Policy identification number: SPON-004
File: Other Operational Policies / Sponsored Research & Federal Relations
Gift or Grant Determination
This policy shall clarify the difference between funds raised as gifts, donations, or pledges or those raised as grants or contracts to: 1) ensure proper financial recording and reporting of gifts vs grants and 2) determine whether funds received from off-campus sources should be administered by the Office of Institutional Advancement or by the Office of Sponsored Research and Federal Relations. The classification of external funding as either a gift or grant serves as an important step in ensuring that the appropriate accounting and compliance action is used.
Provost and Vice President for Academic Affairs
November 2, 2016
November 2, 2016
pvpaa, vpia, g, gift, grant
Scheduled for Review
I. Policy Statement
The classification of funds originating from a source external to Fort Lewis College is made based on the terms and conditions under which the funds are given by the funding source (sponsor).
The chart below shows the general characteristics of and differences between the two funding categories of gifts and grants. Please note that in some cases it may not be readily apparent if the award is a gift or a grant. In these cases the Office of Sponsored Research and Federal Relations, in conjunction with the Office of Institutional Advancement, will review the documentation and decide which classification is most appropriate.
II. Reason for Policy
The College must manage all funds received in accordance with applicable federal, state, and local laws, and with the specific terms and conditions of any gift, grant, or contract. The college’s approval, negotiation, and agreement processes and mechanisms, accounting, budget practices, oversight, and compliance practices differ depending on whether funds received are categorized as a gift or a grant. There are very clear factors that differentiate a gift from a grant. It is essential that the categorization of external funding received be done with care, consistency, and with a sound understanding of the various considerations (outlined in the table above) that drive the determination of funding type. This policy is intended to facilitate the appropriate classification of gifts vs grants and to ensure that external funding for the College receives the proper compliance review, administrative oversight, and monitoring.
For following the policy: All individuals, departments or programs soliciting external funding for College purposes
For enforcement of the policy: The Vice President for Institutional Advancement, the Director of the Office of Sponsored Research and Federal Relations, and the Controller
For oversight of the policy: The Provost and Vice President for Academic Affairs and the Vice President for Institutional Advancement
For notification of policy: Policy Librarian
For procedures implementing the policy: The Vice President for Institutional Advancement and the Director of Sponsored Research and Federal Relations
Gift: A contribution that is donative in intent, given voluntarily and with nothing significant of value given in return, other than recognition and disposition of the gift in accordance with the donor's wishes.
Grant/Contract: An externally funded activity where there is an agreement representing transfer of money or property in exchange for specific services, often including deliverables and specific reporting requirements.
VI. Cross-Referenced Policies
VII. Consequences for Non-Compliance
Potential allegations of misappropriations of funds and associated fines for federal and state dollars, federal and state fines for lack of compliance, jail time for the individual offender, if a federal grant, loss of funding.