External Funds / Fundraising Policy

Policy Statement

The purpose of this document is to clarify the process through which external funds are received and administered at SUNY Brockport. Appropriate classification and processing of external funds ensures institutional compliance with SUNY, the Research Foundation for SUNY (RF), and governmental policies, regulations and reporting requirements, and facilitates acceptable levels of accountability and stewardship for these funds.

Purpose/Scope

All requests for external funds from corporations, foundations, or government entities must be submitted through and processed by either Sponsored Programs Administration or the Brockport Foundation, Division of Advancement. 

The Brockport Auxiliary Service Corporation (BASC) is not subject to this policy and is not authorized to receive or administer funds on behalf of SUNY Brockport.

Funds received from external entities will be made payable to either the Research Foundation for SUNY or Brockport Foundation.  Since awards may be made for many of the same purposes, determination of charitable giving or sponsored program status will be made according to the guidelines provided in the Policy Procedures section of this policy.

• All applications to prospective sponsors by faculty or staff members seeking support for sponsored programs shall be made through the Scholar and Grants Development Office in conjunction with the RF. All applications/solicitations for voluntary support will be made through the Brockport Foundation/Division of Advancement, including corporate and foundation gifts.

Background

In 1977, an agreement between the State University of New York (SUNY) and the RF formalized relationships, duties, and responsibilities in relation to sponsored program activities.  This agreement is the enabling authority for the RF to act as fiscal administrator of the University’s sponsored funds, including research, educational, specific training, fellowship and other sponsored funding, as applicable. The agreement mandates that all federal and state grants and contracts must come through the RF, as well as any private corporation or foundation that is entering into a contractual relationship.

Guidelines also were developed by SUNY for establishing campus-related foundations in that same year. These foundations are responsible for administering voluntary support to the campus. According to the Foundation guidelines for State operated campuses, “The Foundation and each of its Affiliates must operate in accordance with sound business practices and shall ensure:

• Proceeds of campus fundraising are appropriately recorded, credited, acknowledged and administered, based on legal requirements and donor stewardship parameters.
• They adhere to principles as defined in the Association of Fundraising Professionals’ Donor Bill of Rights and Code of Ethical Standards.
• They adhere to all applicable legal requirements and University procedures when providing fiscal, administrative, and investment functions to the auxiliary services corporations, alumni associations, student government associations and/or the chief administrative officer’s fund.
• Appropriate student and faculty participation, when assuming the responsibilities of the auxiliary service corporation.

Per SUNY regulations, the following activities should be managed by SUNY Business Offices and through State accounts:

• Instructional and credit-bearing programs;
• Activities that generate revenue from the use of State property (e.g., cell tower leases and pouring rights).

Applicability

The policy applies to all faculty and staff seeking external funding from corporations, foundations or government entities.

Definitions

Charitable Giving:

• The contributing organization/individual donor refers to the funds as a gift, foundation grant, bequest, donation, or contribution to the Brockport Foundation / Division of Advancement and the funds are given voluntarily without expectation of any tangible compensation to the funder;
• The funds are contributed for an unrestricted purpose or for supporting such activities as endowments (eminent scholars, endowed chairs, professorships, etc.), capital projects (construction or renovation, equipment, etc.), or general student financial assistance (fellowships, scholarships and undergraduate/graduate research opportunities), except those funded by a research grant.

Policy Procedures

The following statements provide general guidance for the classification of sponsored project and charitable giving. Actual classification will be determined according to the “Research Foundation Activities” listed further below.

Sponsored Programs

• The Scholar and Grants Development Office (Pre-Award), in conjunction with the RF, will submit all proposals related to funding of sponsored programs awarded by issuance of a grant, contract, memorandum of understanding (MOU) or another mechanism deemed appropriate by both the funding entity and the RF. The RF will receive and administer awarded funds for sponsored programs.
• Sponsored programs are those for which funds are made available from any source for an express purpose or objective, for which the sponsor usually requires periodic fiscal and programmatic reports, imposes time limitations for the use of such funds, and ordinarily provides for the return of unused funds to the sponsor.

Charitable Giving

• The Brockport Foundation / Division of Advancement will submit all applications related to charitable giving and solicitations. The Brockport Foundation / Division of Advancement will administer gifts, bequests, donations, and contributions from individuals, foundations, corporations, and non-profit organizations. Charitable giving and contributions are unrestricted with no expectation of compensation or return of funds, and generally have no specific timeframe or periodic fiscal and programmatic reports.

