University of Colorado Denver _________________________________________________________________________ Title: Student Organizations Source: Prepared by: Approved by: Effective Date: Replaces: February 13, 2004 Applies: All campuses ______________________________________________________________________ A. Introduction 1. Purpose The purpose of this policy is to set forth the fiscal oversight rules for student organizations conducting activities on a University of Colorado Denver (UCD) campus or associating with the university in any manner. 2. Reference a. State of Colorado Fiscal Rule 2-1 b. Administrative Policy Statement – Fiscal Roles and Responsibilities. c. Administrative Policy Statement – Propriety of Expenses. d. UCD Fiscal Policy – Use of UCD Campus Facilities e. Administrative Policy Statement – Bank Accounts and Investments. f. Administrative Policy Statement – Donations. g. Auraria Higher Education Center – Campus Policies. Student Organizations University of Colorado Denver Fiscal Policy Page 1 3. Responsibility At the Downtown Campus (DC), it is the responsibility of the Director of Student Life and student organization advisors to ensure compliance with this policy. At the Anschutz Medical Campus (AMC), it is the responsibility of the Director of the Student Assistance Office (on behalf of interdisciplinary student organizations), school student affairs officials (on behalf of school-specific student organizations), and student organization advisors to ensure compliance with this policy. B. Table of Contents A. Introduction 1. Purpose 2. Reference Page(s) 1 1 1 3. Responsibility 2 B. Table of Contents 2 C. Applicability and Definitions 2 D. Policy 1. General 2. Coordination of Overlapping Activities 3. Student Organization Approval and Oversight 4. Depositing Monies generated by Student Organizations 5. Use of the university’s procurement, travel office, payroll and personnel systems 6. Use of university’s name, trademark, IRS Tax–Exemption Status 7. Fundraising 8. Donations 9. Awards 10. Alcohol 11. Use of Facilities 12. Legal Liability E. Procedures 4 4 4 5 5 5 6 6 6 7 7 7 7 C. Applicability and Definitions 1. Applicability This policy applies to all student organizations, with or without university affiliation, that conduct activities at UCD. 2. Definitions Student Organizations University of Colorado Denver Fiscal Policy Page 2 a. Affiliated Student Organizations are permitted to use the university’s name, trademark, IRS tax-exemption or governmental status, following established university policies. At DC, the Office of Student Life has recognized them. At AMC, they have been recognized by the Student Senate (if they are interdisciplinary) or a school’s administration (if a student council) or by a school student council (if they are school or program-specific). Recognized organizations have a constitution or bylaws and a student organization advisor, who accepts responsibility for the organization’s compliance with state, university and UCD campus rules and regulations. At DDC, affiliated student organizations also have affiliation agreements approved by the Office of Student Life, and they also must comply with Auraria Higher Education Center (AHEC) campus rules and regulations. At AMC, affiliated student organizations also have affiliation agreements approved by the campus Director of the Student Assistance Office (if they are interdisciplinary) or school directors of student affairs (if they are school-specific). Affiliated student organizations have access to the university’s purchasing, travel office, payroll and personnel system. Affiliated student organizations manage their funds through the university accounting system and may not establish separate checking accounts at any outside banking institutions or credit unions. b. Associated Student Organizations are local chapters of national organizations that have a presence on campus and have been formally recognized by the Student Senate (if interdisciplinary) or the student council of the respective School. Student organizations must be able to use the taxpayer identification (FEIN) of the national student organization or become a legal entity in their own right with their own taxpayer identification (FEIN) to use on their external bank account to be classified as associated, else they must become affiliated. The student organization advisor is responsible for monitoring the activities of the associated student organization and for ensuring compliance with policies related to conducting activities on campus. Associated student organizations are allowed to use meeting rooms in University-owned buildings without charge as long as the usage is nominal and does not conflict with regular university business or student classes. Associated student organizations do not have access to the university’s purchasing, travel office, payroll and personnel system. Any funds collected by associated student organizations may not be deposited to a university account. Associated student organizations may not use the university’s name, IRS tax-exemption, taxpayer identification (FEIN), or governmental status. c. Independent Student Organizations are any student organizations that are neither Affiliated nor Associated. They are fully responsible for their own activities. Independent student organizations must comply with university policies and procedures in scheduling and conducting activities on campus. These groups do not have access to the university’s purchasing, travel office, payroll and personnel