Page History

...

      6.  Government revenue: Review the issue of the status of monthly service fees for new sewer lines to homes that were installed with Federal financial assistance. See the June 2013 Inspector General’s audit of the Coastal Impact Assessment program, page 39.  The Inspector General considered these fees to be program income instead of governmental revenue and the FWS concurred with the its finding. Develop regulatory language to clarify 2 CFR 200.307(c). (75)

From the CIAP Audit, Page 39:

'In one instance, (auditors) found that the (recipient) was awarded a grant to install 260 new sewer lines in homes around the county.  These sewer lines replaced the existing septic tanks, some of which were leaching was into Gulf waters.  Homeowners were required to pay a $32 monthly service fee after these new lines were connected.  As a result, from October 2010 through January 2012, the (recipient) earned $43,232 in service fees for 206 active sewers.  

The grant periods for each of the two grants remains open and, therefore, the amount of program income earned will continue to increase.  In addition, both (recipients) plan to install sewer lines that could also earn substantial program income. 

Revenue earned from these programs was not reported appropriately because the (recipient) officials believed the fees earned were for operations and maintenance, not program income. Operations and maintenance, however, if authorized by Federal regulations or the grant agreement, is a deduction from program income, not in lieu of program income.'

So, when a fee is levied for a grant-funded public benefit, those charges must be substantiated or itemized, and not as a lump category, such as operations and maintenance.  It other words, such income must be documented.  

      7.  Match: Review 50 CFR 80.84 for consistency with 48 U.S.C. 1469a on match requirements in insular areas.

...