U.S. Department of Justice

Office of Community Oriented Policing Services

www.cops.usdoj.gov

March 2019 

Fact Sheet

Program Income for CPD, LEMHWA, 

and PASS Recipients 

What is program income? 

Program income means gross income earned by the recipient or subrecipient that is directly generated by an awardsupported activity or earned as a result of a federal award 

during the award period.1

 Program income includes income 

from fees for services performed, the use or rental of real or 

personal property acquired under federal awards, the sale 

of commodities or items fabricated under a federal award, 

license fees and royalties on patents and copyrights, and principal and interest on loans made with federal award funds. 

Program income means gross income earned by the 

recipient or subrecipient that is directly generated by 

an award-supported activity or earned as a result of 

a federal award during the award period. 

Examples of program income that has been generated from 

some COPS Office–funded activities include fees collected 

for conference registration, exhibit booths, and website 

advertisements. Interest earned on advances of federal funds 

is not program income. Except as otherwise provided for in 

federal statutes, regulations, or the award terms and conditions, program income does not include rebates, credits, 

discounts, or interest earned on any of these. 

The recipient may not earn or keep any profit resulting from 

a federal award unless expressly authorized in writing by the 

COPS Office.2 

1. Program income is defined by 2 C.F.R. § 200.80 in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for 

Federal Awards as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101 for awards made after December 26, 2014. Prior awards would 

follow 28 C.F.R. §§ 66.25 and 70.24. 

2. See 2 C.F.R. § 200.400(g). 

How do I know if my COPS Office award 

generates program income? 

Although recipients are encouraged to earn program income 

to defray program costs where appropriate, most COPS 

Office awards are not conducive to generating program 

income. Contact your COPS Office Program Manager or 

Grant Program Specialist to determine if revenue generated 

from your COPS Office award constitutes program income. 

They will help you assess whether or not the income is generated as a result of the award-supported activity. 

How can program income be used? 

Program income must be used in accordance with the 

standards set forth in 2 C.F.R. § 200.307. Program income 

generated from an award can be used in the following ways: 

Deducted from total allowable project costs to determine 

net allowable costs to reduce the federal award 

Added to the federal award to increase funds committed 

to the project 

Used to meet the cost sharing or matching requirement 

of the federal award 

Unless otherwise specified in the award terms and conditions or approved by the COPS Office, program income will 

be used to defray program costs and reduce the federal share 

of the project. Program income not anticipated at the time 

of the award must be used to reduce the federal award and 

recipient contributions rather than to increase funds 
2

Program Income for CPD, LEMHWA, and PASS Recipients

March 2019

committed to the project. For example, if you were awarded 

$100,000 in COPS Office funding with no local match 

requirement to support a conference and earned $5,000 in 

program income from registration fees generated by that 

conference, an excess of $5,000 would remain in award 

funds at the completion of the project. The $5,000 would 

be returned to the Federal Government, thereby reducing 

the federal share of the project. 

In some cases, with prior approval, recipients may be able to 

work with their COPS Office Program Manager to identify 

additional project-related allowable costs that could be supported with program income. 

Earned program income can be spent only on allowable 

costs incurred during the award period. Program income 

cannot be commingled with other awards and cannot be 

used for purposes outside the scope of the award that generated the income. 

There are a variety of circumstances that can affect how 

program income is treated. If you anticipate generating 

program income, please contact your COPS Office Program 

Manager, Grant Program Specialist, or designated Financial 

Analyst for guidance. 

Table 1. Program income on the SF-425 

Line Transactions Description 

10.l Total federal program 

income earned 

Enter the amount of federal program income earned. Do not report any 

program income here that is being allocated as part of the recipient’s 

cost-sharing amount included in line 10.j. 

10.m Program income expended in accordance 

with the deduction alternative 

Enter the amount of program income that was used to reduce the federal 

share of the total project costs 

10.n Program income expended in accordance 

with the addition alternative 

Enter the amount of program income that was approved and expended 

on the project 

10.o Unexpended program income 

(line l minus line m or line n) 

Enter the remaining amount of unexpended program income by taking 

line l and subtracting either line m or line n, depending on which method 

you are using 

Note: Use lines 10.d–10.o for single award reporting only. Do not complete these lines if reporting on multiple awards. 

