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Update on Research Gift Acceptance Process

A message from the Vice President for Research:

Dear University of Maryland Campus Community:

Gifts in support of research provide faculty members with flexible funds to pursue their research objectives without a predetermined scope or conditions mandated by the donor. Although gifts generally require less administrative oversight, certain federal regulations and funding agency policies must be considered before the University can accept a gift. Complying with these regulations and policies is critical to protect faculty and staff members from legal liability and government funding penalties.

In July 2022, the University updated its gift acceptance process to ensure compliance with these regulations and policies. This letter aims to provide important updates and guidance on our gift review and acceptance business processes,  including Workday, Kuali Build Gift form, and the Integrated External Relationship Portal (inTERP).

Key Points:

  • Gifts that support research often have federal reporting requirements such as proposal disclosures and foreign source reporting (i.e., Section 117 of the Higher Education Act: Reporting of Foreign Gifts and Contracts). These should be considered during the gift acceptance process.
  • Gifts can include funding and/or resources (e.g., equipment, materials, software, student support, and other items of value) and, by definition, cannot require specific deliverables or have other special requirements or terms. Treating a contract or grant as a “gift” creates legal liability and funding risks for the University, as well as the potential for personal liability for involved faculty and staff.

Processes (applicable to gifts received by UMD and by the UMD College Park Foundation):

  • All research-related gifts must be submitted in the Kuali Build’s (KB) Research Gifts Routing module. Information provided will be reviewed, and a determination will be made as to whether the funds are considered a gift or a grant. Questions: giftvsgrant@umd.edu
  • Research-related gifts that specifically name a researcher(s) must be disclosed for COI review.
  • The Gift FAQ section on the COI Website provides information required to be disclosed via inTERP prior to gift acceptance, as well as who is required to disclose. Questions: inTERP@umd.edu
  • Additional review processes may be required depending on the type of gift received.
  • All research-related gifts must also be disclosed in U.S. federal research proposals. Policies vary by agency, but we have provided a general summary below. Questions: rto@umd.edu
  • Gifts designated for a specific project should be disclosed in Current and Pending forms.
  • Gifts supporting general research should be disclosed in biographical sketches.
  • Some agencies require disclosures of all foreign sources of support, including “in-kind support” where no exchange of funding is involved. 

Important reminder: University employees are also State employees and subject to Maryland Public Ethics Law (MPEL; Maryland Code Annotated General Provisions Article, Title 5) that generally restricts the interests and relationships a University employee may have with any external entity that does business—or seeks to do business—with the University. MPEL provides a limited exemption (the “research carve-out”) to the prohibition on these relationships if, and only if, they (1) relate to research and development and (2) are fully and accurately disclosed and managed pursuant to the University’s COI/COC policies and procedures. Please contact the University’s Office of General Counsel with questions about MPEL. 

We appreciate your efforts to bring in gifts and other funding to support the University’s research enterprise while remaining compliant with Federal and State laws, regulations, and procedures. We are most grateful to all our faculty and staff who support and advance the University’s research mission.

Sincerely,

Gregory F. Ball

Vice President for Research 

June 16, 2025

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