system. Any funds collected by an independent student organization may not be deposited to a university account. Independent student organizations may not use the university’s name, IRS tax-exemption, taxpayer identification (FEIN), or governmental status. Usage of university facilities is to subject to a rental charge (see UCD Fiscal Policy 2-4 “Use of Facilities and Equipment by Outside Parties or for Student Organizations University of Colorado Denver Fiscal Policy Page 3 Private Gain”). Independent student organizations may not associate themselves to the university in any manner. d. Bylaws or Constitution: a formalized set of rules adopted by a student organization governing its meetings and affairs. e. Student Organization Advisor: a UCD employee (faculty or staff) assigned to the student organization to provide oversight and guidance and to ensure compliance with state, university, and campus rules and regulations. Advisors must regularly participate in their organization’s plans and activities, including after-hours events, and must maintain direct knowledge of their organization’s finances. Some student organization advisor duties may be delegated to other employees, but overall responsibility of student organization activities remains with the advisor. Advisors must be present during activities, which include the serving of alcohol, unless the activity is within a venue with its own liquor license. No alcohol may be served at any downtown Denver student organization event with the exception of special fund raising events. f. Student: includes any individual who is registered or enrolled in an academic program at UCD. Some student organizations may require full-time status or even degree seeking status within a particular program or on a specific campus for students wishing to participate within the respective organization. g. Student Organization: Students organizing in groups and conducting activities related to the educational and social experience at UCD. Students may form, associate with, or disband any student organization as affiliated, associated, or independent student organizations. D. Policy 1. General Recognizing the value of student organizations to the mission of the university, UCD may provide assistance to student organizations in conducting their activities. The level of assistance varies depending on the relationship of the student organization with UCD. The formal relationship is dependent on the interest of the organization and its mutual agreement for carrying out functions on behalf of the institution. Because student organizations differ in their interest and ability to conduct activities on behalf of UCD, the relationship of student organizations varies by type. The recognized relationship types are affiliated, associated, and independent. Affiliated student organizations shall adhere to policies and procedures for official recognition, including non-discrimination in determining their membership. UCD will deny recognition to groups who advocate inciting or producing lawless action, who engage in unlawful activity or conduct, or who fail to comply with state, university, or campus rules and regulations. 2. Coordination of Overlapping Activities Student Organizations University of Colorado Denver Fiscal Policy Page 4 Student organizations may undertake activities that touch on or overlap with program areas the chancellor has vested in certain offices within the UCD organization. Without close coordination between the student organization and the program director charged with the responsibility for such an activity, there is potential for unnecessary duplication and potential conflict.1 Therefore, it is critical for student organization advisors, the DC Office of Student Life, the AMC Director of the Student Assistance Office, and each AMC school’s student affairs officials to work with student organizations wishing to undertake activities that are similar to or overlap with existing program areas within the campus. In such instances, the student organization’s advisor and officers from the student organization should meet with the director of the program in question to collaborate and work through any issues, including duplication of effort or potential conflicts. The program director in question has the final authority to approve or deny the activities which will affect his/her respective program responsibility. Any conflicts which arise in this area will be referred to the appropriate school or college dean or vice-chancellor for final resolution depending upon the school or campus-specific program in question. 3. Student Organization Approval and Oversight a. Any student organization wishing to have a designation of “Affiliated” status must submit a registration form annually to the Student Assistance Office at AMC or each semester to the Office of Student Life at DC. The form must identify the student organization advisor, who has agreed to participate actively in the organization’s affairs and take responsibility for compliance of the group’s activities with respect to state, university, and campus rules and regulations. It also documents by signature the responsibilities agreed to by the student organization advisor and student organization’s president as an affiliated student organization. The request must include a copy of the organization’s bylaws or constitution. If it is not explicitly stated in the organization’s bylaws or constitution, a written statement outlining the scope of current and planned activities for the