Friday, March 11, 2011

The United States Postal Service Appeals Rate Increase Rejection

Note: This is a summary of a past NPTtv story about how the USPS rate increase for 2011 was denied.

The Unites States Postal Service (USPS) is appealing the decision by the Postal Regulatory Commission, or PRC, to reject USPS's rate increase. As part of the appeal of the fact that it had its proposed rate increase denied, USPS claims that the PRC misread the statute and applied an "incorrect standard in evaluating the request" for the price increase. The Postal Regulatory Commission's denial of the proposed average 6.5% hike represents that first time it has ruled on an exigent rate case under the Postal Accountability and Enhancement Act of 2006.
The postal service concluded its third quarter in June with a net loss of $3.5 billion compared with 2.4 billion at the end of the same quarter in 2009. USPS also decreased costs by $6 billion last year. The proposed rate increase would have generated an estimated $2.3 billion in revenue for USPS in 2011, according to their assessment.

The Rise In Mobile Giving

Note: This is a summary of a past NPTtv story about the rise of mobile giving campaigns.

In the world we find ourselves in today, fundraising in the charitable sector is changing as the technological landscape evolves. Mobile giving is becoming as much of a mainstream tool for making donations as email is for communicating. More and more people are putting their cell phones to use for this purpose. In the wake of the earthquake in Haiti, mobile giving rapidly increased in popularity. A national survey of charitable donors in the United States revealed that mobile giving is growing among young people. As many as 6.5 million people made donations via cell phones in the days following the Haiti earthquake, resulting in more than $50 million being raised.

The mobile giving tipping point is reached

According to Jill Ward, the senior marketing manager at Conveo, the Haiti tragedy has become the tipping point as it relates to mobile giving. She states that the mobile medium is a legitimate and efficient channel for giving due to its convenience and rapid impact. Another reason for the rise in its use may be the fact that it’s striking a chord with donors who otherwise might not have been involved in the fundraising process. The research revealed that 28% of respondents who owned a cell phone that made use of the Facebook application texted a gift to Haiti, 36% were willing to donate via text, and 31% were willing to make use of a text message if a friend was engaged in the fundraising process.

Identifying What Tugs The Heart-Strings Of Donors

Note: This is a summary of an older story from Nonprofit Times TV about what motivated non profit donors.

Over the last surveyed year, approximately 90 million adults or around a third of the American population, have made donations to charity. The two overriding questions are why these individuals were motivated to give, and why others were not. A new Heart of the Donor Study conducted by the Russ Reid Company based in Pasadena California found that donors gave to an average of 5 charitable organizations over a 12 month period. Issues such as disaster relief, domestic hunger, healthcare, people with disabilities, and veterans’ causes accounted for at least half of all charitable giving.

Heart of the Donor survey results

The survey found that levels of giving increased as levels of education increased, and men and women generally made donations in equal proportion. There appears to be a link between apathy in religion and politics, and apathy in supporting a related cause. The survey posed a variety of question via the internet, and through a demographically representative online research panel. As many as 6 out of 10 don't set aside a formalized budget for giving. The study reveals that the people who donate the most and with most consistency, are very intentional about their donation strategies. Nothing is left to impulse when it comes to how much they give, who they give to, and when that giving takes place.

As many as 60% of donors tend to make impulse decisions when it comes to their giving. This makes it necessary for nonprofits to constantly think about presenting people with emotionally compelling stories along with convenient and immediate options for response. Typically, receiving a second gift from a donor is challenging. Three quarters of respondents who gave more than once to a particular cause said they did so for three reasons. The organization that received more than one gift had a clearly defined mission, they made the donor feel that their gift genuinely made a difference, and finally, they explained to the donor exactly what their gift accomplished. These three reasons were cited across all demographic groups.

Two More MA Nonprofit Health Insurers Rethink Their Board Pay

Excessive Executive Compensation has been an issue for the public ever since the bank bailouts.  It's all too common to hear about big Wall Street firms, that have received government bailout funds paying their executives an absurd amount of money.  However, now it's nonprofits that have the excessive compensation spotlght on them.

