Reference Manual 21 -- Chapter 4

Note: This page contains Chapter 4 of Reference Manual 21 that accompanies Director's Order 21, Donations and Philanthropic Partnerships. Users of RM-21 are strongly encouraged to check this page for updates before utilizing previously viewed, printed, or downloaded materials.

Updated September 6, 2019 (link replaced)

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4.0 Philanthropic Support

4.1 Types of Support Accepted by the NPS

The NPS may accept, use and recognize donations of various kinds to support and promote its mission consistent with applicable laws and the Department of the Interior donations policy (Departmental Manual, Series 16-Ethics And Conduct, Chapter 6 Donations).

Donations may come to the NPS as single expressions of support, or in response to an organized fundraising campaign. A donation may be offered directly to a park or program, or indirectly to a partner for the benefit of a park or program. Donations, be they cash or in-kind goods and services, are used to enhance national parks and NPS programs.

Examples of acceptable gifts and forms of support include:

  • Cash for either restricted or unrestricted purposes
  • Tangible personal property
  • Securities (such as common stocks, preferred stocks, and bonds)
  • Real estate (land and improvements), or interests in real property (easements)
  • Museum collections
  • Intellectual property
  • Planned and phased giving (estate planning, bequests, charitable gift annuities, charitable trusts, and retirement plan or life insurance beneficiary designations, etc.)
  • In-kind (such as goods, products, services, volunteer time, and expertise)
  • Pro bono (such as professional services and technical expertise)


For the purposes of DO21, individual contributions of technical expertise or time are considered volunteering (see Director’s Order and Reference Manual 7), while corporate or organizational contributions of technical expertise or time are considered pro bono contributions and are subject to DO21.

Steps

1. Before accepting, an offer of donation must be reviewed in accordance with DO21 Section 5 and as described in RM-21 Chapter 5.

2. The process for accepting the donation (after the review) will vary based on the type of donation:

  • Cash for either restricted or unrestricted purposes
    • When a check or cash is received as a direct donation, it should be deposited into an NPS account that is coded as a donation account. If it is for a restricted purpose, it should be placed in a unique donation account. If it is a general unrestricted donation, it may be added to an existing donation account that was already created for general unrestricted use.
    • Once deposited into an NPS account, the funds are treated like appropriated dollars and the NPS may use them to fund or otherwise support any activity for which appropriated funds could be used, subject to the restrictions described in DO21 Section 4.2. Note: Parks may not purchase food or beverages with appropriated funds or funds donated directly to the NPS except in certain circumstances as authorized under Acquisition Policy and Procedures (AP&P) Memorandum 1443.07-03 (internal link) or Director's Order 50B Occupational Safety and Health Program.
  • Tangible personal property
    • Prior to acceptance, be sure that the item is of value to the park and can be accepted into inventory. A park property officer can assist in accepting the property and adding to the park inventory. Processes will vary based on what type of property is donated.
  • Securities (such as common stocks, preferred stocks, and bonds)
    • Contact Regional Budget Office.
    • Regional Budget Office will contact the Deputy Manager for Financial Operations (DM-FO).
    • DM-FO will coordinate with the Department of the Treasury to request liquidation (sale) of the donated securities.
  • Real estate (land and improvements), or interests in real property (easements)
    • Under 49 CRF 24.108 (Uniform Relocation Act) the Service must offer "just compensation" for the acquisition of land unless the land is offered as a donation.
    • NPS may NOT ask a landowner to donate property to the National Park Service, which would be considered a solicitation. NPS is able to accept donations of land or interest in land if the land is within a park boundary or adjacent/contiguous to a park boundary.
    • If the park Superintendent determines that the offered property is of interest because of resource protection or visitor use needs, they should contact their Regional Land Resources Offices. The Regional Land Resources Offices will handle all the procedural and legal requirements necessary to facilitate conveyance of the property title to the Federal government.
    • See Director’s Order 25 on Land Resource Protection and its companion Reference Manual for additional information. Click on the link and scroll down to Director’s Order 25.
  • Museum collections
    • Consult with park or regional curator for guidance on how to consider and/or accept donations of museum collections or objects.
    • Additional guidance and required forms can be found in Director’s Order 24: NPS Museum Collections Management (policy, handbook, website).
  • Intellectual property
    • The donor of intellectual property should provide documentation transferring the ownership of the property to the National Park Service. The park must keep this documentation on file with the property that was donated. Any metadata associated with electronic files should summarize the rights and reference where the paper files are.
  • Planned and phased giving (estate planning, bequests, charitable gift annuities, charitable trusts, and retirement plan or life insurance beneficiary designations, etc.)
    • These can be accepted in the same manner as cash donations.
    • If a donor contacts a park and desires to make an unrestricted bequest to a National Park Service site or program, they may use the following basic language in their will: “Upon my death, my [Executor(s)/Trustee(s)] shall distribute [$ amount, specific items, assets or residue of the estate] to the National Park Service, a tax-exempt United States agency for the support of programs and projects in ________________(park name). The National Park Service IRS Tax ID is 53-0197094."
    • For a restricted bequest, they may use the following basic language: “Upon my death, my [Executor(s)/Trustee(s)] shall distribute [$ amount, or specific items, assets, or residue of the state] to the National Park Service, a tax-exempt United States agency for the [project/use] ________ in ________________(park name). The National Park Service IRS Tax ID is 53-0197094."
  • In-kind (such as goods, products, services, volunteer time, and expertise)
    • The National Park Service cannot estimate the value of an in-kind gift for the donor’s tax purposes.
    • For the purposes of DO21, individual contributions of technical expertise or time are considered volunteering (see Director’s Order 7 and RM-7), while corporate or organizational contributions of technical expertise or time are considered pro bono contributions and are subject to this Order.
    • Pro bono (such as professional services and technical expertise)
    • These types of donations can be documented in a Donation Agreement.


