Grant Policies

We are committed to being exceptional stewards of charitable funds entrusted to us by donors. If your organization is applying for a grant from a fund within the Community Foundation, the above policies apply. Be sure to click through each tab and read the policies carefully.

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Nondiscrimination

The Foundation seeks to promote respect for all people. The Foundation will not knowingly support organizations whose programs or services are not open to all without discrimination on the basis of race, color, ethnicity, national origin, religion, gender, gender expression, age, sexual orientation, physical or mental ability, pregnancy, veteran status, military obligation, marital status, and any other personal characteristics protected by law. We recognize that organizations may identify special needs in the community and target programs or services to a specific population based on those needs, however the programs must be open to all people in those targeted populations to be eligible for grant consideration.

Organizations eligible to receive grants

Organizations eligible to receive grants from the Community Foundation for the Fox Valley Region are those determined by the IRS to be public charities. This encompasses most charitable, scientific, social service, educational and religious organizations described in § 501(c)(3) and 509(a)(1), (a)(2), or (a)(3) of the tax code, and private operating foundations. The Foundation will not normally make grants to private non-operating foundations. Grants may also be made to units of government (this includes Native American tribal governments) for public purposes. Organizations that are not public charities may apply through a fiscal sponsor. Organizations must serve residents of the Foundation's service area including Outagamie, Calumet, Shawano, Waupaca and/or northern Winnebago counties. Additional eligibility requirements may apply to units of government and schools; see below.

Eligibility for Units of Government (city, county, township, etc.)

The Foundation will consider funding for units of government when the request for support is judged to be an effective means to address a priority issue. A grant from the Foundation may help draw attention to a new issue, leverage additional funding, offer more flexible funds than are typically available in a governmental budget, or provide seed money until program funding can be included in the governmental budget. The Foundation will not typically issue grants for the general operating support of a government program.

Eligibility for Schools

The Foundation will consider funding for public, charter and private/parochial Pre-K-12 schools and post-secondary educational institutions, when the request for support is judged to be an effective means to address a priority issue, particularly when the issue addresses the needs of a substantial or underserved portion of the community. Requests will only be considered if they are unique and community-oriented, or for pilot programs with potential to be sustainable and replicable. The Foundation typically will not issue grants for the general operating support of a school system, school or school program.

Due Diligence Policy for Determining
Charitable Eligibility of an Organization

The Community Foundation for the Fox Valley Region (“the Foundation”) is committed to ensuring that its charitable funds are compliant with all applicable laws (including IRS regulations), and that all grantmaking is aligned with the Foundation’s mission and values. Our core values include respect for and working in partnership with our diverse community members, and that equity and inclusion is essential to the quality of life and long-term well-being of the Fox Valley Region.

Organizations eligible to receive grants from the Foundation are those determined by the IRS to be public charities. This encompasses most charitable, scientific, social service, educational and religious organizations described in Section 501(c)(3) of the tax code, as well as government agencies. Organizations that are not public charities may apply through a fiscal sponsor.

The Foundation will not knowingly support any organizations that discriminate on the basis of race, creed, color, religion, sex, sexual orientation, gender identity or expression, national origin, ancestry, age, marital status, physical or mental ability, medical condition, military service or veteran status or any other legally protected characteristics (collectively, the “Anti-Discrimination Status”) in any of its activities or operations. Further, the Foundation will not contribute (through grantmaking or otherwise) to any organization that supports or engages in Hateful Activities. For the purposes of this policy, “Hateful Activities” are defined to mean activities that incite or engage in violence, intimidation, harassment, threats, or defamation targeting an individual or group based on their Anti-Discrimination Status. These activities are contrary to the Foundation’s mission, values, and philanthropic goals.

The Foundation’s donor base also represents a wide range of religious beliefs and views, which are commonly reflected in grantmaking to churches, synagogues, temples, mosques and other faith-based organizations. The Foundation respects religious freedom and will accept grant recommendations from donors to faith-based organizations, without prejudice, as long as such organizations do not attack, threaten violence against, or intentionally injure individuals or groups of individuals based on their Anti-Discrimination Status. (Grants from unrestricted funds are guided by a separate faith-based funding policy as outlined in the Foundation’s general grant policies.)