After Blue Cross Blue Shield of Massachusetts suspended the pay of their board members after intense public criticism (as well as an outcry over the $11 million severence package given to their ex-CEO), more nonprofits are reconsidering the way they handle executive and board pays.  According to the Boston Globe, two more nonprofit health insurers in Massachusetts are going to consider suspending their board pay after MA Attorney General Martha Coakley said other insurers should follow Blue Cross's lead.  The insurers, Harvard Pilgrim Heath Care and Tufts Health Plan, announced ther plans on Thursday.

Paying nonprofit board members, while not illegal, is considered extremely unethical.  In the Boston Globe article F. Warren McFarlan,a professor at Harvard Business School, harshly criticized this act:

“On for-profit boards, you expect to be paid. In the nonprofit world, it’s about time, talent, and treasure. It’s about serving the organization’s mission."
It is unclear at this point whether these two organizations, along with the rest of the nonprofits that pay their boards, will decide to actually suspend board pay and reduce excessive executive compensation.  One would think they almost have no choice if they want to avoid the wrath of an angry public.

The concept of micro-volunteering gains momentum

Note: This is an older story from NPTtv.  Click here for the video.
A time may be approaching where the giving of time may be profoundly more important than the giving for money. In fact, many would argue that that has always been the case. The concept of micro-volunteering is gaining increasing strength. Donors are able to give minutes or even seconds, and the results that are yielded can often be astounding.

Empowering people for involvement

The First Aid Corp is utilizing crowd sourcing techniques to save lives. With the realization that the survival rate from sudden cardiac arrest is very low, First Aid Corps decided to join forces with an organization known as The Extraordinaries, a social business platform in San Francisco, to develop an online list relevant to what is known as a public automatic external defibrillator, also known as an AED. They have requested people around the world to send in pictures, location descriptions and GPS coordinates of AEDs, in order to create an online list of AEDs. Jacob Colker, CEO of The Extraordinaries, has stated that they have hundreds of billions of hours of spare time that just happens to come in 20 to 30 minute spurts.

Colker states that if there were more opportunities available for people to give of their time, as made possible by something like micro-volunteering, then maybe they will return. The focus is on creating as many platforms as possible to provide people with avenues to give of the time, for the betterment of humanity as a whole. As this notion continues to gather momentum on an increasingly global scale, the resultant positive impact on the world could be immeasurable. A journey of a thousand miles begins with the first step, and the business of changing the world begins with the first second.

The American Lung Association makes it national mark

Note: This is a summary of a past story from NPTtv.  Click here to see the video of the story.

The American Lung Association, or ALA, as launched its first national PSA branding campaign in over 10 years with the objective of raising awareness and engaging the public in the mission of this public health charity which was founded about 100 years ago. The campaign incorporates television, radio, print, as well as out of home elements, all designed to place a focus on the brand platform of the ALA and tag-line, "Fighting For Air".

The ALA vision and objective

Charles D. Connor, the CEO of the ALA was quoted as saying, "We believe that 'Fighting For Air' works on multiple levels to frame the Lung Association's life-saving work." With the new ad campaign that the ALA has launched they are hoping to reconnect with long-time donors, and to increase public awareness about the association's work in providing support to people in the areas of lung disease, the research of cures and medications, fighting to keep children off tobacco and to combat the adverse effects of air pollution.

The air that American's are breathing, generally speaking, is becoming increasingly contaminated with a variety of pollutants. The need to ensure the survival of clean air is paramount to maintaining healthy human existence, and the ALA is committed to seeing this objective realized, although it is an admittedly tall order given the current framework in which the association finds itself laboring. The ALA is the leading organization of its current, and now in the second century of its existence it continues to fight for clean air on behalf of every human being that relies on it.

The impact on lifespan of having a will

Note: This is a summary of an older story fom the Nonprofit Times TV.  To view the full story, click here.

According to Adrian Sargeant, a planned giving specialist, the benefits of having a will go beyond just the financial. Statistics show that on average, someone without a will dies at age 69. On the other hand, someone with a will lives on average up to the age of 79. For those who have a in the form of a bequest, the average lifespan is 82 years of age. It appears that being organized and exercising generosity are exceptionally good for the health.

Thursday, March 10, 2011

Revenue for Top 100 Nonprofit Organizations Down 4%

Note: This is a summary of a story from an older episode of the Nonprofit Times TV.  To view the full story, click here for the video.

