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 May 26, 2023 (added 4.5.3 and webinar information)
Updated June 6, 2023 (fixed link in 4.5.3)
Updated June 8, 2023 (uploaded authorization correction)
Updated September 7, 2023 (added section 4.5.1)
Updated April 1, 2024 (fixed broken links in 4.1)
Updated June 3, 2024 (see 4.5.1, allows AD-PCE and AD-IEV to sign authorizations)
On this page:
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
- 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.
4.5.1 In-park Fundraising by Partners
Special Use Permits for Fundraising Special Events
Authorized philanthropic partners often desire to hold fundraising events (meaning events where ticket sales or entry fees raise funds for the partner) within a park. The park should follow the same analysis used for any special event and must consider the request following applicable regulations and policies. (For special events that require significant restrictions or closures of areas normally open to the public, refer to Policy Memorandum 16-02 for additional guidance.) Should the superintendent decide that the event is an appropriate use of the park, the NPS and the partner should decide how their respective costs and fees for managing and monitoring each event will be covered.
Special Use Permit applications from other entities with similar requests to hold fundraising special events should be treated in a similar manner as a request by the authorized philanthropic partner. Authorized philanthropic partners (or any partners for that matter) may not be given preferential treatment.
In-park fundraising activities and events must be identified in an approved philanthropic partnership agreement or annual work plan.
For special events that require participants to pay a separate admission or participation fee, the payment, whether in the form of a fee or required donation, may not take place within the park per Director’s Order #53, section 7, and PM 16-02, Donations and Participation Fees (page 3).
Raffles, Lotteries, and Other Games of Chance
A Special Use Permit for a special event may not be issued if the fundraising activity is a form of gambling (36 CFR 2.36). Generally, gambling requires three elements:
- A game of chance;
- Payment of consideration for the opportunity to play the game; and
- An offering of a prize (even if donated to charity).
“Consideration” includes a participation fee, a wager of money, and something of value in return for the possibility of winning a reward or prize.
A “prize” would include a monetary award, or a tangible or intangible item. Examples include meals, drinks, gift certificates, tickets to events, or cash.
Silent and Live Auctions
When an authorized philanthropic partner desires to have a silent or live auction, a location not on park land is the preferred option. If an authorized philanthropic partner wants to hold a silent or live auction within park boundaries, the following options are possible:
1. The partner may make a request to a lessee or concessioner to hold the event within their assigned property. The event must fall within the parameters of the lease or the concessioner’s contract. Partners may not use facilities assigned to outdoor schools unless the outdoor school is under a lease that authorizes the type of proposed event or activities. (Most outdoor schools have cooperative agreements with the NPS, and fundraising is not allowed under a cooperative agreement.) The partner may also hold the event on private land within the boundaries of the park. No Special Use Permit is needed for any of these scenarios.
The decision to make property available for a silent or live auction is at the discretion of the assignee or landowner, is completely voluntary, and will not influence the NPS’ evaluation of any entity under its applicable agreement or contract with the NPS (in the case of concessioners). The partner should expect to pay the lessee or concessioner market rates. Parks should not request reduced or waived rates.
2. The park superintendent may issue a Special Use Permit to the partner for a special event involving a silent or live auction if the superintendent determines the event itself is appropriate based on the criteria in 36 CFR 2.50. Sales, donations, and commercial activity when permitted under Special Use Permits are restricted by 54 USC 101702(c), 36 CFR 2.37, and 36 CFR 2.52. As a result, the Special Use Permit for a special event may authorize the partner to hold only certain aspects of an auction on park land. For instance, the following scenarios may be authorized:
- Attendees bid for items during the event, and the winners are announced at the event. These activities take place on park land. Attendees must pay and pick up the items outside the park on non-park land.
- People bid for items and pay online or at a different location outside the park before the event. The partner announces the winners at the event, and attendees may pick up the items during the event on park land.
Due to the restrictions listed above, attendees may not pay for items on park land through any means, including virtual payments through an application or other electronic means while the attendee is on park land.
