The University takes into consideration the intent of the donor or sponsor when determining whether the funds or award being provided could be considered a gift or a sponsored program. The language used by a donor or sponsor in providing the support/funds or award is an important criterion for deciding between classifying it as a gift or a sponsored program. The language in the agreement between the University and the donor or sponsor must reflect this intent and comply with applicable University policies.

The appendix to this policy provides an identification and comparison of common qualities and the associated requirements or expectations for each type of support – gift or sponsored program. With the exceptions outlined in the appendix, no single indicator is determinative of a gift versus a sponsored program. A classification decision must be made based on all the circumstances surrounding the transaction. Whenever doubt exists as to whether the support/funds or award represents a gift or sponsored program, contact the Office of Sponsored Programs. The Office of Sponsored Programs, in consultation with University Advancement and the school/department/unit dean or executive, makes a final determination as to whether the funding in question is treated as a gift or sponsored program.

NOTE: The language a donor or sponsor uses to categorize its support might not align with how the award is categorized by the University.

1. Responsibilities:
   Sponsored programs are generally subject to terms and conditions that require significant attention be paid to use of funds, reporting requirements, and timelines (see appendix).

   • The Office of Sponsored Programs is responsible for the administration of sponsored programs, including:

     • Receiving funding notifications (e.g., of award, termination, or modification).
     • Negotiating initial terms and conditions, as well as subsequent modifications.
     • Setting up sponsored programs in the University’s system(s) of record.
     • Notifying schools/departments/units of the availability of funds and associated terms and conditions.
     • Complying with sponsor invoicing and financial reporting requirements.
     • Serving as the University’s point of contact for sponsor-initiated audits.

     The responsibilities of University schools/departments/units receiving sponsored program funds and individuals managing, supporting, or working on sponsored programs are addressed in other University policies (see Related Information).

   • External Relations is responsible for administration of gifts, including:
     • Evaluating potential gifts for compliance with University policy before acceptance.
     • Clearly establishing the donor intent and expectations for the use of the funds through University-approved gift agreements.
     • Verifying that any terms and conditions are appropriate for processing as a gift.
     • Recording the gift for institutional tracking and reporting purposes.
   • Financial Reporting and Operations is responsible for:
     • Spending funds in accordance with donor or grantor intent.
     • Providing reports to the donor to the extent agreed upon as a condition of the gift (see the Publication and Reporting section of the appendix).

2. Compliance with Policy:
   Failure to comply with the requirements of this policy may result in donor expectations or sponsor requirements not being met, potentially causing reputational damage and loss of current or future support. Intentional violation or circumvention of this policy may result in disciplinary action up to and including termination or expulsion in accordance with relevant University policies.

   Direct questions about this policy to the Office of Sponsored Programs or External Relations.