100 of the United State's largest nonprofits experienced a 4% drop in revenue last year, according to the NPT Top 100 Listing for 2010. At the top of the list was the YMCA, which raised $5.8 billion, a respectable number but still less than it had raised in previous years. Rounding off the top 5 were Catholic Charities USA, United Way Worldwide, Goodwill Industries, and the American Red Cross.
A rebound from the stock market and investments did make revenues at NPOs slightly higher than expected this year. Still, revenue needed to make the NPT 100 declined considerably when compared to previous years. To showyou just how much revenue declined, take a look at this statistic: revenue was $179 million last year. This year?  It came out to a little more than $150 million. Overall, that was a 16% loss of revenue.  Wow. We can only hope that the next year will bring a better result for these esteemed organizations.
To see the complete list of organizations in the 2010 NPT Top 100 List, visit

Guidestar Releases Study of Budget Reductions

Note: This is a summary of an older story from the Nonprofit Times TV.  To view the whole story, click here.

Nnnprofits often have to run on reduced budgets during economic downturns like the one we are experiencing. But in a recent survey by GuideStar, we discoverwhat follows because of these reductions.  In short, NPOs see downsizing of services and activities,salary freezes, and even hiring freezes..
Despite the fact that very few of the organizations in the study reported a decrease in demand for their services in the first five months of the year, half of the organizations that were surveyed said that they implemented a salary freeze. Other statistics from the survey included the following:
  •  38% had layoffs
  • 30% implemented a hiring freeze
  • 23% reduced employee benefits
  • 21% reduced salaries
  • 16% reduced operating hours
Only 1 in 8 of the nonprofits surveyed said they restructured or merged with another company.  While these budget cuts have very bad consequences for nonprofits across the country, it is unfortunately a necessary evil that must take place when times are tough for the country.  Hopefully, budgets for organizations will be able to return to normal within time.

Planned giving within the nonprofit sector

Note: This is a summary of an older NPTV story.  For the full video of the story, click here.

If you've ever wondered what kind of impact bequest giving has on the nonprofit sector, you are sure to find this informative and clearly presented video useful. Almost three quarters of American adults have no wills, or have made no formal plans to leave behind any form of charitable gift. A mere 21 percent of Americans have actually formalized a will, or made any intentional and concrete plans to bequest a gift to a charity. Just three years ago, a total of about 51% of American adults had a will in place.

Bequest giving in 2009 was estimated to be valued at $23.8 billion. A survey conducted by Opinion Research Corporation found that women were more likely to make a charitable gift than men, but men were more inclined to have a formal will in place than women. Contributing factors to the presence of a will include education level and wealth. While this is the case, the actual gift will by and large depend on who is requested to give it. Bequests are predominantly motivated by a personal involvement with a charitable organization or personal experience with a subject addressed by a nonprofit organization. Tax consequences tend not to be the primary motivator. This is according to Adrian Sargeant of the Center for Philanthropy at Indiana University.

Giving motivated by personal ties

As might be expected, people are more open to the idea of saving rather than the notion of giving. In addition to this, most people are more likely to leave their estate to loved ones, rather than channel those assets to an area where no personal ties exist. These are the sentiments of Frank Minton, a planned giving expert and a consultant to PG Calc. Spouses are first in line to benefit from bequests, followed by children and grandchildren. Clara Miller of the Nonprofit Finance Fund acknowledges that times are tough, and that elderly people in particular are seeing their entire retirements passing before their eyes. Be sure to check out this video to get a better idea of the state of planned giving within the nonprofit sector.

The IRS is requested to investigate nonprofit political dealings

Here's another summary of a past NPTV story.  Check it out in its entirety here.

Congressional mid-term elections are just around the corner, and the IRS has been requested to launch investigations into the political campaign dealing of numerous major organizations with 501C4, C5 and C6 designations. This is the subject of those well laid out video presentation. The request was made to the IRS by Max Baccus, a Democrat from Montana and the chairman of the U.S. Senate Finance Committee.

Four primary areas of investigation

The IRS will be focusing their survey on 4 key areas with regard to the organizations in question. Were activities for their states tax-exempt objectives, or are dealings related to political campaigns their primary area of focus? Are they complying with proxy tax and notice requirements? Are their activities bases on the private interests of large contributors, or legislative lobbying? Do they provide extra benefits to significant donors? According to Grant Thornton LLP, organizations that are exempt from federal tax are prohibited from making political campaign dealings their prominent focus.