Use the Appendix “Quick Reference Summary” document, defining Sponsored Awards vs. Gifts, to determine whether Sponsored Programs Administration or the Brockport Foundation / Division of Advancement is the appropriate unit to assist with the request for external funding.

Research Foundation Activities:

• The sponsor is a federal, state, or local government agency, a quasi-governmental agency, or a nonprofit organization which receives a majority of its funding from federal, state, or local general revenues;
• The sponsoring agency/organization refers to the award as a contract, cooperative agreement, consortium agreement, sub-grant, subcontract, or purchase order;
• The funds are awarded by the agency, organization, or individual following a competitive application or bid process;
• The funds are awarded as matching funds for a project funded by a governmental agency, a quasi-governmental agency, or a non-profit organization that receives a majority of its funding from federal, state, or local general revenues;
• The sponsoring agency/organization specifies that the funds are to be used for research, a model project, program development and/or operation, curriculum development, training, community service, planning, or some other specific activity and identifies a specific scope of work;
• The funds are provided by the sponsoring agency/organization to cover the cost of performance of a specified scope of work or set of activities or to provide a specific product, service, or other deliverable or outcome within a specified period of time;
• The sponsoring agency/organization identifies a technical monitor for the purpose of monitoring performance and providing liaison between the sponsor and SUNY Brockport;
• The sponsoring agency/organization imposes publication restrictions and/or requires conveyance of rights to tangible property (equipment, records, technical reports, theses, or dissertations) or intangible property (rights in data, copyrights, or inventions) resulting from the funded project;
• The project or activity funded by the sponsoring agency/organization involves the use of humans or animals in research, radiation hazards, biohazards, or recombinant DNA;
• The sponsoring agency/organization specifies how funds will be used or includes a line item budget that identifies expenses by activity, function, or project period;
• The sponsoring agency/organization requires detailed line-item financial reports and/or invoices which document expenditures for the specific scope of work or set of activities performed;
• The funds are provided by the sponsoring agency/organization to cover the cost of performance of a specified scope of work or set of activities or to provide a specific product, service, or other deliverable or outcome within a specified period of time;
• Conduct of the funded activity requires regular payment of SUNY Brockport employees for a specific scope of work or set of activities through a payroll system;
• The sponsoring agency/organization specifies audit requirements as a condition of award;
• The sponsoring agency/organization stipulates other terms and conditions of award dealing with such topics as compliance with federal or state regulations, allowable and unallowable costs, subcontracting, insurance, warranties, indemnification or hold harmless requirements, protection of proprietary or confidential information, modifications, penalties, remedies, termination, applicable governing law, and assignment.

Brockport Foundation/Division of Advancement Activity:

• Complete the reporting to the contributing organization/individual in a format that conforms with the requirements of the contributing organization/individual;

Responsibility:

• Faculty/Staff
  • Work with the appropriate office (Scholar and Grants Development Office and/or the Brockport Foundation/Division of Advancement) when seeking external funds.
  • Ensure all applications, requests for funds, or agreements are signed by authorized campus representatives.
• Deans/Chairs
  • Approve only those funding requests that have been developed in consultation with either Sponsored Programs Administration and/or the Brockport Foundation/Division of Advancement.
• Brockport Foundation/Division of Advancement
  • Assists with the development of all proposals and budgets related to the grant or gift.
  • Helps identify funders and approves submission.
  • Reviews and submits all requests for gifts, donations, and contributions from individuals, foundations, corporations and non-profit organizations.
  • Administers funds when received.
• Research Foundation
  • Assists with the development of all proposals and budgets related to the funding of sponsored projects.
  • Submits all required documents related to funding of sponsored programs awarded by issuance of a grant, contract, memorandum of understanding (MOU), or another mechanism deemed appropriate by both the funding entity and the RF.
  • Accepts and administers all awards received for the purpose of funding sponsored projects.

Links to Related Procedures and Information

Appendix - Quick Reference Summary
Association of Fundraising Professionals’ Code of Ethical Standards
Association of Fundraising Professionals’ Donor Bill of Rights
Campus Impact Statement - Contact the Director of Scholarship, Research, and Sponsored Programs to complete this form.
Campus Process for External Grant Submissions to Funders
General Fundraising Policy
The Research Foundation Agreement – June 1, 1977

Contact Information

Director of Scholarship, Research, and Sponsored Programs - for both Pre- and Post-Award

History (in descending order)

Approval

This policy was approved by President’s Cabinet on 2020-09-08