Transparency Talk

Category: "Accountability" (90 posts)

Transparency & Start-up Philanthropy: What We Can Learn from Bezos and Zuckerberg
October 11, 2018

Janet Camarena is director of transparency initiatives at Foundation Center.

Janet Camarena PhotoIt’s hard to think of a philanthropic institution as a start-up. The phrase “start-up” conjures the image of two geeks in a garage with big dreams but very limited means. But as we all know from breathless news coverage about them, some of these once resource-constrained, scrappy start-ups have gone the distance, hit it big, and now are learning the ropes of managing another kind of start-up—the philanthropy kind.

I was recently reminded of this trajectory when a reporter from CNBC contacted me to ask me about Jeff Bezos’ new Day One Fund for a story he was working on about the announcement that Bezos and his wife, novelist MacKenzie Bezos, were establishing a $2 billion philanthropic fund to help support homeless initiatives and early childhood education for low-income children. As a tech reporter, he was asking a lot of good questions to better understand the nature of organized philanthropy.  He wanted to know about things like the structure of the fund, where the funds would come from, what kind of philanthropic vehicle it might be, and the transparency and tax regulations for each kind of vehicle.

I had a strong sense of déjà vu, as I realized I’d had a very similar conversation about 18 months ago when Mark Zuckerberg and Priscilla Chan announced the launch of the Chan Zuckerberg Initiative (CZI). In choosing to structure CZI as an Limited Liability Corporation (LLC), and not a private foundation or nonprofit entity, they launched a global debate that put philanthropic transparency on the map like never before. Unlike private foundations, LLCs are not required to provide details on giving, are able to fund both for profit and nonprofit entities, and there is no transfer of funds to an entity that is regulated to serve the public good. So, suddenly topics usually reserved for the geekiest of foundation geeks--tax code, philanthropic vehicles, and the difference between traditional philanthropy and the LLC approach --were being covered by everyone from The New York Times to San Jose Mercury News.

In Bezos’ case, it’s unclear as of this writing how the Day One Fund will be structured or when we might learn more. But Axios reported last month that according to public records, the couple had “incorporated a nonprofit in Washington State called Bezos Foundation, and someone reserved the name ‘Bezos Day 1 Foundation’ for a nonprofit.”

”Philanthropic transparency is very important to building public trust and credibility for institutional giving.“

The announcement did answer long standing speculation and questions that began more than a year ago, when Bezos started a crowd-sourcing experiment asking the world via Twitter to suggest philanthropic ideas to him at the “intersection of urgent need and lasting impact.” The inquiry led to more than 46,000 responses, and much speculation about what the eventual philanthropic mission would be. In his announcement Bezos described two groups within the Day One Fund: The Day 1 Families Fund, which will support homeless support organizations such as Mary’s Place in Seattle; and the Day 1 Academies Fund, which is to fund the launch of a network of Montessori pre-schools for low-income children.

What might be most surprising to Bezos is that though his September announcement puts the focus area questions and speculations to rest, it has created a whole host of new questions about the Fund. This led me to think about our mission at GlassPockets around championing greater philanthropic transparency, and what that might look like for a start-up fund.

Philanthropic transparency is very important to building public trust and credibility for institutional giving. This is particularly true for large, highly visible, and new philanthropic initiatives but could be a helpful guide for other emergent philanthropies. So beyond the social media and the press release, what’s a newly minted philanthropist supposed to share? Based on our “Who Has Glass Pockets?” self-assessment tool, as well from the questions we get from reporters and researchers, here are some suggestions of how to think about telling the story of your start-up philanthropy:

  • Even if short on details, establish a website where people can go to look under the hood and learn more details about the work the philanthropy plans to do, how it plans to do it, and how people can stay informed of new developments. Sunlight Giving, which is a philanthropy that started up in 2014 as a result of the sale of WhatsApp to Facebook, and has already joined the GlassPockets transparency movement, made it a point to establish a website and commit to transparency early on.
  • What motivated the establishment of the fund and the issue areas? Mark Zuckerberg and Priscilla Chan provide a great example of this as the announcement for the launch of CZI was inspired by the birth of their daughter to whom they dedicated the Initiative’s vision in a “Dear Max” letter format.
  • What is the scale of the giving and what is the source of the funds?
  • How will the fund be structured? Is it a private foundation, a donor-advised fund, a limited liability corporation, or a supporting organization of a community foundation? Of these structures, the private foundation provides the most transparency because of the annual 990-PF filing detailing foundation finances, grants, and payout among other disclosures.
  • Who will be running the fund? And if it’s structured as a nonprofit, who will comprise the board of directors? Is it exclusively family members on the board, or a mix?
  • How and who will select grantees? What will the grantmaking process look like? Since this is not likely to be defined at the start-up stage, share a target date by when you hope to have this information available.
  • How will the funders get input from the communities they seek to serve? And how else will the funders learn about the issues they have identified?
  • Through what mechanism will grants and other announcements be made in the future?