The nature of the tax law means that it limits the measure to which charitable organizations can get involved in the political arena. At this stage it is unknown how exactly the IRS will conduct its survey, but it is likely that 501C3 organizations will be the subject of investigation as well in the future due to increasing media attention and pressure from congress. Be sure to check out this video about this interesting development in the nonprofit sector.

Highlighting amendments in the tax form 1099

Here is another summary of an older NPTV story.  View the story in its entirety by following this link.

This video deals with proposed changes to the tax form 1099 and with the associated action taken by the United States senate.

In a recent vote in the United States senate of 52 to 46, proposals to introduce two changes that modify reporting requirements for form 1099, were rejected. The amendment to repeal the modified requirements did not meet with success in the U.S. Senate. A separate change to form 1099 to raise the reporting threshold from $500 to $6000, while providing exemptions to corporations with less than 25 employees, was also rejected.

The Center For Association Leadership has announced that a similar bill has now been introduced which includes the $5000 threshold, but omits the offering of exemptions to certain businesses. The Internal Revenue Service is invited feedback from the public on this issue until September 29th.

Observing trends in religious donations in the USA

This is a summary of an older story from the Nonprofit Times TV.  Want to see the story in full?  Click here.

When it comes to giving and fundraising in the nonprofit sector, religious giving has always topped the list as the main component of the overall donation total. In 2009, religious giving experienced a slight decline of 1% as compared with the previous year, whereas the nonprofit sector as a whole experienced a 7% decline over the same period. This video shares some interesting insights about the challenges that religious institutions face when it comes to attracting the attention of donors. The presentation is clear and well presented.

Challenges facing religious giving figures in the current economy

Sharing some of his thoughts on this issue is Bill Wildey, director of funds development and marketing with Church World Service. Bill says that a growing number of congregations have a growing proportion of people who are battling with unemployment, salary cuts and the loss of stability. This of course has a direct impact on the kinds of resources that are available to and in the religious sphere. One area that Church World Service is involved in heavily is that of refugee relocation and resettlement within the United States, and dealing with the associated immigration challenges can sometimes be tricky when trying to assist refugees in this way.

The business of attracting the attention of potential donors is made more challenging in light of tough economic conditions. One of the difficulties also being experienced is persuading people to exercise compassion and generosity as it relates to various humanitarian endeavors that they themselves are not impacted by. People remain far more inclined to give towards causes that they or a loved one are personally affected by. The prediction is that this will probably not be changing in the near future, with the current trend continuing well into 2011 and beyond. Have a look at this video to learn more about the fundraising challenges faced by religious organizations.

Wednesday, March 9, 2011

Jeff Regen on Multi-Channel Marketing

In the latest installment of the Nonprofit Times TV, Jeff Regen, Senior VP of Integrated Services at M&R Strategic Services, catches up with us after he spoke at the Direct Marketing Association's annual conference in Washington, DC.  Regen spoke at a session called Making Multi-Channel Marketing a Reality, and he talked about the value that multi-channel donors have for charities and nonprofits.  According to Regen, they are worth almost four times more than offline donors, and are worth two and a half times more than online donors, and that their retention rates are "through the roof."

In general, Regen makes a lot of great points about the value of multi-channel marketing.  While it is true that the internet is the main source of donors these days, it makes no sense to completely ignore offline donors.  By reaching out to both parties,  it makes a lot of sense that your organization would be more successful than one that limits its focus to either extreme.  Of course, this is just one opinion.  Do you think Regen is correct, or is he off-base on this point?

Andrew Watt Tapped as New CEO of AFP

The Association of Fundraising Professionals has chosen Andrew Watt to be their new CEO.

The latest episode of the Nonprofit Times TV gives a profile of the new President and CEO of the Virginia-based organization, which is the world's largest organization of professional fundraisers.  Before being named to his new position, Watt was the Chief Programs Officer and VP of International Development.  He joined AFP in 2006, but has been working in the fundraising since 1993.  He was previously Director of Policy for the Institute of Fundraising in the United Kingdom (he is also an Honorary Fellow of that organization).

AFP has been looking to expand its presence abroad for the past five or six years, so it makes sense that they would pick Watt.  Given his experience at the Institute of Fundraising, he was a natural fit for their organization now and in the future.  Do you agree with AFP's choice, or do you think there was a more qualified candidate they looked over?

