Identification and Management of Sponsored Awards Policy

Policy Title	Identification and Management of Sponsored Awards Policy
Policy Category	Academic/Research Policies
Original Policy Approval Date	April 14, 2022
Policies Superseded	Distinguishing Gifts From Sponsored Awards Policy
Responsible Office	Office of the Provost
Related Policies	Review and Approval of Sponsored Project Documents; Facilities and Administrative Cost Recovery and Distribution Policy
Frequency of Review	5 Years
Date of Next Review	April 2027

I. Scope

This Identification and Management of Sponsored Awards Policy (“Policy”) applies to all Arcadia University (“University”) faculty, staff, and students, as well as any other individuals who seek or receive external funding through their affiliation with the University. See Section IV below for the definition of all capitalized terms in this Policy.

II. Policy Statement

The University must manage Sponsored Awards, which are legal agreements executed by the University and the Sponsor, in accordance with all applicable federal, state, and local laws and regulations; University policies and procedures; and the terms and conditions of the Sponsored Award.

To ensure proper administration of a Sponsored Award, this Policy provides the framework to be used to classify external Sponsor support, received by the University, as a Sponsored Award that shall be managed by the Office of Sponsored Research and Programs (“OSRP”).

III. Policy

Requests for external support of research, instruction, or similar activities to be pursued by faculty, staff, or students of the University shall be reviewed and authorized by the OSRP prior to submission to the Sponsor.

In the event the funding request results in a Sponsored Award, it shall be administered by the OSRP and Finance and Administration.

A Sponsored Award ordinarily will have one or more of the following characteristics:

Funding opportunity announcement: The Sponsor’s terms, conditions, and other requirements for award management are disclosed in whole or in part in a funding opportunity announcement.
Performance requirements: The project to be conducted under the Sponsored Award has been described in an Application or Proposal approved by the Sponsor and identifies the key personnel involved, activities to be supported, and period of project performance, among other components.
Budget: The Sponsored Award will include a detailed budget that presents personnel and non-personnel costs allocated to support project activities. Other budget-related matters described in the Sponsored Award include allowable and unallowable costs (i.e., categories or items of cost that may or may not be supported by Sponsored funds); the procedures for re-budgeting between budget categories; and when or if Sponsor prior approval for re-budgeting is required. The Sponsor may also specify when project expenditures are to be audited.
Funding: The Sponsor may provide funds upon award to the University in whole or in part to support project activities. Alternatively, the Sponsor may reimburse the University for costs incurred in support of the Sponsored Project upon submission of an invoice or draw-down. At completion of the Sponsored Award, unexpended funds are either returned to the Sponsor (if provided in advance) or de-obligated (if reimbursed).
Reporting: The Sponsor requires progress, financial, or other reports to monitor project performance and expenditures.

This Policy does not preclude some non-governmental Sponsored Awards to be designated as charitable grants and to be included in University Advancement systems.

If either the source of funding or nature of the project does not align sufficiently with criteria for either a Sponsored Award or a Gift, the OSRP will work in conjunction with other University offices to ensure proper stewardship of the activity and funds. If a consensus cannot be reached between these parties, the funds, along with the respective determinations of the relevant parties, will be forwarded to the Vice President of Administration and Finance or their designee for the final determination.

For other distinguishing features of Sponsored Awards in contrast to gifts, please see Table 1.

IV. Definitions

Application / Proposal: A request for financial support of a project or activity authorized by the University and submitted to a Sponsor in accordance with the Sponsor’s instructions. The project or activity is typically well-aligned with both the University’s mission and the Sponsor’s interests and priority areas and upon completion is expected to result in outcomes or findings of broad benefit to society. If selected for funding, an Application / Proposal ordinarily results in a grant, sub-award, or other similar legal instrument to the University.

Sponsor: A Sponsor is an organization or agency that funds a Sponsored Award. The Sponsor may be a federal, state, or local agency; a non-profit organization; a charitable or non-charitable foundation; a professional society; or a for-profit entity such as a corporation or a small business.

