Reference Manual 21 -- Chapter 5

Note: This page contains Chapter 5 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 August 13, 2019
Revision to order of callout boxes 10/22/2019

On this page:

5.0 Donor Review

• 5.1.1 Prohibited Sources
• 5.2 Evaluation Factors
• 5.3 Process for Vetting Donations Made Directly to the NPS
• 5.4 Review of Indirect Donations and Contributions to Partners
• 5.5 Acceptance of Donations from Donors Involved in Litigation

5.0 Donor Review

Throughout the history of the National Park Service, parks have benefitted from the generosity and engagement of individuals, families, foundations, corporations, and other organizations. In working with both those who donate directly to the NPS and those who donate through authorized non-profit partners, the NPS must ensure that donation review and acceptance procedures protect the agency’s reputation and fulfill its fiduciary responsibilities to the public.

This chapter describes the Donor Review Process, requiring NPS review of all proposed donations, gifts, and cause marketing campaigns prior to acceptance (unless exemptions outlined in section 5.3.3 apply).

The information gathered and reviewed in the donor review process will provide the basis for an informed decision by which to,

(1) accept a donation,
(2) decline a donation, or
(3) defer acceptance until certain conditions are met.

The following definitions apply to all sections of RM-21:

• Direct Donations: Donations made directly to the NPS and may include cash, services, or tangible personal property. For a list of donation categories of direct and indirect donations, see DO21, Section 4.1
• Indirect Donations: Donations made directly to a non-profit partner of the NPS, with the partner subsequently making the donation to the NPS. For a list of donation categories of direct and indirect donations, see DO21, Section 4.1
• Donor Review (or donor vetting): A process that needs to be carried out prior to Donation Approval or Acceptance (definitions below). Donor review or vetting refers to the process that occurs during the consideration of a donation. The donor review process must occur prior to donation acceptance, which refers to the act of actually accepting a donation on behalf of the NPS. Note that an employee may have the delegated authority to accept, but not vet the donation (and in some instances where the authorized employee has a high dollar acceptance threshold, the reverse may be true).
• Donation Approval: When the donor review is done by someone other than the Authorized Employee, the donation must be approved before it can be accepted. For donations over $250,000, the vetting process is conducted by the WASO Partnership Office and approved for acceptance by the Assistant Director for Partnerships and Civic Engagement. Regional policies govern vetting procedures and approval for donations of less than $250,000. Once the authorized employee receives the results from the donor vetting process from WASO, region, or assigned park staff, the authorized employee may approve acceptance of donations from this individual or organization for a period of one year as long as the amount of a donation does not trigger a higher level of review than what was already conducted.
• Donation Acceptance: The process of the Authorized Employee accepting a donation(s) that is within their approved dollar threshold from the donor who has been approved through the vetting process. See 3.1.3.1 Delegations of Authority for Authorized Employees. Acceptance can only occur after the appropriate level of authority conducts Donor Review/Vetting described in this chapter and approves the donation for acceptance.

Donor Vetting Thresholds

Donation Type	Donation Value	Vetting Responsibility
Direct (to NPS)	Under $250,000	Reviewed and approved for acceptance at the Regional level, unless region has delegated this responsibility to a park or program*
Direct (to NPS)	$250,000 and greater**	Reviewed and approved for acceptance at the Assistant Director of Partnerships and Civic Engagement (ADPCE) level through the WASO Partnership Office (See RM Section 5.3 for guidance)**
Indirect (to partner, for NPS)	Under $500,000	Reviewed by partner (See RM Section 5.4 for guidance)
Indirect (to partner, for NPS)	$500,000 and greater	Reviewed and approved for acceptance at the Assistant Director of Partnerships and Civic Engagement (ADPCE) level through the WASO Partnership Office (See RM Section 5.3 for guidance)

*Per DO21, Authorized Superintendents and Program Managers can accept donations up to $100,000 (unless a higher amount is delegated to them); however, they are not given a vetting threshold. This means that it is up to the Regional Office and Regional Partnership Coordinator to communicate vetting responsibilities under $250,000. It is recommended that the Regional Office and Regional Partnership Coordinators determine and communicate to park Superintendents and program managers their vetting responsibilities and thresholds, for donations valued below $250,000.For guidance on setting vetting requirements for smaller donation amounts, (for example, those contributed through donation boxes or through online giving), please see Section 5.3.
**Direct donations above $250,000 must be reviewed at the WASO level as required by the Department of the Interior (374 DM 6).

