Finding Text
Criteria: Program income is gross income earned by a recipient/subrecipient that is directly generated by a supported activity or earned as a result of the federal award during the period of performance. Program income earned during the period of performance must be retained and used in accordance with federal awarding agency regulations or the terms and conditions of the award. Under the terms of the major program grant, program income is to be added to the federal award. Condition: Under the terms of the grant agreement, program income is required to be added to the award and used in accordance with the terms of the grant agreement. Management did not identify this requirement when setting up the grant; accordingly, no program income was added to the award in 2025. Program income for this program consists of rental income on single-family homes renovated with major program dollars, less incidental costs. Based on our review of the 2025 profit and loss (P&L) reports for the homes renovated with major program dollars, approximately $30,153 of program income should have been added to the award in 2025. Cause: The condition appears to have resulted from an insufficient review control over the identification and implementation of award terms related to program income at grant setup and during ongoing grant monitoring, including a lack of procedures to (1) identify program income provisions in the award terms and conditions and (2) ensure rental income (net of incidental costs) is calculated and applied in accordance with the required method (addition method) during the period of performance. Effect: Failure to identify and apply the program income requirement resulted in program income not being added to the award and used in accordance with the grant terms during 2025. This resulted in questioned costs of approximately $30,153 for the year ended December 31, 2025. If not corrected, the deficiency could result in continued noncompliance with program income requirements, additional questioned costs in future periods, and potential noncompliance with SEFA reporting implications when program income is required to be added to the award Questioned Costs: $30,153 Perspective: Questioned costs were determined by reviewing the 2025 P&L activity for the single-family homes renovated with major program dollars and calculating program income as rental income less incidental costs. The resulting amount of approximately $30,153 represents program income that should have been added to the award in 2025 under the grant terms. Recommendation: We recommend that management strengthen internal controls over compliance with program income requirements and establish and document procedures to identify program income provisions in the award terms and conditions at grant setup (including the required method – addition, deduction, or cost sharing/matching) and document the determination.