2213 Classification of Grants and Gifts

Document purpose

To define gifts vs. grants or sponsored projects, to ensure proper classification, acknowledgement, stewardship, administration, financial recording and reporting.


July, 2003


April, 2023


May, 2023

Responsible Office





Administration of gifts vs. grants or sponsored projects:  All gifts are administered by the Office of Gift and Investment Services.  All grants and sponsored projects are reviewed by the Office of Research Services (ORS), to be administered by ORS, The Penn Center for Innovation, and the Office of Clinical Research. Please refer to policy: 2101 Administration of Sponsored Projects for detailed information on sponsored research administration.


  1. What is a gift?

    A gift is a voluntary, irrevocable transfer of funds or property made by a donor motivated by charitable intent, in the interest of and for the benefit of the University. The donor may not receive a more than an insubstantial private return benefit. A gift may restrict the use of funds for specific purposes and provide a general budget for those activities, but may not require deliverables beyond summary financial reporting and standard gift stewardship.

  2. What is a grant or sponsored project?

    Externally sponsored proposals for research or other purposes will be considered a sponsored project or grant if: the project commits the University to a specific line of scholarly or scientific inquiry; a specific commitment is made regarding the level of personnel effort, deliverables, or milestones; project activities are budgeted, and the award includes conditions for specific, detailed or formal fiscal reports; the project requires that unexpended funds be returned to the sponsor at the end of the project period; there is a specific quid pro quo between the sponsor and the University subjecting the University to specific obligations to be fulfilled; an agreement provides for the disposition of either tangible property or intangible property (e.g., inventions) which may result from the project; and the sponsor identifies a period of performance as a term and condition of the award.

  3. Classification issues.

    • Terminology used by funders should not dictate how the University classifies support.
    • Donors, funders, and University employees may not manipulate classification in order to reduce or avoid indirect cost recovery or other fees or administrative charges.
    • Questions on the proper classification of gifts vs. grants/sponsored projects should be referred to the following offices:

    Office of Research Services

    Elisabeth Peloso, Associate Vice President, epelosol@upenn.edu

    Gift and Investment Services

    Margaret Heer, Associate Treasurer, heer@upenn.edu

    These offices will work together to determine the appropriate classification of the proposed funding.