It may seem like a long list, but by opening up the playbook and speaking from the heart, a new philanthropist can inspire others with their vision rather than inspiring the suspicion that inevitably comes with opacity.

--Janet Camarena

Data Fix: Do's and Don'ts for Data Mapping & More!
October 3, 2018

Kati Neiheisel is the eReporting liaison at Foundation Center. eReporting allows funders to quickly and easily tell their stories and improve philanthropy by sharing grants data.

This post is part of a series intended to improve the data available for and about philanthropy.

KatiNeiheisel_FCphotoAs many of you know, Foundation Center was established to provide transparency for the field of philanthropy. A key part of this mission is collecting, indexing, and aggregating millions of grants each year. In recent years this laborious process has become more streamlined thanks to technology, auto-coding, and to those of you who directly report your grants data to us. Your participation also increases the timeliness and accuracy of the data.

Today, over 1300 funders worldwide share grants data directly with Foundation Center. Over the 20 years we've been collecting this data, we've encountered some issues concerning the basic fields required. To make sharing data even quicker and easier, we've put together some dos and don'ts focusing on three areas that may seem straightforward, but often cause confusion.

Location Data for Accurate Mapping and Matching

Quite simply, to map your grants data we need location information! And we need location information for more than mapping. We also use this information to ensure we are matching data to the correct organizations in our database. To help us do this even more accurately, we encourage you to provide as much location data as possible. This also helps you by increasing the usability of your own data when running your own analyses or data visualizations.

DO DON'T
Do supply Recipient City for U.S. and non-U.S. Recipients. Don't forget to supply Recipient Address and Recipient Postal Code, if possible.
Do supply Recipient State for U.S. Recipients. Don't supply post office box in place of street address for Recipient Address, if possible.

Do supply Recipient Country for non-U.S. Recipients.

Don't confuse Recipient location (where the check was sent) with Geographic Area Served (where the service will be provided). 

What's Your Type? Authorized or Paid?

Two types of grant amounts can be reported: Authorized amounts (new grants authorized in a given fiscal year, including the full amount of grants that may be paid over multiple years) or Paid amounts (as grants would appear in your IRS tax form). You can report on either one of these types of amounts – we just need to know which one you are using: Authorized or Paid.

DO DON'T
Do indicate if you are reporting on Authorized or Paid amounts. Don't send more than one column of Amounts in your report – either Authorized or Paid for the entire list.
Do remain consistent from year to year with sending either Authorized amounts or Paid amounts to prevent duplication of grants. Don't forget to include Grant Duration (in months) or Grant Start Date and Grant End Date, if possible.
Do report the type of Currency of the amount listed, if not US Dollars. Don't include more than one amount per grant.

The Essential Fiscal Year

An accurate Fiscal Year is essential since we publish grants data by fiscal year in our data-driven tools and content-rich platforms such as those developed by Foundation Landscapes, including Funding the Ocean, SDG Funders, Equal Footing and Youth Giving. Fiscal Year can be reported with a year (2018) or date range (07/01/2017-06/31/2018), but both formats will appear in published products as YEAR AWARDED: 2018.

DO DON'T
Do include the Fiscal Year in which the grants were either Authorized or Paid by you, the funder. Don't provide the Fiscal Year of the Recipient organization.
Do format your Fiscal Year as a year (2018) or a date range (07/01/2017-06/31/2018). Don't forget, for off-calendar fiscal years, the last year of the date range is the Fiscal Year: 07/01/2017-06/31/2018 = 2018.

More Tips to Come!

I hope you have a better understanding of these three areas of data to be shared through Foundation Center eReporting. Moving forward, we'll explore the required fields of Recipient Name and Grant Description, as well as high priority fields such as Geographic Area Served. If you have any questions, please feel free to contact me. Thank you! And don't forget, the data you share IS making a difference!

-- Kati Neiheisel

“Because It’s Hard” Is Not an Excuse – Challenges in Collecting and Using Demographic Data for Grantmaking
August 30, 2018

Melissa Sines is the Effective Practices Program Manager at PEAK Grantmaking. In this role, she works with internal teams, external consultants, volunteer advisory groups, and partner organizations to articulate and highlight the best ways to make grants – Effective Practices. A version of this post also appears in the PEAK Grantmaking blog.

MelissaFor philanthropy to advance equity in all communities, especially low-income communities and communities of color, it needs to be able to understand the demographics of the organizations being funded (and declined), the people being served, and the communities impacted. That data should be used to assess practices and drive decision making.

PEAK Grantmaking is working to better understand and build the capacity of grantmakers for collecting and utilizing demographic data as part of their grantmaking. Our work is focused on answering four key questions:

  • What demographic data are grantmakers collecting and why?
  • How are they collecting these demographic data?
  • How is demographic data being used and interpreted?
  • How can funders use demographic data to inform their work?

In the process of undertaking this research, we surfaced a lot of myths and challenges around this topic that prevent our field from reaching the goal of being accountable to our communities and collecting this data for responsible and effective use.