3. Acknowledging the donation: Donations to parks and NPS programs are tax-deductible under section 170(c)(1) of the Internal Revenue Code.

The Internal Revenue Service requires that a donor have a record of their contribution in the form of either a bank record or a written receipt or letter from the charity showing the name of the charity and the date and amount of the contribution. Donors cannot claim a tax deduction for any single contribution of $250 or more without a written acknowledgment of the contribution from the organization receiving the donation. A donor can access irs.gov for the most current information on tax code.

To meet these rules, the NPS requires park and program managers to substantiate contributions, where a donor is known. The acknowledgment must include the following information:

  • The name of the organization
  • The amount of a cash contribution
  • A description of a non-cash contribution. This should not include the value of the contribution. The determination of the value is up to the donor and the IRS.
  • A statement that no goods or services were provided by the organization in return for the contribution. If goods or services were provided, the statement should include a description and good faith estimate of those goods or services. This would apply, for example, if the donor received a coffee cup or calendar with their donation.


Example text for the acknowledgment letter sent on park letterhead:

  • Cash donation:

“Thank you for your contribution of (insert amount of cash donation) on (date). No goods or services were provided in exchange for this contribution. (Park Name) is an exempt organization (Tax Exempt ID 53-0197094) as described in Section 501(c)(3) of the Internal Revenue Code.”

  • For a non-cash item:

“Thank you for your contribution of one used oak table and set of six oak chairs that (Park Name) received on (date). No goods or services were provided in exchange for your contribution. (Park Name) is an exempt organization (Tax Exempt ID 53-0197094) as described in Section 501(c)(3) of the Internal Revenue Code.”


Donors should not have to ask for the acknowledgement. Parks must develop a process that provides the acknowledgement as soon as possible and within two weeks of donation receipt. Remember too, for those donations received at the end of the tax year, the acknowledgement must be sent no later than January 31 of the year following the donation.

Park staff can also send a personalized thank you note as part of or in addition to a formal acknowledgement letter. Additional information on thank you notes is available in a variety of places including Classy.org (The ULTIMATE Thank You for Nonprofits), Guidestar.org (Why Are Nonprofits So Terrible At Acknowledging Gifts?), Association of Advancement Services Professionals (Best Practices: Gift Acknowledgment). Mention of these resources does not constitute an endorsement.

4.7 Accountability and Recordkeeping Requirements for Donations

Accounting for Monetary Donations

All monetary donations received directly by the NPS must be deposited in a donation account, be accounted for, and be disbursed using the same standards and procedures used for other appropriated funds. Note: Parks may not purchase food or beverages with appropriated funds or funds donated directly to the NPS except in certain circumstances as authorized under Acquisition Policy and Procedures (AP&P) Memorandum 1443.07-03 (internal link) or Director's Order 50B Occupational Safety and Health Program.

The park budget officer or regional financial officer should be able to provide additional information. Guidance on setting up donation accounts can be found in the FBMS Guidance Document on Donations (internal link for employees).

Starting in FY19, the NPS will begin updating Park Assurance Statements to certify annually that appropriate standards and procedures are in use regarding monetary donations and business carried out with philanthropic partners. Each park superintendent will be required to fill out a section on donations and philanthropic partnerships each year in the Park Assurance Statement that certifies compliance with all recordkeeping and accountability for donations.

Philanthropic partners must account for donations with a system complementary to NPS accounting, allowing for full accountability of a donation from acceptance through disbursement. Ultimately, reports generated from either NPS or philanthropic partners should reconcile all financial activities.

