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DANA's Public Policy Blog
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DANA will be updating you on important public policy matters as they happen. We will also post about the activities of the Governor, Delaware's General Assembly, local issues, hearings & meetings, and legislation that relates to DANA's Public Policy Agenda.


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Workers' Compensation Rates for 2016

Posted By John Baker, Wednesday, November 18, 2015

Hi All,

DANA has continued to represent our members on the issue of Workers’ Compensation Insurance as one of our Public Policy initiatives. My earlier blog alerted you to the hearings on November 4th and 5th and we were there as well to submit a statement. As you can see below, the rate approved was less that half of what was requested, but we continue to work with the Insurance Commissioner and we agree with the position of the members of the “Workers Compensation Oversight Panel,” chaired by Delaware State Chamber of Commerce’s President Richard Heffron, that "rates should be in the range proposed by the Panel's independent actuary, which recommended a 2-3% increase.”

Insurance Department Announces Workers' Compensation Rates for 2016

DOVER, DE (November 17, 2015) - Insurance Commissioner Karen Weldin Stewart today approved the Delaware Compensation Rating Bureau (DCRB)'s workers' compensation amended rate filing, resulting in an overall average increase of 7.09% in residual market rates and 7.20% in voluntary market loss costs.

The DCRB originally proposed overall increases of 14.92% for the residual market plan and 15.03% for the voluntary market loss costs. The Commissioner's independent actuaries and the state's Ratepayer Advocate each examined DCRB's filing and recommended increases lower than the ones requested by DCRB. Following extensive discussions, the three parties proposed the amended rates which the Commissioner approved today.

As always, if you’d like to talk about this with me please give me a call at 302.777.5500 or email me at


Tags:  Delaware  nonprofits  Workers Compensation 

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Workers Compensation Insurance Public Meetings

Posted By John Baker, Tuesday, October 27, 2015

Hi All –

Since 2012, and as one of our continued Public Policy Agenda items again in 2015, DANA has been working to limit growth in Workers Compensation Insurance (WCI) rates. We attended the weekly meetings of the Governor’s Task Force on Workers Comp. Insurance, which was chaired by Lt. Governor Denn, as a representative of the nonprofit sector in Delaware.

In addition to the Governor's Task Force, we've discussed the matter with legislators, as well as colleagues at the Chambers of Commerce. We have also given testimony at the public hearings in 2013, 2014, and will again next week.

With all that in mind, I wanted to pass along the notice below from the Insurance Commissioner.

Please always know that we at DANA are closely watching this issue on your behalf.

As always, if you’d like to talk about this with me please give me a call at 302.777.5500 or email me at





INSURANCE  COMMISSIONER  KAREN  WELDIN  STEWART,  CIR-ML, hereby gives notice that a PUBLIC HEARING will be held on Wednesday, November 4, 2015 and Thursday, November 5, 2015 beginning at 10:00 a.m., in the auditorium on the Mezzanine level of the Carvel State Office Building, 820 North French Street, Wilmington, DE 19801. Although the Hearing has been scheduled to be held over the course of two days, the first day (November 4, 2015) will be reserved for the receipt of oral comments from members of the public, and the second day (November 5, 2015) will be reserved for the introduction of evidence by the parties to the proceeding.  If all parties agree, introduction of evidence by the parties may begin on the first day.


The purpose of the hearing is to consider whether the Delaware Compensation Rating Bureau (DCRB) Filing No. 1502 dated August 28, 2015, complies with applicable law and should be allowed to go into effect, or whether the filing should be disapproved. The filing requests an overall increase in involuntary market rates of approximately 14.92% and an overall increase in the voluntary market loss costs of approximately 15.03%. The filing and other related public documents are available on the State of Delaware Department of Insurancwebsitat


The hearing will be conducted pursuant to applicable law, including without limitation 18 Del. C. §§ 2605 and 2610 and 29 Del. C. §§10121-29. The docket number assigned to this hearing is 2916-2015.  The Honorable Joshua W. Martin,

III, has been appointed to serve as the Hearing Officer.


A party has the right to present evidence, be represented by Delaware counsel, and appear personally or by other representative. The Delaware Department of Insurance is obligated to reach its decision based on the evidence received.


