Policies & Regulations
Academic Affairs: Research & Sponsored Programs


External Funds Classification and Placement: Gifts, Sponsored Projects, Fees for Academic Services
Number: 2.0360P
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New Policy

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Major Revision of Existing Policy

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Minor/Technical Revision of Existing Policy

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Reaffirmation of Existing Policy

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Repealed Policy

Effective Date: 4/23/2008
Revised Date:
Responsible Division/Department:
Academic Affairs /Office of Research and Sponsored Programs


I. OBJECTIVE & PURPOSE

The purpose of this policy is to set forth the classification and placement of external funds received to support research, services, and instructional activities conducted by University faculty and staff under the auspices of the University.

II. STATEMENT OF POLICY

The University of North Florida accepts financial support from organizations, both non-profit and for-profit, for a variety of purposes, including the conduct of research or services. Private funds awarded for general support related to research or public service are typically accepted by the University through the UNF Foundation as Gifts. Funds awarded for specific research or service activities may be accepted as Fees for Academic Services or Sponsored Projects, depending on the particular characteristics of each award.

Regardless of the designation of a research activity as a Gift, Sponsored Project or Fees for Academic Services, it will be subject to the research review process as well as the administrative rules and procedures which apply to all University Funds.

References:
F.S. 1004.22
Financial Accounting and Reporting Manual for Higher Education (FARM):

DEFINITIONS:

Gifts
In general, a Gift is a contribution received by an insitution for either unrestricted or restricted use in the furtherance of the institution for which the institution has made no comitment of resources or services other than possiby, committing to use the gift as the donor specifies. The Foundation requires Gift Agreements for contributions of $25,000 or more, and in some cases for lesser amounts. Unexpended funds are not returned to the donor at the expiration of the Gift period.

In general, funds are classified as Gifts when the following characteristics exist:
* Funder does not require a tangible deliverable: the contribution is a nonreciprocal transfer with no implicit or explicit statement of exchange, purchase of service, or provision of exclusive information.
* Funds are awarded irrevocably.

Reference:
Case Management and Reporting Standards

Gifts are administered through: Institutional Advancement

Sponsored Projects or Fees for Academic Services
In general, Sponsored Projects or Fees for Academic Services are "exchange transactions" between an external funder and the recipient under a grant, contract, cooperative agreement, purchase order, or any other mutually binding agreement that restricts the use of funds or property and stipulates conditions with which the University must comply.

Sponsored Projects
Sponsored Projects are usually intended for the support of specific research projects, i.e., to be used for the execution of a particular research design in accordance with a proposed budget of expenditures.

In general, funds are classified as Sponsored Projects when the following characteristics exist:

- A proposal that responds to a formal RFA, RFP, or other formal solicitation and the project is initiated by a notice of award;
- A Statement of Work to define a line of scholar or scientific inquiry and specifies programmatic objectives that are to be accomplished within a delimited period of time and budget, and/or formal deliverables such as annual progress reports or performance objectives;
- A specified period of performance is prescribed, or termination is at the discretion of the sponsor;
- Testing or evaluating of proprietary products is involved;
- Specified terms regarding fiduciary responsibility or payment contingencies (i.e. return of unexpended funds);
- The award requires spearate accounting procedures and detailed financial reports;
- The award includes provisions for audit by or on behalf of the sponsor;
- The award involves the disposition of property, whether tangible or intangible, that may result from the project (e.g., equipment, records, inventions, copyrights, or rights in data);
- The award requires regulatory oversight in areas such as non-exempt human subjects research, animal care, biological safety, radiation safety or financial conflict of interest.

Sponsored Projects are administered through: Office of Resarch and Sponsored Programs

Fees for Academic Services
Fees for Academic Services are unit activities, usually academic, that provide goods or services at approved rates on a regular and continuing basis. These services are predominantly provided to the general public, incidentally to University departments or individuals who are part of the University community (i.e. staff, faculty, students). The sales are based on established unit prices and like services or products are sold to other non-University customers or University departments based on the same unit prices a department, center, or college would receive by selling supplies or services outside the University community. Income from the sale of services may be subject to Federal or State taxes.

Examples of Fees for Academic Services are:
- Professional services, such as consulting, educational program, health care services, counseling, and training to external entities;
- General services, such as utilities, data collection, proficieny testing, and laboratory testing;
- Entertainment and other events held on University premises;
- Sponsorships for which the University provides acknowledgment opportunities or other considerations in return for contributions or donations, such as athletic sponsorships; and
- Leases or rentals of University propery, such as real estate, facilities, or equipment.

