Responsible Official: University Controller
Responsible Office: Controller’s Office
Effective Date: July 1, 1998
Revision Date: April 1, 2026
Policy Sections
3303.1 General Principles for Gifts from University Funds
3303.2 Expressions of Sympathy
3303.3 Community Member Recognition and Staff Service Milestones
3303.4 Employee Retirement or Departure
3303.5 Gifts from University Funds to Third Parties
3303.6 Gifts to Foreign and Domestic Public Officials
3303.8 Tax Reporting and Withholding
Scope
This policy details the circumstances in which University funds may be used toward the purchase of gifts. This policy also describes when gifts must be reported for tax purposes and outlines the appropriate application of charging instructions.
This policy does not cover gifts given to the University (covered in Policy 2200 Gifts to the University) or gifts from external parties to employees (covered in Policy 2201 Gifts from External Parties to Employees).
Policy Statement
This policy recognizes that, in certain circumstances, the University’s missions of teaching and research, and its public service initiatives, may be advanced through the giving of a gift using University funds. As such, University funds may be used to provide gifts only as explicitly permitted by the sections of this policy.
Reason for the Policy
Federal law, regulations, and principles of responsible stewardship of University resources limit how Yale assets may be used to make gifts to individuals or other organizations. This policy describes the limited instances in which a gift may be appropriate and the restrictions applicable to such gifts. In addition, this policy supports proper accounting treatment in the limited instances where such gifts are allowable.
Definitions
Cash Equivalent
A gift that is considered the same as cash (e.g., gift cards, gift certificates).
Community Member
Yale University faculty, emeritus faculty, staff, students, visiting scholars, or trainees.
Immediate Family Member
With respect to a Yale Community Member, “Immediate Family Member” includes the following:
- spouse or domestic partner; or
- child or child of spouse or domestic partner; or
- sibling or sibling of spouse or domestic partner; or
- parent or parent of spouse or domestic partner; or
- grandparent or grandparent of spouse or domestic partner; or
- grandchild or grandchild of spouse or domestic partner;
- or person in an equivalent relationship to any of the above.
Non-Cash Gift(s)
Tangible good(s) that can be distributed to allowable parties in recognition of the eligible gift scenarios defined in this Policy. Note: Gift cards and gift certificates are considered Cash Equivalents and not Non-Cash Gifts.
Public Official
An individual associated with federal, state, local, tribal, or foreign governments.
Third Party
An entity or individual legally distinct from Yale University. Note: Third Parties include even affiliated entities with close ties to Yale University, such as Yale New Haven Health System (“YNHHS”).
Policy Sections
3303.1 General Principles for Gifts from University Funds
University funds may be used to provide gifts only as explicitly permitted by the sections of this policy. Any other proposed gifts from University funds must be approved in accordance with Special Situations & Exceptions, below.
Unless otherwise explicitly provided, gifts consisting of cash or Cash Equivalents are not permitted. Cash Equivalents include, but are not limited to, all gift cards and gift certificates.
University accounts must not be used to collect contributions either to, or on behalf of, the University for the benefit of Third Parties or other individuals, including employees.
Any gifts purchased with University funds must be properly recorded according to the University’s Chart of Accounts (“COA”).
3303.2 Expressions of Sympathy
University funds, up to a value not to exceed $100, may be used toward the purchase of Non-Cash expressions of sympathy or support (e.g., flowers) when a Community Member or their Immediate Family Member experiences circumstances in which such expressions of sympathy or support are customary, including serious illness, hospitalization, or death.
Note: University funds, up to a value not to exceed $100, may be used toward a cash donation, in lieu of flowers or other expression of sympathy or support, to registered 501(c)(3) organizations in the name of a deceased Community Member or their Immediate Family Member.
3303.3 Community Member Recognition and Staff Service Milestones
A. Community Member Special Recognition
University funds, up to a value not to exceed $100, may be used toward the occasional purchase of Non-Cash expressions of congratulations or recognition for Community Members for special work-related contributions or accomplishments.