Generally, about half of all grantmakers are collecting demographic data either about the communities they are serving or about the leaders of the nonprofits they have supported. For those who reported that they found the collection and use of this data to be challenging, our researcher dug a little deeper and asked about the challenges they were seeing.

Some of the challenges that were brought to the forefront by our research were:

PEAK Grantmaking reportChallenge 1: Fidelity and Accuracy in Self-Reported Data
Data, and self-reported data in particular, will always be limited in its ability to tell the entire story and to achieve the nuance necessary for understanding. Many nonprofits, especially small grassroots organizations, lack the capability or capacity to collect and track data about their communities. In addition, white-led nonprofits may fear that lack of diversity at the board or senior staff level may be judged harshly by grantmakers.

Challenge 2: Broad Variations in Taxonomy
Detailed and flexible identity data can give a more complete picture of the community, but this flexibility works against data standardization. Varying taxonomies, across sectors or organizations, can make it difficult to compare and contrast data. It can also be a real burden if the nonprofit applying for a grant does not collect demographic data in the categories that a grantmaker is using. This can lead to confusion about how to report this data to a funder.

Challenge 3: Varying Data Needs Across Programs
Even inside a single organization, different programs may be collecting and tracking different data, as program officers respond to needs in their community and directives from senior leadership. Different strategies or approaches to a problem demand different data. For instance, an arts advocacy program may be more concerned with constituent demographics and impact, while an artist’s program will want to know about demographics of individual artists.

Challenge 4: Aggregating Data for Coalitions and Collaborations
This becomes even more complex as coalitions and collaborative efforts that bring together numerous organizations, or programs inside of different organizations, to accomplish a single task. The aforementioned challenges are compounded as more organizations, different databases, and various taxonomies try to aggregate consistent demographic data to track impact on specific populations.

These are all very real challenges, but they are not insurmountable. Philanthropy, if it puts itself to the task, can tackle these challenges.

Some suggestions to get the field started from our report include

  • Don’t let the perfect be the enemy of the good. Pilot systems for data collection, then revisit them to ensure that they are working correctly, meeting the need for good data, and serving the ultimate goal of tracking impact.
  • Fund the capacity of nonprofits to collect good data and to engage in their own diversity, equity, and inclusion efforts.
  • Engage in a conversation – internally and externally – about how this data will be collected and how it will be used. If foundation staff and the nonprofits they work with understand the need for this data, they will more willingly seek and provide this information.
  • For coalitions and collaborative efforts, it may make sense to fund a backbone organization that takes on this task (among other administrative or evaluation efforts) in support of the collective effort.
  • Work with your funding peers – in an issue area or in a community – to approach this challenge in a way that will decrease the burden on nonprofits and utilize experts that may exist at larger grantmaking operations.
  • Support field-wide data aggregators, like GuideStar or the Foundation Center, and work alongside them as they try to collect and disseminate demographic data about the staff and boards at nonprofits and the demographics of communities that are being supported by grantmaking funds.

Grantmakers have the resources and the expertise to begin solving this issue and to share their learning with the entire field. To read more about how grantmakers are collecting and using demographic data, download the full report.

--Melissa Sines

Meet Our New GlassPockets Foundation: An interview with Kate Fryberg of New Zealand's Te Muka Rau Charitable Trust
August 2, 2018

Te Muka Rau Charitable Trust is the first New Zealand Foundation to join the GlassPockets movement. Kate Frykberg, trustee and philanthropy advisor, explains why.

Katie 2GlassPockets: Why is Te Muka Rau prioritizing foundation transparency?

Kate Frykberg: For us, transparency is simply about being open and honest about who we are, what we do, and how our funds are spent.  I would hate people to wonder if we had anything to hide, and I think this does sometimes happen with foundations that are not transparent.  Additionally, charitable foundations receive tax benefits, so we need to clearly show that we are using that foregone tax for the public good – and that we have achieved at least as much public good as the government would have done with that tax money.

”If we are being philanthropic, we should be upfront about how we are serving our communities.“

GP: Some assume that transparency is important for larger foundations. Why do you think it's important for smaller foundations as well?

KF: We are a small foundation by New Zealand standards and we are tiny by US standards – but transparency matters whatever the size.  If we are lucky enough to live comfortably, we should, I believe, be philanthropic and share some of what we have.  And if we are being philanthropic, we should be upfront about how we are serving our communities.  Big foundation, small foundation - the concept is the same – it’s just the number of zeros in the dollar figures that are different.

That said, one size does not fit all – so it was important for us that the GlassPockets process did not issue a score that counted against us if we were not sharing all of the indicators. For example, a small foundation like us with no paid staff doesn’t need things like executive compensation processes and whistle blower policies.  So transparency needs to be able to be adjusted to fit values, purpose, and  size.  It’s really just about openness and clarity.

GP: You have lots of experience as a philanthropy consultant and also as the prior Chair of Philanthropy New Zealand. Why is philanthropic transparency important in the New Zealand context?

