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

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