Comments are being solicited from any person. Comments may be in writing or may be presented orally at the Hearing. Written comments must be received no later than Wednesday, October 28, 2015 by 4:30 p.m., and should be addressed to the attention of Rhonda West, Regulatory Specialist, Delaware Department of Insurance, 841 Silver Lake Boulevard, Dover, DE 19904. Also, those intending to provide oral comments at the hearing must notify Rhonda West at (302) 674-7379 or, no later than 4:30 p.m., Wednesday, Octobe28, 2015.

Tags:  Delaware  Governor  Lt. Governor  nonprofits  Public Policy  Workers Compensation 

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Keeping You Informed and Engaged in Delaware’s Challenging Budget

Posted By John Baker, Monday, September 28, 2015

As I tweeted out on Friday (@JohnDBaker1) the Governor announced the creation of the “Delaware Expenditure Review Committee.” The committee is led by Fred Sears of the Delaware Community Foundation, and will review state government for opportunities to create efficiencies and provide services in a more cost-effective manner. This new group complements the work of the Delaware Economic Financial Advisory Council (DEFAC) on revenues and their report published in May. 

The work of this group, along with that of DEFAC, JFC, Business Roundtable, and other projects, will be important in informing the work of the Nonprofit Sector’s initiative “Delaware Revenue Solutions Working Group” which is hosting a public forum on October 20th from 9:00 to 11:00 a.m. Read more about it at this link to register and save your seat for this important nonprofit sector initiative.

Fred Sears, Chairperson of the Governor’s Expenditure Review Committee, had this to say about the newly created Committee: “This is not going to be easy, but I think the Governor and legislative leaders have appointed a good team that is prepared to go to work."

Joint Finance Committee (JFC) Co-Chair, Melanie George Smith said: “The JFC has made it a top priority to examine our budget for areas where we can save the taxpayers money while improving outcomes for everyone who relies on government services. The JFC welcomes the input, time and ideas of our friends and colleagues in the private sector, and looks forward to working together.”

The Committee, a bipartisan group of government and private sector leaders, includes:

  • Chairperson Fred Sears – Delaware Community Foundation, appointed by the Speaker of the House and designated as Chairperson by the Co-Chairs of the JFC
  • Fred Cottrell – Richards, Layton & Finger, appointed by the Senate Minority Leader
  • Rick Gessner – Capital One, representing the Delaware State Chamber of Commerce
  • Dennis Greenhouse – Former County Executive and State Auditor
  • The Hon,. Joshua Martin – Chairperson of DEFAC; Potter Anderson & Corroon LLP
  • Robert McMurray – Christiana Care Health System, representing the Delaware Business Roundtable
  • Mike Morton – Controller General
  • Ed Ratledge – Chaiperson of DEFAC’s Subcommittee on Expenditures; University of Delaware
  • Jack Riddle – Community Bank, appointed by the House Minority Leader
  • Jeff Taschner – DSEA, appointed by the Senate President Pro Tempore
  • Ann Visalli – Director of the Office of Management and Budget
  • Lincoln Willis – Former State Rep.; Willis Chevrolet

Recent important community voices in the News Journal’s editorial pages:

Tags:  budget  DEFAC  Delaware  Governor  Joint Finance Committee 

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Does Delaware’s Projected Budget Gap Have You Concerned? We Have The Solution For You!

Posted By John Baker, Wednesday, September 16, 2015

The “Delaware Revenue Solutions Working Group – An Initiative of the Nonprofit Sector”  was formed in July, just after the bruising struggle to balance this year’s $50 Million shortfall.  We know that this year will be a much greater challenge, so we’ve started to tackle this Delaware State Budget issue collaboratively, meeting on a weekly basis. 

The “We” is the Delaware Alliance for Nonprofit Advancement (DANA), Delaware Association of Rehabilitation Facilities (DelARF), Delaware Grantmakers Association (DGA), Delaware Community Foundation (DCF), United Way of Delaware (Uway of DE), Association of Fundraising Professionals (AFP), University of Delaware (UD), and many of our Government and Business Partners. 

This is the Working Group that has been moving forward with this on your behalf, but we need to hear from you (and you need to be seen by our elected officials). Join us to have your voices heard at the Delaware Revenue Solutions Working Group Forum:

Click here to Register

Tuesday, October 20th 

Delaware State Police: Troop 2
100 Lagrange Ave
Newark, DE 19702

Join the conversation! Delawareans need to have a statewide conversation about how we will address the challenges, maintain a high quality of life, and build an economy that provides everyone the opportunity to succeed. 