University funds must not be used to purchase gifts for any individual in recognition of personal events or holidays. Examples of unallowable occasions for recognition include, but are not limited to:
- birthdays;
- weddings or wedding showers;
- birth or arrival of a child or baby showers;
- housewarmings;
- Administrative Professionals’ Day;
- civic or religious holidays.
Note: Certain gifts are subject to tax reporting and withholding. Refer to Section 3303.8 for details on reporting and tax withholding.
B. Staff Service Recognition Program for Milestones
The Staff Service Recognition Program is the University-supported program to celebrate staff service milestones. As part of this program, staff are recognized as follows:
| Years of Service | Certificate of Appreciation | Milestone Recognition Portal Gift | Long Service Recognition Dinner, Video & Yearbook |
|---|---|---|---|
| 5 | X | ||
| 10, 15, 20 | X | X | |
| 25 + | X | X | X |
Beginning with the 10-year service milestone, and at each subsequent 5-year milestone, staff are eligible to select a gift of value proportionate to their years of service, as determined by the Department of Human Resources.
Milestone gifts must be selected from the Milestone Recognition Portal, with gift-ordering instructions provided at the time of eligibility. University funds must not be used for any additional milestone gifts.
3303.4 Employee Retirement or Departure
A. Retirement or Departure from Yale of Employee with 10+ Years of Service
University funds, up to a value not to exceed $400, may be used toward the purchase of a Non-Cash Gift in recognition of the retirement or departure from Yale of a long-standing University employee with at least 10 cumulative years of service.
B. Retirement or Departure from Yale of Employee with Fewer than 10 Years of Service
University funds, up to a value not to exceed $100, may be used toward the purchase of a Non-Cash Gift in recognition of the retirement or departure from Yale of an employee with fewer than 10 years of service.
3303.5 Gifts from University Funds to Third Parties
Except for the specific situations described in this section, University funds must not be used to provide gifts to Third Parties.
A. Contributions to Other Organizations
University funds may be used, in certain circumstances, toward contributions and gifts of nominal value made to other organizations, provided there is a justifiable business purpose serving the University’s objectives. In general, organizations to which contributions may be permitted are 501(c)(3) entities. In every such instance, these contributions require prior approval by the Controller’s Office in consultation with the Provost’s Office or the Office of General Counsel (“OGC”), as appropriate (with the limited exception of cash donations in lieu of expressions of sympathy, as described in Section 3303.2, above).
B. Development and Alumni Relations Gifts
University funds, up to a value not to exceed $100, may be used toward the purchase of a Non-Cash Gift for Third Party donors or other individuals serving development interests, or for alumni relations purposes.
C. Institutional Gifts
University funds, up to a value not to exceed $100, may be used toward the purchase of a Non-Cash Gift as a sign of institutional appreciation or gratitude under the following circumstances:
- When University officials are hosted by Third Parties, who are not Public Officials, while visiting another institution: or
- When University officials are hosting Third Party visitors, who are not Public Officials, from another institution.
3303.6 Gifts to Foreign and Domestic Public Officials
Federal, state, and other laws may severely restrict the nature and value of gifts that may be made to Public Officials, and those restrictions may vary depending on the type of gift, as well as the office held by the Public Official. Yale’s Office of Federal and State Relations (“OFSR”) maintains guidance regarding major laws and regulations.
Note: There may also be restrictions on paying honoraria to Public Officials. Refer to Policy 3210.4 Guest Speaker Contracts, Artists and Performers, and Honoraria for additional information.
Questions regarding Section 3303.6 should be directed to OGC at general.counsel@yale.edu.
A. Gifts to Domestic Public Officials
In general, University policy prohibits all gifts from University funds to domestic Public Officials with the exception of token gifts valued at less than $10. Any exception to this limit should be discussed in advance with OFSR, in consultation with OGC, in order to make certain of its allowability under the specific governing conditions. Any gift from University funds made in connection with a lobbying effort must be reported to OFSR.
B. Gifts to Foreign Public Officials
Gifts to foreign Public Officials may be subject to the Foreign Corrupt Practices Act or other laws and regulations. OGC maintains guidance on anti-bribery laws within Yale’s International Toolkit webpage. Any gift from University funds made to a foreign Public Official must be discussed in advance with OGC (general.counsel@yale.edu).
