Wilma;
We have a couple of ways to deal with such situations since our foundation
has no research capability and for corporate reasons neither we nor they
want to involve themselves in grant and contract activities:
1. If we see the proposal in advance (we usually do since we
have policies and procedures in place with our foundation that this office
must sign off through the University clearance process for all the
compliance reasons) we try to determine if the 501(c)(3) status is a
specific and hard requirement of the private foundation or if it is short
hand for general tax exempt status.
As a public university our tax exempt status flows through
IRS section 117. We are of course subject to section 170(c)(1) regarding
unrelated business income. In many cases we have found that the Foundation
will accept the 117 status once they realize that we are exempt but not
specifically under 501 (c)(3) and make the award to the University.
2. If the award must go to the university foundation, the
foundation will route the award to the university before acceptance. This
is to allow us time to look for unacceptable terms and conditions. If the
award is made without acceptance sign-off and particular terms are
unacceptable we may have to go back to the private foundation for
resolution. Once we have the best award language circumstances will allow,
we will then write an agreement with the university foundation for the to
become a subrecipient and we will assume responsibility for the conduct and
management of the grant.
Gary
Gary Chaffins
Director, Office of Research Services and Administration
5219 - University of Oregon
Eugene, OR 97403-5219
Voice (541)346-2395
FAX (541) 346-5138
E-mail xxxxxx@orsa.uoregon.edu
-----Original Message-----
From: Wilma Ennenga [mailto:xxxxxx@NAU.EDU]
Sent: Friday, January 31, 2003 7:18 AM
To: xxxxxx@HRINET.ORG
Subject: [RESADM-L] Grants vs gifts
How would your university handle a grant awarded with the conditions
described below from a private foundation? Would the grant be administered
by the foundation or by the university sponsored projects/grants office?
The award in question is from private foundation whose literature states
that "Grants are awarded to nonprofit public charitable organizations that
are tax exempt under Section 501(c)(3) of the Internal Revenue Code". The
purpose of the grant is to "recruit and train (ethnic minority) school
administrators". The grant was "paid up front" rather than cost
reimbursement, and allows 15% indirect costs which the foundation would
intend to claim if grant expenditures are made directly from the foundation
rather than from the university. The deliverable is a final product
report/video to help distribute knowledge/lessons learned to others in the
field. Other specific terms and conditions are that the award is revocable,
a period of performance is specified, a detailed financial report is
required showing how the funds were expended, and unexpended funds must be
returned.
Thanks for your responses, and please feel free to respond to me directly
at xxxxxx@nau.edu
Wilma G. (Winnie) Ennenga
Director, Office of Grant and Contract Services
Northern Arizona University
BAC 100C, Building 51, Knoles Drive
Flagstaff, AZ 86011-4130
Telephone: 928/523-8319 Fax: 928/523-1075
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