In general, funds are classified as Fees for Academic Services when the following characteristics exist:
- Activity is a routine service provided at a fixed price, available to any customer in the general public;
- Activity is not Federally funded (directly or under subcontract);
- Activity does not constitute program income related to a sponsored project;
- Activity does not involve any proprietary data (Funder's or University's);
- Unexpended funds do not need to be returned to Funder, and no auditing of expenditures by on or behalf of Funder is required
- Funder does no claim patent, licensing or other intellectual property rights generated by the project/activity;
- Funder does not restrict publication rights or require approval of publications;
- Funder does not require matching or cost sharing.

Fees for Academic Services are administered through: Academic Affairs

CLASSIFICATION OF FUNDS:

The attributes listed in each category above are used to guide determination of funds classification. The final determination will be made after a thorough assessment of each proposed service by the Office of Research and Sponsored Programs, in conjuction with Academic Affairs and Institutional Advancement as applicable.

Since, in many situations, all of the above characteristics will not be present, judgment must be exercised in order to classify the funds in accordance with the intent of this policy. The decision as to whether a particular award should be considered a gift, sales, or grant cannot be made based upon the presence or absence of a single characteristic or citerion. Rather, the correspondence from the sponsoring agency for each activity must be reviewed and further investigation may be required in order to make a judgment as to the activity's proper classification.

Responsibility for implementing procedures for reviewing proposals and entering into agreements for sponsored programs (grants or contracts) is delegated to the Office of Research and Sponsored Programs. These procedures are a critical part of the campus's management system established to assure compliance with Federal and other sponsor requirements. Procedures for entering into Fees for Academic Services contracts need to be consistent with these procedures. The need for this policy is driven by the requirement that the campus must be able to demonstrate (e.g., to Federal, State, or System auditors) that appropriate procedures are in place to assure compliance with Federal, State, and University rules and laws.


III. STATEMENT OF PROCEDURES

Classification as Gift or Exchange Activity (Fees for Academic Services or Sponsored Project)
An initial review of funding that might be classified as either a gift or an exchange shall be done jointly by Institutional Advancement and the Office of Research and Sponsored Programs (ORSP) to determine which classification is appropriate. If this review indicates that the associated funds are not provided as a gift, the activity will be reviewed in accordance with the Procedures for Classifying Proposed Exchange Activities. All sponsored project activities will be reviewed exclusively by ORSP.

Procedures for Classifying Proposed Exchange Activities
Any person(s) considering engagement in possible Fees for Academic Services activity shall submit information about the activity on an Exchange Activity Classification form to the ORSP. This form should be submitted as soon as a potential activity has been identified. ORSP will review the information presented and request additional information if necessary.

The information will be reviewed by ORSP using the characteristics listed above and sponsored programs related regulations and policies to determine if the activity must be managed as a Sponsored Project.

If the initial review indicates that the activity is a Sponsored Project, the activity will be processed and administered through ORSP in accordance with standard sponsored programs procedures.

If the initial review indicates that the activity could be classified as Fees for Academic Services, ORSP will submit the form to Academic Affairs for acceptance of the activity as Fees for Academic Services. If Academic Affairs concurs that the activity can be managed as Fees for Academic Services, the activity will be processed and administered in accordance with standard auxiliary funds procedures. If not, the activity will be managed by ORSP as a Sponsored Project.

If the information provided to ORSP is insufficient to make a classification determination, ORSP may contact the potential funder for additional information.

PLACEMENT OF FUNDS:

Gifts
Funding received in the form of Gifts will be processed and managed by Institutional Advancement. Funds will be deposited in TSI/Foundation Accounting.

Sponsored Projects
Exchange activities that do not meet the criteria for designation as Fees for Academic Services activity are considered sponsored projects and will be managed through the Office of Research and Sponsored Programs. Funds will be deposited in the ORSP Contracts and Grants Trust Fund.

Fees for Academic Services
Revenues generated by activited designated as Fees for Academic Services activity will be deposited into an Auxiliary Fund in Academic Affairs. In requesting that an auxiliary account be established, the proposed fund manager will submit an auxiliary Budget Worksheet to the Office of Academic Affairs (AA). the request will identify the revenue contemplated from the Fees for Academic Services as well as the anticipated expenses. If approved by AA, the request will be submitted to the Auxiliary Oversight Committee for review and approval.

Fees for Academic Services activites are subject to the policies and procedures governing auxiliary accounts. Contact Academic Affairs and the Budget Office with questions about these policies and procedures.

FACILITIES AND ADMINISTRATIVE/INDIRECT COSTS:

The processing of Gifts will not include the application of Facilities and Administrative (F&A), otherwise referred to as indirect costs. Processing of Sponsored Projects and Fees for Academic Services will include the application of F&A or indirect costs in accordance with University policies.