3303.7 Specific Restrictions
Sponsored Awards, Provostial Research Funds, and Restricted Gift and Endowment Income have the following restrictions as detailed below:
A. Sponsored Awards
Expenses incurred in connection with gifts from University funds, including expressions of sympathy or recognition, should not, generally, be charged to sponsored awards (unless explicitly permitted by the award agreement and verified in advance by Sponsored Projects Financial Administration (“SPFA”)). Department Lead Administrators and Operations Managers are responsible for ensuring that sponsored awards in any of their organizations are used in a manner consistent with the terms and conditions of the award. For guidance on the proper use of sponsored awards, please contact Sponsored Projects Financial Administration (“SPFA”) via the SPFA Intake Portal.
B. Provostial Research Funds
Expenses incurred in connection with gifts from University funds, including expressions of sympathy or recognition, should not, generally, be charged to research funds awarded by the Office of the Provost. Department Lead Administrators and Operations Managers are responsible for ensuring that research funds in any of their organizations are used in a manner consistent with the Appropriate Use of University Research Funds. For guidance on the proper use of research funds, please contact the Provost’s Office.
C. Restricted Gift and Endowment Income
Expenses incurred in connection with gifts from University funds, including expressions of sympathy or recognition, should not, generally, be charged to restricted gift and endowment income accounts. Department Lead Administrators and Operations Managers are responsible for ensuring that restricted funds owned by any of their organizations are used in a manner consistent with the stated intentions of the donor. For guidance on the proper use of income associated with specific restricted funds, please contact Gift Accounting at giftawards@yale.edu.
3303.8 Tax Reporting and Withholding
The Internal Revenue Service (“IRS”) requires the University to report the cash value of certain gifts, depending on the value, type, and recipient of the gift. In general, the gifts explicitly permitted under this policy are not required to be reported for tax purposes. In certain scenarios, such as when gifts are permitted as part of an approved exception to this policy, gifts may be required to be reported for tax purposes. The following summarizes when gifts must be reported for tax purposes:
- Non-Cash Gifts exceeding the allowable amounts described in the sections of this policy (if allowed as part of an approved exception); and
- Cash or Cash Equivalents of all amounts (if allowed as part of an approved exception).
Gifts to employees, if reportable for tax purposes, must be reported to the University Payroll Department (employee.services@yale.edu) for proper tax withholding and reporting. Gifts to non-employees, if reportable for tax purposes, must be reported to Accounts Payable (askfinance@yale.edu) for proper tax withholding and reporting.
Special Situations & Exceptions
Exceptions to this policy must be approved by the Controller’s Office, in consultation with the Provost’s Office, OGC, the Office of Development, or an Officer of the Corporation, as appropriate.
Roles & Responsibilities
Controller’s Office
- Interpretation of this policy.
- Reviews and rules upon requests for exceptions to this policy, in consultation with the Provost’s Office, OGC, the Office of Development, or an Officer of the Corporation, as appropriate.
Department of Human Resources
- Determines, obtains, and distributes University gifts for employee milestones.
Lead Administrators (or designee)
- Establish protocols to familiarize departmental personnel with this policy.
- Establish protocols for the appropriate departmental review and approval of gifts providing from University funds.
- Establish protocols for the proper coding of all gifts given by their department(s).
Yale Office of Federal and State Relations (“OFSR”)
- Advise on gifts made to Public Officials in consultation with OGC.
Office of General Counsel (“OGC”)
- Advise on proposed gifts and donations.
- Upon consultation from the Controller’s Office, considers and rules on proposed gifts serving development or alumni relations interests.
Office of Development
- Upon consultation from the Controller’s Office, considers and rules on proposed gifts serving development or alumni relations interests.
Related Resources
Policy 2200 Gifts to the University
Policy 2201 Gifts from External Parties to Employees
Policy 3210.4 Guest Speaker Contracts, Artists and Performers, and Honoraria
Policy 3302 Business Meals, Entertainment, and Other Social Events