I believe the rationale for why you don’t see cost sharing listed as reportable on the SEFA in 2 CFR 200.502a is because the funds to meet cost sharing obligations stem from your own institutional funds (or other
non-Federal sources), whereas program income stems from income earned as a result of your institution having the federal award.
We’ve never used program income to meet cost sharing commitments, and this would require prior written approval from the sponsor, per 2 CFR 200.307e3. Maybe others could speak to this situation better than I
could, but I would think that even if you were allowed to use program income to meet cost sharing commitments, that you’d still have to report it on the SEFA because the source of funds stem from program income.
Does anyone else have any thoughts on this?
Sincerely,
Jason Guilbeault, CRA
Director, Post Award Services
Sponsored Program Administration
Augusta University (formerly Georgia Regents University)
1120 15th St. CJ-3301
Augusta, GA 30912
706-721-0007
Georgia Regents University is now Augusta University. Effective immediately, my email address has changed to
xxxxxx@augusta.edu. Please update your address book accordingly.
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Nelson, Heather (xxxxxx@uidaho.edu)
Sent: Monday, May 01, 2017 11:35 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] [EXTERNAL] [RESADM-L] Question on UG 2 CFR 200.502 - Program Income and the SEFA
Thank you. However, since cost share is just as auditable how is program income different? As a matter of fact, program income is oftentimes used as cost share so that makes it even more confusing that this
would be included. I do understand that it’s not ours to keep, but we view the funds as project funds rather than federal funds.
Heather
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Guilbeault, Jason
Sent: Monday, May 01, 2017 6:10 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] [EXTERNAL] [RESADM-L] Question on UG 2 CFR 200.502 - Program Income and the SEFA
We report the program income that we spend on our SEFA. The expenses on your program income accounts are just as auditable as the expenses you directly charge and bill for on your Federal awards. Even though
the program income comes from non-federal sources, at the end of the day it is not the university’s money to keep and it’s treated as federal money. The program income also has to be utilized before drawing down cash from the Federal government (see 2 CFR
200.305b5).
2 CFR 200.305b(5) Use of resources before requesting cash advance payments. To the extent available,
the non-Federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds
before requesting additional cash payments.
Sincerely,
Jason Guilbeault, CRA
Director, Post Award Services
Sponsored Program Administration
Augusta University (formerly Georgia Regents University)
1120 15th St. CJ-3301
Augusta, GA 30912
706-721-0007
Georgia Regents University is now Augusta University. Effective immediately, my email address has changed to
xxxxxx@augusta.edu. Please update your address book accordingly.
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Nelson, Heather (xxxxxx@uidaho.edu)
Sent: Friday, April 28, 2017 8:11 PM
To: xxxxxx@lists.healthresearch.org
Subject: [EXTERNAL] [RESADM-L] Question on UG 2 CFR 200.502 - Program Income and the SEFA
This is an external email. Use caution responding, opening attachments and following links.
For all of you wonderful regulation interpreters what do you make of the below? Does inclusion of program income in this section make it reportable on the SEFA? We here have always assumed that program-income,
since it would typically come from third parties, is non-federal and therefore not reportable on the SEFA. One of our inquiring minds here looked at this and was concerned…
200.502 Basis for determining Federal awards expended.
(a)
Determining Federal awards expended. The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply
with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements,
and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property;
the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance
is in force.
Heather Nelson
Associate Director
Office of Sponsored Programs
University of Idaho
208-885-6680
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<br> ======================================================================<br> Instructions on how to use the RESADM-L Mailing List, including<br> subscription information
and a web-searchable archive, are available<br> via our web site at
http://www.healthresearch.org (click on the<br> "LISTSERV" link in the upper right corner)<br> <br> A link directly to helpful tips:
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