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The Uniform Guidance does not include language limiting the treatment of licensing/royalty revenue as program income (A-110, .24(h)), which is inconsistent with Bayh-Dole Act.  In FAQ .307-1, COFAR clarified that “U.S. law or statute takes precedent over the Uniform Guidance.”  Therefore, income from license fees and royalties on research funded by a Federal award should be excluded from the definition of program income. 

Policy Guide on Profit (200.400).  Entities may not earn or keep profit resulting from Federal financial assistance, unless expressly authorized by the terms and conditions of the Federal award.

Action Plan

  • The University needs a mechanism to report Analytical Service Agreements (ASAs) agreements to the Controller's Office so it can be included in the financial report. (TBD)





  • Division of Research to modify internal work instructions to review ASA's during negotiation and create a standard sign-off and process for informing the Controller's Office.