The Foundation has the responsibility to review and approve all grants issued from all charitable funds established with the Foundation. To qualify for a grant distribution f rom the Foundation, the grantee must satisfy the due diligence requirements established by the Foundation’s Board of Directors. As part of its due diligence process, the Foundation conducts a review of all grant recommendations to verify the recommended grantee’s charitable status, that the grant purpose is permissible under applicable laws, including IRS regulations, and that the grant is made in accordance with its charitable mission and values. Decisions regarding grant distributions made f rom all funds and the investment of assets, are made at the Foundation’s discretion (in consultation with advisors in appropriate circumstances).

Grants from Unrestricted and Field of Interest Funds

1. Verification of charitable status and charitable purpose:

a) Grants may be made to public charities; organizations described in section 501(c)(3) and 509(a)(1), (a)(2), or (a)(3); and to private operating foundations. The Foundation will not typically make grants to private non-operating foundations.

b) Grants may also be made to units of government (this includes Native American tribal governments) for public purposes.

c) In exceptional circumstances, grants may be made to other types of nonprofit organizations and businesses. Using expenditure responsibility as a guideline, the Foundation will carefully supervise any such grants to document the use of its funds solely for charitable purposes.

2. Verification of public charity status; the Foundation will use the following methods to verify a potential grantee’s charitable status:

a) Internal Revenue Service, Exempt Organizations Select Check(http://www.irs.gov/Charities-&-Non-Profits/Exempt-Organizations-Select-Check)

b) Internal Revenue Service Business Master File

c) Grantee’s Internal Revenue Service determination letter or group ruling letter identifying grantee as included in the ruling

d) GuideStar’s Charity Check

e) Verification of church status and affiliated schools not found on the above lists

f) The organization records within our constituent and granting databases, with separate confirmation as necessary.

3. Verification of units of government; the Foundation will use the following methods to verify a potential grantee’s status as a unit of government:

a) Internet search to establish the unit of government (city, county, town, school district, etc.).

b) For Native American tribal governments, consult the list maintained by the Department of the Interior’s Bureau of Indian Affairs. Staff will analyze, with assistance of counsel, if necessary, situations in which governmental status is not clear.

4. Verification of organization’s mission and activities; the Foundation will use the following methods to verify a potential grantee’s mission and activities:

a) Consult resources such as the Southern Poverty Law Center (including the Center’s list of Extremist Groups and/or Hate Group Map) in a good faith attempt to identify potentially Hateful Activities and organizations.

b) Review of the organization’s financials and audits, and IRS Form 990 where applicable, to assess appropriateness of business practices and organizational stability.

Designated Funds

Before establishing a designated fund, the Foundation will verify that the proposed designee is public charity or unit of government and follow the verification process outlined in Steps 1-4 above. Designated grants are paid out to the relevant organization named in the fund agreement.

Agency Endowment Funds

Before establishing an agency fund, the Foundation will verify that the organization seeking to establish the fund is eligible to receive grants from the Foundation and follow the verification process outlined in Steps 1-4 above. If a unit of government, such as a public library, asks to establish an agency fund, the Foundation will determine whether it is permissible under the laws of the State of Wisconsin. Agency grants are paid out to the relevant organization named in the fund agreement.

Grants from Donor Advised Funds

1. The Foundation will make grants f rom donor advised funds to most public charities and units of government.

a. The Foundation will follow the verification process outlined in Step 2 -4 above to verify public charity status and eligibility.

b. In addition, the Foundation will follow its procedure determining Supporting Organization type outlined in the Procedure for Determining Tax Status and Expenditure Responsibility from a Donor Advised Fund to determine whether a potential public charity grantee is a Type III supporting organization (as classified by the IRS) that is not functionally integrated or supports an organization controlled by the donor, advisor, or related persons. If either of these conditions is present, the Foundation will either refuse the grant or exercise expenditure responsibility

2. The Foundation will not make the following types of grants from a donor advised fund:

a. Grants to individuals, including grants payable to a school, college or university for the benefit of an individual.

b. Grants or other similar payments, including expense reimbursements, to donors, advisors, and related parties.

c. Any grant for a purpose that is not charitable.

d. Any grant to a private non-operating foundation, except in exceptional circumstances using expenditure responsibility as a guideline. The Foundation will carefully supervise any such grants to document the use of its funds solely for charitable purposes.

