Effective May 9, 2022 all charitable grant budgets administered by the sponsored research office will include: 1) a research administration direct cost line item where possible and appropriate; 2) applicable project cost line items, normally funded as F&A, added as direct costs whenever possible and appropriate; 3) an indirect cost or fee calculated at the maximum rate permitted by the granting organization, per the donor's *published policy.
*Letters signed by donor organizations will no longer be accepted in lieu of a published indirect rate limitation.
Charitable Grants 101 Training Video
ASU staff: log into Research Academy to view the video recording of our recent Charitable Grants 101 - 2023 Refresh.
What is a charitable gift/grant?
Grants/gifts are broadly categorized as those awarded by the federal and local governments (public entities) and those awarded by non-federal entities (private entities including corporations and foundations).
As determined by the Federal Tax Code, charitable gift/grants are voluntary donations to tax-exempt organizations to support activities for religious, charitable, scientific, literary, or educational purposes. Budget restrictions, payment schedules, reporting and deliverables are irrelevant. See: IRC §170(c)(2)(B) and (D); IRS Pub. 526 (2010) Source: Internal Revenue Manual (IRM) https://www.irs.gov/irm.
Also, the funder’s description of funds as a gift, grant, sponsored project, or other terminology has no bearing on whether or not monies qualify as charitable.
What is not a charitable gift/grant?
A charitable gift/grant is NOT an exchange transaction having potential commercial benefit or profit that does not support charitable purposes.
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What are the fundamental principles of the ASUF/ASU Partnership?
- ASU Foundation (ASUF) is the applicant for charitable grants.
- All charitable grants are received by ASUF for reporting and receipting purposes.
- Charitable grants eligible for administration by ORSPA must contain at least one of the following: a specific statement of work, a designated principal investigator (PI) or program director (PD), or a budget.
- Unless otherwise specified, ASU Research Advancement staff/PNT will manage proposal development, review and submission for all charitable grants less than $100K.
- ASUF will assist, as needed, with charitable grants of a $100K or more; ASUF will be responsible for stewarding funders. Unless otherwise stated, PNT will submit the charitable grant on behalf of ASUF.
- Maximum allowable fees/F&A will be charged and shared by ASUF/ASU. If funder’s policy prohibits fees/F&A costs both ASUF and ASU will waive the fees/F&A.
Who administers charitable gifts/grants?
Though submitted with ASUF as applicant, charitable grants including a specific statement of work, a designated principal investigator (PI) or program director (PD), or a budget are administered by ORSPA. Please contact the unit RA for assistance in developing the proposal.
Are there times when ASUF should NOT be listed as the applicant on a charitable gift/grant proposal?
Yes. These include:
- The sponsor does not make awards to 501(c)3, non-profit
- The sponsor is a federal agency
- ASU is a subgrantee
- The award is being transferred into ASU from another institution
- The application portal or format requires that the University be listed (system limitation, etc.)
- The work being performed will provide a commercial benefit to the sponsor
- The sponsor does not make awards to a fiscal agent
In these limited circumstances, ASU/ORSPA would be the applicant.
Also, if the sponsor is a foreign entity, it may be necessary for ASU to be the applicant institution (rather than ASUF).
Can ASUF receive funding from governmental agencies?
ASU Foundation accepts and administers philanthropic contributions from private (non-governmental) entities, as well as funds from governmental entities including municipalities and tribal/sovereign nations which require awards to be made to a 501(c)(3), non-profit. An Example includes tribal contributions made under the Arizona Tribal-State Gaming Compacts.
ASU Foundation does not accept funding that originates from U.S. federal funding agencies (e.g. NSF, DOD, USAID). These funds are accepted by ASU-ORSPA.
ASU Foundation also accepts charitable funding from foreign entities, whether from public or private entities, provided the funds don’t originate from countries, such as Canada, for which ASU Foundation is not an authorized charity or from countries/governments under sanction by the United States. See U.S. Treasury list of sanction programs at: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information.
What if there is a limit on the number of proposals the institution may submit?
Limited Submission (LS) opportunities for charitable grants are managed through the standard ASU Limited Submissions process outlined at https://funding.asu.edu/search-for-funding/about-limited-submissions
What is the difference between a discretionary gift and a charitable gift/grant?
Discretionary gifts are discretionary funds for a general area of work without specific spending requirements.
Example: XYZ Foundation makes a gift to support Dr. C’s research on siclet reproduction. Funds may be used at the researcher’s discretion.
Charitable gifts/grants that qualify for administration by ORSPA are restricted gifts that support a specific project/scope of work.
Example: XYZ Foundation is making $10,000 available to develop an internship program for faculty scholars between the ages of 26-35 who live in Arizona. Funds may be used strictly for the work outlined.
If a discretionary gift will be used to support research that involves Human Subjects or other special review components, should the gift be managed as a Charitable gift/grant?
Yes, any externally-funded research that involves special review aspects (e.g., human subjects, laboratory animals, Native American Involvement, foreign sponsor, etc.) should typically be managed as a charitable gift/grant, rather than as a discretionary gift.
Who administers discretionary gifts?
Discretionary gifts are reviewed, accepted, and administered by ASUF and the appropriate academic unit.
Who can assist with seeking and receiving philanthropic gifts/grants?
RAs/PIs should contact the unit's ASUF development officer. Refer to the Unit Development Contacts list to discover your unit’s assigned Director of Development (DOD) that can assist with seeking and receiving philanthropic gifts/grants. If the DOD contact is still unclear, email ASUFoundationgrants@asufoundation.org with a copy to Angela Vasquez.
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