Policy Name: Federal Grant Program Income Policy

Owner: Vice President for College Advancement

Author: Director of Foundation & Government Resources

Contact information: Amanda Abrahamson Roseth, aabrahamson@css.edu

Effective Date: August 1, 2023

Next Review Date: 

Applicable Laws, regulations, compliance: 2 CFR 200.307

I. Purpose

This policy ensures that The College of St. Scholastica (CSS) will be compliant with the
provisions of the Federal Office of Management and Budget’s regulations including 2 CFR 200, Uniform Guidance, specifically the provisions related to program income (2 CFR 200.37).

II. Definitions

• Grant Manager – The CSS employee responsible for administering a grant project.
• Program Income – Gross income earned by CSS that is generated directly from activities supported by or as a result of a federally sponsored grant award during the period of performance.
• Program Income Accounting - Any of the four methods of accounting for program income and award value. The method to be used on a specific award is determined by the applicable federal agency, usually via the award terms and conditions.
  • Additive Method – Program income earnings may be added to the federal award by the federal agency and CSS, with approval. The program income must be used for the purposes and under the conditions of the federal award.
  • Deductive Method – Program income earnings must be deducted from total allowable costs to determine net allowable costs. Program income must be used for current costs unless the federal agency authorizes otherwise. Program income that CSS did not anticipate at the time of the federal award must be used to reduce the federal award and CSS contributions rather than to increase the funds committed to the project.
  • Matching – Program income earnings may be used to meet the cost sharing or matching requirements of the federal award, with approval. The amount of the federal award remains the same.
  • Add/Deduct Method – A portion of program income earnings are treated according to the additive method while the other portion is treated according to the deductive method, with approval.

Roles and Responsibilities

• Grant Project Director / Principal Investigator  – Identify instances or potential for program income; complete theProgram Income Documentation Form; communicate promptly with the Senior Grants Analyst.
• Director of Foundation and Government Resources – Recognize potential for program income during proposal preparation; include program income appropriately based on the funding agency guidelines; review and approve the Program Income Documentation Form.
• Grants Specialist – Recognize the potential for program income during proposal preparation and include program income appropriately based on the funding agency guidelines.
• Grants Management Specialist – Contact federal agency representatives if necessary to determine appropriate program income accounting method; review the Program Income Documentation Form.
• Senior Grants Analyst– Review and approve the Program Income Documentation Form; track program income separately; use excess program income to offset federal drawdowns; report program income funds as required by the corresponding federal agency.

III. Policy

This policy applies to all Federally funded grant programs. Because program income is
generated using federal grant resources, the revenue is the property of the corresponding federal agency and must be accounted for according to that agency’s requirements. The cost of generating the program income should be deducted from the gross program income to determine net program income if those costs have not already been charged to the federal award.

Program income fees charged and collected should be based on the actual costs of performing the work.

Whether anticipated in the proposal or not, all situations that generate program income must be documented by the Project Director / Principal Investigator as they occur or on an annual basis (for ongoing situations)  All program income earned during the project period should be appropriately expended prior to spending awarded allocations. Any program income that remains at the conclusion of the grant must be remitted to the appropriate federal agency.

The College of St. Scholastica will report program income earned to federal sponsors according to their designated reporting formats and deadlines.

Sales of property or equipment are not considered program income and must be conducted according to College’s Federal Equipment Disposal Policy.

Unless stated otherwise in the award document and corresponding terms and conditions or negotiated during award closeout, there is no obligation to the federal agency for program income earned after the project period. In the absence of either of these situations, such earnings are no longer considered program income and belong to CSS.

IV. Individuals and entities affected by this policy

• Foundation & Government Resources
• Finance
• Grant Project Directors / Principal Investigators

V. Related documents, forms, and procedures 

• Program Income Procedure
• Program Income Documentation Form

VI. History and updates

August 1, 2023: The policy was put into a new standard template. Headers and related documents and procedures were added if applicable. No substantive changes were made to content.

The College reserves the right to modify policies at any time, ensuring the involvement of relevant committees and constituents in the decision-making process (e.g., policy committee, faculty assembly, staff council, student government association, etc.).