TLDR
Once you elect additive or deductive treatment, it is binding for the life of the award. Under 2 CFR 200.307, program income — revenue earned by the grantee that is directly generated by activities under the federal award — must be tracked, reported, and disposed of according to a treatment election made at award time. The additive-vs-deductive election is made up front and most federal program officers never ask about it until audit — at which point changing it requires retroactive correction.
Program income reporting is one of the least understood compliance requirements in federal grant management. Many organizations earn it — patient fees, admission charges, training tuition, facility rentals — and either do not recognize it as program income or do not track it consistently enough to report accurately on the FFR. Auditors know this pattern and test program income specifically as a Single Audit compliance element.
When to run this workflow
Run the setup steps at award start — identify income sources, confirm the disposition election, and establish the tracking account — before any program activity begins. Program income earned before you have a ledger tracking it is program income you cannot reconcile retroactively.
Run the ongoing steps quarterly, aligned to the FFR submission schedule. Most federal awards require quarterly FFRs; the FFR due date is the deadline by which the program income earned in the preceding quarter must be reconciled, documented, and reported.
Common pitfalls
Not recognizing an activity as generating program income. Organizations often have a narrow view of what constitutes program income — patient fees at a federally-funded clinic, yes; rental of federally-funded space to a community organization at below-market rates, no. But any revenue earned through an activity that the federal award supports is potentially program income. If in doubt, ask the program officer before the revenue is earned, not after.
Commingling program income with operating revenue. Program income deposited into the general operating account without a separate tracking mechanism becomes invisible within 30 days. It must be segregated in the accounting system from the date of receipt.
Assuming the election does not matter for small amounts. The election is binding regardless of amount. An organization that elects additive treatment and earns $500 in program income must apply it additively — to additional project costs — not deductively by reducing the draw. The $500 is small; the compliance principle is not.
Missing FFR Lines 10 and 10a. Some finance staff who prepare FFRs are not aware that Lines 10 and 10a require reporting. Others assume that if the amount is small, leaving the lines blank is acceptable. Both assumptions lead to incomplete FFRs that an auditor will flag.
Audit trail requirements
The program income file for each award should contain:
- The award document identifying income-generating activities
- The written disposition election (or confirmation of the default deductive treatment)
- The program income ledger showing earnings by date and source
- Documentation of how income was applied (additional expenditures under additive; drawdown reduction log under deductive; match documentation under matching)
- Quarterly FFR copies showing Lines 10 and 10a for each reporting period
- Reconciliation of program income ledger to GL and to FFR, by quarter
Auditors testing program income compliance will request the award terms, the ledger, the application documentation, and the FFRs — verifying all four are internally consistent.
How GrantPipe automates this
GrantPipe tracks program income by award from the point of configuration, so the disposition method is embedded in the award record and applied automatically as income is posted. FFR preparation pulls the cumulative program income and expenditure figures directly from the ledger, eliminating the manual lookup that most organizations perform before each quarterly submission. Start a trial.
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Source: OMB 2 CFR 200.307(e)(1)
Source: OMB SF-425 Instructions
Source: OMB 2 CFR 200.307(f)
- Program income
- Gross income earned by a non-federal entity that is directly generated by a supported activity or earned as a result of the federal award during the period of performance. Defined and regulated under 2 CFR 200.307.
DEFINITION
- Additive treatment
- A program income disposition method where income is added to the total award amount and used to fund additional allowable project activities, increasing total project scope.
DEFINITION
- Deductive treatment
- A program income disposition method where income is subtracted from the total federal expenditures, reducing the amount of federal drawdown required. The default under 2 CFR 200.307(e)(1) when the award is silent.
DEFINITION
- Matching treatment
- A program income disposition method where income is counted as the non-federal share of project costs, satisfying a cost-share or matching requirement of the award.
DEFINITION
- Post-award period income
- Program income earned after the period of performance ends, from activities that were supported during the award period. Subject to reporting requirements under certain federal programs per 2 CFR 200.307(f).
DEFINITION
Q&A
How does program income affect the FFR?
Program income is reported on SF-425 Lines 10 and 10a — cumulative income earned and cumulative income expended, respectively. Under deductive treatment, Line 10a offsets the federal expenditures, reducing the effective federal share. Under additive treatment, Line 10a adds to the total expenditures. Auditors compare the FFR program income lines to the accounting records as part of Single Audit testing.
Q&A
Can we change the income disposition method mid-award?
Changing from one disposition method to another requires written federal agency prior approval. An unapproved mid-award change is not recognized by the federal agency — the original election remains binding, and any activity inconsistent with it is a compliance finding. Plan the election carefully at award time.
Q&A
What types of fees do not qualify as program income?
Fees earned from activities not supported by the federal award, income earned from unrelated business activities, and proceeds from the sale of property purchased entirely with non-federal funds are not program income. Also excluded: income earned after the award period ends unless the program specifically extends reporting. Membership dues unrelated to grant activities are also excluded.
Frequently asked