The NPS Partnerships Reporting Site (Partnerships Portal) allows for reporting on multiple partner categories, including philanthropic partners. Park managers should ensure philanthropic partner information is reported through the Partnerships Portal on an annual basis and that their partner contact information is accurate. Most information required to report can be found on the partner’s IRS Form 990. Beginning in spring 2019, parks will be required to provide this information through this web-based reporting system. Before the first notification to report through the Partnerships Portal, an instructions sheet will be provided here.

Accounting for Non-Monetary Donations

All non-monetary donations accepted by a park or program must be accounted for under the same standards and procedures used to account for other similar government property. (See Director’s Order 44: Personal Property Management, Director’s Order 25: Land Protection, and Director’s Order 24: NPS Museum Collections Management, all available in the Director's Orders area of the NPS Policy website).

The Park Assurance Statement certifies annually that appropriate standards and procedures are in use regarding non-monetary donations acquired through philanthropic partners. Each park superintendent will be required to fill out a section on donations and philanthropic partnerships each year that certifies compliance with all recordkeeping and accountability for non-monetary donations.

Philanthropic partners must account for non-monetary donations, intended to support a park project or program identified in an annual work plan, with a system complementary to NPS non-monetary donation accounting, from acceptance through acquisition and when applicable, consumption or disbursement. Ultimately, reports generated from either NPS or philanthropic partners should reconcile all non-monetary donations.

The information provided in the Partnerships Portal will include non-monetary donations as reported on the partner’s IRS Form 990.

Records and Documentation

When they exist, the following records should be kept on file in a central location in the park for donations and philanthropic partnership activities. Maintenance of these files should follow the records retention policy found in Director’s Order 11D. Each year in the Park Assurance Statement, the park superintendent certifies that these records are retained and accessible:

  • All Current Agreements and Attachments
    • Annual Work Plans for each year that a partnership agreement is active
    • Feasibility Studies (when required)
  • Donation Records
    • NPS accounts should be tracked by the NPS budgeting software system (As of 2018 this system is called AFS)
    • For all donations, a copy of the letter of acknowledgement provided to the donor
    • Confirmation that Partner keeps accounts for each approved project in a financial system that is able to run reports on income and expenditures of donated dollars.
  • Support for Expenditures
    • Includes original approved budget for the partnership project as provided in the annual work plan or agreement.
    • Includes completed forms documenting request, receipt, and/or purchases made on behalf of the park from these project or program accounts
  • Form IRS 990 (when required under IRS rules)


EXAMPLE: Donation accountability and recordkeeping at XYZ National Park:

Step 1: Annual workplan documents a calendar-year plan between XYZ National Park (park) and XYZ Foundation (foundation). It includes a project where the foundation provides $200,000 in cash and non-monetary donations to support a Youth Conservation Program. This program provides a comprehensive, hands-on work experience for youth within the park. The annual workplan budget defines portions of the budget that are direct donations and those that are in kind.

Sample Project Budget Summary

Donation to NPS by check:

  • Crew Leader Wages: $75,000
  • Personal Protection Equipment: $2,000
  • Trail and Project Supplies: $3,000
  • 3 Month GSA Vehicle Rentals (2 vans and truck): $23,000
  • Gas/service on vehicles: $1,000

Payments made by foundation on behalf of the program:

  • 20 YCP participants (l2.00/hr): $96,000

Step 2: Park and foundation both set up a unique accounting string (donation account at park and general ledger account at foundation) to account for deposits and charges for this program.

Step 3: Park submits requests throughout the year for funding transfers from foundation to park, or for foundation to make payment directly. In order to streamline this process, the park and foundation created a local form. This funding request form includes the following information:

  • Date
  • Project title
  • Total budget agreed to in workplan
  • NPS project manager name
  • Total amount requested
  • Balance remaining in budget after request
  • FBMS park account number for deposit (cost center, functional area, fund, WBS)
  • Description of how the funds from this request will be utilized
  • Date a final report on this project will be submitted
  • Signatures of project manager, project manager’s division chief, and superintendent or partnerships manager at the park.


This executed form is scanned and emailed to the foundation point of contact, the park budget office, and the park administration office.

At any time in this process, the park or partner should be able to run a report to show accountability for how donated dollars were spent and what in kind purchases were provided by the partner on behalf of the agreed-upon project.

The park superintendent will certify as part of the annual Park Assurance Statement that donation funds are received and expended within policy guidance provided in Director’s Order 21. The foundation includes the donation of $200,000 for the Youth Conservation Program in the total contributions listed in their IRS 990, which is then entered in the NPS Partnerships Portal (in development).

Last updated: September 6, 2019