KF: The New Zealand context is a little different from the United States – for example there is currently no legally required annual payout amount here.  I think this makes it all the more important to open up things and be very clear how much is given and how the community is benefiting.  Additionally, people here are often a little shy about talking about their giving, so transparency can help normalise philanthropy and build the culture of giving.  Finally, unless we are transparent, it is very difficult for the organisations that we might want to support to know about us and decide whether they should try to connect with us.  So transparency also helps our core business of funding public good initiatives.

”…with templates like what GlassPockets offers, this stuff isn’t hard to do.“

GP: How did the GlassPockets assessment help you to improve your foundation and its transparency, and why should your peers also participate?

KF: With the help of the GlassPockets team, a New Zealand version of the transparency guidelines and a self-assessment form was created; we went through that first and made quite a few changes to our website as a result.  Then we did the US GlassPockets assessment and made a few more changes.  But actually both processes were really easy – maybe a day’s work in total to think things through and tweak our website.  Of course, the leaner a foundation is, the faster the process. But, I think it’s a good message for peers to hear– with templates like what GlassPockets offers, this stuff isn’t hard to do. 

GP: Do you have any examples or anecdotes to share regarding how being a transparent funder has helped you to become more effective in your philanthropy?

KF: I think that being transparent has made it easier for organisations working in the space we fund (social cohesion) to find us, to assess how well our values and work fits theirs and then to connect with us.  That said, what helps create effective philanthropy is a much debated question and requires more than transparency alone, but it’s an important piece of the puzzle that helps build the field as a whole. 

GP: Since transparency is always evolving, what are some of your hopes for how you continue to evolve your openness in the future?

 KF: We value continual learning and I think the next thing we will prioritize is to add a place to share what we are learning.  For example, we are a bicultural funder and half our trustees are Māori (indigenous) – there may be something we can share about this journey.   On the GlassPockets assessment there is an item called “knowledge centre” – which sounds a bit grand for us - but actually no matter what size we are, we have lessons and learnings to share.  So ticking off the knowledge centre box by sharing our learnings will probably be our next step.

Meet Our New GlassPockets Foundation: C&A Foundation reflects on becoming accountable from the inside out
July 26, 2018

C&A Foundation is the first European foundation to sign up for GlassPockets. Sarah Ong, Programme Manager, Supply Chain Innovation and Transformation, explains why.

Untitled design (89)Disclosure of transparent data is one of the C&A Foundation’s major strategies to improve conditions in the garment industry. We believe transparency is an essential tool to increase accountability in apparel production and much of our support is focused on enabling partners to disclose and use transparent data on supply chains and working conditions. Discovering GlassPockets, it only seemed right to practice what we preach and make our own way of working transparent too. Our Executive Director, Leslie Johnston explains:

"Joining GlassPockets was an important first step, allowing us to apply our deep commitment to transparency to ourselves while also learning from others how else we can be more open."

"C&A Foundation is working hard to positively transform one of the world’s most opaque industries: fashion. To do so, we believe in the power of transparency which can move hearts, change minds, and nudge action. It is therefore equally important that we embrace transparency in how we operate. Joining GlassPockets was an important first step, allowing us to apply our deep commitment to transparency to ourselves while also learning from others how else we can be more open. We still have work to do but are grateful for initiatives like GlassPockets that enable more accountability in the philanthropic sector.”

One of the things we’ve found from the transparency work we support is that disclosure is more useful when it is made in a standardised way, so that performance can be compared against peers and over time. It is for this reason we believe it’s important to disclose through our new GlassPockets profile, as well as on our own website.

Untitled design (90)As a relatively new foundation we are still on a transparency journey. We began by making our external evaluations public, and last year the Center for Effective Philanthropy (CEP) conducted our first anonymous partner survey. CEP then used the survey results to benchmark our performance against 300 other funders, which we made a priority to publish on our website. The results were like holding up a mirror to our own performance. We learned that our first few years as a global foundation have not always been easy on our partners, particularly as we have been developing our processes and strategy. Reflecting on the results, we have identified two priorities for improvement:

  • Improving the transparency and efficiency of our processes: Survey respondents rated the foundation lower than typical on the clarity and consistency of its communications. The feedback showed we need to be more transparent on what we do and don't fund, and on how our grantmaking process works.
  • Improving our quality of relationship with partners: While foundation staff have higher than typical contact with survey respondents, we received lower than typical ratings for understanding of our partners' contexts. Simply, we need to listen better.

Publishing the results of our CEP benchmarking, was our way of taking them seriously, holding ourselves accountable and letting others hold us accountable to act on what we heard. We hope the changes we have made, and the process of being transparent will have improved the quality of our relationships with our partners and the change we can achieve together.

"We still have work to do but are grateful for initiatives like GlassPockets that enable more accountability in the philanthropic sector."

Participating in GlassPockets is the next step on our transparency journey. Completing the disclosure has highlighted several more areas where we can be more transparent, and we plan to add to our disclosures over the coming months. For example, we realised that we do not disclose our diversity data or diversity values and policies, which is an oversight since gender equity is so central to our work. We hope this disclosure encourages partners and those in the communities where we work to help us get better in how we do what we do. Our doors are open for your feedback.

