As documented in the Washington University Recharge Centers Policy document, “All recharge centers will establish separate operating accounts to record revenues and expenses related to the products/services provided.” A new AIS fund should be requested from the applicable schools Finance Office for each RC/SSF.
AIS Account Set Up
Establish a LC 11/12 account type (School of Medicine (SOM) uses 92xxx and Danforth Campus uses 94xxx). The LC 11 account is used to record the revenue earned from external customers. Internal revenue is recorded in LC 12 using SC 81.
Expenses associated with the RC/SSF operations will be directly charged to this 92/94xxx account except when the 92/94xxx fund is used as the debit account for a LC 22 program income account as described in the Program Income Account Set Up section.
Reserve Account (or fund balance account)
A reserve fund should also be established so that the fiscal year-end results close to a separate reserve/fund balance account.
Subclass/Object Code (aka Budget/Object Code)
A unique Recharge Center Activity Only SCOB code (32-XX) needs to be assigned to the RC/SSF by the Washington University Cost Analysis Office to allow for separate recording and tracking of expenses related to the billing activity for a specific RC/SSF. For these unique SCOB codes, there is a system edit that will not allow order departments to enter any code other than the one assigned to the specific RC/SSF. (Subclass/Object Code Information)
Autopay can be requested for managing the recharge center’s internal IDs. When Autopay is turned on, any outstanding IDs will automatically pay against the order department’s default account after a set period of time. (For SOM RC/SSF, contact Finance Office for assistance. For Danforth Campus RC/SSF contact the FIS Helpdesk for assistance.)
Recharge/Service Center Account Set-up Summary Table
|Center Type||Separate Fund||Unique Reserve||Unique Subclass/Object Code|
|Minor Recharge Centers|| Yes|| Yes||Unique SCOB 32-XX preferred, OR use 32-97|
|Major Recharge Centers||Yes|| Yes||Yes (32-XX)|
|Specialized Service Centers||Yes||Yes||Yes (32-XX)|
Program Income Account Set-Up
“Program Income” is revenue that is directly generated by grant or contract-supported activity or earned as a result of the award. Such income may be generated from internal or external sources. Since this income is project related, the university is required to consistently record, monitor, and report these dollars in a separate account in accordance with funding agency policies.
Determining if revenue earned is strictly due to the existence of the sponsored project award and must therefore be managed as program income:
- If a core facility is created by a grant award, charges for services/products to users requires that the fee-for-service activity be tracked as program income against the grant which is funding the core facility.
- If a RC/SSF providing services/products already exists and an award is received to support a portion of the center’s activity, then the fee-for-service income would continue to be recorded as standard RC/SSF recharge activity and would not have to be tracked as program income associated with the newly awarded grant.
When it is determined that revenue earned is strictly due to the existence of the sponsored project award, this revenue and the associated expenses are considered program income and would be managed under two FIS accounts as described below.
Program income account set-up steps include:
- Establish a LC 11/12 92/94xxx account as described above in Account Set-Up for a recharge center. The LC 12 account does not incur the direct expenses but is used as the debit account for a cost sharing (LC22 “W, Y or Z”) allocation account associated with the applicable grant or contract.
- Establish a LC 22 (“W,Y or Z”) program income cost sharing account on the grant responsible for revenue generating and use the new LC 12 92/94xxx fund as the debit account on this cost sharing fund. Example: If the Washington University grant fund number is 51234, the program income account allocation will be 51234W. All expenditures related to the program income should be charged directly to the 51234W account/fund.The expenses applied to the revenue received should match the type of costs billed to the user. Also, in the case of program income, funding agencies expect that income earned would be expended before incurring like expenses on the grant award account. Further guidance, including the logistics of setting up and managing program income in the Washington University financial system, is provided on the Washington University Program Income Policy and Procedures page. Federal requirements for managing program income are detailed in OMB’s Uniform Guidance. The National Institutes of Health (NIH), in particular, provides additional guidance in the NIH Grants Policy Statement and also provides specific terms in each Notice of Award or contract terms that may affect program income management.
