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 OMB Circular A-110 and the applicable Code of Federal Regulations (CFR) explicit processes to be used to identify, record, report, and monitor income that is generated during the project period. To be consistent in managing program income, the University of Georgia extends the requirements to nonfederal sponsors.

Definitions

OMB Circular A-110 (Office of Management and Budget Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations) establishes uniform regulations for each federal agency to follow regarding the administration of projects sponsored by the federal government. In addition, each federal agency has its own regulations that are listed in the CFR and explained in its policy handbook, if available.

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 (OMB Circular A-110). Examples of program income include:

• income from fees for services performed, such as laboratory tests.
• money generated from the use, sale, or rental of equipment purchased with project funds.
• proceeds from the sale of supplies or equipment purchased or fabricated with project funds.
• proceeds from the sale of software, tapes, or publications.
• income from the sale of research materials such as animal models.
• fees from participants at conferences or symposia.
• sales of products with an accompanying material transfer agreement (MTA).
• royalties from patents and copyrights (NOTE:  Royalty income from copyrights, while defined as program income, is not reportable unless the terms and conditions of the award indicate otherwise. Royalties resulting from patents are program income but are reported following the University policy on Reporting Inventions.)

Program income does not include:

• patient care credits.
• interest earned on advances of federal funds.
• receipt of principal on loans, credits, discounts, etc. or interest earned on them.
• taxes, special assessments, levies, and fines raised by government recipients.

Sponsored Project is an externally funded activity that is governed by specific terms and conditions. Sponsored projects must be separately budgeted and accounted for subject to terms of the sponsoring organization. Sponsored projects may include grants, contracts, and cooperative agreements for research, training, and other public service activities.

The University of Georgia requires Principal Investigators (PI) to identify and document program income on projects from both federal and non-federal sponsors. The nature of this income must be appropriately documented and the resulting revenue properly recorded. This income must be sent to the Contracts and Grants Division (C&G) 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.   Excluded from program income reporting requirements are:

?         revenue generated through programs funded by sources other than sponsored projects, royalty income resulting from copyrights unless addressed in the award terms, and royalties or license fees for unpatented, but potentially patentable discoveries that are disclosed to the Technology Commercialization Office.

?         income received on non-federal awards that are silent on program income.

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.

Responsibilities

 Principal Investigator
Identify sources of actual and potential program income at the proposal stage and mark 'yes' to the program income question on the Sponsored Program Transmittal Form. Complete required program income sections in application. Determine whether it is reportable to the sponsor and seek advice, if necessary, from the Office for Sponsored Programs.  Prepare plan for using program income. Discuss anticipated program income with the department administrator. Provide information regarding budget categories for program income account establishment. Verify program income on reports. At final project termination, address account balance issues.

Department Administrator
Invoice for product or service. For cash, deliver to C&G for deposit. Verify program income receipt on financial reports. Redistribute program income revenue in spending categories. Monitor expenditure levels in project to ensure that program income is spent first. Provide administrative assistance to the Principal Investigator, including initiating collections actions for unpaid invoices. Verify program income reported on financial reports submitted by C&G to the sponsor.

 Office for Sponsored Programs
Review proposal and Transmittal Form for anticipated program income, and determine whether it is reportable or non-reportable.

Accounting Division
At project termination, handle revenue earned after the grant period has ended as a departmental sales and service activity