--Sarah Ong

The IRS just made an important change related to transparency
July 19, 2018

This post originally appeared in Philanthropy News Digest July 19, 2018.

The U.S. Department of the Treasury has announced that the Internal Revenue Service will no longer require 501(c) organizations other than 501(c)(3)s to file personally identifiable information about donors on their Form 990s.

While the procedure does not affect the statutory reporting requirements that apply to tax-exempt groups organized under section 501(c)(3) or section 527, it will exempt associations, labor unions, social welfare organizations, and other groups from having to file Schedule B information with their 990s — though organizations must still collect that information and make it available to the IRS upon request.

According to Treasury department officials, the information was not necessary for the government to enforce tax laws, and the change itself will better protect private taxpayer information. "Americans shouldn't be required to send the IRS information that it doesn't need to effectively enforce our tax laws, and the IRS simply does not need tax returns with donor names and addresses to do its job in this area," said U.S. Treasury Secretary Steven T. Mnuchin. "The IRS's new policy for certain tax-exempt organizations will make our tax system simpler and less susceptible to abuse."

However, Philip Hackney, an associate professor at the University of Pittsburgh School of Law and former IRS attorney, told the NonProfit Times that, from a tax-exemption perspective, the Schedule B requirement was crucial to the agency's federally mandated oversight of the nonprofit sector. No longer requiring the information "does harm to our democracy and harm to the IRS's ability to oversee the tax law generally," he said. And because the IRS is willingly giving up important data related to where money is flowing in a tax-exempt manner from wealthy individuals, Hackney added, "[i]t makes it [easier] for wealthy interests to influence our political system covertly."

What Philanthropy Can Learn from Open Government Data Efforts
July 5, 2018

Daniela Pineda, Ph.D., is vice president of integration and learning at First 5 LA, an independent public agency created by voters to advocate for programs and polices benefiting young children. A version of this post also appears in the GOVERNING blog.

Daniela Pineda Photo 2Statistics-packed spreadsheets and lengthy, jargon-filled reports can be enough to make anybody feel dizzy. It's natural. That makes it the responsibility for those of us involved in government and its related institutions to find more creative ways to share the breadth of information we have with those who can benefit from it.

Government agencies, foundations and nonprofits can find ways to make data, outcomes and reports more user-friendly and accessible. In meeting the goal of transparency, we must go beyond inviting people to wade through dense piles of data and instead make them feel welcome using it, so they gain insights and understanding.

How can this be done? We need to make our data less wonky, if you will.

This might sound silly, and being transparent might sound as easy as simply releasing documents. But while leaders of public agencies and officeholders are compelled to comply with requests under freedom-of-information and public-records laws, genuine transparency requires a commitment to making the information being shared easy to understand and useful.

“…genuine transparency requires a commitment to making the information being shared easy to understand and useful.”

Things to consider include how your intended audience prefers to access and consume information. For instance, there are generational differences in the accessing of information on tablets and mobile devices as opposed to traditional websites. Consider all the platforms your audience uses to view information, such as smartphone apps, news websites and social media platforms, to constantly evolve based on their feedback.

Spreadsheets just won't work here. You need to invest in data visualization techniques and content writing to explain data, no matter how it is accessed.

The second annual Equipt to Innovate survey, published by Governing in partnership with Living Cities, found several cities not only using data consistently to drive decision-making but also embracing ways to make data digestible for the publics they serve.

Los Angeles' DataLA portal, for example, offers more than 1,000 data sets for all to use along with trainings and tutorials on how to make charts, maps and other visualization. The portal's blog offers a robust discussion of the issues and challenges faced with using existing data to meet common requests. Louisville, Ky., went the proverbial extra mile, putting a lot of thought into what data would be of interest to residents and sharing the best examples of free online services that have been built using the metro government's open data.

Louisville's efforts point up the seemingly obvious but critical strategy of making sure you know what information your target audience actually needs. Have you asked? Perhaps not. The answers should guide you, but also remember to be flexible about what you are asking. For example, the Los Angeles Unified School District is set to launch a new portal later this summer to provide parents with data, and is still learning how to supply information that parents find useful. District officials are listening to feedback throughout the process, and they are willing to adjust. One important strategy for this is to make your audience -- or a sampling of them -- part of your beta testing. Ask what information they found useful and what else would have been helpful.

“When you share, you are inviting others to engage with you about how to improve your work.”

Remember, the first time you allow a glimpse into your data and processes, it's inevitable your information will have gaps and kinks that you can't foresee. And if you are lucky to get feedback about what didn't work so well, it may even seem harsh. Don't take it personally. It's an opportunity to ask your audience what could be done better and commit to doing so. It may take weeks, months or maybe longer to package information for release, making it usable and accessible, but this is an investment worth making. You might miss the mark the first time, but make a commitment to keep trying.

And don't be daunted by the reality that anytime you share information you expose yourself to criticism. Sharing with the public that a project didn't meet expectations or failed completely is a challenge no matter how you look at it. But sharing, even when it is sharing your weaknesses, is a strength your organization can use to build its reputation and gain influence in the long term.

