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SNAP: Strengthening Nonprofit Advocacy Project Overview of Findings May, 2002. A multi-year research project of Tufts University, OMB Watch, and Charity Lobbying in the Public Interest. Table of Contents. Section I About the Research Section II About the Respondents

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SNAP:Strengthening Nonprofit Advocacy ProjectOverview of Findings May, 2002

A multi-year research project of Tufts University, OMB Watch, and Charity Lobbying in the Public Interest

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Table of Contents

Section I About the Research

Section II About the Respondents

Section III Findings

Part A: Language Makes A Difference

Part B: Policy Participation

Part C: Major Barriers and Incentives

Part D: Understanding the Rules

Part E: Who Makes the Decisions

Part F: Using Technology

Section IV Implications and Next Steps

Section V Acknowledgments

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About the Research

  • Why the Research was Needed

  • To understand how to motivate more public policy participation by nonprofits in the U.S.

  • To inform organizations working with nonprofit leaders about the factors that influence and deter public policy participation and how to help organizations hurdle persistent barriers to policy engagement.

  • To investigate current perceptions of nonprofits’ lobbying, advocacy and public policy role.

  • To provide a comprehensive body of national research on the state of nonprofit advocacy and public policy participation.

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About the Research

  • The Key Research Questions

  • What words and phrases do nonprofits use to describe public policy activities?

  • What internal and external factors motivate and deter nonprofit participation in the public policy process?

  • How do the staff of nonprofits and their volunteer leadership make decisions about the course of their public policy participation?

  • What resources are needed to strengthen nonprofit advocacy and public policy participation?

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About the Research

  • Methods Used

  • National survey of 2,735 randomly selected charities (i.e., 501(c)(3) organizations) that file IRS Form 990, with the exception of hospitals, universities, and private foundations. Survey: January to June, 2000; 63.7% response rate.

  • Approximately 45 telephone interviews with executive directors that responded to the survey conducted from September, 2000 to February, 2001.

  • 17 focus groups of executive directors and board members from February to September, 2001 in: MN (Minneapolis/St. Paul), TN (Nashville), MA (Boston), CA (Sacramento & Redding), TX (Austin & San Antonio), MI (Detroit & Lansing), & one held in VA with state nonprofit leaders from across the country.

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About the Research

The survey did NOT go to:

  • Hospitals

  • Colleges and universities

  • Private foundations

  • Religious congregations since most do not file IRS Form 990

  • Other organizations that do not file the IRS Form 990, such as those with budgets of less than $25,000

  • Organizations that are not charities, such as 501(c)(4)s (social welfare) and 501(c)(6)s (trade associations)

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About the Research

Research Design

A stratified sample of 501(c)(3) (charity) organizations filing IRS Form 990 in 1998 was selected

501(c)(3) (charities) can choose – or “elect” – to be governed by section 501(h) of the tax code. These “Electors” then know how much they can spend on lobbying.

Charities not making this choice fall, by default, under a vague “no substantial part” test, which we call Non-Electors

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About the Research

Who Received & Responded to the Survey

Note: 3 of the 4 groups – Electors and Non-Electors with lobbying expenditures and Electors without lobbying expenditures -- were over-sampled to ensure a statistically valid analysis of each group.

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About the Research

Focus Groups

Participants were:

  • Organization heads/senior staff

  • Board members

    Types of Groups:

  • General nonprofit

  • Groups whose primary focus is advocacy

  • Health

  • Foundations

Interviews of survey respondents

45 executive directors who volunteered on the questionnaire to be interviewed.

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About the Respondents

On average, 25% of a respondent’s revenue comes from individuals, with 82% of respondents receiving revenue from individuals.

Percent of Respondents Reporting Different Sources of Revenue

Where $1 of Revenue Comes From

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About the Respondents

Annual Expenses

Range: $500 to $457.6 million

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About the Respondents

  • The average age of responding organizations is 34.1 years. The median age is 25 years.

  • Two-thirds of respondents have 11 professionals or fewer on staff (the range is from 0 to 3,600).