5.1.1 Prohibited Sources

NPS policy is to decline direct donations for its parks, projects, and programs from:

• Concessioners or those seeking a concessions contract, or others where the donation would appear to unduly influence the NPS (this does not prohibit an authorized philanthropic partner from accepting donations from these sources for NPS projects, nor does it prohibit an authorized philanthropic partner with a Category III Concession Contract for convenience items from donating to a park);
• Sources that would identify the NPS with tobacco or any illegal products;
• Sources that would generate controversy, harm public confidence, or associate the NPS with products that are inconsistent with our mission, or require activities that circumvent Federal regulations or ethics rules; or
• Donors involved in litigation with the Department or its bureaus, except under circumstances described in Section 5.5.

Concessioners

In general, concessioners or those in the process of seeking or renewing a concessions contract are prohibited from donating directly to the NPS or its parks and programs. This is to avoid a conflict of interest and the appearance that the donation is unduly influencing the NPS when issuing concessions contracts. Regional Concessions Coordinators or Solicitors can advise on which concessioners are currently in the bidding process. However, under the following exceptions concessioners are authorized to make philanthropic donations that are intended to benefit the NPS or its parks and programs:

• If a concessioner makes a donation that is accepted by an authorized philanthropic partner
• If the donation comes from an authorized philanthropic partner with a Category III Concession Contract (for convenience items)

Alcohol Beverage Companies

Per DO #21, the NPS may permit philanthropic partnerships with and accept donations from corporations that produce and/or distribute alcohol (“Alcoholic Beverage Companies”), pending the review and approval by the Director.

These types of philanthropic partnerships are often defined as cause marketing and can take the form of point-of-sale, purchase or action-triggered donation, licensing, message promotion, employee engagement, and digital programs. The NPS will not allow any promotion that advertises a corporate brand, service, product, or enterprise to use the NPS Arrowhead symbol, an NPS employee, any part of the NPS uniform, or other elements of NPS intellectual property. The NPS considers full, official names of parks and unit names as proprietary and protected under common law trademark. Note that the use of park, unit, or program names on alcohol beverage labels requires approval of the NPS. In a separate transaction, alcohol beverage labels are reviewed by the Department of the Treasury’s Alcohol and Tobacco Tax and Trade Bureau (TTB), as required by law. In order to streamline the approval of the labels, NPS Partnership offices, the Alcohol Beverage Company, and the TTB coordinate their review of the proposed labels.

This section of the reference manual provides clarity on which types of partnerships with Alcoholic Beverage Companies require approval from the Director and/or from regional offices. Key factors in determining which level in the organization approval or disapproval would come from include:

• whether the relationship is direct or indirect;
• the size and scope of the relationship;
• if the reach is local, regional, or national; and/or
• whether the company is already working with another park partner.

Please note that NPS policy encourages cause marketing campaigns including relationships with alcohol producers/distributors, to be run through a philanthropic partner.

Direct Donations and Partnerships with Alcoholic Beverage Companies

Direct donations and partnerships are those that are directly between the NPS and the Alcoholic Beverage Company. NPS policy encourages cause marketing campaigns, including relationships with Alcoholic Beverage Companies, to be run through a philanthropic partner. Where a park or program has determined such a direct relationship between the NPS and an Alcoholic Beverage Company is of interest, NPS Director’s approval is required with one exception described below.

