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Sponsored Projects and Gifts

  • Responsible Office: Sponsored Programs, Research and Innovation
  • Current Approved Version: 10/26/2021
  • Policy Type: Administrative

Policy Statement and Purpose

This policy provides clarification regarding the difference between sponsored projects and gifts. The distinction between gifts and sponsored projects can be subtle. VCU uses the term “sponsored project” in lieu of grant because the term “grant” is defined differently by various sponsors. The use of the term “grant” by a sponsor does not automatically mean that the award is a sponsored project; instead, the terms of the award should be used to determine its status.

A sponsored project describes a planned university teaching, training, service, or research project that is supported by an extramural award from any funding source. If any one of the following characteristics applies to a project, including commitments made in the proposal or required in the award agreement, it should be processed through VCU's Division of Sponsored Programs, which is housed in the Office of the Vice President for Research and Innovation:

  1. Sponsor is the federal, state, or local government OR an agency that has been established simply as a flow-through of federal, state, or local government funds for accounting purposes.
  2. Award contains provisions regarding ownership of intellectual properties (i.e., patents and copyrights).
  3. Sponsor requires the delivery of specific goods or services by the university (e.g., technical assistance or training). Continuing education programs are specifically excluded from this policy.
  4. Award includes a provision for audit by the sponsor.
  5. Award restricts or monitors publications or use of results.
  6. Award requires protection of sponsor proprietary and/or confidential information.
  7. Proposal or award requires a signature from the authorized official binding the university to the terms and conditions of the proposed project.

Activities supported by a donor that are generally not considered sponsored projects and can be processed as gifts might include the following characteristics:

  1. Awards in which the corporation or foundation can report it as a charitable contribution on IRS filings. Award provides support for broadly defined activities, such as professorships, endowments, building projects, instructional programs or unrestricted research. The donor can restrict the use of funds to a specific program area or purpose.
  2. Award contains only minimal requirements, generally relating to required donor pledge payments and the university’s commitment to effectuate the donor’s intent.
  3. Award requires only minimal reporting to the donor in the form of a general statement or report of how funds were used and the outcomes of the project. The unit or faculty member involved can provide the donor with a brief summary of the results of supported activities and/or a statement that expenditures were made in accord with the intent of the gift.
  4. Award may require a signature from an authorized official acknowledging acceptance of the award. Award agreement to be signed by authorized official may include a general statement of the goals and aims of the project as they are understood by the donor but such statements are not to be construed as a contract between the university (and/or its supporting foundations) and the donor wherein any specific project deliverables, intellectual properties, goods, services, products or outcomes are to be delivered or provided to the donor.
  5. Award requires that recipient be a 501(c)(3) organization.

All projects determined to be a sponsored project should be processed through the Division of Sponsored Programs. Activities supported by a donor that are generally not considered sponsored projects can be processed as gifts to the university.

Noncompliance with this policy may result in disciplinary action up to and including termination. VCU supports an environment free from retaliation. Retaliation against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited.

Who Should Know This Policy

All individuals involved in sponsored projects are responsible for knowing this policy and familiarizing themselves with its contents and provisions.

Definitions

Authorized Official

The individual(s) formally authorized to bind the institution to grants, contracts and other agreements; the official signatory for the institution.

Sponsored Project 

A sponsored project describes a planned university teaching, training, service, or research project that is supported by an extramural award from any funding source.

Contacts

The Division of Sponsored Programs officially interprets this policy. The Division of Sponsored Programs is responsible for obtaining approval for any revisions as required by the policy Creating and Maintaining Policies and Procedures through the appropriate governance structures. Please direct policy questions to associate vice president for sponsored programs.

Policy Specifics and Procedures

Questions regarding whether a proposal or an award is a gift or a sponsored project should be directed to your school’s dean or to the VCU Division of Sponsored Programs or the VCU Office of Corporate and Foundation Relations within the Division of Development and Alumni Relations. In some cases, projects that appear to be gifts at the proposal stage become sponsored projects at the award stage because of conditions set forth in the award agreement. In these situations, and others where the classification of a particular project may be unclear, the Division of Sponsored Programs and Office of Corporate and Foundation Relations will work together to determine a project’s classification and processing method.

Forms

There are no forms associated with this policy and procedure.

Related Documents

 

  1. VCU Policy: Development and Alumni Relations Activities
  2. VCU Policy: Gift Acceptance and Administration

 

Revision History

This policy supersedes the following archived policies:

Approval/Revision DateTitle
10/24/2017 Sponsored Agreements and Gifts [minor revision to replace decision tree image in Related Documents section]
10/26/2021 Minor Revisions


FAQ

 

1. As the individual responsible, can I agree to provide reports to the donor/sponsor under a separate agreement that is not executed by the university?

All arrangements for either a gift or sponsored project must be evident in the documentation maintained in the university-level record.

2. If I know of a potential donor/sponsor for research, should I have them contact the Division of Sponsored Programs or Office of Corporate and Foundation Relations to determine if the funding will be considered a gift or a sponsored project? 

The potential donor/sponsor can contact either office for this determination.