How should recipients report program income? 

You are required to report gross program income earned and 

expended on the Federal Financial Report (SF-425)3

 submitted each quarter. How you complete the report depends 

on when you earn and spend the program income and the 

status of your award. Using the example discussed earlier in 

which you earned $5,000 from registration fees, you would 

enter the total amount of program income earned ($5,000) 

on 10.l and the total amount of program income expended 

on line 10.m.4 

3. To access this form, visit https://www.cops.usdoj.gov/pdf/SF-425_Form.pdf. 

4. For examples of when lines 10.n and 10.o on the SF-425 are used, contact your COPS Office Program Manager. 

Program income earned and expended must be reported 

on a cumulative basis. You must manually enter these 

cumulative amounts each quarter, as the SF-425 form does 

not automatically calculate these amounts. For example, if 

$5,000 in program income was earned in the 1st quarter 

and $10,000 was earned in the 2nd quarter, you would 

add those amounts together and enter $15,000 as earned 

on line 10.l of the 2nd quarter’s SF-425. Similarly, if you 

spent $5,000 of program income in the 1st quarter and an 

additional $10,000 of program income in the 2nd quarter, 

you would enter $15,000 as expended on line 10.m of the 

2nd quarter’s SF-425. See table 1 for explanation of what to 

include in form SF-425. 

In the event of an audit or other award compliance review, 

your agency should maintain detailed records that identify 

the specific project activity source (e.g., conference registra-
Program Income for CPD, LEMHWA, and PASS Recipients

March 2019

3

tion fees) and the amount of all program income generated. 

Line 12 (“Remarks”) on the SF-425 can be useful to provide narrative explanations supporting the financial information entered. 

Can recipients keep program income as 

a cash reserve for future project costs? 

No. Recipients should expend earned project income before 

drawing down award funds.5 

5. See 2 C.F.R. § 200.305 for awards made after December 26, 2014. Prior awards would follow 28 C.F.R. §§ 66.21 and 70.22. 

How much time is available to 

spend program income? 

Allowable project expenses can be supported by earned 

program income during the open award period. Funds cannot be drawn down for expenses that are incurred after the 

award end date. 

Avoid retaining earned program income for extended 

periods of time. If you anticipate a significant laps of time 

occurring between earning and spending program income, 

contact your COPS Office Program Manager or Grant Program Specialist. Unused program income should be deposited into your COPS Office award account to reduce your 

federal share.6 These funds remain available for future use 

on allowable costs, incurred before award expiration, to fully 

implement your project. 

If you anticipate having unused program income remaining toward the end of the award period, you may submit a 

request to your COPS Office Program Manager or Grant 

Program Specialist for a no-cost extension to provide additional time for your agency to spend program income on 

allowable costs to fully implement your project. No-cost 

extension requests must be submitted prior to the award 

end date and are approved on a case-by-case basis based on 

reasonable justification. 

Unused program income remaining 90 days after the award 

end date must be promptly returned to the COPS Office. 

Please contact your COPS Office Program Manager for 

guidance on how to return excess program income and 

complete your final SF-425. 

In the event that you earn interest on program income, 

please contact your designated COPS Office Financial 

Analyst for guidance on how to complete your final 

SF-425 to account for interest earned. 

Important: Awards must be open and active to 

incur project expenses paid for by program income. 

6. It can take up to six weeks for the returned program income to appear in your COPS Office account. 

Contact the COPS Office 

If you have any questions regarding the federal 

requirements on program income, please contact 

your COPS Office Program Manager, Grant Program Specialist, or designated Financial Analyst. 

For more information about COPS Office programs and resources, please call the COPS Office 

Response Center at 800-421-6770 or by email at 

AskCopsRC@usdoj.gov or visit the COPS Office 

website at www.cops.usdoj.gov.