4.5.3 Checkout Counter Donation Program
Background: Checkout counter campaigns (or point-of-sale donation programs) are a type of cause marketing where the sales clerk at a hotel, gift shop, restaurant, park store, outfitter, etc. offers the customer an opportunity to add to their bill to benefit a charitable cause. The NPS makes the program available through commercial visitor service providers and cooperating associations operating inside a park under the guidelines presented here. Similar programs that occur outside of a park are considered cause marketing, and would be either negotiated under a philanthropic support agreement (if the relationship was directly between NPS and the external entity) or would be described in an annual work plan (if the relationship is between an authorized philanthropic partner and the external entity), see section 4.3.1.1 Cause Marketing and 6.3 Philanthropic Support Agreement as well as RM 6.4.1 Annual Work Plans and Aid-to-NPS Work Plans respectively. This section, in particular the Authorization for NPS Checkout Counter Donation Program can guide the design of programs that occur outside of a park.
Program: Under this voluntary program, park superintendents may authorize a cooperating association or commercial visitor service provider (lessees, concessioners, commercial use authorization (CUA) holders) (collectively, in-park operators), to give their customers the opportunity to support the park they are visiting through a donation added to their lodging, meal, or other transaction. (All NPS CUA holders are eligible to participate in this program and are considered "in-park operators" for the purposes of this policy, regardless of whether the CUA holder is designated as "in-park" or "out-of-park" on their CUA.) The park’s nonprofit partners (specifically, cooperating associations, authorized philanthropic partners, or the National Park Foundation) use these donations to undertake or support programs and projects identified in the Authorization for NPS Checkout Counter Donation Program (Authorization) and the annual work plan and/or annual aid-to-NPS plan.
Commercial visitor service providers must transfer all funds collected under the program to the park’s authorized philanthropic partner, park cooperating association, or the National Park Foundation. The funds must be accounted for in a special account within their general ledger or chart of accounts. Unless authorized as part of a revenue sharing business model agreement, as is often the case with cooperating associations, funds should be credited to the individual park unit and not comingled.
Program Management: Management responsibilities require a level of expertise in budget, communication, partnerships (authorized philanthropic and cooperating association), visitor experience, and project management. Park superintendents may assign overall program management to a subordinate employee or office, as appropriate.
Copies of Authorizations must be provided to the Region and to the Office of Partnerships and Philanthropic Stewardship.
Authorization for NPS Checkout Counter Donation Program: The funds collected under the program are donations made by customers. These donations must be used for the purposes described in the Authorization. These purposes should guide what is included in the annual work plan or annual aid-to-NPS plan; the plans may provide additional details about the use of funds but must be within the parameters of the Authorization.
The use of funds collected by cooperating associations under this program is limited to educational, scientific, historical, or interpretive activities, unless an association’s Authorization specifies it will:
- apply the funds to a program on the annual work plan associated with their philanthropic partnership agreement; or
- provide the funds to one of a park’s authorized philanthropic partners.
A cooperating association that supports multiple parks or implements the program online or implements the program at off-site locations may use a single authorization form (please contact the Office of Partnerships and Philanthropic Stewardship for assistance) for all its locations.
The signature level is as follows:
- When the in-park operator is a commercial visitor service provider: The Authorization is signed by the in-park operator, the authorized philanthropic partner or cooperating association accepting the funds, and the park superintendent.
- When the in-park operator is a cooperating association: The Authorization is signed by the cooperating association, the recipient authorized philanthropic partner (if applicable) and the NPS at the same level as the standard cooperating association agreement. Authorizations that would be signed at the Director's level can instead be signed by the Associate Director for Partnerships and Civic Engagement and the Associate Director for Interpretation, Education, and Volunteers.
Copies of the Authorization must be provided to the Region and to the Office of Partnerships and Philanthropic Stewardship.
Administrative costs: Cooperating association and authorized philanthropic partners may deduct program administrative costs from the proceeds, as long as all parties to the Authorization consent to the details of these costs. Administrative costs must be documented and justified with a detailed budget included in the Authorization. Commercial visitor service providers may not use proceeds to cover administrative costs.
Administrative costs should be revisited annually during the development of the annual work plan to ensure all parties agree that (1) the administrative costs are reasonable, and (2) the program benefit exceeds the administrative costs by an acceptable margin. If the administrative costs change, the budget section of the Authorization should be updated and reviewed at the region. Copies of the updated Authorization must be provided to the Region and to the Office of Partnerships and Philanthropic Stewardship.
