Iowa Campus Compact received additional guidance from Volunteer Iowa regarding allowable member fundraising activities. The guidance does not expand existing CNCS policy, but does clarify how AmeriCorps members can fundraise.
ICAP members can fundraise for their specific projects so long as
Because fundraising is once again being reviewed so heavily by Volunteer Iowa staff, IACC will seek their guidance whenever fundraising is listed on a member’s position description or timesheet. We want to ensure that we have a firm understanding as to what is allowable and unallowable, especially in the cases of fundraising. We are doing this in order to avoid having to disallow member service hours, especially after the member has been exited.
We are including the following guidance to our position description guidelines. This guidance reinforces existing CNCS policy included in the host site and member agreements.
Fundraising (cash or in-kind) is generally not allowed
Take good care,
Justin
ICAP members can fundraise for their specific projects so long as
- They do not exceed the 10% limit in fundraising service hours
- The raised cash or in-kind funds directly support their project
- The raised cash or in-kind funds are not being directed to a general fund, including an organization other than their own.
Because fundraising is once again being reviewed so heavily by Volunteer Iowa staff, IACC will seek their guidance whenever fundraising is listed on a member’s position description or timesheet. We want to ensure that we have a firm understanding as to what is allowable and unallowable, especially in the cases of fundraising. We are doing this in order to avoid having to disallow member service hours, especially after the member has been exited.
We are including the following guidance to our position description guidelines. This guidance reinforces existing CNCS policy included in the host site and member agreements.
Fundraising (cash or in-kind) is generally not allowed
- Members cannot:
- Raise funds for their living allowance
- Raise funds for an organization’s operating expenses or endowment
- Write a grant application for funding provided by a federal agency including AmeriCorps VISTA, Summer VISTA associates, the Corporation for National and Community Service grant proposals, and AmeriCorps grants.
- Spend more than 10% of their service hours on fundraising activities.
- Fundraising activities might be allowable if:
- The activities raise cash or in-kind funds directly supporting the member’s specific service project.
Take good care,
Justin
Notes taken from phone call.
Where did this concern come from?
CNCS has an increased their scrutiny about certain member activities. They are increasingly interested in the area of fundraising.
What is the existing policy?
FUNDRAISING. 45 CFR§§ 2520.40 AmeriCorps members may raise resources directly in support of your program's service activities. Examples of fundraising activities AmeriCorps members may perform include, but are not limited to, the following:
1.Seeking donations of books from companies and individuals for a program in which volunteers teach children to read;
2.Writing a grant proposal to a foundation to secure resources to support the training of volunteers;
3.Securing supplies and equipment from the community to enable volunteers to help build houses for low-income individuals;
4.Seeking donations of books from companies and individuals for a program in which volunteers teach children to read;
5.Securing financial resources from the community to assist in launching or expanding a program that provides social services to the members of the community and is delivered, in whole or in part, through the members of a community-based organization;
6.Seeking donations from alumni of the program for specific service projects being performed by current members.
FUNDRAISING LIMITATIONS. An AmeriCorps Member may spend no more than ten percent of his or her originally agreed-upon term of service, as reflected in the member enrollment in the National Service Trust, performing fundraising activities.
AmeriCorps members may not:
45 CFR§§ 2520.45 An AmeriCorps member may spend no more than ten percent of his or her originally agreed-upon term of service, as reflected in the member enrollment in the National Service Trust, performing fundraising activities. The grantee mush ensure that it does not exceed the limitation on member service hours spent in education and training set forth in 45 CFR§§ 2520.50.
What are some examples of allowable fundraising?
What is the new guidance?
Members can only raise funds for their service site. But, their service project cannot be focused on fundraising, or leveraging volunteers to raise funds. Some examples are members serving at a thrift store or other revenue generating program for the nonprofit.
Volunteer Iowa gave the example of a member serving with the Leukemia Lymphoma Society who coordinates a Relay for Life fundraiser. This is unallowable because the member is not serving at Relay for Life, the funds are going to a general fund, and the member’s fundraising hours would exceed 10%.
When might a member be able to serve at organizations like a thrift store?
A member can serve at a thrift store if their capacity building project is focused on something other than fundraising. Such as, developing a job training program for the employees.
How do the fundraising limitations apply to recruiting volunteers?
A member’s primary focus cannot be to recruit volunteers for an unallowable activity, this includes fundraising. A member can generally recruit volunteers for an organization. Some volunteers may be placed in positions that fundraise, but the member’s duties are dedicated to recruiting volunteers who will serve in many types of positions.
Where did this concern come from?
CNCS has an increased their scrutiny about certain member activities. They are increasingly interested in the area of fundraising.
What is the existing policy?
FUNDRAISING. 45 CFR§§ 2520.40 AmeriCorps members may raise resources directly in support of your program's service activities. Examples of fundraising activities AmeriCorps members may perform include, but are not limited to, the following:
1.Seeking donations of books from companies and individuals for a program in which volunteers teach children to read;
2.Writing a grant proposal to a foundation to secure resources to support the training of volunteers;
3.Securing supplies and equipment from the community to enable volunteers to help build houses for low-income individuals;
4.Seeking donations of books from companies and individuals for a program in which volunteers teach children to read;
5.Securing financial resources from the community to assist in launching or expanding a program that provides social services to the members of the community and is delivered, in whole or in part, through the members of a community-based organization;
6.Seeking donations from alumni of the program for specific service projects being performed by current members.
