Be Reconfirmed in Compliance with National Standards

Five years after your organization is confirmed in compliance with National Standards, you are required to complete the following process of reconfirmation to maintain your compliance status.

To be reconfirmed in compliance with National Standards, you must verify that the evidence of compliance you supplied in support of your initial confirmation remains accurate. In addition, you must supply new information where realities at your community foundation have changed and where National Standards have evolved. Learn about changes to National Standards and how they affect what you’re required to submit and review the entire process.

Take these steps toward reconfirmation:

 

1. Receive your reconfirmation submission date.

At least one year prior to your submission date, Community Foundations National Standards Board will send you notification of this date, and the cost of the reconfirmation process. Your submission date will be assigned based on the date of your confirmation.

 

2. Send your Statement of Agreement.

Complete, sign and send the Statement of Agreement, indicating whether your community foundation intends to submit materials for reconfirmation within 90 days of receipt.

  • You can use the form to request one, six-month extension, which will be automatically granted upon receipt of your request. This form also grants an extension of the licensing agreement until a final reconfirmation decision is reached or your foundation fails to submit reconfirmation materials. Absent extenuating circumstances, additional extensions will be denied.
  • Your reply form must be signed by the president/CEO and board chair of your organization.
  • You must make a non-refundable deposit at this time.
  • If you fail to submit a record binder on the date indicated on the reply form or subsequent extension, your deposit will be forfeited, and you will lose the benefits associated with confirmation of compliance on your license expiration date. If you wish to reenter the process, you will be required to proceed through the full confirmation process.

 

3. Review your past compliance evidence.

Return to the policies and other paperwork you submitted when you applied for confirmation of compliance. For the most part, if your organization’s policies and practices have remained the same and your board and president sign the resolution (see step eight below) attesting to this, you do not have to resubmit these materials. However, National Standards have evolved since you were confirmed—and your new record binder will need to address new requirements.

 

4. Review compliance tabs.

Before you begin documentation, peruse each of the 35 tabs of this website. Each tab describes a set of key elements you’ll need to evidence by submitting specific materials. In some cases, you must complete the requirements for multiple tabs in order to satisfy a single standard. Please note that the numbering of what were formerly called National Standards “documents” and are now called National Standards “tabs” has changed as items have been added, removed or combined. This comparison tool may be helpful as you navigate your old record binder and assemble your new one.

Since your organization is not required to resubmit many of the materials that you submitted as part of your original confirmation, it’s important to know what you will be required to submit. In brief, you must submit materials that reflect changes in your policy or practice, those that address baseline National Standards requirements, and those that address new or modified Standards. Within the tabs pages, some key elements and core materials are called out with symbols: reconfirm indicates a baseline or new requirement and PPA indicates that the requirement addresses provisions of the Pension Protection Act. Items marked with a PPA are especially important if you submitted your confirmation record book prior to January 2007, when National Standards were first modified to respond to the Pension Protection Act.

 

5. Print cover sheets.

Each tab is represented by a cover sheet—a template that you’ll complete to describe the documentation you’ve assembled to address the tab’s key elements. Print out all of these coversheets to guide and organize your documentation. Later, use completed cover sheets to organize your record binder by tabs. Each cover sheet contains:

  • “Key Elements,” describing the documentation you are to submit in order to comply with the related National Standards.
  • “Supporting materials,” providing space to name the documents you’ve supplied under each coversheet (e.g., “Bylaws”) or to include a cross-reference if you’ve already supplied the evidence beneath a different tab coversheet.
  • “Page and/or Section,” providing space to direct the reviewer to the specific evidence within the submitted material (e.g., “Page 1, Article III-Directors, Section 2.”). Within the actual materials you supply, you should also highlight the language that evidences the key element.

In some cases, the same material can be used to address more than one key element. For example, your bylaws or your corporate minutes may satisfy a key element for several tabs. In this situation, use the cover sheets to cross-reference the material to the appropriate section in your record binder.

6. Prepare materials for submission.

Materials that you must submit as part of a new record binder include those that reflect changes in your policy or practice, those that address “minimum threshold” National Standards, and those that address new or modified Standards. Find out about these requirements before you start gathering materials. All materials you gather must be final—record binders containing un-finalized drafts will not be accepted.