The NPS Director’s approval is required for direct relationships with companies whose primary function is the production and/or sale of alcoholic beverages at a wholesale or retail level. For example, a cause relationship with a multinational corporation that produces and/or distributes beer would need this type of approval, as would a regional winery or brewery that primarily serves a local consumer base.

To seek consideration for approval, the NPS park or program site shall submit a memo to the Director, routed through their regional or program office. Requirements and a sample memo are included at the end of this chapter.

The NPS Director’s approval is NOT always required for direct relationships with companies who distribute alcohol not as a primary function, but as one complementary to its overall mission. For example, relationships with restaurants, banquet halls and hotels do not require the Director’s approval, since these facilities are not producing alcoholic beverages and the sale of alcohol is not their primary function. A winery, distillery, or brewery would fall into this category if the product is being served in an onsite restaurant or bar. However, if a product is branded with any NPS intellectual property as part of a relationship - then Director’s approval is required.

In any relationship with a business, the park should consult and follow the guidance on cause marketing in DO#21, Section 4.3.1.1.

Indirect Donations and Partnerships with Alcoholic Beverage Companies

As noted, most times, any relationship with Alcoholic Beverage Companies, will be between the company and the park philanthropic partner. NPS review and approval would only be required if the use of park, unit, or program names (or other NPS intellectual property) is proposed for use on packaging, labels, or marketing, or if language about a partnership benefitting the park, unit, or program is proposed for use on packaging, labels, or marketing.

When NPS review and approval is required, it will be conducted by either the regional office (e.g., campaigns involving NPS regional programs or parks within one region) or by the WASO Office of Partnerships and Philanthropic Stewardship (e.g., campaigns over $250,000 or involving parks or programs in more than one region). The Office of Partnerships and Philanthropic Stewardship will review cause marketing campaigns involving national programs or initiatives. In addition to reviewing all program collateral (marketing materials, table tents, beer labeling, etc.) for use of NPS intellectual property, NPS will review the messaging to ensure it does not undermine the NPS brand values. For example, messaging should not encourage overindulgence with phrases like “get buzzed for pollinators” or “get hammered for historic restoration”.

Small scale, local events between a park partner or NPS program and a local winery, distillery, or brewery/brewpub require consultation with your Regional Partnership Coordinator and adherence to the guidance on cause marketing in DO #21, Section 4.3.1.1.
For any partnership with an Alcoholic Beverage Company that extends beyond a local community or is likely to generate significant publicity, your Regional Partnerships Coordinator is required to consult with the WASO Office of Partnerships and Philanthropic Stewardship to determine if it should be submitted for Director’s approval as described above for Direct Donations.

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Exercise Caution

There are many examples of breweries, distilleries, wineries, and local restaurants/pubs, etc serving their products on designated nights where varying levels of proceeds go to local charities or non-profits.  These go by many names: Pints for Pets, Bats and Brews benefit, Pour a Glass for, etc. These local cause marketing efforts do not require the approval of the NPS Director unless they extend beyond a local community or are likely to generate national publicity.  However, the benefiting park or program should still consult with their Regional Partnership Coordinator. 

NPS employees’ participation in these events (while on duty) should follow the guidelines provided in the Events and Public Speaking section of RM-21 Chapter 3. Specifically, an NPS employee may:

• Attend in official capacity and through remarks or participation acknowledge donors and the partner’s work in meeting NPS needs.
• Wear a uniform if attending in an official capacity. 
• Acknowledge that a partner is authorized through a formal agreement to fundraise in support of the NPS and identify ongoing and completed fundraising efforts of the partner in support of NPS needs.
• Participate as an NPS subject-matter expert to explain NPS needs and provide helpful context and content.

Additionally, a uniformed NPS employee may conduct an outreach program as appropriate. 