The Associate Director, Partnerships and Civic Engagement, and the Associate Director, Interpretation, Education, and Volunteers, will work together to assess trends in administrative costs and determine whether benchmarks or ceilings are warranted.
Special Account: The NPS requires in-park operators and authorized philanthropic partners to ensure funds collected under this program are accounted for and disbursed properly by creating a special account within their general ledger or chart of accounts (hereafter, Special Account).
Program Design: The program can be designed to give visitors or customers the choice to “opt-in” or opt-out” of making a donation as described below.
“Opt-in” opportunities ask the customer if they would like to make a donation. The options can be presented in several ways, including:
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Verbal or Electronic Request: A clerk or a message on an electronic checkout device asks the customer if they would like to make a donation.
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Round-up at the register: The customer is asked if they would like to round up their total to the nearest dollar.
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Online: The point-of-sale is at a virtual checkout counter, and the customer has the opportunity to donate when they complete their transaction.
The “opt-out” option is restricted to lodging. A donation is added to a lodging bill, and the customer can decline to donate. Customers must be given ample notice and an opportunity to decline to participate. A best practice is to inform visitors at check-in, through a tent card or other notification in their room, and again at check-out.
Voluntary Participation: It is important to note that a decision to participate or not participate in the program is voluntary and will not influence the NPS’s evaluation of an in-park operator under its applicable agreement with the NPS. However, adherence to the Authorization will be a part of any standard operational reviews undertaken by the NPS.
Additional information specific to commercial visitor service providers follows:
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Lessee: This is a voluntary action by the lessee or sublessee, and not a donation by, or on behalf of, the lessee or sublessee. The donations received from these collections are not revenue subject to rent that is calculated based on revenue.
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Concessioner: This is a voluntary action by the concessioner, and not a donation by, or on behalf of, the concessioner. It is neither a rate addition, nor part of the rate that is approved for the service being provided. The donations received from these collections are not revenue subject to franchise fees.
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CUA holder: This is a voluntary action by the CUA holder and not a donation by or on behalf of the CUA holder. The donations received from these collections are not revenue subject to CUA fees. All NPS CUA holders are eligible to participate in this program and are considered "in-park operators" for the purposes of this policy, regardless of whether the CUA holder is designated as "in-park" or "out-of-park" on their CUA.
Best Practices for Donation Opportunity Planning for National Parks: Superintendents should err on the side of offering select opportunities to donate versus oversaturation of donation opportunities and the creation of a negative visitor experience.
The following best practices are intended to help superintendents decide how many opportunities to approve:
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Parks with multiple types of donation opportunities or complex geographical considerations should consider developing a map with all opportunities represented. This may help identify saturated locations.
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Ensure all existing opportunities to donate are considered when approving new locations, types of donation opportunities, or programs.
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Ensure annual work plans and aid-to-NPS plans have complete lists of types and locations of donation opportunities.
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Ensure all opportunities to donate directly to the NPS are approved by the park superintendent. Parks with complex opportunities should consider a written plan for signature.
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Be a visitor in your own park—consider how many times you encounter opportunities to donate and the tone and message you receive.
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Consider tone—creating a positive opportunity to support and engage with your park may enhance a visitor experience.
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Review donation data to eliminate ineffective methods or locations.
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Approve one new program at a time to allow for visitor feedback and evaluation of effectiveness.
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Consider eliminating opportunities when adding new opportunities.
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Consider opportunities for small and larger donations and electronic and cash donations to offer opportunities that meet the preferences for all generations.
Park superintendents will need to work with their community of authorized philanthropic partners and in-park operators to balance the needs of park visitors with the desire to provide opportunities for visitors to donate. It is important to manage the number of times a visitor may be asked to donate by in-park operators so as not to overwhelm park visitors with opportunities of this kind.
