Is it required to create and maintain documentation supporting the determination of gift vs. sponsored award? If so, what format should be used for documentation and for how long is documentation required to be kept?

Documentation of the gift vs. sponsored award determination is highly desirable and making and retaining the documentation in “close cases” should be standard practice in the submitting office and RSO. Due to the high volume of gift and sponsored awards, it would be onerous to create and retain documentation for all transactions. As such, documentation should be prepared and retained only for “close calls,” in which the designation is not clear. Consultation with another party or office within the school or University related to the conclusion reached should be documented. More specifically, if the conclusion is not obvious to a reasonable, informed person, then documentation should be kept.

There is no prescribed decision tree or checklist required as documentation. If there was correspondence via email, preserving the e mail trail may be sufficient. If there was correspondence in person or over the telephone, a brief written summary of the key points would likely be sufficient. The final documentation should generally include the key factors considered in the final designation, with a brief explanation of the reasoning for the designation.

In general, consistent with the research data retention principles of the University, such documentation should be preserved for seven years after the end of activities under, or a financial close‐out of, a gift or sponsored award, whichever is later.