NPI Guide to Managing USG-Funded HIV/AIDS Programs - This invaluable new tool guides the reader through the whole award process for a grant through the New Partners Initiative (NPI). This Guide can help you assess your NGO's readiness to partner with the USG.
Speakers:
Mauricio Vera, Acting Director of the Center for Faith-Based and Community Initiatives at USAID
Craig Lamberton, Program Analyst, Private and Voluntary Cooperation Division, Office of Development Partners
Mary Newton, previous PVO registrar working with ODP/PVC as a consultant on PVO Registration
Mauricio Vera
Welcome to the CFBCI conference call. We have a very interesting presentation for you today. Our speakers will be from the Office of Development Partners (ODP) and will speak on registering with USAID as a Private Voluntary Organization (PVO). We've had a lot of interest on this topic from groups so we hope this presentation is useful.
Mr. Craig Lamberton is a Program Analyst in the Private & Voluntary Cooperation Division of the Office of Development Partners. Ms. Mary Newton was the previous PVO registrar and is working with ODP/PVC as a consultant on PVO Registration.
Craig Lamberton
It is great to be here and to speak to you today. (Click here for the PowerPoint presentation used by Mr. Lamberton.)
I will start out by providing some history and background information for you on PVO registration. Registration of U.S. PVOs through the Department of State originated on the eve of World War II with The Neutrality Act of 1939. The Foreign Assistance Act (FAA) of 1961, which established USAID, transferred responsibility for PVO registration to USAID. In the 1970s, USAID expanded the registry to include both U.S. and non-U.S. PVOs, and delegated the authority to implement PVO registration to the Office of Private and Voluntary Cooperation. This office now exists as the Private and Voluntary Cooperation Division within the Office of Development Partners.
Registration allows USAID to:
Identify PVOs that engage in, or intend to engage in, voluntary foreign aid operations
Determine whether PVOs meet certain general operating guidelines and accountability standards
Approve registration of those PVOs eligible for USAID assistance
How is a private voluntary organization defined? A U.S. private voluntary organization (PVO) is a nonprofit, U.S.-based nongovernmental organization that is incorporated and headquartered in the U.S., solicits and receives cash contributions from the U.S. general public, is exempt from Federal income taxes under Section 501 (C) (3) of the IRS Code, and conducts or anticipates conducting program activities that are consistent with the purposes of the Foreign Assistance Act or Public Law 480.
What kinds of organizations are not considered private voluntary organizations? For registration purposes, universities, colleges, accredited degree-granting institutions of education, private foundations, hospitals, organizations engaged exclusively in research or scientific activities, churches, synagogues, mosques, or other similar entities organized primarily for religious purposes are not defined as PVOs.
What is the purpose of PVO registration? PVOs register with USAID to become eligible to compete for specific types of funding, e.g., assistance grants and cooperative agreements.
The registration requirement does not apply to disaster assistance funding, sub-grants, or contracts.
There are eight conditions of U.S. PVO registration. As set forth in Part 203, Chapter II, Title 22 of the Code of Federal Regulations, there are eight Conditions of Registration for U.S. organizations. The first four relate to the definition of a U.S. PVO:
U.S. based - The entity is organized under the laws of and headquartered in the United States
Private - The NGO solicits and receives cash contributions from the U.S. general public
Voluntary - The organization is:
Nonprofit and exempt from Federal income taxes under Section 501(C) 3 of the Internal Revenue Code
A PVO is not a
University, college, or accredited degree-granting institution of education
Private foundation
Hospital
Organization established by a major political party in the United States
Organization established, funded and audited by the U.S. Congress
Organization engaged exclusively in research or scientific activities
Church, synagogue, mosque or other similar entity organized primarily for religious purposes
Overseas Program Activities - The organization conducts, or anticipates conducting, overseas program activities that are consistent with the general purposes of the Foreign Assistance Act and/or Public Law 480.
The remaining four Conditions establish standards by which the U.S. PVO is evaluated:
Board of Directors - The organization maintains a governing body that meets annually whose members do not receive income for serving on the board and whose majority is not composed of the PVO's officers or staffers.
Financial Viability - The organization accounts for its funds in accordance with generally accepted accounting principles (GAAP); has a sound financial position; provides its financial statements to the public upon request; and has been incorporated for not less than 18 months
Program Activities vs. Supporting Services - The organization expends and distributes funds in accordance with the annual report of program activities; does not expend more than 40 percent of total expenses on supporting services; and conducts international program activities within the last 3 years
General Eligibility - It is not:
Suspended or debarred by an agency of the U.S. Government;
Designated as a foreign terrorist organization by the Sec of State;
The subject of a decision by the Department of State that registration or a financial relationship between USAID and the organization is contrary to the foreign policy interests of the United States
An organization applies for registration by completing an application on USAID's PVO Registration Web site. To find this website, go to www.usaid.gov and do a Keyword search for "PVO Registration" or click here.