Tools
The Checkout Counter Program Authorization sets out processes for the collection and handling of funds, and the dispersal of funds and reporting. As a reminder, the signature level is as follows:
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When the on-site operator is a commercial visitor service provider: The Authorization is signed by the cooperating association, the recipient authorized philanthropic partner (if applicable) and the NPS at the same level as the standard cooperating association agreement. Authorizations that would be signed at the Director's level can instead be signed by the Associate Director for Partnerships and Civic Engagement and the Associate Director for Interpretation, Education, and Volunteers.
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When the on-site operator is a cooperating association: The Authorization is signed by the cooperating association, the recipient authorized philanthropic partner (if applicable) and the NPS at the same level as the standard cooperating association agreement.
The remainder of this chapter of RM-21 will discuss the development and implementation of a checkout counter campaign for an in-park operator.
Instructions for developing a Checkout Counter Program
Program Initiation
If a park superintendent is interested in initiating a discussion about the possibility of an in-park operator participating in the Checkout Counter Donation Program, the topic would ideally be raised during the development of an annual work plan or annual aid-to-NPS work plan. An authorized philanthropic partner or in-park operator may also initiate the discussion about participation in the program.
Once the discussion is opened by any of the parties listed above, the following steps should be followed:
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Set aside time for the in-park operator, park superintendent, and authorized philanthropic partner (if this entity is not the same as the in-park operator) to meet. Prior to that meeting, each participant should review the Roles and Responsibilities section of this chapter and the Authorization to become familiar with their responsibilities.
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Meet to discuss the goals for the program – what project(s) would be supported, the program design (opt-in or opt-out), disbursement schedule for funds, and program collateral and messaging. A key factor in the final decision is the estimated cost to benefit ratio. The program should not be initiated if administrative costs for the cooperating association or authorized philanthropic partner are expected to exceed the proceeds in the first year of operation.
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Complete the Authorization and submit for appropriate consideration and signature by all parties.
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For cooperating associations that support multiple parks, one Authorization form may be used so long as all superintendents at parks where the program will be implemented agree, in writing, to participate. The key NPS official identified in a cooperating association agreement can assist in adding signature lines or attaching a spreadsheet to the Authorization to allow for this.
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Update annual work plans and aid-to-NPS plans.
Roles and Responsibilities
As with any fundraising activity, an authorized philanthropic partner or in-park operator should consult an accountant or tax attorney to ensure compliance with any Federal or State specific laws, rules, and regulations.
In-park operator as collector of funds will:
- Work with the park and authorized philanthropic partner to complete the Authorization;
- Follow any Federal, State, or local laws, rules, and regulations relating to this activity;
- Respect customers’ wishes about participation;
- Provide staff training;
- Ensure funds are accounted for and disbursed properly;
- List the donation separately in the transaction at the point-of-sale. Registers or other point-of-sale tools or equipment must be equipped to separate the donation from the rest of the transaction and to log the donation as a separate item within the transaction;
- Create a Special Account to hold the funds until they are transferred or expended;
- Appropriately transfer funds:
- In-park operators that are commercial visitor service providers must transfer 100% of the gross proceeds to the designated recipient at least annually;
- In-park operators that are cooperating associations must transfer 100% of the net proceeds to the designated recipient or project at least annually, unless the superintendent and association have agreed that the proceeds be held by the association for upcoming or ongoing projects or programs;
- Develop, produce, and display signage and program marketing collateral (in collaboration with the NPS and where applicable, the authorized philanthropic partner); the NPS must approve all materials;
- Provide the park superintendent or program manager with an annual accounting of funds received and deposited to the Special Account;
- Advise visitors about the program, its benefits, and how to participate. The program should be designed and developed by the as a collaboration among the parties. The cooperating association or authorized philanthropic partner will typically have the necessary expertise;
- Research and adopt industry best practices; and
- Advise the park of any issues with the program.
Authorized philanthropic partner as recipient of funds will:
- Work with the park and in-park operator to complete the Authorization;
- Provide staff training;
- Ensure funds are accounted for and expended properly, creating a Special Account to hold the funds until they are transferred to the park or expended on behalf of the park;
- Transfer 100% of the net proceeds to the designated recipient or project at least annually, unless the superintendent and authorized philanthropic partner have agreed (in the annual work plan and Authorization) the authorized philanthropic partner will hold the proceeds for upcoming or ongoing projects or programs;
- Provide information about the program in their communication channels;
- Report annually on the program (as part of established annual partnership and cooperating association reporting) including a summary of the deposits, withdrawals, and program accomplishments*; and
- Advise the park of any issues with the program.