Finally, since participation in such events involves alcoholic beverages, it is important for NPS staff to be aware of any perception that may be associated with their consumption. Note that the reference manual for DO43 states that “employees are specifically prohibited from purchasing or consuming alcoholic beverages, whether on or off duty,” while wearing the NPS uniform. Caution should also apply to wearing Arrowhead pride-wear or readily available uniform components at such events.
 

National Level Partnerships with Alcoholic Beverage Companies

National campaigns between philanthropic partners and Alcoholic Beverage Companies where the messaging ties back to the National Park Service or support of a park would need to be reviewed by Region or WASO. NPS review and approval would be required if the use of park, unit, or program names (or other NPS intellectual property) is proposed for use on packaging or labels or if language about a partnership benefitting the park is proposed for use on packaging or labels.

National campaigns between philanthropic partners and Alcoholic Beverage Companies, where the messaging does not tie back to the National Park Service or support of a park, would be reviewed only to confirm that the NPS (park or program) is not mentioned.

Exercise Caution

The use of park or program names on bottle labels or packaging requires review by WASO PPS and SOL and written approval by WASO PPS. 

The use of full park, unit, or program names (or other NPS intellectual property, including the outline of the NPS Arrowhead or a colorable imitation) as the name or part of the name of the product will not be approved and would constitute a violation of NPS trademarks.  
Branding associated with a general location or feature within a national park or a generic reference to the park is permitted (e.g., Highland Brewing Company produces a “Balsam Mountain Brown” to celebrate the Balsam Mountain Campground in Great Smoky Mountains National Park,  or the Southbound Brewing Company produces “Pulaski Pilsner” to honor Fort Pulaski National Monument”).

In addition, the NPS considers full, official names of parks and unit names as proprietary and protected under common law trademark. A beverage or commercial product name that incorporates full, official park or unit names may confuse the consumer as to the origin of such product or distort the mission of NPS.  Thus, the NPS only permits beverages with shortened park names or unrelated branding (e.g., Kennesaw Park Kolsch would not be approved while Kennesaw Kolsch could be approved). In particular, brand names of the product may not incorporate full, official park or unit names.  

The Department of the Treasury’s Alcohol and Tobacco Tax and Trade Bureau (TTB) is the federal entity charged with approving the labels and packaging of alcoholic beverages.  The NPS is often contacted by the TTB to confirm that the use of NPS intellectual property has been authorized.  To prevent delays, misunderstandings, or rejections, NPS should thoroughly review any submissions of labels or packaging by the alcoholic beverage producer and forward this authorization to TTB to streamline their separate labeling process. 

5.2 Evaluation Factors

Through a donor-review process, NPS employees and partners are required to consider and evaluate a donation based on the factors listed in this section in order to understand if the donation could impact the public confidence in the integrity and impartiality of the employees and programs of NPS and DOI.

While partner processes for evaluations may vary (see Section 5.4 Indirect Donations) from NPS processes, and are subject to their own internal policy, it is important to use these factors as a guideline for evaluating a proposed donation that will benefit the NPS.

The information obtained during the evaluation will enable authorized employees or those approving a donation to weigh the totality of the circumstances and make a decision on whether to accept or decline a donation. This means that when reviewing a proposed donation, all factors must be considered relative to the donation. When examining the totality of the circumstances, one evaluation factor should not outweigh the rest, in the context of a specific proposed donation. (RM-21 Section 5.3: Process for Vetting Donations Made Directly to the NPS, provides guidance on how to carry out this vetting process from an NPS standpoint.)

When evaluating a donation, the following factors should be used as a guide in order to maintain integrity, impartiality, and public confidence in NPS and DOI (see also Departmental Manual, Part 374, Chapter 6.6). (There is a Donor Review Decision Worksheet that can be downloaded in Section 5.3 below.)

