Research Policy Analysis and Coordination
Sponsor Code Attributes
In addition to sponsor categories/types, certain attributes are applied to sponsor codes to better identify certain classes of entities across categories.
- Disregarded Entity
- Entity of Concern - Contact Export Control Officer
- Contract Research Organization
- Agricultural Entity
- DOE National Laboratories
- Do Not Use This Sponsor
Disregarded entities are Single-Member Limited Liability Companies (LLC) which:
- do not have their own IRS tax-exempt determination and do not file their own Form 990s or other federal tax returns;
- are wholly owned by a single parent entity which does have IRS tax-exempt determination;
- have their income and expenses included on the parent entity's Form 990; and
- are specifically identified on Part I of Schedule R (pdf) on the parent entity's Form 990 as treated for federal tax purposes as part of the parent entity.
Although disregarded entities lack their own independent tax-exempt determinations, UC campuses/locations may treat these entities as non-profit organizations.
- This attribute will only be visible when a parent sponsor has been identified.
- When submitting a new sponsor code request for a disregarded entity, please submit a copy of the parent sponsor's most recent Form 990 identifying the sponsor as a disregarded entity with your request. Typically this is included on Part I of Schedule R.
RPAC staff perform Visual Compliance Restricted Party Screenings on all new foreign sponsors. All results are forwarded to UCOP's Office of Ethics, Compliance and Audit Services (ECAS) for review. In the event that ECAS determines that sanctions or restrictions exist which may impact UC's ability to engage with the entity, this attribute will be checked.
If this attribute is checked, please contact your campus/location's Export Control Officer before proceeding to make further determinations regarding any sanctions/restrictions that may impact the proposed activities.
See's UC Export Control Policy (pdf) for further information.
The Contract Research Organization (CRO) attribute is used to identify entities that provide support to UC or other outside organizations in the form of research services outsourced on a contract basis.
The Agricultural Entity indicator includes entities subject to UC’s practice, as clarified in President Napolitano’s August 2019 letter (pdf), regarding collection of indirect costs from agricultural commodity groups. Although these entities are typically assigned to Sponsor Category 12, this funding may also be provided by internal California Department of Food and Agriculture programs (Sponsor Category 02) funded by grower assessment or fees on agricultural products, and by non-profit associations (Sponsor Category 05 or 07) and other types of entities.
This attribute allows better identification of these entities across sponsor categories.
This attribute identifies organizations that operate/manage Department of Energy (DOE) National Laboratories. Because the operating entities include higher education institutions (including UC), non-profit organizations, for-profit corporations, and the DOE itself, this attribute facilitates identification of DOE National Laboratories across sponsor categories.
This attribute identifies codes that should be discontinued and that will be deactivated once funding is no longer associated with that code. This attribute may be checked when, for example:
- Duplicate sponsor codes were created inadvertently for the same entity
- Two sponsors have merged into a single entity
- The entity no longer exists, e.g., a company has dissolved or a government office/organization closed
If this attribute is marked, please see the Comment field in the sponsor code entry for further instruction, including any codes that should be used instead.