*When a cooperating association is the in-park operator they are also responsible for the starred roles.
Park will:
- Manage the quantity and volume of program activation across the park to preserve the visitor experience. The superintendent must consider the total number of in-park operators and associated facilities participating in this program so as not to overwhelm the visitor with opportunities to donate;
- Provide information to the public on the use of the funds – options include a notice at a project site or an article for the park website or newspaper;
- Provide information to the in-park operator about use of the funds at least annually; this can be incorporated into existing reporting systems. The information must be shared with the regional partnership office and WASO Office of Partnerships and Philanthropic Stewardship;
- Review, approve, and post (or authorize posting of) all program collateral and messaging required by this policy;
- Advise the regional director and WASO Office of Partnerships and Philanthropy if a participating in-park operator fails to operate the program in compliance with this policy, as well as with other pertinent laws, regulations, or policies;
- Respond appropriately to all visitor complaints or concerns raised about the program and working collaboratively with the in-park operators to resolve reasonable concerns and complaints;
- Ensure that participating in-park operators comply with this policy. One way to accomplish this is to undertake a review of program implementation concurrently with any standard operational review of participants;
- Respond to issues identified by in-park operator or recipients;
- Ensure park staff are aware of and able to answer basic questions about the program; and
- Ensure NPS employees who staff cooperating association registers do not ask customers if they want to make a donation. This is not a prohibition on display of information. Cooperating associations authorized to operate the program may have information about the program displayed at the checkout counter to alert the customer to the opportunity. NPS staff working the register may not ask a customer if they would like to participate in the program and donate. However, if a customer initiates the ask to participate in the program and add a donation to their purchase, the NPS staff may ring it up through the register/point-of-sale system.
Funds Management
All parties involved with the program (park management, in-park operator, and authorized philanthropic partner (if not the same entity as the in-park operator)) must agree to the intended use of the funds generated before the program is set up. Fund use should be described in any associated program collateral or messaging. Funds collected under the program by cooperating associations must be used for educational, scientific, historical, or interpretive activities unless the Authorization specifies the funds will be applied to a program on the philanthropic partnership agreement annual work plan, or the association provides the funds to a separate park authorized philanthropic partner. As with any fundraising activity, an authorized philanthropic partner or in-park operator should consult an accountant or tax attorney to ensure compliance with any Federal or State specific laws, rules, or regulations.
The in-park operator must deposit funds donated by visitors to a Special Account. These funds can only be used for the mutually agreed upon administrative costs (if the in-park operator is a cooperating association) or transferred to the park or philanthropic partner’s account. Recordkeeping should be designed to allow for simple retrieval of program revenue and expenditures.
The in-park operator must transfer funds at least once a year to the participating authorized philanthropic partner. Funds can be transferred more often if the participants agree. If the in-park operator collecting funds is a cooperating association, funds may remain in a Special Account until the park superintendent requests it be transferred or used in a partnership project.
Misuse of the contributed funds by an in-park operator may result in its termination from this program and such other actions as may be appropriate.
Parks participating in this program must report on financials annually, in conjunction with required reporting on cooperating associations and authorized philanthropic partnerships.
These campaigns succeed or fail based on how informed, inspired, and engaged employees are, as well as the in-park operator’s ability to set up the infrastructure to process the donations. Transparency about use and impact is critical to the success of this program. Many organizations have identified best practices for checkout counter donation programs, and we encourage participants to seek them out.
Program Termination
Unless otherwise noted in the Authorization, the following terms will apply:
- The program can be suspended by any party pending resolution of issues it may have identified.
- The program may be terminated by the NPS or participants with ten business-days' notice if issues triggering program suspension cannot be resolved.
- Upon termination, all revenue and associated reporting must be transferred to the recipient organization no later than one month after termination.
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 FY 22, parks will be required to provide this information through this web-based reporting system. Each year the system will generate a publicly accessible directory similar to this one, generated from the summer data call to parks. 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: June 3, 2024