In this Open Comment: Make a Donation in Support of Your Own Program
The Office of Business and Financial Services, Office of the Vice President for Research, and the University of Illinois Foundation are proposing updates to Section 11.7: Gifts and Endowments - Donations from Employees in Support of Their Own Programs, and the Employee Donor Agreement form. These modifications are being proposed due to a variety of reasons, including recent Illinois regulatory changes, and other factors. Proposed updates include:
- Clarifying the issue of actual or potential conflict of interest arising from making this type of donation.
- Clarifying that a conflict of interest can arise from the employee’s “controlling interest” in a business entity, and identifying the business (if it exists) is required in the updated Employee Donor Agreement form.
- Defining requirements for managing and using the donated funds.
- Emphasizing that a “unit executive officer” must approve and oversee the management and use.
- Identifying that the campus Conflict of Interest Office(s) are now involved in this process.
- Emphasizing that units are required to submit the Employee Donor Agreement form when these donations are made.
- Redeveloping the Employee Donor Agreement form to automatically route to both the University of Illinois Foundation and the campus Conflict of Interest Office, after approval by unit executive officer.
Make a Donation in Support of Your Own Program
Before you Begin
As a University employee you, your family, or a business entity in which you hold a significant or controlling interest, can make donations in support of your own research program.
To avoid the appearance of a conflict of interest (COI), donated funds (or substituted equivalent amounts from institutional funds) cannot be used to fund any or all of the employee/donor's salary. If the funds are to be used in an area where the employee-donor has consulting relationships or other interactions with personal business activities, special care must be exercised in the use of donated funds, including:
- Donated funds must be deposited in a FOAPAL controlled by your unit executive officer or other employee not under the employee-donor’s supervision.
- Deficit spending is not allowed.
- Donated funds may be used for the employee-donor's travel only when it is determined by your unit executive officer that such travel is exclusively for University business.
- If University students are involved in the employee-donor’s personal business activities, those students cannot receive funding from the donation.
The unit executive officer is responsible for ensuring that expenditures of donated funds comply with all relevant regulations referenced inSection 11 - Gifts and Endowments.
If you have questions about applying conflict of commitment and interest policy to your situation, consult RNUA Contacts and Resources for contact names, phone numbers, and email addresses.
To make a donation in support of your own program:
- Inform your unit executive officer that you wish to make a donation, and how the donation will be used.
- If you plan to declare your donation as a deductible charitable contribution on your personal tax return, consult with your tax advisor, as Section 170 of the Internal Revenue Code stipulates that a gift may not be fully deductible if there is a direct or indirect personal benefit to the donor.
- Consult the Office of Sponsored Programs and Research Administration (OSPRA) at Urbana, or the Office for Research Services (ORS) at Chicago, if you have questions as to whether the funds should be considered as a sponsored activity in accordance with Section 11.2, Distinctions Among Gifts, Grants, and Contracts.
- Submit an Employee Donor Agreement form to your unit executive officer. The unit executive officer will approve and route the form to the University of Illinois Foundation (UIF) and your campus Conflict of Interest office.
Forms used in this procedure
Employee Donor Agreement (not available for open comment)
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