The application review is an eight-week process. If a PVO anticipates responding to a competitive solicitation, this period of time should be taken into account.
To complete the registration application, you will need to supply the following information:
A DUNS Number, available from Dun & Bradstreet, Inc.
An IRS Employer Identification Number
Two unique addresses - one for your executive contact and one for your financial contact
Auditor's name and contact information
Financial data from your organization's audited financial statements
Current U.S. Government grant or contract award information, including amounts
Overseas activity areas (education, disaster assistance, etc.)
Countries of activity, including approximate numbers of personnel engaged in the field
Names of members of the board of directors
Short narrative description of activities
You will need the following information in portable document format (pdf) for uploading:
Articles of incorporation, including amendments, on state letterhead or with state seal
By-laws
Audited financial statements for the most recently ended fiscal year, or the fiscal year that ended not more than 15 months before the application submission date
Annual report (If an annual report is not available, an executive statement describing activities may be pasted or keyed into a Web form.)
Once registered with USAID, annual renewal is required in order to maintain registration. A registered PVO submits its annual renewal online within nine months of its fiscal year end. The annual renewal submission allows USAID to review the PVO's ongoing compliance with the Conditions of Registration. In addition, once your organization has registered as a PVO, please keep the PVC division informed of staff changes and please provide updated email addresses for staff contacts.
Contact information:
Craig Lamberton, Registrar
Private and Voluntary Cooperation Division
Office of Development Partners
Email: clamberton@usaid.gov
Phone: (202) 712-4747
Mary Newton
I would like to add a few points to Craig's presentation. If an organization does not qualify as a PVO, it can still receive grants from USAID. They just do not fit into the definition of PVO and thus are not required to register. They can apply for any grant as long as they are eligible under the criteria listed in the grant documents.
In addition, all Federal government grant solicitations are listed on www.grants.gov. Once you have registered on www.grants.gov, you can sign up to get regular emails when new grant opportunities are posted.
With regard to the conditions of registration, we often get questions regarding the required audit. When your organization initially registers, USAID does require an audit as Craig described earlier. Once registered, organizations are not required to submit audited financial statements if total support and revenue is less than $100,000.
One final point, Craig noted that the registration process takes eight weeks. Registration will take eight weeks if all the fields are completed and all the documentation provided. If the application is incomplete it will delay the review of your application so it is important to fill in all the fields. If you have questions while you are actually filling out the online form, there is a registration Help Desk telephone number provided on the website that you can call: (703) 998-0601.
Q&A
If my nonprofit has just started up and is new, is it qualified to register as a PVO?
An organization must be incorporated for at least 18 months before it can register.
I missed some of what you said. Can the information you provided be found on a website? Also, you said that no more than 40 percent of an organization's total expenses can be spent on supporting services. What does this mean?
Yes, this information is online. You can find it by going to www.usaid.gov and doing a Keyword Search for "PVO Registration" or you can click here. The PowerPoint presentation will be posted on the CFBCI website as well.
The 40 percent requirement means that no more than 40 percent of an organization's expenses can be spent to staff, administrative costs, and fundraising.
My organization has been incorporated for more than 18 months, but we have had limited activity. Do we need to show activity in order to register?
No, the fourth condition of registration states that the entity must conduct or anticipate conducting overseas program activities that are consistent with the general purposes of the Foreign Assistance Act.
If my organization is new and has not had a high level of activity and we have submitted tax returns to the IRS and they have been accepted, does my organization still need an audit before it registers?
Yes, as part of the registration process you will need to provide an audited financial statement. Some certified public accountant (CPA) firms and universities encourage or allow their staff to perform pro bono audits for nonprofits. I encourage you to explore whether there are any in your area who would do an audit on a volunteer basis.
My organization is not registered as a PVO. Do I need to register in order to apply for funding? What if I am applying together with another organization?
If you will be receiving a sub-grant from another organization who is receiving the funds directly from USAID, you do not need to register. For most USAID grants, you will need to register if you are seeking funds directly from USAID and you meet the definition of a Private Voluntary Organization that Craig gave earlier.
As explained earlier, when your organization initially registers, USAID does require an audit. Once registered, organizations are not required to submit audited financial statements as part of the annual registration renewal process if total support and revenue is less than $100,000.
