Policy 2107: Program Income

Subject Area: Sponsored Awards
Responsible Office: Financial Services
Sponsor: Chief Financial Officer
Originally Issued: October 1994
Revised: February 2010, December 2014
Refer Questions To: Christine Sorensen, 773-702-2398

Purpose: To ensure compliance with federal regulations and other regulatory policies regarding program income on Federal projects. These regulations vary from granting agency to granting agency as well as from award to award.


  1. Program income is gross income earned during the award period from a sponsored project's activities. Types of program income include, but are not limited to:
    1. Fees for services performed.
    2. Fees for the use or rental of real or personal property acquired under Federally funded projects,
    3. Sales of commodities or items fabricated under an award, and
    4. License fees and royalties on patents and copyrights.

Note: The two primary sources of Federal research funding at the University of Chicago, the Department of Health and Human Services and the National Science Foundation, have waived any University obligation for program income earned from the license fees and royalties for copyrights and patents unless specifically noted on the grant award.

  1. Separate associate accounts must be established to record federal award program income.
  2. Because of the complexity and variation between individual Federal agency's policies governing program income, a principal investor or designee must notify Financial Services if a sponsored project will generate program income.
  3. Financial Services will inform the principle investigator of designee if the program income can be:
    1. Added to funds committed to the project by the federal awarding agency and University and used to further eligible project or program objectives.
    2. Used to finance the non-federal share of the project, or
    3. Deducted from the total project or program allowable cost in determining the net allowable costs on which the federal share of costs is based.