What Donors Want: A Guide to Auction Items

Having a fundraising auction anytime soon?  Then you might want to listen to the latest advice from Bidding For Good.

In the latest episode of Nonprofit Times TV, the Cambridge, MA-based organization lists some items that consistently pull in more donors than others.  Travel and dining activities are among the largest draws, along with entertainment, sports, health spas, antiques, arts, and "unique experiences" (hikes, etc).  Bidding For Good also lists several popular brands at online auctions, including Apple, Starbucks, Nintendo, and The Cheesecake Factory.

It makes a lot of sense that these items would be so popular at fundraising auctions, as they are things that any donor would enjoy.  Travel is especially obvious, as everybody needs a break from the hustle and bustle of everyday life from time to time.  Have you found the items Bidding For Good lists have held true for your auctions?  Let us know in the comments section.

Larry Jones and Feed The Children Kiss and Make-Up...Sort Of

In the newest installment of Nonprofit Times TV, we get the update on the now concluded legal struggle between Feed the Children and its founder, Larry Jones.  The Oklahoma City-based nonprofit recently announced that the litigation between the two parties has ended.  Terms of the agreement, however, were not disclosed as they were deemed "confidential."  We do know, however, that no part of the agreement will have Mr. Jones return to the organization in any capacity.  Jones was dismissed by the organization in 2009, which sparked his legal challenge of Feed the Children.

The dispute between Jones and Feed the Children has been well-documented, so it's good to hear that these two parties have finally put their differences behind them.  It is especially useful for Feed the Children.  This legal battle must have been a huge distraction to their business.  With the litigation over, they can get back to the job that Larry Jones intended them to do when he established the organization in 1979.  As always, give us your thoughts on this fascinating story.

Robert Jones, Nonprofit CEO, Gets 10 Years in Prison

It's never good to hear about a nonprofit CEO involved in fraudulent activity, but that's exactly the case in the latest installment of Nonprofit Times TV.  According to the report, the head of the National Center for the Employment of the Disabled, Robert Jones, has been sentenced to 10 years in prison for fraud related to government contracts.  Jones was convicted for, among other things, lying about the number of disabled workers his organization had to qualify for no-bid government contracts.  Jones was also fined $65 million in restitution.

Patrick Woods, a former board member of the organization, was also convicted in the case. He was sentenced to three years in prison, and must pay $1.7 million.  The El Paso, Texas organization, looking to move on from this story, is now operating under the name ReadyOne Industries.

We hear stories about fraud in major businesses all the time, so it's especially sad when we see people working for an organization that is supposed to be fighting for the disadvantaged involved in criminal activity.  What are your thoughts about the sentencing of Robert Jones and Patrick Woods?  Is it too harsh or not harsh enough, considering the crime?  Tell us your thoughts.  

Watch a New Episode of The NonProfit Times TV Today 1PM!!!

Watch Online at

In this webcast:
• Nonprofit CEO Gets 10 Years: CEO gets jail time for fraud.

• Feed The Children and Founder Settle Lawsuits: Larry Jones and Feed the Children have settled multiple, dueling lawsuits.

• Donors Want Travel, Dining From Charity Auctions: The top 10 items for online charity auctions.

• Watch online at

It take less then 7 minutes to watch the whole episode

Results from the Commonfund Benchmarks Study

Here is a look back at another past episode of NPTV.  You can view the episode here.

Investments by health groups returned an average of 18.8 percent in the face of a turbulent ride in the stock market. This is according the to the Commonfund Benchmarks Study of healthcare organizations. The study focused on the fiscal year 2009 average total rate of return on investable assets as it relates to 85 charitable healthcare organizations. The study has been running for 8 years now, and this is the highest return reported over that period. This follows the lowest return reported in the 2009 results.

The 85 organizations represented in the study account for $76.8 billion dollars in investable assets and $26.8 Billion is defined benefit plan assets as of the end of 2009. Investable assets are comprised of various asset types including endowment foundation funds, funded depreciation, working capital and other separately traded assets and investments.

What is Commonfund?
Commonfund provides charitable institutions with fund management and investment advice. It is one of the leading investment firms for colleges, universities and secondary schools, foundations, hospitals and other philanthropic and tax exempt organizations. It was founded in 1971 as a nonprofit, membership organization with a grant from the Ford foundation. Commonfund's mission is to improve and enhance the investment management practices and financial resources of its clients. It manages over $25 Billion with a focus on three primary activities, being outsourced solutions, private capital and alternative investment strategies.