Examples of Fee-for-Service and Program Income Activity on Sponsored Project Accounts
Presented below are examples of a few scenarios when you will need to consider if a fee-for-service is appropriate for activities related to a sponsored project grant or contract award, and if so, if the fee-for-service income and expense should be identified and tracked as program income on the sponsored project account. Also see Program Income Flow Chart (PDF).
- My PI received an NIH grant that provides funding to establish a core facility. The objective of this core facility is to provide a service to investigators involved in the specific scope of research supported by this grant. The grant is funded to provide full support of the costs (salaries/fringe, supplies, and other expenses) to offer the service.
- There is no fee-for-service or program income tracking when providing these services to the investigators involved in the grant related scope of research – costs are fully supported by the grant.
- We received an NIH grant that provides funding to establish a core facility. The objective of this core facility is to provide a service to investigators involved in the specific scope of research supported by this grant. The grant only has enough funding to support the salaries/fringe of the personnel to run the facility. There are real supply costs and other expenses associated with providing this service. These non-personnel costs can be accurately identified and used to develop a billing rate.
- A billing rate would be developed for the non-personnel costs and the investigators involved in the specific scope of research supported by this grant would be charged this rate which includes only the costs that are not supported by the grant. This fee-for-service activity would be tracked as program income against the grant funding the core facility. These service fees recorded as program income would then be expended on the program income account for supply and other expense costs.
- We are in the third year of an NIH grant that provided funding for the initial set up a core facility to provide a service to investigators involved in the specific scope of research supported by this grant. Our core facility is fully supported by the grant (salaries/fringe, supplies, etc.). Other investigators, not associated with this grant’s scope of research, would like to use the facility for their projects, and the core does have excess capacity to be able to serve this other group of investigators. We would like to charge these non-grant associated users a fee for the services they are requesting.
- Billing rates would be developed for both the personnel and non-personnel costs currently paid for by the grant. (Users could potentially be WUSTL investigators or external non-WUSTL investigators and the billing rates would be established in accordance with the applicable re-charge guidelines.) This fee-for-service activity for both internal and external service users not involved in the grant related scope of work would be tracked as program income against the grant funding the core facility. These service fees recorded as program income would then be expended on the program income account for the personnel, supply, and other expense costs associated with providing these services to this non-grant related user group – these costs would no longer be directly charged to the grant but rather to the program income account.
- We are in the third year of an NIH grant that allowed us to purchase a specialized piece of equipment for the grant specified protocol. Other internal investigators outside of our supported scope of research would like to utilize the equipment and need no support from us for running or using the equipment. Can we bill for the usage of our equipment?
- No. As described, there is no basis for a fee-for-service/re-charge activity if there are no real costs associated with the additional usage of the equipment, so no billing should take place.
- We are in the third year of an NIH grant that allowed us to purchase a specialized piece of equipment for the grant specified protocol. Other investigators outside of our supported scope of research would like to utilize the equipment. In order to accommodate the additional usage, we will have to hire an additional FTE to run the equipment. Can we bill for the usage of our equipment?
- Yes, billing for the additional costs to accommodate non- grant associated users is appropriate. This fee-for-service activity would be tracked as program income against the grant funding the equipment. These service fees recorded as program income would then be expended on the program income account for the personnel costs associated with providing this service to this non-grant related user group (i.e., the additional FTE would have payroll sourcing applied to the program income account).
- A more complex, and maybe realistic situation, is that an additional FTE is hired, but this FTE is not solely managing the non-grant related investigator equipment activity, but rather the new FTE along with other existing personnel share the activity and also manage other aspects of the service process. In this scenario, a percent of salary for each of the individuals involved in the non-grant related investigator activity would be charged to the program income account and the new FTE would have some direct grant payroll sourcing for grant specific activity.
Presented above are only a handful of scenarios when tracking of fee-for-service activities as program income on a sponsored project fund may be applicable. More examples will be added over time as presented to Sponsored Projects Accounting and/or will be addressed in the re-charge FAQs. If you have potential program income situations contact Sponsored Project Accounting for discussion to help ensure the university is in compliance with the funding agency requirements.
Contact for Program Income Questions: Washington University Sponsored Projects Accounting Personnel
Director: Joe Gindhardt at firstname.lastname@example.org or 314-935-7089
Manager: Krys Gross at email@example.com or 314-935-5793