organization must be attached to the registration form. For AMC, all registration materials will be reviewed and copies forwarded to the Student Senate (for interdisciplinary organizations) or school-specific student councils for further review and proposed recognition. Final approval of these agreements at DC rests with the Office of Student Life, and at AMC it rests with the Director of the Student Assistance Office (for interdisciplinary organizations) and the school directors of student affairs (for school-specific organizations). b. Associated student organizations are required to submit a registration form annually to Student Assistance Office at AMC or each semester to the Office of Student Life at DC. The registration material is used for informational purposes only and allows the Student Assistance Office at AMC and the Student Life Office at DC to be aware of new associated student organizations on campus so they can be advised of the policies 1 For example, as one of its service activities, a student organization may wish to provide students at the campus information on UCD Financial Aid opportunities and various scholarships that may be available for students pursuing health professions. This activity is already vested in the campus Student Financial Aid Office. The web and many private, profession-oriented and federal sites contain general financial aid and scholarship information that a student group might want to share with students that would not necessarily be duplicative of the UCD Financial Aid Office’s mission. Student Organizations University of Colorado Denver Fiscal Policy Page 5 that pertain to the student group, such as, facilities usage policies and the student organizations policy. Since associated student organizations do not have funds on the university’s books, no university employee has fiscal oversight responsibilities over them. c. All approved registration forms for AMC will be kept on file in the office of the Director of the Student Assistance Office, and for DC they will be kept on file in the Office of Student Life. 4. Depositing Monies Generated by Student Organizations Funds collected by affiliated student organizations shall be deposited into one or more university accounts in accordance with campus policies. Funds will be deposited and managed at AMC by the Student Assistance Office (for interdisciplinary student organizations) or the student organization advisor (for school/program specific student organizations) and at DC by the Office of Student Life. Affiliated student organizations may not deposit monies into an outside bank account. Associated and independent student organizations are not permitted to deposit funds with the university and may not use the university’s taxpayer identification (FEIN) on external bank accounts. 5. Use of the University’s Procurement, Travel Office, Payroll and Personnel Systems Affiliated student organizations will have access to the university’s procurement, travel office, payroll and personnel systems at AMC through their fiscal oversight staff and at DC through the Office of Student Life. Access to these services is to be in compliance with the related state, university and campus policies, rules and regulations regarding procurement and propriety of expenditures. The student organization advisor is responsible for ensuring compliance with these related policies. Associated and independent student organizations are not allowed to use the university’s procurement, travel office, payroll and personnel systems. 6. Use of University’s Name, Trademark, IRS Tax –Exemption Status Affiliated student organizations are allowed to use the university’s name, CU logo, trademark, letterhead, taxpayer identification (FEIN), tax exempt, and governmental status. Associated student organizations must obtain prior approval from the Director of University Licensing to use the CU logo or trademark. Associated student organizations may not hold themselves out to the public as affiliated student organizations, nor are they allowed to use the university’s letterhead, taxpayer identification (FEIN), tax exempt, or governmental status. Independent student organizations are not allowed to hold themselves out to the public as being either affiliated or associated with UCD or any UCD college, school or program. Independent student organizations are not allowed to use the university’s logo, trademark, letterhead, taxpayer identification (FEIN), tax-exempt, or governmental status. Student Organizations University of Colorado Denver Fiscal Policy Page 6 7. Fundraising Fundraising consists of soliciting and collecting gift revenue for the organization. A fundraising special event is an event sponsored by an organization for which any payment made to attend or sponsor or to purchase goods or services at the event is composed of an identifiable gift and non-gift component. Determining if the fundraising event meets the requirements of an immaterial fundraising event or material fundraising event. An immaterial fundraising event is a fundraising event that does not involve purchase of meals; sale of goods or services valued at more than $40 (individual item value); or receipt of monies equal to or greater than $250 from a single donor. A material fundraising event is any fundraising event that does not meet the definition of an immaterial fundraising event. The Office of University Controller has the authority to make the final ruling on whether a fundraising event is an immaterial fundraising event or material