Business Policies and Procedures Manual

Use of Resources to Support a Charity, Charitable Organization, or Charitable Purpose

BPPM 10.24

For more information contact:
    Finance and Administration
    509-335-5524

1.0   Policy

State resources may not be used to support a charity, charitable organization, or charitable purpose without compensation to the University unless all of the following conditions are met:

  1. After considering state ethics statutes and requirements (see Executive Policy Manual EP45), the director or head of the unit proposing to engage in the activity approves the activity in writing;
  2. The unit proposing to engage in the activity requests a review of the activity by the Ethics Compliance Advisor;
  3. The Ethics Compliance Advisor provides a written determination to the proposing unit that the activity does not violate state ethics statutes and requirements;
  4. The unit proposing to engage in the activity completes a written approval request and submits the same to the Vice President for Finance and Administration or designee; and
  5. The Vice President for Finance and Administration or designee approves the activity after concluding that the activity promotes organizational effectiveness and that the activity will involve only a de minimis use of University resources.

1.1   General Rule

The University cannot provide University resources for non-University purposes to support a charity, charitable organization, or charitable purpose unless it receives consideration in exchange for those resources, except as authorized by WAC 504-35-050.

Such consideration is to be documented in a signed agreement between the University and the particular charity or organization involved in a charitable purpose, and approved by a University officer with authority to sign contracts (see BPPM 10.11).

1.2   Use Without Consideration

University employees may use state resources for the benefit of a charity, charitable organization, or charitable purpose without financial consideration if the use promotes organizational effectiveness. (See De Minimis Use and Organizational Effectiveness definitions below.)

See also Combined Fund Drive below.

1.3   Examples

An example of an impermissible activity would be an employee sending a broadcast e-mail selling a product or attempting to raise funds that will generate a personal benefit to the employee who sent the e-mail.

Employees are permitted to post notices of charitable solicitations or fundraisers on bulletin boards or in break areas.

Coworkers volunteering outside of their work hours to help raise funds for a local charity or a charitable event is permissible and does not require approvals or review as long as no state resources are used for the effort.

An e-mail or broad announcement sent from state resources to notify employees of the charitable activity would be considered a limited use of resources and is permissible. Note: Employees must follow the procedures outlined in this policy to seek approval for this limited use.

If the charitable activity requires additional state paid time or use of resources, the additional use may exceed the de minimis use guidelines and no longer be permissible.

2.0   Definitions

Charity. A charity is defined, for purposes of this policy, as a gift for humanitarian, philanthropic, or other purposes beneficial to the public. Also a charity may be an institution or organization founded by such a gift.

A charitable purpose results in humanitarian or philanthropic assistance, or is otherwise beneficial to the public.

Charitable Organization. A charitable organization in the state of Washington is defined as any entity that solicits or collects contributions from the public, where the contribution is, or is said to be used to support a charitable purpose.

Charitable organizations must register with the state unless the organization:

  • Raises less than $50,000 annually; or
  • Appeals for funds for an individual who keeps all the proceeds of the solicitations.

Charitable Purpose. A charitable purpose results in humanitarian or philanthropic assistance, or is otherwise beneficial to the public or also benefits an individual or group of individuals.

De Minimis Use. De minimis use occurs when all of the following conditions are met:

  • There is little or no cost to the University.
  • Any use is brief in duration, occurs infrequently, and is the most effective use of time or resources.
  • The use does not materially interfere with the performance of the officer’s or employee’s official duties.
  • The use does not disrupt or distract from the conduct of University business due to volume or frequency.
  • The use does not disrupt other University employees and does not obligate them to make personal use of University resources.
  • The use does not compromise the security or integrity of University property, information, or software.

Employees with questions regarding a particular proposed de minimis use of state resources for charitable purposes should contact the Ethics Compliance Advisor.

Organizational Effectiveness. In order to promote organizational effectiveness, the activity must meet at least one of the following criteria:

  • A relationship to the University’s mission and encompasses activities that enhance or augment the University’s ability to perform its mission.
  • Participation in activities that are not necessarily official duties but support a collegial work environment.
  • Participation in charity support activities that are part of official University duties. Such support may incidentally support a private organization.

Such activities may not involve a University endorsement or promotion of a commercial activity, such as in advertising or selling products.

3.0   Approval Request

To seek the approval of the Vice President for Finance and Administration or designee, the unit proposing to engage in the activity must submit a written approval request which includes the following information:

  • The circumstances of the charitable activity;
  • A description of the charity, charitable organization, or charitable purpose;
  • The specific amount and type of state resource to be used; and
  • What consideration the University is to receive  from the charitable entity, if any.
    • If the University will not receive consideration, the request must also include explanations of:
    • How the level of state resources to be used is de minimis (see De Minimis above); and
    • How the activity promotes organizational effectiveness (see Organizational Effectiveness above).

3.1    Supporting Documentation

 The unit proposing to engage in the activity must attach the following supporting documentation to the approval request:

  • Written approval (in e-mail or memorandum) from the director or head of the unit proposing to engage in the activity; and
  • Written determination (in e-mail or memorandum) from the Ethics Compliance Advisor that the activity does not violate state ethics statutes and requirements.

3.2    Submitting Request

The proposing unit submits the approval request and supporting documentation to the Vice President for Finance and Administration; campus mail code 1045; e-mail VPFA@wsu.edu.

3.3    Determination

The Vice President or designee notifies the administrator of their determination regarding the request.

4.0  Co-Sponsored Events

With the approval of the Vice President for Finance and Administration or designee, a University unit may co-sponsor an event with a charity. A request for a co-sponsored event must be submitted and approved in accordance with the procedures outlined in Approval Request above.

Any co-sponsorship of an event would require the Vice President for Finance and Administration or designee to determine that the University’s participation in the event would enhance the University’s ability to perform one of its missions (education, research, or public service). The responsibilities of the co-sponsoring parties must be explained in a signed agreement prior to the event.

An example of a co-sponsored event might involve an agreement between a local charitable organization and a self-sustaining University unit to co-sponsor a fun run. The co-sponsorship agreement must explain the relationship and duties of the parties. The terms of the co-sponsorship agreement could also permit the co-sponsoring charitable organization to independently pursue specified collateral charitable fundraising efforts in conjunction with the fun run. Such fundraising efforts must be clearly identified.

5.0  Combined Fund Drive

The Combined Fund Drive is an exception to the above rules. Since the Combined Fund drive was established by the state legislature, the University can assign employees to work on the Combined Fund Drive as part of their official duties.

Combined Fund Drive coordinators should confine the time and effort spent conducting the drive to those official duties assigned by the University. University employees not officially assigned to participate in the Combined Fund Drive must observe the de minimis rule when working on the Combined Fund Drive.

For further information, see the Combined Fund Drive website.

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Revisions:  December 2022 (Rev. 604); January 2014 (Rev. 427); Nov. 2006 – new policy (Rev. 289).