Sponsored Award: A formal, written legal agreement executed by the University and the Sponsor for specific work outlined in the Application / Proposal with the reciprocal transfer of something of value. The term includes but is not limited to grants; cooperative agreements; traineeships, scholarships, and fellowships; sponsored service, testing, and training agreements; sub-awards; and contracts, including fixed-price contracts. In the event that funds obligated by the Sponsor for the award are not fully expended during the period of award and that period cannot be extended in time, the unexpended funds ordinarily are either de-obligated or returned to the Sponsor. Unexpended funds may be retained by the University only if supported by a fixed-price agreement.

Sponsored Project: The specific activity (e.g., research, instruction, training), deliverable (e.g., service), and associated requirements (e.g., technical and financial progress reports) to be provided or completed as a condition of and supported by the Sponsor’s funding. The Sponsored Project and proposed personnel to be involved are ordinarily described in a University-authorized Application/Proposal submitted to the Sponsor for their consideration of funding. Sponsored Projects ordinarily do not include major construction or renovation activities.

Terms and Conditions: All legal and administrative requirements imposed on the University by acceptance of the Sponsored Award, whether expressly stated or incorporated by reference in the Sponsored Award.
University: Arcadia University, its colleges, schools, affiliates, divisions, and subsidiaries.

V. Effective Date

This Policy is effective on the date that it is signed by the President.

VI. Date of Approval

April 14, 2022

Attachment: A
Table 1: Distinguishing Features between Donations/Gifts and Sponsored Awards

Feature	University Advancement -Donations, Gifts, and Charitable Grants-	Sponsored Research & Programs -Sponsored Awards-
Intent	Gift is motivated by charitable intent and does not include a commercially valuable return to the funder (quid pro quo). The language used – gift, charitable grant, contract, or award – does not necessarily reflect intent.	Award may be either a grant which benefits the public or a contract, which benefits the Sponsor. In both situations, (quid pro quo), the benefit is provided in exchange for the funds.
Purpose	Gift supports a restricted or unrestricted purpose – including unrestricted support for research – or activities such as endowment, scholarship, student support (i.e. fellowship), construction, and general support of outreach and service programs.	Award supports research or non-research projects with defined deliverables or set of activities that are completed within a specified period of performance Award conditions are governed by a legal agreement executed by the Sponsor and University’s authorized legal representative.
Documentation	A gift agreement codifies an irrevocable charitable gift of $10,000 or greater which must outline an amount, intent, purpose, and fulfillment schedule. All endowed gifts must be signed by the President and Vice President.	Award conditions for the defined project are governed by a legal agreement executed by the Sponsor and University’s authorized legal representatives.
Risk	Project does not include research risk items.	Sponsored awards may include research risk items (e.g., human subjects, export controls, radioactive materials, recombinant DNA, etc.)
Intellectual Property	Donor relinquishes intellectual property and data rights to the University.	Governed by federal regulations, Sponsor and University policies, where University usually owns IP created during the project. Sponsor may negotiate licensing rights, patent rights, etc.
Deliverables	Project promises few, if any, deliverables other than stewardship reports.	Award requires specific deliverables (e.g., technical reports, evaluations, training, etc.)
Reporting	Gifts require strategic stewardship and communication as a courtesy to the donor (e.g., progress reports, reports of expended funds, financial or summary reports, and/or fund balances.)	Award requires post-award financial reports, certifications or assurances of adherence to policy requirements (e.g. IRB/IACUC approvals, public access requirements, documentation of personal compensation, etc.)
Return of Funds	Gift is irrevocable and return of expended funds is usually not a requirement or is negotiable.	Award may be revocable or the Sponsor may reduce funds awarded. Unexpended funds are either de-obligated or returned to the Sponsor. Expended funds may be disallowed if Sponsor policies are not followed.
Control of Funds	Donor does not control expenditures. Control is prohibited.	Sponsor requires grantee to follow the authorized budget; changes in budget categories may require prior Sponsor approval.
Accounting	Gifts for the same purpose may be combined into one fund. In such cases, financial reporting is handled by the department or program.	Awards may not be comingled in the University’s financial system; each must be separately budgeted and accounted for.
Publicity	Donor may request the right to review and approve press releases or publicity announcements.	Sponsor may request the right to preview and approve press releases or review presentation or manuscripts prior to delivery or publication, respectively.