Integrated CSU Administrative Manual



Section 15000 Policies

Policy Number:  15401.00

Policy Title: Fundraising - Matching Gifts

Policy Effective Date: March 1, 2012

Last Revision Date: December 1, 2011
(see revision history)


It is the policy of the California State University (CSU) to accept matching gifts in compliance with eligibility requirements. Matching gift programs issue conditional gifts to fulfill certain purposes. By completing an appropriate matching gift claim, the recipient organization acknowledges that it understands the conditions of the program and to the - best if its knowledge the request submitted fulfills those conditions. Each campus is required to develop written procedures, consistent with this policy.



100      PURPOSE

The purpose of this policy is to establish proper internal controls for the acceptance of matching gifts, which includes a dual review process.  It is guided by industry best practices published by the Council for Advancement and Support of Education. 

200      SCOPE

This policy governs matching gift acceptance by the university and its auxiliaries.

300      AUTHORITY

Authority to this policy is pursuant to Education Code section 89720.  This policy is issued under delegation of authority from the Chancellor to the Vice Chancellor, University Relations and Advancement, and implementation and compliance with the policy is further delegated to the campus chief advancement officer.  California Education Code 89035.


401      Approving Authority - a person to whom authority has been delegated in writing to verify and certify matching gifts solicitations. This approving function shall be segregated from the record keeping function which, among other duties, ensures matching gifts are designated in accordance with donor intent.

402      Recipient Organization - the entity receiving both the initial gift establishing eligibility for a matching gift program and the conditional gift distributed by the matching gift program.  Though it is customary for CSU gifts to be accepted by an authorized auxiliary organization, the recipient organization may be the university.

403      Matching Gift Claim – the certification form, either paper or electronic, submitted to the matching gift program acknowledging the receipt of an eligible donor gift and certifying the charitable status of the recipient organization.


501      Board Responsibility
The governing board of the recipient organization should ensure that internal controls of gifts are sufficient to protect the assets and reputation of the CSU.

502      Chief Executive’s Responsibility
The chief executive officer of the recipient organization should establish the administrative structure and general procedures to achieve appropriate internal controls.

503      Approving Authority Responsibilities
Where the recipient organization is expected to act on a donor contribution and submit a claim or application, this staff member should:

  1. Review and verify all donor contributions for which matching gifts are to be requested to ensure that the gift conforms to the guidelines for donations to the recipient organization and the relevant matching gift program; any apparent questions should be resolved by appropriate inquiries before a matching gift is requested.  Specifically, the approving authority should review any restrictions related to personal benefit provided to the donor; e.g., athletics tickets.
  2. Sign and transmit all matching gift requests, thereby certifying review of eligible donor gifts.
  3. Submit to the record keeper documentation of matching gift claims and evidence of eligibility review.
  4. Be available for questions concerning transactions, and communicate with the donor and matching gift program as appropriate in confirming transactions.
  5. Review gift record on at least an annual basis to determine whether follow-up action is required, whether the claim should be recorded as uncollectable and whether received matching gifts were properly assigned.

504      Record Keeping Responsibilities
Record keeping responsibilities may be assigned to one or more staff members and should include:

  1. Maintaining records of donor contributions and matching gifts in such a manner that there is a clear record of the individual contribution, the related matching gift claim, and compliance with the matching gift program.
  2. Maintaining a record documenting that the matching gift purpose mirrors the purpose of the original donor gift and is consistent with representations to the matching gift program.  In rare exceptions, the donor (or the matching gift program) may request in writing that the matching gift to be used for a purpose that differs from the donor’s gift to be matched.  This is allowable, so long as the requested purpose is consistent with the matching gift program restrictions.

505      Documentation
To substantiate the dual review process, 1) the record keeper may countersign the claim certification, 2) the approving authority and record keeper may both sign an affirmation or 3) the process may be automated in a secure database that tracks the actions of both the approving authority and record keeper.


Matching gift claims should not be treated as pledge receivables.  Matching gifts are accounted for when received.


Garrett P. Ashley
Vice Chancellor, University Relations and Advancement

Approved: December 1, 2011







Useful Guidelines:


Related Principles:


Sound Business Practices:


Laws, State Codes, Regulations and Mandates:



CO Manager:

Ms. Lori A. Redfearn
Assistant Vice Chancellor, Advancement Services
CSU Office of the Chancellor

Subject Expert:

Ms. Lori A. Redfearn
Assistant Vice Chancellor, Advancement Services
CSU Office of the Chancellor


Affinity Group: