Suggestions For Attachment "A"
CFC Memorandum 2003-9
All organizations seeking national list eligibility must certify
that it provides or conducts real services, benefits, assistance, or program
activities, in 15 or more different states or a foreign country over the
3 year period immediately preceding the start of the year involved. This
requirement cannot be met on the sole basis of services provided through
an "800" telephone number or by sending materials via the U.S.
Postal Service or a combination thereof. A schedule listing those
states (minimum 15) or the foreign countries (minimum 1) where the program
activities have been provided and a detailed description of the activities
in each state or foreign country must be included with the application. While
it is not expected that an organization maintain an office in each state
or foreign country, a clear showing must be made of the actual services,
benefits, assistance, or activities in each state or foreign country. See
5 CFR § 950.202(a).
DO
- Specify the recipient(s) of the service, benefit, assistance, or program
activity (WHO)
- Describe the type of activities provided or conducted (WHAT)
- Describe how the services were provided or conducted (HOW)
- Provide dates of services within the 3 year period immediately prior
to the application year (WHEN)
- Describe where the activities were provided by state or country (WHERE)
- a total of 15 states or 1 foreign country must be represented
DON'T
- Generalize the nature of the activity
- State that an activity was provided in "numerous states"
- List activities that were "offered"
- List location of membership organizations, affiliates, individual
members, or Board members
NATIONAL ELIGIBILITY GUIDANCE (CFC Memorandum 2002-7)
While CFC regulations note that an organization is not expected to maintain
an office in each state or foreign country, a clear showing must be made
of the actual services, benefits, assistance or program activities provided
in each state or foreign country. That is, a listing of services, benefits,
assistance or activities must be provided for each of the 15 or more states
or 1 foreign country where coverage is claimed. Providing the location
of where organization members reside, alone, is not a sufficient clear
showing to support eligibility.
- Dissemination of Information/Research. The dissemination of
information and publications, alone, does not meet the eligibility criteria
in CFC regulations at 5 CFR §§ 950.202 and 203 for providing
real services, benefits, assistance or program activities.
- Use of lists (i.e. member listings/affiliated or support group
listings). Providing listings of affiliated support groups and a breakdown
of attendees, by state or foreign country, at an annual conference without
further documentation of national or international presence is not a
sufficient demonstration of real services, benefits, assistance or program
activities required for national or international eligibility.
- Memorials, Museums and Public Recreation Facilities. Merely
listing the names and addresses of an organization's members or visitors
to a facility does not satisfy national eligibility criteria.
EXAMPLE OF A QUALIFYING ATTACHMENT A
NOTE: There are many ways to present the information necessary to
meet this eligibility requirement. Following is a sample of one format
with hypothetical information that provides the required details.
1) STATE-BY-STATE DESCRIPTION OF SERVICES
California
June 1, 2002 - Sacramento - staff presented volunteer training
on healthcare advocacy issues; attended by 100 individuals from northern
California
July 9, 2001 -- Annual meeting, "Philanthropy in the New Millennium"
conducted in San Francisco
Colorado
October 20, 2001 - Presented at the University of Colorado Health and
Wellness Fair. Staff were on-hand to distribute educational information
and answer questions from students
2) DESCRIPTION OF SERVICE WITH DETAILS ON RECIPIENTS
ABC Charity provides educational tools to inner-city schoolchildren whose
families are below the poverty line. $5,000 educational scholarships for
tuition at two or four year colleges are awarded to recipients who meet
the eligibility criteria (3.0 grade point average, involvement in extra-curricular
activities, 500-word essay, etc.). Following is a listing of the students
who have received ABC scholarships in 2000-2002.
2001
A. Johnson - Miami, FL
C. Smith - Seattle, WA
J. Andrews - Los Angeles, CA
J. Callahan - Philadelphia, PA
EXAMPLES OF NON-QUALIFYING ATTACHMENTS A
ABC Charity's publication, ABC Cares, is distributed monthly to
3,000 members residing in all 50 states, the District of Columbia, and
Puerto Rico. Thousand of others receive ABC Charity's information from
our website and other publications.
- This information does not provide specific information to demonstrate
that a real service was provided in at least 15 states.
ABC Charity offers educational packages to schools in every state. The
package includes information on cancer prevention and detection.
- This statement does not indicate that a real service has been provided.
Applicants must demonstrate clearly that a service was rendered, describe
the nature of the service, when it was provided, and who received it.
Attached is a listing of ABC Charity-affiliated support groups in 25
states.
- A listing of affiliated groups, alone, is not sufficient to demonstrate
real services, programs, or assistance. Applicants must provide additional
details on the nature of the applicant's relationship with these groups
and the services provided to them ( financial support, presentations,
educational materials, etc.)
Over the past three years, ABC Charity's literature is used by high schools
and universities in the following states: AL, CA, DE, FL, GA, IL, IN,
ME, NY, NH, OH, OR, PA,
- This example does not provide sufficient details to demonstrate
who received the service, when it was delivered, or how it was delivered.
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