• Will acceptance of the donation maintain the integrity of the NPS and the Department’s programs and operations:
  • The value and any applicable conditions of the donations, including whether the donation is expected to be included in marketing or advertising.
  • The donation neither is, nor appears to be (such as by its size or circumstances), an attempt to influence the exercise of any NPS or Departmental regulatory or other authority.
  • The donation meets a legitimate NPS need.
  • The donation does not require the commitment of funding that is not planned or available.
  • The donation is consistent with and does not otherwise circumvent law, regulation, or policy.
  • Any conditions or restrictions on the donation are consistent with policy, authorized purposes, or applicable plans.
  • NPS is able to properly and effectively use and manage any donated real or personal property consistent with policy, programmatic, and management goals.
  • The donor will not use the donation to state or imply NPS endorsement of the donor or the donor’s product or services.
  • The donation, if it involves temporary or term personnel or provides funding to hire temporary or term personnel, is structured in such a manner that these personnel do not inappropriately influence any regulatory actions or other significant decisions.
• Will acceptance of the donation maintain the impartiality, and the appearance of impartiality, of the NPS, the Department, and their employees:
  • The proposed donation is made to a park or program, or made in an amount that would not influence or appear to influence any significant pending NPS or Departmental decision or action involving the donor’s interests. There is neither an actual nor an implied commitment to take an action favorable to the donor in exchange for the donation.
  • The donor will not obtain or appear to obtain special treatment in dealing with the NPS, the Department, or any of its bureaus.
  • Please see RM Section 5.5 if potential donor is involved in litigation with the Department or NPS.
  • Whether the donor is seeking or is otherwise engaged in any type of financial or business relationship with the Department, for example: a contract, permit, lease, grant or cooperative agreement (See RM Section 5.3 Donor Vetting Process for guidance).
• Will acceptance of the donation maintain public confidence in the NPS, the Department, and their programs and employees:
  • Acceptance would not likely result in public controversy.
  • The donor complies with NPS public lands rules and regulations.
  • The donation comes only with conditions that are consistent with NPS program and policy goals.
  • The donation consists of only goods or services needed by the NPS.
  • The donor has not been debarred, suspended, proposed for debarment, excluded or disqualified under the nonprocurement common rule, or otherwise declared ineligible from doing business with any Federal government agency as specified in the CFR (See RM Section 5.3 Donor Vetting Process for guidance).

5.3 Process for Vetting Donations Made Directly to the NPS

Parks and programs are expected to work with their in-park Partnership liaisons (where applicable) and Regional Partnership Coordinators to determine a donor vetting process that best fits their capacity. When designing a schedule and process for donor review, it may be beneficial to follow the model that has allowed WASO Partnership Office to effectively review donors who meet the WASO vetting threshold.

This section details the levels at which parks, programs, regions, and WASO are authorized to vet donations and provides information on how to carry out an effective donor review.

1. Determining Donor Vetting Requirements

When vetting a potential donation, first determine who is responsible for carrying out the donor review process by consulting the Donor Vetting Thresholds table in Section 5.0 at the beginning of this chapter. The value of the donation will determine the level at which the review will be conducted. Once you have made this determination, you can begin.

2. Carrying Out Your Review

Vetting Direct Donations under $250,000:

Note: Direct Donations refer to donations made directly to the NPS and may include any of the donations described in DO21, Section 4.1.

While partners and WASO share review responsibilities with parks and programs, all direct donations below $250,000 will be vetted by NPS employees at the park, program, or regional level (check with your Regional Partnership Coordinator for the level your park or program is authorized to vet). For donations that may be complicated or could benefit from a national level review, park, program, and regional partnership coordinators may request WASO review of a donation below $250,000.

The Regional Partnership Coordinators should work with Regional Directors to design a region-specific plan for vetting donations under $250,000. This plan will determine park or program-based thresholds and will delegate authority to parks and programs to vet donations based on their own capacity. For example, a region may determine that one of its parks with robust resources and experience in navigating partnerships has the authority to vet donations at a higher threshold (still under $250,000), than a park lacking this capacity.