fundraising event. a. Immaterial Fundraising Event Sales of minimal-value goods, such as bake sales or tee-shirts, are considered regular sales, not fundraising events. Before conducting any regular sales activities, student organizations must obtain written approval from the Office of Student Life at DC or from the Director of the Student Assistance Office or the appropriate School’s student affairs official at AMC and sales tax must be collected on all proceeds. All proceeds from fundraising events held by affiliated student organizations must be deposited with the Office of Student Life at the DC or with the Director of the Student Assistance Office or the appropriate School’s student affairs official as soon as the activity is completed. b. Material Fundraising Event Special policies and procedures apply to fundraising special events. Responsibility for ensuring compliance with these policies and procedures for any fundraising efforts of affiliated student organizations shall rest with the student organization advisor. Before conducting a material fundraising activity, student organizations must obtain written approval from the Office of Student Life at DC or from the Director of the Student Assistance Office or the appropriate School’s student affairs official at AMC. All procedures outlined in the University of Colorado, Office of the University Controller, Finance Procedural Statement: Fundraising Events must be followed for material fundraising events. https://www.cu.edu/controller/documents/FPS-Fundraising-Events.pdf Affiliated student organizations are allowed to conduct fundraising activities on campus. All fundraising activities, including printed materials soliciting donations to benefit the student organization at DC must be reviewed and approved by the Office of Student Life, and at AMC they must be reviewed and approved by the Director of the Student Assistance Office (on behalf of interdisciplinary student organizations), School student affairs officials (on behalf of school-specific student organizations), and the student organization advisor. Student Organizations University of Colorado Denver Fiscal Policy Page 7 All procedures outlined in the University of Colorado, Office of the University Controller, Finance Procedural Statement: Fundraising Events must be followed for material fundraising events and supersedes any statements within this policy. https://www.cu.edu/controller/documents/FPS-FundraisingEvents.pdf Student organizations are prohibited from securing a raffle license as a fund raising activity. 8. Donations Affiliated student organizations may not donate university funds including monies generated from fundraising activities as a contribution or charitable gifts to any organization or make in-kind contributions to campaigns involving the nomination, retention, or election of any person to any public office, or to urge voters to vote in favor of or against a ballot initiative. The prohibition does not include donations to non profit organizations when (1) the donation is directly related to achieving the university's educational, research, or public service mission and (2) the donation has been approved in advance by the Vice Chancellor for Finance. See the Administrative Policy Statement “Donations”. 9. Awards Affiliated student organizations applying for financial assistance in the form of an award from external organizations such as foundations, community civic groups, or local businesses may do so using the related identifying information of the university (e.g. tax identification number, etc.). For successful awards, the check should be made payable to the “Regents of the University of Colorado” and deposited into the related student organization program in the general ledger. Award applications filed by an affiliated student organization need to be reviewed and approved prior to submittal by the student organization advisor at AMC or the Office of Student Life at DC. Associated and independent student organizations are not allowed to apply for awards or financial assistance using the university name or tax identification number. 10. Alcohol The purchase of alcohol by affiliated student organizations at AMC is prohibited. At the Downtown Campus, no student organization is permitted to purchase alcohol for use at an on campus event. As stated in the “Use of UCD Campus Facilities” policy, the consumption of alcohol on campus is prohibited except at approved events. 11. Use of Facilities Affiliated and associated student organizations may use university-owned meeting rooms without charge as long as the usage is nominal and does not conflict with regular university business or student classes. Use of Auraria facilities is subject to AHEC rules. Student Organizations University of Colorado Denver Fiscal Policy Page 8 Use of Auraria facilities by associated student organizations may require a damage deposit; contact the DC Office of Student Life for details. 12. Legal Liability As indicated in the Administrative Policy Statement “Fiscal Roles and Responsibilities,” the individuals involved in a transaction may be held personally liable for a transaction that is made in violation of policies, laws, regulations, and rules and contracts, grants and donor restrictions, regardless of when the approval occurred. Procedures for AMC http://www.uchsc.edu/studentassistance/orgs/index.htm Procedures for DC http://thunder1.cudenver.edu/studentorgs/recognitionguidelines.html Student Organizations University of Colorado Denver Fiscal Policy Page 9