FUNDRAISING LIMITATIONS. An AmeriCorps Member may spend no more than ten percent of his or her originally agreed-upon term of service, as reflected in the member enrollment in the National Service Trust, performing fundraising activities.
AmeriCorps members may not:
- Raising funds for his/her living allowance; raising funds for an organization’s operating expenses or endowment;
- Write a grant application for funding provided by a federal agency including Campus Compact Days of Service grants, AmeriCorps VISTA, Summer VISTA Associates, the Corporation for National Community Service grant proposals and AmeriCorps grants.
45 CFR§§ 2520.45 An AmeriCorps member may spend no more than ten percent of his or her originally agreed-upon term of service, as reflected in the member enrollment in the National Service Trust, performing fundraising activities. The grantee mush ensure that it does not exceed the limitation on member service hours spent in education and training set forth in 45 CFR§§ 2520.50.
What are some examples of allowable fundraising?
- A member is developing a reading program and collects donations of books for the program.
- A member writes a non-federal grant proposal in order to purchase curriculum to train volunteers.
What is the new guidance?
Members can only raise funds for their service site. But, their service project cannot be focused on fundraising, or leveraging volunteers to raise funds. Some examples are members serving at a thrift store or other revenue generating program for the nonprofit.
Volunteer Iowa gave the example of a member serving with the Leukemia Lymphoma Society who coordinates a Relay for Life fundraiser. This is unallowable because the member is not serving at Relay for Life, the funds are going to a general fund, and the member’s fundraising hours would exceed 10%.
When might a member be able to serve at organizations like a thrift store?
A member can serve at a thrift store if their capacity building project is focused on something other than fundraising. Such as, developing a job training program for the employees.
How do the fundraising limitations apply to recruiting volunteers?
A member’s primary focus cannot be to recruit volunteers for an unallowable activity, this includes fundraising. A member can generally recruit volunteers for an organization. Some volunteers may be placed in positions that fundraise, but the member’s duties are dedicated to recruiting volunteers who will serve in many types of positions.
Kristin,
Unless I am misunderstanding what is proposed in your email, I would have three concerns about its allowability.
Dear CNCS,
Can you please provide guidance on whether the following member activity would be considered allowable? And why/why not? Thank you. I’m hoping to get a response in writing, if possible.
Background: A member is serving with the Leukemia/Lymphoma Society helping build capacity for the organization.
Situation: The member learns of a local Relay for Life event which benefits cancer patients and survivors. She thinks that this is a great cause and would like to participate. She has a few activities in mind: 1) serving on the planning committee, 2) recruiting volunteers to walk/raise money for the Relay for Life, 3) putting a collection can at the front desk of the office building in which she serves, 4) promoting the event to her college friends and with kids from her high school, and 5) contacting businesses to provide food to be served during the Relay.
The primary purpose of the member’s service with Relay for Life would be building her own skills with recruitment and helping a great cause. It’s also a great way to increase volunteering among college and high school students and the member is very passionate about connecting with young people. In her eyes, the main goal of this event is gaining leadership, bringing the community together and helping volunteers find meaning. Since the main goal for the member and organization is not raising money, can this be okay?
So, are these allowable activities? Why/why not?
Thanks!
Kristin Honz | Senior Program Officer
Iowa Commission on Volunteer Service
Unless I am misunderstanding what is proposed in your email, I would have three concerns about its allowability.
- The type of activity proposed appears to me be fundraising as defined in 45 CFR §§ 2520.40 (b) which can be allowable so long as it meets the standard established in 45 CFR §§ 2520.40 (a) and does not exceed ten percent of the hours toward the education award and the grantee organization is able to track this effort. The grantee must demonstrate they can meet these standards.
- I do not know the relationship between the Leukemia/Lymphoma Society and Relay for Life but it would appear it would not meet the standard required in 45 CFR §§ 2520.5. The grantee must demonstrate the proposed activities by the member directly support the program.
- The third concern is that even if the activity meets the requirements elaborated above, the proposed activity (fundraising for the Relay of Life event) is likely out of scope of the grant agreement. What is the purpose of the grant or proposed outcome for the grant and how does the member’s proposed activity directly impact that outcome? If this grant does not have member development performance measures, I would need significant convincing that “...building a member’s skills with recruitment …” or “…helping a great cause..” justifies counting the effort toward the member’s required service hours for an education award.
Dear CNCS,
Can you please provide guidance on whether the following member activity would be considered allowable? And why/why not? Thank you. I’m hoping to get a response in writing, if possible.
Background: A member is serving with the Leukemia/Lymphoma Society helping build capacity for the organization.
Situation: The member learns of a local Relay for Life event which benefits cancer patients and survivors. She thinks that this is a great cause and would like to participate. She has a few activities in mind: 1) serving on the planning committee, 2) recruiting volunteers to walk/raise money for the Relay for Life, 3) putting a collection can at the front desk of the office building in which she serves, 4) promoting the event to her college friends and with kids from her high school, and 5) contacting businesses to provide food to be served during the Relay.
The primary purpose of the member’s service with Relay for Life would be building her own skills with recruitment and helping a great cause. It’s also a great way to increase volunteering among college and high school students and the member is very passionate about connecting with young people. In her eyes, the main goal of this event is gaining leadership, bringing the community together and helping volunteers find meaning. Since the main goal for the member and organization is not raising money, can this be okay?
So, are these allowable activities? Why/why not?
Thanks!
Kristin Honz | Senior Program Officer
Iowa Commission on Volunteer Service