When you share, you are inviting others to engage with you about how to improve your work. You also are modeling the importance of being open about failure. This openness is what helps others feel like partners in the work, and they will feel more comfortable opening up about their own struggles. You might be surprised at who will reach out and what type of partnerships can come from sharing.

Through this process, you will build your reputation and credibility, helping your organization advance its goals. Ultimately, it's about helping those you serve by giving them the opportunity to help you.

--Daniela Pineda

Knowledge Sharing to Strengthen Grantmaking
April 26, 2018

Clare Nolan, MPP, co-founder of Engage R+D, is a nationally recognized evaluation and strategy consultant for the foundation, nonprofit and public sectors. Her expertise helps foundations to document and learn from their investments in systems and policy change, networks, scaling, and innovation. This post also appears on the Grantmakers for Effective Organizations’ (GEO) Perspectives blog.

This post is part of the Glasspockets’ #OpenForGood series in partnership with the Fund for Shared Insight. The series explores new tools, promising practices, and inspiring examples showing how some foundations are opening up the knowledge that they are learning for the benefit of the larger philanthropic sector. Contribute your comments on each post and share the series using #OpenForGood.

Clare Nolan PhotoKnowledge has the power to spark change, but only if it is shared. Many grantmakers instinctively like the idea of sharing the knowledge they generate with others. But in the face of competing priorities, a stronger case must be made for foundations to devote time and resources to sharing knowledge. The truth is that when foundations share knowledge generated through evaluation, strategy development and thought leadership, they benefit not only others but also themselves. Sharing knowledge can deepen internal reflection and learning, lead to new connections and ideas, and promote institutional credibility and influence.

Foundations can strengthen their knowledge sharing practices by enhancing organizational capacity and culture, and by understanding how to overcome common hurdles to sharing knowledge. The forthcoming GrantCraft guide Open for Good: Knowledge Sharing to Strengthen Grantmaking provides tips and resources for how foundations can do just that. My organization, Engage R+D, partnered with Foundation Center to produce this guide as part of #OpenForGood, a call to action for foundations to openly share their knowledge.

Knowledge Sharing GraphTo produce the guide, we conducted interviews with the staff of foundations, varying by origin, content focus, size, and geography. The participants shared their insights about the benefits of sharing knowledge not only for others, but also for their own organizations. They also described strategies they use for sharing knowledge, which we then converted into concrete and actionable tips for grantmakers. Some of the tips and resources available in the guide include:

  • A quiz to determine what type of knowledge sharer you are. Based upon responses to questions about your organization’s capacity and culture, you can determine where you fall within a quadrant of knowledge sharing (see visual). The guide offers tips for how to integrate knowledge sharing into your practice in ways that would be a good fit for you and your organization.
  • Nuts and bolts guidance on how to go about sharing knowledge. To take the mystery out of the knowledge sharing process, the guide breaks down the different elements that are needed to actually put knowledge sharing into practice. It provides answers to common questions grantmakers have on this topic, such as: What kinds of knowledge should I be sharing exactly? Where can I disseminate this knowledge? Who at my foundation should be responsible for doing the sharing?
  • Ideas on how to evolve your foundation’s knowledge-sharing practice. Even foundation staff engaged in sophisticated knowledge-sharing practices noted the importance of evolving their practice to meet the demands of a rapidly changing external context. The guide includes tips on how foundations can adapt their practice in this way. For example, it offers guidance on how to optimize the use of technology for knowledge sharing, while still finding ways to engage audiences with less technological capacity.

The tips and resources in the guide are interspersed with quotes, audio clips, and case examples from the foundation staff members we interviewed. These interviews provide voices from the field sharing tangible examples of how to put the strategies in the guide into practice.

Want to know how your foundation measures up when it comes to knowledge sharing? We are pleased to provide readers of this blog with an advance copy of Chapter 2 from the forthcoming Guide which includes the quiz referenced above. Want to learn more? Sign up for the Foundation Center’s GrantCraft newsletter and receive a copy of the Guide upon its release. And, for those who are attending the GEO conference next week in San Francisco, visit us at our #OpenForGood pop-up quiz station where you can learn more about what kind of knowledge sharer you are.

--Clare Nolan

Robert K. Ross, MD, President and CEO, The California Endowment: Parkland Students Inspire Foundation to Screen Out Investments in Firearms Manufacturing
March 14, 2018

Dr. Robert Ross photoOne month after the school shooting in Parkland, Florida that killed 17 people, students across the country are continuing to press for stricter gun control legislation with protests and school walk-outs. According to the Gun Violence Archive, more than 2,837 gun related deaths have occurred so far this year, and both the American Medical Association and the American Public Health Association have recommended addressing gun violence as a public health issue.

