Gifts and Donations to External Parties Policy
|History:||Issued -- September 6, 2016|
|Related Policies:||Conflict of Interest Policy for Staff and Faculty; Gift Card Policy; Honoraria Policy; Political Activities Policy|
|Responsible Official:||Vice President for Finance and Treasurer tel. (202) 319-5606|
I. Policy Statement
The Catholic University of America is substantially funded by donor and student-paid monies. The reasonable expectation of these stakeholders is that these funds shall be applied to support the mission of the University. The University’s tax exempt status also is dependent on fidelity to donors’ intent, mission-related use of funds, absence of conflict of interest, and effective internal controls.
For the foregoing reasons, gifts or donations from University funds from any source to non-University individuals are strictly limited as set forth in this policy. This prohibition also applies to provision of University goods or services, or use of University spaces or facilities at no charge or for reduced rates.
In rare circumstances where gifts or donations are permissible, such gifts or donations may be subject to financial, accounting and tax requirements as administered through the Finance Division.
A. Donations or Transfer of University Funds
University funds from any source shall not be donated, transferred or otherwise given to external individuals or entities, nor applied to their obligations, for any purpose other than to advance a specific goal that is integral to the University’s educational mission. Determinations as to whether a donation or transfer is permissible must be made in advance by a cognizant dean and Vice President or the University President.
B. Gifts and Mementos
Items given as gifts or mementos (e.g., mugs, clothing, pens, or University logo items) that are of minimal value ($35 or less) may be provided to non-University individuals as a sign of appreciation or for participation in a University activity. Formal approval is not required in such circumstances. Note, however, that gift cards may only be provided as gifts in the limited circumstances set forth in the University’s Gift Card Policy.
All other gifts or mementos made with University funds to non-University individuals or entities are prohibited absent advance approval of the cognizant dean and Vice President or the President of the University, who will determination whether a mission-related goal is supported or achieved by making the gift.
C. Providing University Goods, Services or Resources
The provision of University goods or services to non-University individuals or entities in lieu of money (“in kind”) is prohibited except where such provision supports or achieves a mission-related goal. Likewise, University resources, spaces or facilities may be provided at no charge or for reduced rates to external individuals or entities, or for external activities or projects, only to support or achieve a mission-related goal. Determination as to whether a mission-related goal is supported or achieved must be made in advance by a cognizant dean and Vice President or the University President.
Examples of possibly appropriate use of University resources include support for campus programs organized and run by approved University student groups and academic units, support for Academic Senate activities, and co-sponsorship of activities with recognized alumni or community groups.
Examples of inappropriate use of University resources include support for political activities as defined in the University’s Political Activities Policy, or support for any other organization or activity that might put at risk the University’s not-for-profit status under Internal Revenue Code. ?
III. Failure to follow this Policy
Individuals or units who make gifts or donations in violation of this policy may be required to reimburse the University for the cost of the gift or donation.