniform Guidance, program income is gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the award. Program income includes, but is not limited to, income from fees for services performed, the use or rental of real or personal property acquired under federally-funded projects, the sale of commodities or items fabricated under an award, license fees and royalties on patents and copyrights, and interest on loans made with award funds. Interest earned on advances of Federal funds is not program income. Except as otherwise provided in Federal awarding agency regulations or the terms and conditions of the award, program income does not include the receipt of principal on loans, rebates, credits, discounts, etc., or interest earned on any of them.
05/06/2016: Removed Date Last Reviewed
04/18/2016: Uploaded into Policy Library
05/20/15: Updated contacts and link to Uniform Guidance.
12/11/07: Effective Date