The federal definition is not too helpful when you're dealing with an Advancement Office. They speak a different language. Our Vice Provost is working on guidelines to help us differentiate between gifts and grants. These were taken from Washington State, but other universities have similar guidelines. Below is a draft. DRAFT Guidelines for Defining Sponsored Projects and Gifts at The University of Connecticut This document contains definitions for sponsored projects and gifts at The University of Connecticut (UConn). Special care should be taken in determining whether a project is a sponsored project or a gift. The distinctions help to define UConn's legal obligations and liabilities and are important for all personnel from faculty to professionals working in the Office of Sponsored Programs (OSP) and the UConn Foundation. SPONSORED PROJECTS A proposal for external support, including all proposals involving federal funds, must be processed through OSP if any of the following conditions are included in the terms of the agreement. The presence of any one of the following factors distinguishes the resulting award from a gift and classifies the project as a sponsored project: 1. The proposed work binds the University to a specific line of scholarly or scientific inquiry which requires either a work statement or an orderly testing of specific hypotheses, methodology, or validation of particular approaches. 2. A specific commitment is made regarding the level of personnel effort or items of output (e.g., publication of papers or reports), or achievement of specific performance targets as a condition of obtaining sponsorship. 3. A line item budget detailing expenditures by activity, function, and project period is required as a condition of funding and a detailed fiscal or activity report or external audit is required at intervals during the course of the work or at the end of the project period. 4. Any unexpended funds must be returned to the sponsor at the end of the project period. 5. The proposed agreement with the sponsor provides for the disposition of either tangible properties (e.g., equipment, records, technical reports, theses or dissertations), or intangible property (e.g., rights in data, copyrights, inventions) which may result from the activity. 6. Construction projects or acquisition of equipment or facilities where a state or federal agency is involved. In addition to the above, any sponsored project proposal or solicitation of gifts which support activities involving the following conditions must also be reviewed by OSP for relevant approval, to insure compliance with University policies and federal general assurances: * human subjects * laboratory animals * radiological hazards * biohazards * conflict of interest Sponsored projects solicitations are coordinated through departments and deans' offices. The OSP should be contacted for procedures applicable to sponsored projects solicitations. If none of the above listed characteristics of sponsored projects are present, such awards may be treated as gifts. GIFTS Gifts to the UConn Foundation do not include any of the factors listed in the definition of sponsored projects, and they are not processed through the OSP (unless they involve use of human or animal subjects, or hazards requiring review and approval). Gifts are administered by the UConn Foundation and have one or more of the following characteristics: 1. The award is from a private individual. 2. The award is from a non-governmental source and is either for "bricks and mortar" or for the University's endowment. 3. The donor specifically intends the award to be a charitable gift as reflected by the characteristics of the award instrument. 4. The conditions or stipulations placed on the intended use of the award are reasonable and serve to direct the funds to areas such as scholarships, bricks and mortar, or general research support of specific interest to the donor. 5. The donor intends the gift to be irrevocable and, therefore relinquishes the right to reclaim the gift or any unused remainder. 6. The donor makes the gift to the University without expectation of direct economic benefit or other tangible benefit commensurate with the worth of the gift. Indirect benefits such as tax advantages, business or personal goodwill derived from close association with the University, and the miscellaneous benefits derived from the donor club status are not sufficient to negate gift intent. Gift solicitations should be coordinated with the appropriate Development Officer in each College or equivalent unit. The UConn Foundation office should be contacted for procedures applicable to gift solicitations. 5/98 - Sandy Schulte Asst Vice Provost for Research Administration University of Connecticut Tel: 860-486-0985; FAX 860-486-5381 ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
