Policy on Designation of Funds as Donation/Gift or Grant/Sponsored Program

Title: Designation of Funds as Donation/Gift or Grant/Sponsored Program
Effective Date: January 1, 2018
Revision Date: First Version
Responsible Office(s):  Sponsored Programs, Finance & Administration

I. Scope and Purpose

This policy applies to gift or grant funds received on behalf of or for the benefit of The College of William & Mary, hereafter referred to as the “university”.[1]  It applies to gifts or donations received by any foundation affiliated with the university.  The Policy establishes guidelines for distinguishing between two types of funding given to the university or an affiliated foundation:  gifts and grants.  Gifts, as defined below, are managed by University Advancement.  Grants may be procured with assistance from University Advancement, but are managed by the Office of Sponsored Programs if they meet the criteria outlined below. 

II. Policy Statement 

This policy establishes classification and management guidelines for application and oversight responsibilities associated with grants and gifts.  Grants, which are associated with sponsored projects, are managed by the Office of Sponsored Programs (OSP).  Gifts and donations are managed through University Advancement and the organization designated by the donor, either the university or an affiliated foundation.

While there are a number of characteristics differentiating gifts and grants, the principal consideration in classifying the receipts is the intention of the payment. 

Gifts or Donations:  A gift or donation is defined as an item of value given from a donor who expects nothing significant of value in return, other than recognition and disposition of the gift in accordance with the donor's wishes.  In general, the following characteristics describe a gift:

  • Gift or donation provides support for broadly defined activities such as named professorships, endowments, building projects, instructional programs, and unrestricted research. Funds may be restricted to a specific program area or general purpose.
  • Gift or donation includes only minimal requirements, generally relating to required donor pledge payments and confirming the university’s commitment to honoring the donor’s intent.
  • Gift or donation requires only minimal financial reporting to the donor in the form of a general statement of how the funds were used. In addition, the university, unit, faculty or staff member may provide the donor with a brief summary of the activities resulting from the donation. 
  • Gift or donation is irrevocable.

Funds or any other items of value from contractors or vendors doing business with the university should be specifically reviewed to determine any business relationship and the extent to which, if any, those dollars meet the definition of a gift or donation. 

Funding for programs or projects determined to be gifts or donations are processed through University Advancement’s Gift Accounting Department and are managed through the university or a foundation affiliated with the university.  

Grants/Sponsored Projects:  A sponsored project is a research, public service, or scholarly activity with a defined scope of work and a set of objectives supported by external funds.  If any one of the following characteristics describes the activity – either as a proposal or an award – the funds are related to a sponsored project and must be processed through and managed by OSP.

  • Sponsor is the federal, state, or local government or an entity that has been established to distribute funds originating from a governmental entity.
  • Proposal or award requires a signature from an authorized official binding the university to the terms and conditions of the proposed activity.
  • Sponsor has written policies requiring recoveries of indirect (facilities and administration) costs.
  • Award contains provision regarding ownership of intellectual properties such as patents and copyrights.
  • Sponsor requires the delivery of specific goods or services as a result of funding support.
  • Award requires a detailed technical or financial report.
  • Award payments are contingent upon programmatic or fiscal reporting such as invoices or documentation of progress toward milestones.
  • Award includes budget restrictions such as requiring prior approval for reallocation within the budget and restrictions on specified budget categories, equipment, or fringe benefits.
  • Award includes a provision for audit.
  • Award restricts publication or use of results.
  • Award requires protection of sponsor and/or confidential information.
  • Project involves the use of human subjects, vertebrate animals, radioisotopes, radioactive materials, recombinant DNA, etiologic agents, or proprietary materials.

William & Mary’s OSP, where applicable, will work with the administration of the affiliated foundations to apply these guidelines.  Individual proposals and awards will be reviewed to determine who should manage the grant/sponsored project(s).  In the event of any questions, the Chief Financial Officer will make the final decision.  

III. Procedures for Developing Proposals and Solicitations

A. Corporation or Foundation Solicitations

University Advancement’s Office of Corporate and Foundation Relations (CFR) is charged with building relationships between William & Mary and corporations or foundations and assisting faculty or staff who are seeking support.  Faculty or staff who are interested in approaching those entities and soliciting support must first contact CFR ([[cfr]]) and work with the CFR staff to identify potential sponsors and to develop and submit proposals. 

For proposals for gifts or donations, financial management and accounting are handled through University Advancement in collaboration with the appropriate Department or School and   affiliated foundation, as applicable. 

B. Grant or Sponsored Project Solicitations

Any request to an external entity must be reviewed and evaluated by OSP and coordinated with the Department Chair or Dean, as appropriate.  Complete proposal submission guidelines and access to the mandatory Routing/Review Form are available at:  http://www.wm.edu/offices/sponsoredprograms/index.php.  

For proposals to be submitted under the name of an affiliated foundation, approval is needed by the administration of the affiliated foundation prior to submission.  Approval will be granted only after consideration of the capacity of the foundation to manage all compliance and reporting obligations relating to administration of the sponsored project in accordance with the standards employed by the university. 

Researchers initiate the process by contacting OSP ([[wosp]]) or the administrator who handles submissions for the specific department. (http://www.wm.edu/offices/sponsoredprograms/about/contact/index.php)

OSP is responsible for ensuring that all grant submissions are adequately reviewed for budget and financial compliance and that all research compliance requirements (http://www.wm.edu/offices/sponsoredprograms/researchcompliance/guidanceandprocedures/index.php) are identified and managed.  Further, it is OSP’s responsibility to review and accept all external awards and serve as the central point for all post-award accounting and contractual interactions with the funding entity.

IV. Approval, Interpretation and Amendment

This policy is approved by the Senior Vice President for Finance and Administration and the Provost.  The policy is administered and interpreted by the Vice Provost for Research and the Chief Financial Officer and may be amended with approval by the Senior Vice President for Finance and Administration.

 

 


[1] The management of grant funds received to support sponsored research or scholarship at the Virginia Institute of Marine Science (VIMS) are subject to policies and procedures promulgated by the VIMS’ Office of Sponsored Programs.