We’ve gone back to the grant management mailbag for some common problems encountered in the “real-world” by “real-life” grant managers.
Today we’re looking at 3 tips so you aren’t blindsided by program income related to conference registration fees when managing your Federal grant.
A grant manager writes:
“Where do we put revenue from a conference registration fees?”
“We sponsor an annual conference for colleagues interested in our Federally-sponsored program topic.
We allow our sub-grantees to budget their attendance to that conference, i.e., registration fees, lodging, meal per diem, and mileage.
We aren’t sure how to account for the registration fees-especially when we give a sub-grantee an award which includes expenses for coming to the conference.
When they register, they are paying us for the conference and they are being reimbursed from us as a sub-grantee to cover the expense.
How do we record that registration revenue coming back in?
Is it truly revenue? Is the registration expense in their award budget truly an expense?
Can you help?”
What to do?
What our grant manager is talking about is program income (registration fees) -and participant support (sub-grants for participants to attend the conference.)
Here are some basics:
What are Program Income and Participant Support?
Program Income is the gross income directly generated by a program or project activity or earned as a result of the award and earned by the recipient during the period of a Federal award.
Participant Support costs are direct costs for items such as stipends, travel allowances and registration fees paid to or on behalf of participants or trainees in connection with meetings, conferences, or training projects.
Watch out! Participant support can’t be paid to employees of the organization getting the Federal award.
The starting place to determine the correct grant management treatment is your award terms and conditions.
Tip #1: What Do Your Terms and Conditions Say?
Start with the terms and conditions for the conference and see what it says about program income and participant support.
There are (at least) three different methods for program income (income generated as a direct result of the award-in this case holding the conference.)
In many cases, the registration fees are used to offset the expenses of the conference.
Tip #2: Check with Your Funding Agency
Often your funding agency will have specific guidance about various grant management topics including program income and participant support.
Here are a couple examples:
Example #1: National Science Foundation
The NSF offers a program income brochure with offers the following guidance:
Conference and Group Travel Award Program Income
“[R]registration or other fees paid by conference
participants shall be used to defray reasonable expenses
directly associated with the conference for which funds
are not otherwise available. If fees exceed such
expenses, the remainder shall be used to offset
allowable costs otherwise chargeable to the[e] grant.”
(F.L. 26, Administration of NSF Conference or Group
Travel Award Grant Special
Conditions, Section j)
Example #2: Environmental Protection Agency
From their guidance on “Managing Your Grant”
6. What is program income and what are my responsibilities?
Program income is gross income received by the grantee or sub-grantee directly generated by a grant supported activity or earned only as a result of the grant agreement during the grant period.
Examples of program income include, but are not limited to:
Fees for services funded by the grant.
Income generated from the use or rental of property acquired with grant funds.
Income from the sale of commodities or items fabricated under a grant agreement.
Income from the payment of principal and interest on loans made with grant funds.
Registration fees for a conference.
How to account for program income:
All program income should be deducted from the total grant expenses to determine net allowable grant expenses. However, when appropriate, EPA may add a condition to the grant at the time of award or amendment, authorizing one or more of the following uses of program income:
To increase the total funds committed to the project. In this case, the income must be used to further eligible project activities.
To meet the recipient’s cost-share or match requirement of the project.
If program income is generated during the project period of the grant and that income was not anticipated at the time your grant was awarded, contact your EPA Project Officer immediately for guidance on the treatment of the income.
Tip #3: There’s No Free Money!
Just in case you are wondering…we’ve never seen where the organization just gets to keep the registration fees as unrestricted “free” money.
The Administrative Requirements and Cost Principles for your type of organization will have requirements for program income and participant support as well, so if the terms and conditions and your agency are silent, check the grant management regulations.
Don’t forget that regardless of the accounting method used, program income may be used only for allowable costs.
Where can I find out more about Participant Support?
For Non-profit Organizations:
The relevant sections are contained in 2 CFR Part 230 (Formerly OMB Circular A-122)
Appendix B: Selected Items of Cost for Non-Profit Organizations
For Institutions of Higher Learning:
The relevant sections are contained in 2 CFR Part 220 (formerly OMB Circular A-21)
Appendix A, Section J: Selected Items of Cost
For State, Local and Tribal Governments:
The relevant section is contained in 2 CFR Part 225 (formerly OMB Circular A-87)
Appendix B: Selected Items of Cost
Want to learn the basics of grant management? Sign up for our free 5-part series “Grant Management Basics” today.
Lucy Morgan CPA, MBA
CEO, Compliance Warrior