3. The Foundation will not typically make grants from donor advised funds that require the exercise of expenditure responsibility. This includes grants to nonprofit organizations that are not public charities and grants to for-profit businesses.

Implementation of Charitable Eligibility
Due Diligence for All Fund Types

1.  Foundation staff members will receive annual training on this policy, with a particular focus on methods and available resources for verifying the eligibility requirements outlined above.

2. If a Foundation staff member becomes concerned that a grant recommendation involves an ineligible organization, the grant recommendation will be flagged for additional internal review by the Foundation’s Donor Services or Community Engagement Manager, VP of Donor Services & Gift Planning or VP of Community Engagement and President/CEO, together with appropriate Database Team members.

The Foundation will use its best efforts to complete this confirmatory review within five (5) business days of receipt of the original grant recommendation. If the Foundation ultimately determines that the proposed grant recipient is an ineligible organization and the grant recommendation cannot be fulfilled, the CEO/President and/or the VP of Donor Services & Gift Planning or VP of Community Engagement, in consultation with the Donor Services or Community Engagement Manager, will promptly notify the fund contact and work in good faith with such contact to determine available alternatives and appropriate next steps.

3. Funds within a Geographic Affiliate: If a grant recommendation from a fund within one of the Foundation’s geographic affiliates is flagged for review, the chairperson of such affiliate will be included in the confirmatory review and communication processes outlined above.

Faith-Based Funding

The Foundation will consider funding for programs, services or initiatives that address unmet human needs through non-sectarian organizations or collective efforts of faith-based organizations that draw support from the community at large to meet a demonstrated community need, and that refrain from promoting a specific journey of faith. Requests will be considered from individual faith-based organizations or organizations with a specific journey of faith as an aspect of its mission only if the program, services or initiatives do not promote that specific journey of faith or include activities such as religious worship, instruction or proselytization. In making its determination for eligibility, the Foundation will consider not only the mission of the applicant but the participant experience and the intended outcome(s) for the program, service or activity, for the target participants and/or audience.

Controversial Grants

The Foundation will consider whether any potential grant might be controversial, divisive in the community or have potential to alienate donors. When requests of this nature are received, the Foundation will determine if the controversial stance is important enough, if its impact will be profound enough, and/or if it will do enough community good to justify the Foundation staking its credibility and reputation on it. Each request will be considered with great care on a case-by-case basis.

Requests for Interim, Progress or Final Reports

The Foundation takes seriously its role of stewardship and cares deeply about the impact of awarded funds. All requested interim, progress or final reports will be diligently reviewed by staff, shared with committee members and used in numerous ways to publicize our fulfillment of mission, to raise awareness around critical community needs, to improve our understanding of charitable organizations and their outcomes, and/or to set future grantmaking direction. As such, organizations with past-due or incomplete grant reports will be ineligible to apply for additional funding from the Foundation until the requested report(s) is received and accepted.

Redirected or Declined Applications

The Foundation reserves the right to redirect, at its sole discretion, any submitted application for grant funding. The Foundation also reserves the right to decline a request if it does not meet eligibility requirements or grant guidelines, or for some other reasons as determined by the Foundation. All decisions to decline a grant are made at the sole discretion of the Foundation and may not be appealed.