  • 50% of respondents have a total paid staff of 11 or fewer (the range is 0 to 5,500).

  • The average number of volunteers is 2,084. However, the number drops to 150 when the 10 largest organizations are dropped.

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About the Respondents

Of those with members:

  • 53% have individual members

  • 23% have nonprofit organizational members

  • 16% have corporations or trade association members

  • 8% have government agency members

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Section III:FINDINGSPart ALanguage Makes A Difference

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Language Makes a Difference

On a survey question regarding the frequency of policy participation, one-third of the questionnaires used the word “lobby,” another third “advocate,” and the final third “educate.” The response was very different depending on the word used.

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Language Makes a Difference

The definition of “lobbying” in this survey is broader than the IRS definition

  • 61% of those who report no lobbying expenses to the IRS on the Form 990 indicate on our survey that they do “lobby.”

  • This confirms we are measuring different types of behavior than that reported to the IRS – and means our data cannot be compared to the IRS Form 990 data.

  • This suggests that those writing for nonprofit audiences need to use more consistent language to talk about lobbying, advocacy and public policy participation – or at least be aware of varying definitions.

We asked if they have done: “Lobbying on behalf of or against a proposed bill or other policy pronouncement”

IRS has a narrower legal definition based on attempts to influence legislation. IRS has legal exemptions to “lobbying” and does not include the broader policy issues our survey does.


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Language Makes a Difference

Call it Anything Except “Lobbying”

  • A health care executive in Boston, MA said his organization calls it “impact analysis.”

  • A human services executive director in Austin, TX claims he doesn’t lobby after describing a lobby effort to get a spending bill enacted in Texas.

  • The head of a voluntary association in Sacramento, CA said the organization lobbies, but will never use the word. She said, “we educate legislators.”

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Language Makes a Difference

Call it Whatever You Want, Just Do It

  • The head of a MN environmental group emphasized that you can’t keep “putting out forest fires everyday. You have to change the system… to impact public policy is very important for nonprofits.”

  • A director of a community services organization in TN reflected comments from many other nonprofit leaders: Nonprofits need to “get beyond that negative connotation and realize this is their voice and without it, they're left behind.”

  • Some MI foundations felt that they should support coalition building, research and other approaches to help grantees engage in public policy.

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FINDINGS:Part BPolicy Participation

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Policy Participation

  • We looked at 9 types of activities:

  • Testifying

  • Direct Lobbying

  • Indirect or Grassroots Lobbying

  • Responding to Government Requests for Information

  • Working in Planning or Advisory Groups with Government Officials

  • Meeting Government Officials about Work

  • Releasing Research Reports

  • Discussing Grants/Contracts with Government Officials

  • Interacting Socially with Government Officials

Of these 9 activities, focus group participants unanimously defined policy participation as those activities in red italics.

Our analysis classifies a charity as a “participator” if they engage in one or more of the three red italicized activities regardless of frequency.

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Policy Participation

A Good News – Bad News Story

The Good News

Respondents say they participate in the public policy process and that they lobby…

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Policy Participation

A Good News – Bad News Story

The Bad News

But the frequency of participation is low. For example, 69% either never do direct lobbying or do so infrequently…

Grassroots Lobbying

Direct Lobbying

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Policy Participation

A Good News – Bad News Story

The Bad News

And, for example, 78% either have never released a research report to the media, public or policymakers or do so infrequently.


Release Research

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Policy Participation

Charities say that lobbying and participation in public policy is a core part of their mission…

  • In focus groups, many executive directors said that being a policy advocate is a key responsibility of being an executive director.

  • As a MN housing group said, “We do legislative work. We put together an agenda and advocate for [it].”

  • “We carry out a core function of government; therefore we insist on a partnership with government. But that sometimes means we have to pressure government for a place at the table and to act upon our recommendations.” – a PA disability association

  • An executive director of a small human services organization in NE notes: “I try to sit on as many committees and commissions as possible so I can try to influence public policy.”

