In the past, the most difficult part of the CFC application process has always been documenting a charity’s services and benefits, especially for a national organization, which had to document its services in at least 15 states. At the CFC’s 2017 application training, the CFC’s Marcus Glasgow talked a lot about how a charity should document its services, responding to many questions.
The biggest change in the new application system is that you only have to document your services and benefits once every three years. If this is your charity’s year, here’s what you need to know.
First, in the past, your charity’s schedule of services was part of “Attachment A,” which you attached to your application. While this section is still called "Attachment A," it is now part of the online application -- Step 4: Areas of Service.
The biggest change is that you now have only 256 characters to describe each service. CFC reviewers hated long and/or redundant service descriptions. They go through a lot of applications. Now they want just the facts.
If you provide multiple services, you can do multiple service descriptions. However, CFC officials do not want applicants to use another service description to complete describing the prior service. Indeed, they will reject that service. Succinctness is a virtue.
In a separate field, you then note how many people benefitted from the service and/or the monetary value of the service. Glasgow’s discussion of this was interesting. If your charity just gives one scholarship to a student in, say, Hawaii, but the scholarship is worth, say, $30,000, this would qualify as providing service in Hawaii. However, if your museum had 30 visitors from Hawaii during the year, this would not count as providing service in Hawaii.
You don’t have to prove that a service both benefitted many people and had considerable monetary value, Glasgow explained. One or the other can qualify you.
The main criterion is that your service in a state was more than “de minimus.” This is a legal term meaning that something has minimal value – “too trivial or minor to merit consideration,” according to one dictionary. The CFC rules don’t define de minimus, just how it will be determined, using eight possible factors (number of beneficiaries, extent of the service, duration, etc.).
Glasgow defined it as “services so minor they don’t count.” He added that, “The bar is lower than many assume. We hold charities to a standard. We don’t publicize that standard.” They don’t, he added, because then everyone would shape what they do to try to meet the standard.
“Just tell us what you do,” Glasgow said. “If you tell us who, what, when, where, if you tell us what the benefit is or how many people benefit, you should be okay.”
Be as specific and concrete as possible. In the CFC’s “2017 Application Templates” memo, a service description that was unacceptable (because it filled up two service description fields) began, “Our organization was founded in 1995 and is dedicated to eradicating cancer. Our founder, Mr. John Doe, was passionate about….” In other words, get to the point: what did you do, when, where, why, how many people benefitted or what was the value of what you did?
Importantly, to qualify as a national charity, you do not have to provide services or benefits in 15 states every year. You have a three-year window. For a 2017 application, you can describe services provided between 2014 and 2016. This is also true for international charities, which must describe services provided in at least one foreign country over a three-year period.
Local charities, however, can only qualify based on the services they provided in the past year. (The online application includes a section to describe your charity's services in the prior two years, but reviewers will focus just on the most recent year. Indeed, a charity does not even have to be in existence in years prior to the most recent year -- 2016 for a 2017 application.)
To be eligible, a local charity must demonstrate a “substantial local presence.” This is defined as a staffed facility, office or dedicated portion of a residence that is available to the public who are seeking services or benefits. This facility must be open at least l5 hours a week and have a dedicated phone. The staff can be volunteers. Simply having an “800” number or disseminating information via the mail or the internet is not enough.
One final consideration: to be eligible for the CFC, a charity does not have to provide direct services, such as feeding the homeless or mentoring the young. The CFC’s rules specify that “services” means “services, benefits, assistance or program activities.” In other words, charities that do research, public education, advocacy or other activities that have a public benefit are eligible. This broader language (“benefits, assistance or program activities”) was critical when the CFC was opened up to a much broader range of charities in the 1980s.