The week following the shooting, The California Endowment (TCE), California’s largest healthcare foundation, announced it would begin screening out firearms manufacturing from its investment holdings. TCE’s mission is to expand access to affordable, quality health care for underserved individuals and communities and to promote fundamental improvements in the health status of all Californians. TCE’s mission statement also outlines that the foundation doesn’t focus on prescriptions, but rather “we focus on fixing broken systems and outdated policies, ensuring the balance of power is with the people. We don’t focus on the individual, we focus on the larger community as an ecosystem of health. We work with citizens and elected leaders to find lasting solutions to impact the most people we possibly can.”

Recently, Glasspockets spoke with TCE president and chief executive officer Dr. Robert Ross, about the foundation’s decision to ban firearms investments, and how this aligns with both TCE’s stated health mission, and its core values around diversity, equity, and inclusion.

Glasspockets: The California Endowment recently announced that it will be scrubbing its investments of any holdings in firearms manufacturing, and this is actually not a new practice, but the third “negative screen” you are adding, since you already had screening in place for tobacco and for-profit prisons. Data shows that this practice is actually fairly uncommon in foundation philanthropy, so it’s clear it’s a challenge for the field. When did you begin the practice, and what led to you going down this path initially when you first implemented negative screening?

Dr. Ross: Since we are a health foundation, the founding board actually started with the tobacco screen in the late 90’s.  We added for-profit prisons more recently, after hearing from community leaders that they considered hyper-incarceration as an unhealthy practice affecting communities of color. This is consistent with our core values statement, which also helps guide our board. The very first item in our values states: “We believe that diversity, equity and inclusion are essential to our effectiveness and the long-term health of all Californians and commit to the integration of diversity, equity and inclusion in all our policies, practices, processes, relationships, internal working culture and systems.” By filtering out tobacco, for-profit prisons, and now gun manufacturing we are being consistent with these values.

“We really have to ask ourselves the question of whether the management of our investments portfolio reflects the values we hold dear.”

Glasspockets: There have sadly been many shootings prior to Parkland. What was it about this one that motivated your foundation to act?  

Dr. Ross: We were motivated by the youth and high school student activism – I think we were “shamed” to act by their leadership. The California Endowment “values the energy, agility and fearlessness of youth leadership and youth organizing in its many forms including local, statewide and online community-building.”

Glasspockets: And are you aware of other foundations being similarly motivated to act, either now or that already had such prohibitions in place? 

Dr. Ross: We have followed the leadership efforts of The California Wellness Foundation, Bloomberg Philanthropies and Joyce Foundation, all of which, to the best of my knowledge, already have a screen on firearms in place. I’m not certain how many other funders currently have a firearms manufacturing screen.

Glasspockets: The California Endowment was an early adopter of our Glasspockets approach to a more transparent philanthropy. So clearly transparency, openness, and accountability are priorities. Is your commitment to these values part of what motivated the decision and the public stand you are now taking? 

Dr. Ross: Yes, and it was the reason I published the OpEd in the Chronicle of Philanthropy.  Even though these boardroom conversations can get a little “messy,” it strengthens philanthropic practice if we can demonstrate vulnerability and transparency on tough issues. Without actions, our values just become words on a page.

Glasspockets: Glasspockets is currently advising foundations to become more familiar with what holdings they do have, since these are publicly listed on the 990-PF that foundations annually file with the IRS. And that data is now being released as machine-readable, open data—making it more open and accessible than ever before. Is this something TCE is tracking or do you have any internal practices about monitoring what’s in your 990-PF that may be helpful for others? 

“Without actions, our values just become words on a page.”

Dr. Ross: We have begun utilizing ESG (Environmental, Social and Governance) practice approaches, as have many others, as a “values and principles” overlay to our investments portfolio. [ESG screening is an array of ethical exclusion metrics designed to govern certain investment decisions. Excluded companies can include those in the tobacco, firearms, and for-profit prison industries. The alerts look for mentions of portfolio companies (those not currently excluded) and rate them as positive, negative or neutral in terms of these screens.]

Glasspockets: The things you are screening out make a lot of sense for a healthcare foundation. Why do you think so few do it? And what advice would you have for them as far as overcoming those challenges?

Dr. Ross: The answer to this is values-values-values.  Most foundations have both a statement of mission and a statement of values, and we really have to ask ourselves the question of whether the management of our investments portfolio reflects the values we hold dear.  You can’t make a blanket values exception for the investments portfolio.  

Glasspockets: In terms of the screening that had already been in place, what has been the impact on endowment growth?

Dr. Ross: I’m not sure, but I do know that a concern some raise when discussing this is the belief that growth may be negatively impacted by the lack of tobacco and private prisons holdings.  But if you’re acting on your values, then I’m not sure the question is material.  Slavery is profitable, but we’d never invest in that….

Glasspockets: And how about the qualitative impact—things that bottom lines don’t measure? 

Dr. Ross: It’s good for boardroom cohesion, and messaging to staff and community that we intend to live up to our values, even if it is discomforting.  It’s hard to put a price tag on reputation and accountability.

--Janet Camarena

IRS Warns Donor-Advised Funds May Face New Restrictions
February 28, 2018

Lauren Haverlock, CPA, has practiced public accounting since 2004. As a senior manager at Moss Adams LLP, she provides compliance and consulting services to all types of exempt organizations, including public charities and private foundations.