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Policy Participation

But some do not see public policy participation as important, ethical, or a wise use of resources

  • Many executive directors felt that spending time on lobbying detracted from doing the work that they should or must be doing – such things as fundraising, dealing with staff issues, and day-to-day crises.

  • “We simply don’t do those types of things,” said a faith-based group in San Antonio, TX.

  • “It is not our mission to engage in public policy. It is inappropriate to lobby,” said a nonprofit executive of an organization dealing with substance abuse in Sacramento, CA.

  • Some board members do not fully understand the role charities play with regard to public policy or actually have negative views about them engaging in lobbying – or even advocacy.

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Policy Participation

Even When Charities Engage in Policy They Do Not Think of Themselves as Influencing Policy

  • 46% of survey respondents who said they “never make any effort to influence government” also identify themselves as “participators,” meaning they either lobby or testify.

  • This suggests that charities do not view their policy participation as attempting to influence government.

  • One recipient of our survey called to say that “our organization is inappropriate for the study because we’re not involved in public affairs.” Yet, when asked if they deal with public officials, she said, “Oh yes, we harass our state legislators all the time.”

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Policy Participation

Most Groups that Lobby

Do Not Make it a Priority

  • 3 of 5 respondents that lobby say they do so at a low level.

  • A majority (33%) of low level lobbyers do it at the lowest level available on the survey.

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Policy Participation

Direct Lobbying Comparisons

By Different Types of Charities

(On a 0-4 Scale)

Survey average

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Policy Participation

Grassroots Lobbying Comparisons

By Different Types of Charities

(On a 0 to 4 Scale)

Survey average

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Policy Participation

Testifying Comparisons

By Different Types of Charities

(On a 0 to 4 Scale)

Survey average

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FINDINGS:Part CMajor Barriers and Incentives

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Barriers & Incentives

Money, tax rules, and staff skills are the top three barriers to policy participation

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Barriers & Incentives

Limited Funds as a Barrier by Type of Charity

(On a 0 to 4 Scale)

Survey average

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Barriers & Incentives

Tax Law/Regulation as a Barrier

by Type of Charity

(On a 0 to 4 Scale)

Survey average

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Barriers & Incentives

Staff Skills as a Barrier by Type of Charity

(On a 0 to 4 Scale)

Survey average

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Barriers & Incentives

Role of Government Funding

Three of four respondents that get government grants feel that government funding is a barrier to their participating in policy matters.

As government revenue increases so does the barrier level.



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Barriers & Incentives

Nonprofits raised major fear of government retribution for engaging in public policy matters

  • One human services director in TX noted that they expected their state grant to be eliminated or cut because they lobbied an opposite point of view of a legislative staffer who now works in the state agency providing grants.

  • One large voluntary organization claimed they “lost 80% of their state grants because of lobbying.”

  • One director of a health care provider in MA said, “Literally, you take a position critical [of a policy], the next day the special audit team from the state, they’re in all your records… [I]t’s very hard to be an advocate when you’re dependent upon state money.”

  • In MI, many supported the comment made by a participant that “government grants can dilute advocacy.” A PA disability group added: “If you [receive] government funding then there are subtle ways government can coerce you. When this happens our Board begins to tremble.”

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Barriers & Incentives

Role of Foundations

Although 58% of respondents said that receiving foundation funds is not a barrier, it is a barrier for certain types of groups.

As the percentage of a charity’s revenue from foundations increases so does the perception that foundation revenue is a barrier to lobbying.

Those that do not lobby see foundation funding as a statistically significant barrier when compared to those that do lobby.


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Barriers & Incentives

It is perceived that foundations are reluctant to provide resources for meaningful policy participation

  • Advocacy is ignored. The director of a health group in PA summed it up: “Foundations are interested in national advocacy but not in supporting it locally… They want to have a national impact.” Yet national groups also say foundations do not support advocacy.

  • Advocacy is restricted. As a TN human services group said, “All the major foundations have a clause [in grant letters] that says you cannot do any lobbying with their money, every one of them.”

  • It takes a crisis. The director of a MN housing program echoed a common refrain: “In the past, they [foundations] have denied us [grants]. But now the housing situation here is getting so desperate that they realize that they need to get behind the advocates.”

