Restricted Fund Spending Compliance

Policy Statement

All Harvard University schools and units are required to establish sound procedures to manage spending on donor restricted funds to comply with terms and conditions. This policy establishes key controls that each school must include in its local procedures.

Reason for Policy

The University has a stewardship obligation to ensure that restricted funds are spent in accordance with donor terms.

Who Must Comply

All Harvard University schools, tubs, local units, Affiliate Institutions, Allied Institutions and University-wide Initiatives must comply.


  1. Certify in writing annually for existing funds. Every year, all Harvard University schools/units will require staff who spend against donor-restricted funds (or managers who oversee such staff) to certify in writing that they are familiar with and will abide by spending terms on those funds.

  2. Define the format of certification.
    1. Due to differences in school size, operations, and number of restricted funds, the form of this certification, the time of year that it is completed, and the organizational level at which it is completed may vary by school.
    2. See Appendix B, Sample Annual Restricted Fund Certification template.

  3. Certify in writing for new funds and changes in fund terms. Managers and/or staff who spend against donor-restricted funds must make the same certification upon creation of a new restricted fund or upon a change of spending terms on an existing restricted fund.

  4. Monitor charges to restricted funds. Schools are required to periodically monitor charges against restricted funds to test that those expenditures are in accordance with terms.

    1. Monitoring at schools with a decentralized approval model must include both analytical review and transaction sampling; see Appendix A.

    2. Monitoring at schools with a centralized approval model must include analytical review; transaction sampling is not required if the central approval process includes review of fund terms. However, transaction sampling must be included in a school’s monitoring program if there are gaps in the centralized approval structure, including but not limited to:
    1. Central approval does not include review of fund terms.
    2. Central approval excludes certain departments, centers or PIs.
    3. Central approval is required only above a dollar threshold.

  • Receive updated fund terms annually. To ensure that administrators have access to fund terms, each June the Recording Secretary’s Office will distribute copies of terms on restricted funds to each school or unit that holds these funds.

  • Responsibilities and Contacts

    Tub financial deans or equivalent tub financial officers are responsible for ensuring that local units abide by this policy and the accompanying procedures.

    Office of the Controller (OC), within Financial Administration, is responsible for maintaining the University’s Restricted Fund Spending Compliance policy. Tub finance offices may contact OC with questions regarding this policy. Contact (617) 495-8032

    Recording Secretary’s Office (RSO) provides copies of fund terms to tubs and also advises tubs on interpretation of donor terms. Contact: (617) 495-1750

    Risk Management and Audit Services is responsible for periodically auditing tub compliance with this policy. Contact:


    Restricted fund: a voluntary donation (either for current use or endowment) that requires funds to be used for a specific purpose; includes construction funds.

    Revision History

    6/30/2013: added more detailed required monitoring procedures; added sample Annual Attestation Form; and updated format.


    Appendix A: Monitoring Procedures for Restricted Funds
    Appendix B: Sample Annual Attestation Form (.docx)


    See also: Policy, Accounting