Smaller Scale Donations: The regional office will determine which (if any) vetting requirements are logical to apply to reviewing donations of a relatively small dollar amounts that may be received in the form of a personal check placed in a donation box or sent through the mail or through online giving. Generally these are less than $1,000. When determining requirements consider the context with which the donation was made and ensuring the amount of the donation would not reasonably appear to curry favor on a donor or create a conflict of interest.

For more information on the process of determining vetting responsibilities, refer to the Donor Review Responsibilities Flow Chart.

While each region, park, and program may have their own unique vetting processes, certain key features must be present to ensure that potential donations share mission alignment with the NPS and meet the Evaluation Factors outlined in DO21 Section 5.2. Ideally, a donor review process will be similar to the process conducted by WASO, which may act as an example of best practice for parks, programs, and regions.

An effective donation review process has several key features that, at minimum, will ensure that an accepted donation maintains NPS integrity, impartiality, and public confidence.

When conducting your review, determine if the donation meets the Evaluation Factors outlined in DO21 Section 5.2 by completing the following Donor Review Checklist and Donor Review Decision Worksheet.

Vetting Considerations:

• Is the donation from a prohibited source: See RM Section 5.1.1 Prohibited Sources for guidance.
• Is the donor involved in litigation with the NPS or Department: See RM Section 5.5 Acceptance of Donations from Donors Involved in Litigation for guidance.
• Is the donor seeking, or otherwise engaged, in any type of financial or business relationship with the NPS or Department, for example, a contract, permit, lease, grant, or cooperative agreement.
• Is the donor debarred, suspended, proposed for debarment, excluded or disqualified under the nonprocurement common rule, or otherwise declared ineligible, from doing business with any Federal government agency as specified in the CFR.
• Is the donation expected to be connected with marketing or advertising (requires Directors approval for corporate partnerships). See DO21 Section 4.
• What is the value and any applicable conditions of the donation.
• Is the donation a singular event or part of a series of donations. Note: If the donation is part of a series of donations, it may reach an amount that requires a higher review level (please refer to the review requirements chart in RM Section 5.3).
• Whether the donor is associated with controversy that may impact the public confidence in the NPS, the Department, and their programs and employees.

Resources to Research Vetting Considerations: Use the following resources to gather the information that will help you determine if the vetting evaluation criteria is met.

• NPS Programs and Offices: It is recommended that Regional Partnership Coordinators (unless otherwise delegated to park level) collaborate with program managers from the following regional programs to effectively review the scope of a donation.
• Commercial Services: To review financial and business affiliations between the donor and the NPS, including their association with NPS commercial service operations.
• Special Park Uses: To assess the extent of financial and business affiliations between the donor and the NPS, including those involving permits and leases.
• Natural Resources: To determine if there is a donor connection, and associated litigation, to NPS resource damage.
• Contracting: To identify the contractual relationships between the donor and the NPS.
• Solicitor’s Office: To determine if the donor is involved in litigation with the NPS or DOI.
• Internet Searches:
• FPDS: The Federal Procurement Data System provides information on companies engaged in government contracts. Search results can be narrowed down to department and agency. This search provides the total dollar amount of NPS contracts the organization(s) engaged in within the last four years and should be utilized when considering whether a proposed donation may impact the integrity or impartiality of the NPS.
• SAM: The System for Awards Management is a database that provides information on companies who have been excluded from contracting with the federal government.
• NRDAR: Use this website when a review indicates that a potential donor is involved in a Natural Resource Damage Assessment and Restoration case with the department. This website provides case information and documents, which will help identify the scope of a potential donor’s involvement in the damage, their legal relationship with the department and agency and their participation in the restoration.
• EPA Superfund: When the review indicates that a potential donor is involved with an Environmental Protection Agency Superfund site, a search of this website will be beneficial (the Regional Solicitors Office will flag this in their review). This website provides information related to each case, which will help identify the scope of a potential donor’s involvement in the damage, the impact to NPS and DOI lands, their legal relationship with the department and agency, and their participation in the restoration.
• News Search: A search for news about a potential donor should be conducted to ensure that a potential donation maintains NPS integrity and public confidence, aligns with the NPS mission, and will not likely result in public controversy. A simple internet news search of the company will provide information on the company's recent news stories. The WASO process is to review news from the past four years.

