Gift or sponsored project determinations
The following steps should be taken when determining if a funding opportunity or award is a gift or sponsored project. This process mirrors the KU policy to assist PIs in determining whether a source of external support should be treated as a sponsored project (processed through the KU Office of Research) or a gift (processed through KU Endowment).
Decision-makers will collaborate with each other, resulting in an objective determination.
The chair or director of the department/center/institute makes an initial determination at the pre-award stage based on evaluation of the funding opportunity, using the gift or sponsored project characteristics chart (below). All initial determinations are subject to review and approval by KU Endowment and the KU Office of Research.
If a department/center/institute cannot determine if a funding opportunity is a gift or a sponsored project, the KU Research Pre-Award unit should be consulted. The Pre-Award unit will confer and provide a written decision. Decisions are subject to change.
In cases where it is more difficult to make a determination, the KU Research and KU Endowment Corporate & Foundation Development teams will review the information jointly and make a decision. The Pre-Award unit will provide written documentation of the resolution to all parties.
In cases that are particularly difficult to resolve, the Vice Chancellor for Research and the Senior Vice President of Administration at KU Endowment will review the information jointly and make a decision. The Pre-Award team will provide written documentation of the agreed-upon resolution to all parties.
Certain terms or conditions automatically require review by KU Research:
- Work involving research risk factors, such as IRB, IACUC, COI, export controls, environmental safety and/or restricted research elements (required delay of publication; indefinite or permanent delay of publication; limits on access by foreign students, scholars, faculty or staff; restrictions on access to campus facilities in ways that disrupt the overall research and teaching activities of the university; may have primarily harmful consequences for human beings).
- Subawarding work to another institution or entity
- Financial audit
All factors must be assessed in the determination of a gift or sponsored project, as a single factor most often will not be determinative. Proposed in-kind gifts (such as equipment, facility usage and personnel) will be handled in accord with KU's Guidelines for Acceptance of In-Kind Gifts policy.
Gift or sponsored project characteristics
| Funding opportunity characteristic | Sponsored project | Gift |
|---|---|---|
| Project requires compliance review (e.g. IRB, IACUC, COI, etc.) | X | |
| Submission requirements | Sponsored project | Gift |
| May involve funder-defined scope of work | X | |
| Limited numbers of submissions permitted | X | |
| Proposal submitted in response to an RFP | X | X |
| Faculty-defined scope of work | X | X |
| Source of funds | Sponsored project | Gift |
| Funding provided by governmental agency | X | |
| Funding provided by private (for-profit or nonprofit) entity | X | X |
| Funding provided by an individual | X | |
| Funder remains anonymous | X | |
| Funder's intent | Sponsored project | Gift |
| Deliverables due to sponsor | X | |
| Charitable purpose | X | X |
| Funding a professorship or endowment | X | |
| Award terms & conditions | Sponsored project | Gift |
| Use of funds governed by funder guidelines/policies | X | X |
| Funds are revocable | X | |
| Funds are irrevocable (unless gift conditions are unmet, unspent funds may need to be returned) | X | |
| Specific period of performance | X | X |
| No specific period of performance | X | |
| Prior approval required for budget, scope and/or date changes | X | X |
| Facilities & administrative (indirect) costs | X | |
| Actual cost reimbursement | X | |
| Fixed fee or milestone-based reimbursement | X | |
| Funder may audit expenses | X | |
| Funder may terminate unilaterally | X | |
| University may terminate unilaterally | X | X |
| Funder may request project records | X | X |
| Funds are restricted | X | |
| Detailed financial and progress reporting | X | |
| High-level financial and summary progress reporting (no detailed financials) | X | |
| No financial or progress reporting | X | |
| Must return unexpended funds (if agreement is cost-reimbursable) | X | X |
| May negotiate re-allocation of unexpended funds | X | X |
| Anticipated outcomes generated from use of funds | Sponsored project | Gift |
| Sponsor receives tangible benefits (i.e., projects, services) | X | |
| Public benefits | X | X |
| IP owned by funder | X | |
| IP owned by university | X | X |
| Possible publication restrictions or required pre-publication review | X | |
| Publication encouraged | X | X |