Question: At the financial management workshop you mentioned that the income generated by our programs had to be used within the time frame as the grant used to derive the income. Can you point me in the direction of the guidance that specifies these restrictions. Thanks in advance!

The reference is 2 CFR 200.307. Here is the content:

§ 200.307 Program income.

(a) General. Non-Federal entities are encouraged to earn income to defray program costs where appropriate.
(b) Cost of generating program income. If authorized by Federal regulations or the Federal award, costs incidental to
the generation of program income may be deducted from gross income to determine program income, provided these costs have not been charged to the Federal award.
(c) Governmental revenues. Taxes, special assessments, levies, fines, and other such revenues raised by a non-Federal entity are not program Catch of the Dayincome unless the revenues are specifically identified in the Federal award or Federal awarding agency regulations as program income.
(d) Property. Proceeds from the sale of real property or equipment are not program income; such proceeds will be handled in accordance with the requirements of Subpart D—Post Federal Award Requirements of this part, Property Standards §§  200.311 Real property and 200.313 Equipment, or as specifically identified in Federal statutes,
regulations, or the terms and conditions of the Federal award.
(e) Use of program income. If the Federal awarding agency does not specify in its regulations or the terms and conditions
of the Federal award, or give prior approval for how program income is to be used, paragraph (e)(1) of this section must apply…
(1) Deduction. Ordinarily program income must be deducted from total allowable costs to determine the net allowable costs. Program income must be used for current costs unless the Federal awarding agency authorizes otherwise. Program income that the non-Federal entity did not anticipate at the time of the Federal award must be used to reduce the Federal award and non-Federal entity contributions rather than to increase the funds committed to the project.
(2) Addition. With prior approval of the Federal awarding agency, program income may be added to the Federal award by the Federal agency and the non-Federal entity. The program income must be used for the purposes and under the conditions of the Federal award.
(3) Cost sharing or matching. With prior approval of the Federal awarding agency, program income may be used to meet the cost sharing or matching requirement of the Federal award. The amount of the Federal award remains
the same.
(f) Income after the period of performance. There are no Federal requirements governing the disposition of income earned after the end of the period of performance for the Federal award, unless the Federal awarding agency regulations or the terms and conditions of the Federal award provide otherwise. The Federal awarding agency may negotiate agreements with  recipients regarding appropriate uses of income earned after the period of performance as part of the grant closeout
process. See also § 200.343 Closeout.

In the past, unless you could prove you didn’t raise the money with federal funds, it counted as program income. Someone not paid with federal funds (at least for the time to develop the funding) has to do the work, or the project needs to recoup the costs of the time it took to develop the project through a business plan and clear, separate financial records. This can include fund raising efforts by the board members.

Typically fees for service have not been included as program income even if the staff working in the project are paid with federal funds.

But what has been typical is not necessarily what we will see in the future, so my suggestions are 1) work out your own analysis using this section of Uniform Guidance and 2) when in doubt, clear the project with your program officer at ILA. Hope that helps!

Free Picture, Catch of the Day, ID: 189905 © Dana Rothstein | Dreamstime Stock Photos

How can I spend Program Income?

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