Additional guidance regarding research methods can be found in the Research Web Links Tool.

3. Approving and Accepting the Donation

Once the donation has been vetted it must be approved for acceptance. Donations under $250,000 must receive the final vetting determination and approval as outlined in the regional vetting plan. The authority to accept donations on behalf of the NPS must be delegated by the Director. NPS employees who have been delegated this authority are designated as “authorized employees,” see 3.1.3.1 Delegations of Authority for Authorized Employees. Once a donation has been successfully vetted and approved for acceptance, the authorized employee should conduct a final review of the findings. This review is to ensure the vetting did not reveal new information that while not of concern at a national or regional level may be an issue at a local level and could influence the decision to either accept or forgo the donation.

A record should be kept of accepting the donation. See DO21 Section 4 for recordkeeping requirements.

4. Closing Out

Once the Authorized Employee or the person conducting the vetting has decided to approve or decline the donation, the vetting results should be recorded for future reference. Potential donors are reviewed once per year and, once approved, remain so for one year unless their donation total for the year triggers a higher evaluation requirement.

Vetting Direct Donations at or greater than $250,000

Direct donations that may reach a dollar value of $250,000 or higher, require vetting through offices at WASO and DOI (DM Part 374 Chapter 6). The Office of Partnerships and Philanthropic Stewardship (Partnership Office) facilitates the reviews.

The Partnership Office carries out vetting once per month. This vetting cycle takes approximately three to four weeks.

• The monthly vetting cycle is initiated the 4th Monday of each month, when partners, parks, and programs submit their donor review list to their Regional Partnerships Coordinator, who will forward the list to the WASO Partnerships Office.
• The 1st Monday of each month, the Partnership Office sends submissions to WASO and DOI reviewers.
• The 3rd Monday of each month, reviewers send vetting results to the Partnership Office, who processes responses and emails final results to requesters. In rare cases, additional review time may be needed when the vetting process reveals concerns that may affect the NPS’ ability to accept a donation.

1. Submitting Your Donation review List to WASO
Send your list of potential donors to the WASO Partnership Office:

• As soon as you think an entity or individual is interested in making a donation or
• During the prospect research phase of fundraising to avoid a situation where a donation would have to be declined after it is solicited.

Submission Requirements:

• Use the Donor Vetting Submission Template to submit the following information:
  1. Your contact information (include your Region, Phone, and Email Address)
  2. Submission Month and Year
  3. Friends/Partner Group name and Name of Recipient Park or Program
  4. Donor Name (corporation, foundation, organization, or individual)
  5. The Donor's Headquarters or Home City, State and Website
  6. Description/purpose of the donation (ex. for Visitor Center exhibits)
  7. Donation dollar amount (if known). Indicate if the donation amount will be $1,000,000 or greater.
• Email your donor vetting submission list to the Program Analyst position of the Office of Partnerships and Philanthropic Stewardship.

For details of the WASO Partnership Office vetting process (which is outlined in RM-21 Section 5.3), you may refer to the WASO Donor Vetting Process flowchart.

2. Reviewing Results and Donation Approval
After the Partnership Office completes the donor vetting, the results indicating approval or disapproval to accept the donation will be emailed to the employee who submitted the donor vetting request. Donors are reviewed once per year and, once approved, remain so for one year from approval date unless their donation total for the year triggers a higher evaluation requirement.

