The classification of external funds as a grant or a gift are important fiscal and fiduciary responsibilities of the University. Classification and processing of these awards are sometimes complex and requires the exercise of informed judgment, particularly in the many cases where the nature of an award is not immediately clear. When this happens, a careful review of the documents that accompanied the external funding is needed in order to understand the donor’s intended use of the funds. The flow chart below will help users with this determination. If the award document contains any of the indicators listed under sponsored project in the table below, the funds should be treated as a sponsored project.
Sponsored programs (which includes both research and non-research activities) are defined as those activities, sponsored in whole or in part by sources external to the University, for which there is an expectation (implied or specifically stated) on the part of the sponsor for performance, a deliverable or outcome. Sponsored programs are awarded through various mechanisms such as grants, contracts, and cooperative agreements, and/or other legally binding means of transfer. The Office of Contracts and Grants (OCG) is the unit authorized to seek, accept and administer all Sponsored agreements.
A research gift is defined as a flexible, irrevocable award of money, equipment, or other property of value given to the University by a donor who wishes to support the research of a faculty member or group of faculty members, but who expects nothing of significant value in return, other than the recognition and disposition of the gift in accordance with the donor’s wishes. The University Office of Development processes donor gifts. However, research gifts and donations may be received and setup in project cost centers through OCG while at the same time be recognized as gifts by the Office of Development.
Research Gift Classification
In order to account for expenditures from research gifts, the funds should be separately budgeted in university cost centers with fund code Bxxx. OMB's Uniform Guidance Appendix III to part 200 requires the institution to organize its sponsored expenditures into certain defined functional activities; one of which is organized research (sponsored research, and university research). These costs are then used to develop the Facilities & Administrative (F&A) rates, negotiated with the federal government.
|Factors||Sponsored Project (Grant) Indicator||Unrestricted funds (Gift) Indicator|
|Application||Formal or informal application submitted to sponsor includes a budget and scope of work||Proposals do not include itemized budget or milestone payment|
|Fiscal Reporting and Accountability||Submission of invoices, financial reports, audit provisions and/or an obligation to return unexpended funds||No formal fiscal accountability to the donor beyond periodic reports as requested|
|Period of Performance||A period of performance is specified by the sponsor. If work is not completed within time an extension must be requested||No period of performance is specified by the donor|
|Technical Monitoring||Sponsor designates one of its employees (agents) as project manager/officer||Donors may designate a contact person/employee to improve communications|
|Terms and Conditions||Terms and conditions may include indemnity, export control, intellectual property (e.g., patent rights requested by grantor), data use and ownership, prior approval requirements||The terms of a gift award agreement are not characterized as contractual obligations or "deliverables"|
|Confidential Information/ Publication||Award may require protection of sponsor confidential information and may restrict or monitor publications or use of results||No restriction on information and publication mentoring|
|IRB Compliance and Bio-safety||Project may involves the use of human subjects, vertebrate animals, radioisotopes on humans, radioactive materials, recombinant DNA, human body substances, etiologic agents or proprietary materials foreign collaborators or is subject to Export Control||
This type of activity if funded by research gift, should not bypass compliance review and approvals
|Deliverables and/or Technical Reporting||Sponsor requires specific deliverables and/or technical or narrative reports, evaluations, technical assistance, training, etc.||No deliverables and report as evidenced by the absence of any quid pro quo language|
|Effort Commitment||Commitment of personnel effort to complete scope of work||No commitment of personnel effort on the research supported|