New Jersey puts the squeeze on nonprofits

Here is another past episode of NPTV.  Check it out here.

New Jersey has gone about cutting corners in a controversial way in an attempt to save dollars. The state has proposed a limit on how much it is willing to pay towards state contracted CEO salaries, as well as on employee benefits for nonprofit social service agencies. The proposed alteration to the third party contract language would result in New Jersey capping salaries and employee benefits based on the operational budgets of nonprofit organizations.

What this proposal looks like
For nonprofits with a budget of more than $20 Million, salaries would be capped at $141,000. In instances where the budget ranges between $10-$20 Million, the proposed cap would be $126,900. In the case of budgets between $5-$10 Million, the relevant proposed cap would fall at $119,850. Meanwhile, budgets of less than $5 Million would attract a salary cap of $105,750. At this stage is unclear is that number is total compensation or base salary as reported on the federal form 990.

Less funding for other areas also
Beyond placing a cap on salaries, the state would also limit its funding with regard to issues like travel, education, severance and vehicle operating costs relating to all employees in the charitable sector. In proposing these controversial measures, the state of New Jersey is hoping to save an estimated $5 Million. These changes are due to take effect on July 1st 2011. As might be expected, it is a move that has many charitable workers disappointed and enraged.

Attracting the correct mix of minds to the nonprofit sector

This is a look back at an older NPTV episode.  Check it out here.

One issue that has always been a focus of discussion in the nonprofit sector is how to go about attracting the correct partnership of minds, particularly as it relates to board members. Getting this combination to operate efficiently can be a real challenge, not least of which when times are difficult. The issues under discussion have included salary for board members, the operational function that boards should exercise, and the adversity of members to risk. These issues have often been the cause of controversy.

Gaining some insight
According to Dennis C. Miller, President of Dennis C. Miller and associates and author of the new book entitled "The Nonprofit Board Therapist", paying board members beyond covering operational expenses will detract from the overall efficiency of the organization in question. He feels that boards should be more purposefully focused on assisting the organization in achieving its fundraising objectives so that the relevant vision and goals can be met more effectively. When a nonprofit consistently fails to operate at it maximum potential, Miller feels that it's a failure on the part of the board and the CEO. Dennis Miller feels that a new type of board member is necessary for a new that is more open minded to new and innovative avenues of fundraising and operational strategies.

The new role of the nonprofit CEO
Miller goes on to say that the role of the nonprofit CEO in the current economic and technological climate is to ensure that the potential of board members is fully reached as it relates to their impact on the organization. This involves engaging them in discussion, seeking their ideas and asking pertinent questions. The most suitable scenario is where the CEO and board member operate as partners from a leadership point of view. A board needs to be highly enthusiastic and motivated, be willing to examine itself and it's performance, and be actively and personally involved in fundraising, according to Miller.

NASA seeks management support of the nonprofit kind

This is a look back at a past NPTV episode.  You can view the episode in it's entirety here.

NASA has announced its desire to identify a nonprofit organization to manage its international space station programs As the space shuttle program comes to an end NASA is looking for an independent research management organization to grow and manage the US portion of the space station. In 2005 the space station in question was designated a National laboratory. The NASA authorization act of 2010 directed NASA to extend station operations until 2020, as well as to establish an organization to manage station research by other US government agencies, academic institutions and private corporations.

The NASA authorization act was signed by President Barack Obama on October 11th, 2010. The act approved the spending of $58.4 billion on NASA programs over the following three years. The spending would include additional shuttle flight, the extension of the international space station, and the development of heavy-lift rocket technology. With this act in place, NASA has a strategic roadmap and has set its sights firmly on Mars. This move on the part of NASA represents an attractive prospect for the suitable organization It means that a relatively stable line of income can be secured over a significant period of time, working on a sought after and prestigious contract.

Eligibility criteria established by the authorization act

According to the NASA authorization act 2010, the organization chosen to fulfill this role has to comply with a range of criteria. The organization must be exempt from taxation under section 501C3 of the internal revenue code of 1986, and must not have any other organizational objective or responsibility on behalf of the organization, or any parent organization or other entity.