N. Program Income on Externally Sponsored Programs

(Note: OLPM sections on this page may be cited following the format of, for example, "UNH.VIII.N.1.1". These policies may be amended at any time, do not constitute an employment contract, and are provided here only for ease of reference and without any warranty of accuracy. See OLPM Main Menu for details.)

1.    Preamble

1.1   This University of New Hampshire (UNH) policy was created in order to provide guidance to faculty and staff concerning program income generated under sponsored programs, including:

  • Requirements for including program income in proposals for sponsored programs;
  • The management of program income according to federal requirements; and
  • The procedures to record program income expenditures in UNH's financial system

1.2   This policy applies to all externally sponsored grants at UNH regardless of the source of sponsorship. That said, income generated through non-federal awards will be administered on a case-by-case basis according to the terms and conditions in the award document. If the sponsor does not address the issue of program income, the income is not reportable and therefore not considered program income. In these instances, income is handled according to the USNH Administrative Procedures for Revenue and Cash Receipts. This policy does not apply to externally sponsored contracts unless required by the terms and conditions of a specific contract.

2.   Definitions

2.1   Program income is the gross income directly generated by a sponsored activity or earned as a result of an externally funded award during the period of performance. Examples of program income include, but are not limited to:

  • Fees earned from services performed under the project, such as laboratory tests;
  • Funds generated from sales of commodities and research materials, such as tissue cultures, cell lines and research animals;
  • Conference fees charged when a grant funds a conference;
  • Income from registration fees, consulting, and sales of educational materials; and
  • Sale, rental, or usage fees, such as fees charged for the use of computing or laboratory equipment purchased with grant funds

2.2   "Project performance" means the time during which UNH may incur new obligations to carry out the work authorized under an externally sponsored program.

3.   Policy

3.1   Anticipated program income must be declared in the proposal or application to the prospective sponsor. Unanticipated program income realized during the project period must be reported promptly to the sponsor with a request for disposition instructions as noted below.

3.2   Program income earned during the sponsored program project period is administered according to one of the following methods as specified by sponsor policies and/or the terms of the award:

  • Additive Method: Program income will be added to funds committed to the project by the sponsor and UNH, and used to further eligible program or project objectives.
  • Cost-sharing Method: Program income will be used to finance in part or in total any required non-sponsor share of the program or project.
  • Deductive Method: Program income will be deducted from the total project allowable costs in determining the net allowable costs on which the sponsor's share is based.

3.3   Salaries and wages paid from a program income account are assessed fringe benefits charges at UNH's federally-approved rate for externally sponsored programs. Similarly, all direct costs are subject to Facilities & Administrative (F&A) cost charges at the same rate charged to the sponsored award itself.

3.4   To ensure proper reporting and record keeping for audit purposes, program income must be accounted for separately but in conjunction with the sponsored program award it supports. Expenses to program income accounts must not exceed budgets. Any deficit of program income expenses against program income revenues at the end of the project period must be resolved with UNH non-restricted funds by mutual agreement of the principal investigator and the relevant Responsibility Center (RC) unit head or designee.

3.5   The RC unit is responsible for maintaining all documentation on how program income is generated and how it is spent. Deposit slips, copies of checks, and registration forms are acceptable forms of documentation. This information will be required as supporting material in the event of an audit.

3.6   Unless otherwise provided by a sponsor's regulations or the terms and conditions of a specific award, the University has no obligation to the sponsor regarding program income earned after the period of performance. Accounting for such program income is the responsibility of the relevant Responsibility Center (RC) unit.

3.7   Unless required by federal statute or the terms and conditions of a specific non-federal award, the University has no obligation to the sponsor for program income earned from license fees and royalties for copyrighted material, patents, etc.

For awards made prior to 12/26/14

OMB Circular A-110

Subpart A, __.2(x)        (Definitions, Program Income)


Subpart C, __.24          (Program Income)

For awards made after 12/26/14

2 CFR §200.307

Administrative Responsibility: UNH Senior Vice Provost for Research