Do grants for Pakistan go through the PVO office?
The Office of Development Partners runs the Development Grants Program. You can find more information on this program by clicking here. This more recent program is specifically intended for organizations with limited previous experience with USAID.
I have worked with several organizations and run into the same roadblock with USAID - the requirement for audited financial statements. I cannot readily find pro bono resources and I cannot afford an independent financial audit. What is the level of audit required? Do you have a targeted size of organizations that you are trying to reach? Should small organizations only receive sub-grants?
The Federal regulations require a CPA audit of an organization's financial statements. We do not have an estimate of how much that may cost. We register organizations of all sizes, small and large. The purpose of the audit requirement and the registration requirement is to ensure that organizations are financially viable and self-sustainable. An organization needs to demonstrate that it is capable of managing government funds. This is a function of the registration process for the Agency.
The Agency is reaching out to smaller organizations through the Development Grants Program or DGP which was mentioned earlier. It limits eligibility to organizations that have previously had little experience with the Agency. Keep checking www.grants.gov and the PVC website so you will know when the FY2009 DGP Request for Applications (RFA) comes out. The DGP does require applicants to be either registered U.S. PVOs or local, indigenous NGOs. Local, indigenous NGOs are not required to be registered with USAID to be eligible to compete for development assistance.
Sub-grants have been mentioned as a path for pursuing funding. Is there a way to find out which organizations have received funds?
On the PVC website, there is a link to the PVO Registry. This is a searchable database that provides information on the organizations who have registered with USAID. It is searchable by activity sector, activity country, and the state where its headquarters are incorporated. This may be a good resource for finding other organizations with whom to partner.
My organization has been operating in Canada for 20 years. We just started a U.S. office three months ago. Do we have to wait 18 months to register with USAID? Can we register as an International PVO? Will that diminish our chances as a U.S. PVO?
Your organization should register as an international PVO. It will not preclude your organization from registering as a U.S. PVO once you have been incorporated in this country for 18 months. Once you do register as a U.S. PVO, you can maintain your registration as an International PVO or voluntarily remove your organization from registration as an International PVO.
In most cases, there is no preference for either an International PVO or a U.S. PVO. However, a small number of USAID grant programs may restrict eligibility to U.S. PVOs.
My organization will be doing prisoner re-entry ministry. It is only running programs in the U.S. I understand that the President may be starting new programs on this. Do you have information on how to get started?
If you do not anticipate running program internationally, you do not need to register. If you do anticipate running an international program and you meet the criteria described above, you can register. You will have to select the countries in which you anticipate running programs.
Before you do that, you should make sure that USAID is working in the countries you are most interested in. USAID works only in developing countries. If you go to the USAID website - www.usaid.gov - you will find country profiles for each country in which we work. Read those profiles to see what USAID is doing there. In order to be considered for funding, your work needs to support USAID's strategic plan for that country.
If you have domestic programs and are interested in finding out more information on President Obama's work, please email your question to WHpartnerships@who.eop.gov.
Is there a maximum or minimum time limit or requirement for how long we have been working in a country?
No, there is no required or maximum time.
My church denomination has been active in working on a radio program providing information on agriculture, health and religious programs in Africa. We do not issue an annual report. Is that required?
An annual report is not required if you can provide a narrative of your organization's activities. In addition, if your organization is not defined as a PVO (for example, churches, mosques, and universities are not PVOs), your organization is not required to register with USAID. It still may compete for funds as long as it fits within the eligibility requirements provided in the funding solicitation.
My organization has $40,000 worth of materials to send to the Philippines. Is there a program that can provide transport for these materials?
Yes, the Denton program funds transport of humanitarian goods by using excess military cargo space. You can find out more by clicking here or here.
My organization has been established for several years. The programs are based on relationships I have in West Africa. I have spent much of my own money for my programming and need to raise funds to build the capacity of my programs. Many of the gifts I have received for my organization were in-kind and not cash. Are these taken into account in the audit?
You will need to show that your organization has some cash flow and that you have been fundraising. There is a place to report in-kind gifts on the application form. However, it will be up to the CPA to determine how to handle and report these gifts when he or she is performing the audit.
I have a CPA on my board. Would it count as an independent and certified audit if that board member was to perform the audit?
As long as the audit was done by a certified CPA, that would meet the criteria for an independent audit.
Mauricio Vera
Craig and Mary, thank you very much for your great presentation and for taking all these questions. If anyone has additional questions that we did not have time for, please send them to fbci@usaid.gov and we will make sure you get an answer. The notes from this call will be placed on the website in the coming weeks.
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