Lauren Haverlock - 150

In recent years, donor-advised funds (DAFs) have gained popularity as a philanthropic tool. The National Philanthropic Trust reports that in 2016, charitable assets under management in DAFs exceeded $85 billion—representing a record amount.

DAFs offer donors a flexible giving option when they want a charitable deduction with administrative simplicity, a long-term distribution of funds, and less transparency than is common with private foundation grants.

But the IRS has indicated that organizations and individuals may be taking advantage of DAFs. Because of this, the IRS has provided a notice warning of tightening its restrictions on the funds.

Background

A DAF is a separately-identified and managed account that’s operated by a section 501(c)(3) public charity—a sponsoring organization—on the original donor’s behalf.

Once a donor contributes to a DAF, the sponsoring organization has legal control over the use and reporting of the funds. The organization then invests the funds until the donor advises they be distributed. Donors often need to follow specific guidelines when advising about fund distribution, but a sponsoring organization has ultimate control.

DAFs and Private Foundations

Private foundations also use DAFs in a variety of ways. Many uses clearly relate to charitable planning, but some are less transparent—including the following:

  • Using a DAF that exists within a community foundation to support the foundation’s initiatives
  • Granting DAFs to another community foundation that offers grant support services for which the foundation doesn’t have its own internal structure
  • Using DAFs to obscure charitable giving. Since the Form 990-PF is public, a grant to a DAF would show up as such on the 990-PF while obscuring the DAF’s recipient
  • Giving funds to a nonqualified recipient. A foundation can bypass giving restrictions—and the additional steps necessary for validating using their grants—by providing a donor-advised fund instead
  • Employing DAFs to help meet minimum distribution requirements—or avoid complex set-aside rules—when it might otherwise fall short

Next Steps from the IRS

In Notice 2017-73, issued in December 2017, the IRS and Treasury Department are considering regulations addressing perceived abuses of DAFs, including some of the above issues. The notice limits the following areas:

Prohibiting Donor Sponsorship or Membership Benefits. The notice prohibits distribution from DAFs that subsidize the donor’s participation in a charity-sponsored event or membership in a charity. This is because the benefit is more than incidental. DAF donors or advisors can only receive an incidental benefit from DAF distributions.

If the prohibited distribution occurs, the donor would be taxed 125%. The fund manager who permitted the transaction would be taxed 10%.

Giving Relief when Distributions Apply to DAF Donors’ Pledges. A charity may use DAF distribution funds to relieve a pledge obligation from the DAF’s donor because the DAF doesn’t provide the donor with a benefit that’s more than incidental.

The guidance provides an example of a benefit that’s incidental and permissible. This rule stems from the difficulty of assessing if the outstanding pledge existed before the donor granted the DAF. To be permissible, a benefit must meet the following criteria:

  • The recipient didn’t reference the pledge when making the DAF distribution
  • The donor didn’t receive additional benefits from the distribution
  • The donor didn’t take charitable contribution deduction, even if the grantee sent them an acknowledgement 

Circumventing Public Support. Donors may no longer be able to use a DAF to anonymize their contribution to a public charity. The notice indicates that the IRS may treat a distribution from a DAF as an indirect contribution from the donor—or donors—that funded the DAF.

If a public charity funds another public charity, the income is considered unlimited public support. If the IRS then treats the DAF as a donation from the original donor, public support could be limited—which could reclassify the charity as a private foundation.

The charity would also face additional donation tracking requirements based on the original DAF donor, and may need to disclose the donor on the Form 990’s Schedule B.

Provide Your Input

The IRS has requested comments on how foundations use DAFs. Comments and data pulled from Form 990-PF reporting could determine the IRS’s future actions in the area.

Specifically, the IRS wants to know:

  • How private foundations use DAFs in support of their charitable purpose
  • Whether a private foundation’s transfer of funds to a DAF should only be treated as a qualifying distribution if the DAF-sponsoring organization agrees to distribute the funds for charitable purposes—or to transfer the funds to its general fund—within a certain timeframe.

Comments may be submitted by March 5, 2018, to notice.comments@irscounsel.treas.gov, or to the following address:

Internal Revenue Service

CC:PA:LPD:PR (Notice 2017-73) Room 5203

P.O. Box 7604, Ben Franklin Station

Washington, DC 20044

Please include “Notice 2017-73” in the subject line. Comments will be available for public inspection and copying.

The Future of DAFs

We expect the popularity of DAFs will continue to grow—especially as the tax landscape evolves. DAFs continue to be a great philanthropic tool for individuals and foundations, so restricting their use could have a wide impact. If you have strong opinions on the matter, now’s the time to let the IRS know.

--Lauren Haverlock, CPA

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About Transparency Talk

  • Transparency Talk, the Glasspockets blog, is a platform for candid and constructive conversation about foundation transparency and accountability. In this space, Foundation Center highlights strategies, findings, and best practices on the web and in foundations–illuminating the importance of having "glass pockets."

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