Implementation of Amendment to Section 5.4 of Director's Order 21

Implementation of Amendment to Section 5.4 of Director's Order 21: Review of Indirect Donations and Contributions to Partners

On November 21, Director Sams approved an amendment to section 5.4 of Director's Order 21 on Donations and Philanthropic Partnerships, modifying the threshold for review of indirect donations to the NPS. Indirect donations are defined as those made directly to an authorized philanthropic partner of the NPS, with the partner subsequently making the donation to the NPS. A field memo was sent sent out to Regional Directors and Regional Partnership/Cooperating Association Coordinators this morning.

The policy previously permitted authorized philanthropic partners to review (sometimes referred to as “vet”) certain indirect donations up to $500,000 and present the results to the NPS authorized employee for concurrence. This amendment expands partner review of indirect donations to the following new thresholds, based on the source of the donation:

• Donations less than $1,000,000 from individual donors and private or public foundations (other than corporate foundations)

• Philanthropic donations (restricted or unrestricted) less than $500,000 from corporations or corporate foundations,

• Donations less than $250,000 for corporate partnerships which involve cause marketing, sponsorship or similar (see 4.3.1 of Director’s Order 21 for additional requirements)

• NPS authorized employees still review the results presented by philanthropic partners, and indicate concurrence, prior to the donation being accepted. The NPS continues to make the final decisions on whether indirect donations meet the requirements for acceptance listed in DO-21, see 5.1 Acceptance Considerations.

• Indirect donations in amounts higher than the above-noted limits will continue to be reviewed by WASO and DOI following the guidance in RM-21, section 5.4.

Summary of Policy Amendment to DO 21, Section 5.4

Source of Indirect Donation	Donations Reviewed by Partners	Requires WASO and DOI Review
Individual Donors and Private or Public Foundations (other than corporate foundations)	Less than $1,000,000	$1,000,000 +
Corporate Philanthropy	Less than $500,000	$500,000 +
Corporate Partnerships*	Less than $250,000	$250,000 +

* Any corporate partnership that involves more than one region, is national, or is related to alcoholic beverages must be reviewed by NPS, regardless of the donation amount

In the first quarter of 2025, the Office of Partnerships and Philanthropic Stewardship (PPS) will complete the next steps to implement this policy change including updates to Reference Manual 21 (RM-21) which will include providing a definition of various foundation types. PPS will be available to provide additional guidance until updates to RM-21, DO-21, and required training information are published.

Until the final RM-21 guidance is issued, authorized philanthropic partners and NPS authorized employees may implement this amendment to policy as follows:

• Authorized philanthropic partners should use the processes in the philanthropic partnership agreements to formally review donations by donor type.
• NPS authorized employees may work directly with their philanthropic partner(s) to assess the partner review or seek assistance from the Office of Partnerships and Philanthropic Stewardship for a final determination on approval for acceptance.

Please contact acting Division Chief, Office of Partnerships and Philanthropic Stewardship, Karyn Ferro and Partnerships Program Coordinator, Karissa DeCarlo at e-mail us with any questions.