  • There is no consistent support. A national arms control organization noted that even when foundations do provide support for advocacy or lobbying, they don’t understand the need for continued support. “Foundations will fund something for a few years…Unfortunately, two or three years is not how change works. They want instant gratification… Foundations think there is an instant solution for social problems.”

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Barriers & Incentives

Ironically, as government and foundation revenues increase, respondents tend to become more involved in policy matters

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Barriers & Incentives






Degree of Motivation

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Barriers & Incentives

Impact of Perceived Government Interest in Your Organization on Policy Policy Participation

Respondents that believe government officials are interested in their organization tend to participate more in public policy matters

Level of Interest

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Barriers & Incentives

Policy participation, by all measures, is significantly higher as the number of government initiated contacts to any staff member increases

# of Govt Initiated Contacts

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Barriers & Incentives

Budget Size is a Great Predictor

of Policy Participation

Respondents with annual expenses of $1 million or more are significantly more likely to participate in policy than those with expenses below $1 million.

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Barriers & Incentives

Staff Size is a Predictor

of Policy Participation

As organization size increases by number of staff, respondents participate more in public policy.

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Barriers & Incentives

Respondents that belong to associations that represent them before government are more likely to participate in public policy matters

Respondents that are Participators

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Barriers & Incentives

Policy participation remains high regardless of whether respondents are represented by a local, state or national organization.

However, the frequency of participation is significantly higher when the respondent belongs to a national organization. Direct lobbying is significantly higher when you belong to either a state or national organization.

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Barriers & Incentives

Number of Times Per Month Contacted by Associations to Take Action

Two-thirds of respondents that belong to associations that represent them before government are asked once a month or less to contact policymakers

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Barriers & Incentives

How Often Respondents Act Upon Requests by Associations to Take Action

Contact and Actions Per Month

Ask and You Shall Receive

As frequency of requests to take action are made by associations, respondents increase the number of times they act upon the request.

When contacted 4 or more times per month, 78% of respondents take 2 or more actions per month.

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FINDINGS:Part DUnderstanding the Rules

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Understanding the Rules

There is a broad understanding of some of the general laws and regulations governing policy participation

  • 94% know they cannot use federal funds to lobby

  • 91% know they can talk to elected officials about public policy matters

  • 87% know they cannot endorse candidates for office

  • 82% know they can take policy positions without referencing specific legislation

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Understanding the Rules

Two areas in which education is still needed deal with key components of policy participation

  • Only 72% know they can support or oppose federal legislation

  • Only 79% know they can support or oppose federal regulations

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Understanding the Rules

Two areas that present potential major problems for respondents

  • 50% thought they could not lobby if part of their budget comes from federal funds

  • 43% thought they could not sponsor a forum or debate featuring candidates for office

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Understanding the Rules

Understanding of federal lobbying laws and rules is not very deep and fairly limited

  • Even in focus groups of high participators, most executives did not know basic information about lobby laws, such as how much lobbying they can do or even what constitutes lobbying by IRS definitions.

  • Board members and foundation staff, in particular, do not have a good understanding of lobby rules.

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Understanding the Rules

Correct Answers to Survey Questions

by Type of Charity

(Maximum correct is 8)

Survey average

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Understanding the Rules

Elected officials do not understand the rules faced by 501(c)(3) organizations

  • During focus groups, executive directors in different cities spontaneously raised concern about pressure that politicians put on them for organizational campaign contributions, even though charities are prohibited from making such contributions.

  • Many directors choose to make personal campaign contributions because they are worried that it might affect the organization’s ability to raise policy issues with the elected official.

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FINDINGS:Part EWho Makes the Decisions

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Who Makes the Decisions

  • The executive director has the most influence regarding government relations and is most often identified as the person with responsibility for public policy.

  • Yet organizations with an executive director in charge of public policy are statistically less likely to engage in all forms of public policy participation – testifying, direct lobbying, grassroots lobbying, and releasing research to policymakers.