3. Accepting the Donation
Once the donation has been vetted and approved, it can be accepted. The authority to accept donations on behalf of the NPS must be delegated by the Director. NPS employees who have been delegated this authority are designated as “authorized employees,” See 3.1.3.1 Delegations of Authority for Authorized Employees. Once a donation has been successfully vetted and approved for acceptance, the authorized employee should conduct a final review the Vetting Considerations [link] to ensure the vetting did not reveal new information that while not of concern at a national level may be an issue at a local level and could influence the decision to either accept or forgo the donation.

5.4 Review of Indirect Donations and Contributions to Partners

Partners play a crucial role in the process of reviewing donations that will ultimately further the NPS mission. Many donations made to NPS partners are expressly for purposes that support, enhance, and maintain parks. These donations, made to partners with the understanding that they will be donated to the NPS, are referred to as indirect donations. NPS accepts these donations given that the gift conforms to the requirements of their philanthropic agreement and DO21 and supports a jointly identified need of the NPS and its nonprofit partner through a philanthropic agreement or annual work plan.

When these indirect donations are valued in excess of $500,000, NPS is required to vet the potential donation through its own donor review process. Partner organizations who have a philanthropic partnership agreement with the NPS may conduct their own review of indirect donations under the $500,000 threshold.

While each organization has unique capabilities and thus has their own unique vetting process, certain key features should be present within their review process to ensure that potential indirect donations share mission alignment with NPS. Ideally, a partner’s donor review process will be similar to NPS processes (see the "Vetting Donations at or Greater than $250,000" portion of RM-21 Section 5.3), which may act as an example of best practice for organizations with less donor vetting experience. A partner’s proposed vetting process for indirect NPS donations should be communicated with its partner park or program (through the gift acceptance policy of a philanthropic agreement) to ensure that it meets NPS standards.

In some cases, including when a donation is made in relation to a cause-marketing campaign or when the donation comes from a producer/distributor of alcoholic beverages, indirect donations must be reviewed by NPS, regardless of the donation amount.

Note: Anonymous donations or donations made to partners to support their general administrative/operational needs or for partner programs and projects that do not involve NPS are not subject to NPS donor review policies.

5.5 Acceptance of Donations from Donors Involved in Litigation

A donation from an entity or an individual involved in litigation with the Department or its bureaus may be seen as an attempt to influence the handling or outcome of legal disputes or litigation. Therefore, the NPS will decline any gifts or donations that appear to do so. However, in some cases, the context of the litigation and donation may allow for donation acceptance. This section details these exceptions.

As part of the vetting process described in Section 5.3, the reviewer should receive notice from the appropriate solicitor regarding the status of a potential donor and whether it is currently involved in litigation with DOI, NPS, or any other departmental agencies. If a potential donor is, in fact, in litigation with DOI or one of its agencies, there are a few factors that should be considered to further analyze the decision. The NPS will normally decline a gift from a donor involved in litigation with the Department or its bureaus but when analyzing the context of the donation and litigation, the person conducting the vetting should consider:

• The geographic proximity of the litigation to the park or program that the donation is intended to benefit and whether the affected area in litigation is in close proximity or affects the region receiving the donation;
  • Watershed or Ecosystem
  • State level
  • NPS Region level
• The donor’s programmatic relationship with the recipient of the donation and if the proposed donation is intended to benefit a program area that may influence all or part of the litigation at hand; and
  • National program
  • Region based program
  • Park based program
• The relationship of the decision maker to the potential donation and if the employee or partner is sufficiently removed from the donation/donor.

In some cases, the context of the proposed donation may be sufficiently removed from the litigation that it will not appear to be an attempt to influence the litigation. For example, a donor may propose a donation to an NPS region that is unrelated to where the litigation is, or the litigation may involve another bureau, or the amount of the donation does not suggest any intent to influence the handling of the litigation. In general, over the course of the vetting, if a reviewer finds that a donor is involved in litigation with DOI or its bureaus, the donation should be rejected, unless the context of the litigation and donation do not appear to be connected or imply a conflict of interest.