Capital Investments

In general, the Foundation will not consider grant requests solely related to real estate, bricks and mortar, or other capital expenditures that are not directly related to program delivery, service to clients, or organizational capacity building, given the substantial funding normally associated with such initiatives and the Foundation's relatively limited resources for unrestricted grantmaking. The Foundation will, however, consider grant requests for capital projects or capital programs, if such initiatives are expected to significantly enhance the quality of life in our service region, and are clearly aligned with the Foundation's mission, focus areas and priorities. The Foundation will apply established guidelines in assessing capital grant requests on a case-by-case basis, but reserves the right to consider any criteria that it believes is prudent. Grant requests for capital projects or programs may also be considered for funding from Field of Interest funds, unless specifically disallowed by the Foundation, in its sole discretion, or not authorized pursuant to the terms of a specific fund agreement.

Grant applications for small capital items that are directly related to program delivery or service to clients, such as a refrigerator for a food pantry, signage for a nature trail, or new technology will also be considered. Examples of requests that do not fall within consideration as small capital items include: office furniture; health and safety equipment including automatic external defibrillators (AEDs), smoke detectors, or security systems; and playground equipment.

Fundraising Activities

The Foundation’s grant programs will not support annual fund drives, fund-raising events or endowment-building campaigns.

Medical Research

The Foundation will not consider requests to support community-based research for the advancement of medicine. However, requests will be considered for programs that provide for the medical, dental and mental health needs of residents of the Fox Valley region.

Previously Incurred Expenses

The Foundation will consider funding requests only for programs or services that have not yet occurred. Organizations must submit requests with sufficient lead time being mindful of the timing of grant decisions.

Repeat Funding

The Foundation encourages organizations to develop realistic plans for long-term sustainability that do not depend upon recurring support from Foundation competitive grant programs. The Foundation's competitive grant programs should not be considered a source of ongoing funding for any project or program.

Multi-year requests

The Foundation recognizes that there are certain circumstances, such as efforts to build organizational capacity, the length of time required to stabilize operations and implement plans for financial sustainability requires support beyond a one-time grant. Therefore, the Foundation will consider multi-year requests within specific grant programs; and will identify any exception within each program's guidelines.

Repeat funding requests

The Foundation acknowledges that certain recurring events, presentations, performances or educational activities require organizers to build a base of community support before becoming self-sustaining. On occasion, the Foundation may even partner with the community to provide these kinds of activities in fulfillment of its mission and strategic plan. As a result, the Foundation will consider recurring requests for community or charitable educational activities within specific grant programs; refer to each program’s guidelines for these exceptions.

Multiple requests from a single organization

The Foundation recognizes that an organization may request funding several times, each with a request for a different program. If the program is truly new and different each time, the Foundation will consider these requests unique and not a form of repeat funding, so long as the guidelines of the specific program are followed.

Travel

The Foundation will not consider requests solely to defray travel or lodging expenses for either individuals or groups. This includes travel to attend conferences, training or competitions, as well as trips for bands, sports teams, classes or similar groups.

Fiscal Sponsorship

Grants from the Community Foundation for the Fox Valley Region and its affiliated foundations are awarded to support a wide range of projects, including grassroots community efforts.

Generally, organizations eligible to receive grants from the Community Foundation for the Fox Valley Region and its affiliated foundations are those determined by the IRS to be public charities. This encompasses most charitable, scientific, social service, educational, and religious organizations described in § 501(c)(3) of the tax code, as well as government agencies. However, we are aware that some worthwhile organizations may not have this status.

Therefore, organizations that are not public charities may apply if they have an established relationship with a fiscal sponsor that is a qualifying charitable organization under the following circumstances:

• The non-exempt group operates as a not-for-profit and has an oversight committee or advisory board comprised of more than one individual.
• The program or project for which the non-exempt group is seeking funding falls within the charitable purposes of the sponsoring organization/fiscal sponsor, and the two groups have established a relationship prior to applying to the Foundation for funding.
• If you require a fiscal sponsorship form to submit a grant inquiry or application, please contact [email protected].

Educational Events

The Foundation’s grant programs will consider supporting speaker costs for community education events when determined to be closely aligned with, or have an immediate impact on, a Foundation priority. Educational events that also serve to raise funds for the organizing agency may be considered but will be given greater scrutiny.