 

7. Build your new reconfirmation record binder.

  • Create a narrative introduction, providing context for the compliance reviewer.
  • Place each single-sided, completed cover sheet before its corresponding set of required materials.
  • Divide each of these stacks of evidence with actual binder tabs with numbers corresponding to the tab numbers on this website. When necessary, further divide separate pieces of evidence using colored sheets of paper or some other device (e.g., separate 12 months’ worth of minutes into 12 sections; separate two years’ IRS Forms 990 into two sections.
  • Make three reconfirmation record binders: two for submission and at least one more copy at your office. Submitted record binders cannot be returned.
  • Avoid using staples and sheet protectors on the evidence you’re preparing for submission because they make it difficult for reviewers to scan and handle. Exceptions include materials, such as annual reports, that cannot be hole-punched for inclusion in a binder.
  • Clearly mark “confidential” on any documents that should be shared only with those directly involved in the reconfirmation process (primarily reviewers). To promote use and knowledge of effective practices in the field, we anticipate sharing exemplary documents not marked “confidential,” so please limit the number of documents you mark in this way to those containing nonpublic, sensitive information. We will contact you prior to sharing any of your documents.
  • Assemble record binder content, including cover sheets and tabs, in one or more three-ring binders. Large binders fall apart during shipping and repeated use, so please do not send binders larger than two-inches thick. If you use more than one binder, indicate the number of volumes on each binder (e.g., volume 1 of 3).
  • Avoid including any identifying information on the outside of your record binder. The Community Foundations National Standards Board considers reconfirmation reviews to be private. Any identifying information on the outside of record binders will be removed or covered.
  • As you prepare your reconfirmation package, be sure you don’t fall into one of the pitfalls of submission.

 

8. Approve a board resolution.

Using the sample board resolution, develop and validate your own board resolution testifying to the confirmation status of your community foundation, your intent to pursue reconfirmation, the validity of any evidence not re-submitted since your initial confirmation, and the accuracy of new/updated materials submitted.

 

9. Submit your reconfirmation package.

Using paper or airbags (not packing peanuts) and a trusted mailing resource with tracking capabilities, submit the following:

  • Signed copy of your approved board resolution
  • The remaining fee
  • Two copies of your completed reconfirmation record binder

Send your package to:

Diane Miller
National Standards Manager
Community Foundations National Standards Board
Council on Foundations
2121 Crystal Drive, Suite 700
Arlington, VA 22202

703-879-0600

 

10. Receive acknowledgement.

The Community Foundations National Standards Board will notify you of receipt of your record binder within 10 business days from the time it arrives. Due to the volume of work involved in processing, tracking and preparing record binders for review, please be patient with our staff as it may take them longer than usual to answer calls and emails asking about reconfirmation status.

 

11. Await the pre-screening process.

Upon receipt of your submission, the Community Foundations National Standards Board will pre-screen materials for completeness and verify continued Section 170(b)(1)(a)(vi) classification by the IRS.

  • If information is missing, you’ll receive notification and have 30 calendar days to supply what’s needed.
  • If missing/final materials are not supplied within the allotted time period, your record binder will not be reviewed. Your deposit will not be refunded, but the other fees will be returned to you. You will lose the benefits associated with confirmation of compliance on your license expiration date. If you wish to reenter the process, you will be required to proceed through the full confirmation process.

 

12. Await the review process.

Reconfirmation materials are peer reviewed by individuals trained to review original submissions and reconfirmation materials in tandem. Reviewers use a standardized reporting form to help ensure each record binder is reviewed fairly and consistently. The review is limited to information you submit. For example, the reviewers may not review material on your website to help determine compliance. As a cross-check to ensure that community foundations’ record binders receive uniform and comprehensive reviews, Community Foundations National Standards Board staff or designees may spot check record binders during the review process.

  • If the reviewer indicates that your community foundation is not in compliance or that it is not possible to determine compliance in light of omissions, discrepancies or other problems with the documents submitted, he/she may ask for additional documents (beyond those automatically requested for reconfirmation).
  • If, after three such interactions, the reviewer remains unsatisfied with your organization’s submissions, the CFNSB Determinations Committee will perform a secondary review.
  • As the liaison between you and your reviewer, Community Foundations National Standards Board will convey to you in writing, any questions or requests for additional materials. In general, you will have 30 calendar days to respond. This period may be extended to up to 90 days. You have up to two opportunities to submit additional materials to answer any questions that reviewers may have and demonstrate compliance.

 

13. Receive notice of the decision.

Following your successful reconfirmation of compliance, you will be notified in writing and you get details about the benefits. If a reviewer determines that your organization is no longer in compliance, this decision will be reviewed by a special committee of the Community Foundations National Standards Board. You will receive notice of this committee’s decision and any options for appeal. At this stage, fees submitted cannot be returned. 

 

14. Uphold the National Standards and reconfirm again.

Your community foundation’s compliance with National Standards is valid for five more years, after which, you will require reconfirmation. During this time, keep your record binder up to date. Your foundation has an ongoing responsibility during the five-year period to ensure its policies and procedures continue to meet National Standards and your foundation may be subject to a random verification during that time. To inform Your foundation should inform to inform the Community Foundations National Standards Board if the information submitted for review during the confirmation of compliance process materially changes (i.e., key elements no longer support compliance). The Community Foundations National Standards Board may request, either randomly or with cause, an audit of your compliance record book during the five year period of compliance. It is anticipated that no more than 5% of community foundations in compliance will be randomly audited in any year.

 

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