  • Organizations where either a lobbyist or staff are in charge of public policy are significantly more likely to be engaged in public policy than when the executive director or a board member is in charge of public policy.

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Who Makes the Decisions

  • The executive director is most often identified as the person with responsibility for public policy

  • Policy participation is significantly higher when such responsibility is entrusted to others

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FINDINGS:Part FUse of Technology

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Use of Technology

90% of respondents use email, while 63% use it for public policy purposes

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Use of Technology

Organization Size and Use of Email: A Digital Divide?

As budget size increases so does use of email, including for public policy.

87% of respondents not using email have annual expenses of less than $1 million.

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Use of Technology

Use of Email and Lobbying

To what extent do those who use email engage in lobbying?

As use of email increases, it is significantly more likely that respondents lobby.

However, use of email is not a good predictor of frequency of lobbying.

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Implications & Next Steps

Addressing Barriers to Participation is Vital

  • There are persistent barriers to public policy participation that nonprofits face that must be addressed if there is to be a robust civil society

  • Even when motivated, many are not ready, lacking organizational infrastructure and staff skills

  • However, some nonprofits, particularly those providing direct services, view policy participation as beyond their scope

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Ordinary Tasks

Service Delivery


Staff Issues

Responding to Day-to-Day Issues


Extraordinary Tasks



Policy Advocacy

Implications & Next Steps

The Challenge:

Turning the Extraordinary into

the Ordinary

It is essential to help nonprofits understand that public policy participation is as important as other day-to-day organizational activities

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Implications & Next Steps

Some of the Key Training Needs

  • Organizational capacity building for public policy

  • Government grant rules on lobbying

    • Although 1/3 of nonprofit revenue comes from government, 50% of nonprofits don’t know they can engage in advocacy if they get government grants.

    • Focus groups show that understanding of lobby restrictions under grant rules is very poor

  • Lobby and advocacy rules

    • Nearly 30% of nonprofits do not know they can lobby and advocate. Moreover, focus groups show the understanding of the laws and regulations is not very good – even among those who are very engaged in public policy.

    • Nonprofits need to better understand the rules around electoral activity, particularly since many are being asked for candidate endorsements

  • How to lobby and advocate effectively

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Implications & Next Steps

Other Important Issues

  • The rules regarding lobbying and advocacy need to be simplified in order to encourage greater participation

  • Different strokes for different folks. Not all nonprofits have the same needs with regards to strengthening public policy participation. Training and technical assistance should be differentiated for the audience.

  • Foundation staff need a better understanding of the importance of nonprofit public policy participation and the legal opportunities for funding advocacy activities.

  • Training board members on the importance of public policy participation is very important and largely non-existent.

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Implications & Next Steps

Schedule for Future Actions


  • Report on public policy participation of health organizations

  • Report on use of email and technology for public policy

  • Testing of website,, a resource center for information about nonprofit public policy participation and use of technology


  • Comprehensive report based on this Overview data


  • Reports on various types of nonprofits

  • Special analyses

  • Public release of

  • Release of book on advocacy incorporating SNAP data

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Aspen Institute’s Nonprofit Sector Research Fund

Atlantic Philanthropies

Nathan Cummings Foundation

Ford Foundation

Robert Wood Johnson Foundation

David and Lucile Packard Foundation

Surdna Foundation

SNAP Supporting Organizations

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SNAP Project Team

OMB Watch

Gary D. Bass

Executive Director

Kay Guinane

Manager, Community Education Center

Matthew Carter

Policy Analyst

Ryan Turner


Barbara J. Western

Assistant to the Executive Director

Melissa Brennan

Administrative Assistant

Former employees Patrick Lemmon, Heather Hamilton, and Kelly Patterson

Tufts University

Jeffrey M. Berry


Kent Portney


Erin Desmarais, Catherine Ma, Louis Tavaras, and Mo Twine

Project Assistants

Charity Lobbying in the Public Interest

David Arons

Co-Director (& SNAP Project Director)

Bob Smucker


Carolyn Nelson

Project Assistant