“The Delaware Revenue Solutions Working Group: An Initiative of the Nonprofit Sector” will deliver a whitepaper to you so you can digest all the critical factors at your own pace. (We know how busy you are just serving our fellow Delawareans in need!)  We’ll also provide the additional items listed below:

  • The whitepaper will be committed to by all the organizing groups mentioned above and will present a course forward that will strive to speak for those among us who can not speak for themselves, and preserve the services that they so desperately need.  The expectation is that we’ll integrate your input from the October 20th forum and each organization can use it with their board, staff, and volunteers as your organizing document to plan your advocacy efforts for the year.  We’ll integrate with your efforts and work in coalition.
  • We’ll provide you with materials and key actions that your nonprofit can use with your board, staff, and volunteers.
  • Key dates for action and testimony at JFC, OMB, and other hearings and public events.
  • The forum with the Governor’s Office, the Office of Management and Budget, both chambers of the Delaware General Assembly, the Joint Finance Committee, and the State Chamber of Commerce committed so far.

We’ve examined circumstances in Delaware and learned from other states' experiences. We’ve also looked at applicable reports that have been published recently within Delaware. They will also be summarized for you in the White Paper.  They include:

  • The Final Report of the DEFAC Advisory Council on Revenues
  • The Delaware Business Roundtable – “Delaware’s Structural Budget Problem:
  • Delaware Voice piece by Co-Chair JFC, Rep. Melanie George Smith
  • Delaware Voice piece by General Assembly Leadership, Sen. Blevins, and Rep. Schwartzkopf

Click here for the Working Group’s organizing document

As always, I welcome you to reach out to me with comments or questions.


Tags:  budget  Delaware  nonprofits  revenue 

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Quick Updates on the U.S. TAX CODE and OVERTIME PAY

Posted By John Baker, Tuesday, July 21, 2015

Here are two items that we’re watching.  We keep you updated on items like these in case you want to engage directly with the Delaware U.S. Delegation on these important matters: 

1. U.S. Department of Labor proposed overtime regulations, we alert you to an analysis that the National Council of Nonprofits (NCNP) prepared and circulated.  In the analysis, they summarize the proposal, provide legal and historical background, and offer questions we think nonprofits should consider when submitting comments to the Department of Labor.

“Because the impact of these regulations will be different for every nonprofit – depending on factors such as whether it is a large institution paying large salaries or a smaller community-based organization, and whether its revenue model is based largely on contributions or earning funds through government contracts that may not pay the presumed increased costs – we recognize that the proposed rules will be more nuanced than ‘everybody in a diverse sector loves it or hates it.” That’s why we are encouraging each organization to do its own mission-based analysis of the impact on its own operations and those it serves and to share comments directly with the Department of Labor.”  (National Council of Nonprofits)

House Education and the Workforce Committee will conduct a hearing on Thursday, July 23 entitled, "Examining the Costs and Consequences of the Administration’s Overtime Proposal." We will keep you updated as this matter develops.

2. Senate Finance Committee: Tuesday, July 21, the Committee will “markup” a bill to renew and extend through next year 55 expired tax provisions, including the IRA rollover and the enhanced deductions for donations of food inventories and land conservation easements. Committee Chairman Hatch (R-UT) has made clear that he only wants to extend the expired tax provisions (the so-called “extenders package”) through 2016 and will require all amendments to be paid for. The Thune/Stabenow amendment does not have a revenue offset, but the Senators want the record of the markup to reflect the support that does exist for the charitable provisions and to keep the issues on the table for future consideration.

As always you can contact me with any questions or comments at or 302.777.5500

- John


Tags:  Department of Labor  National Council of Nonprofits  nonprofits  overtime  taxes 

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Grant-In-Aid Letter Clarifications

Posted By John Baker, Monday, July 13, 2015

If you receive Grant-In-Aid funds, you’ll be receiving your “Grant-In-Aid Recipient Letter” shortly, if you haven’t already.

I recently spoke with the Delaware Controller General’s office, responsible for Grant-In-Aid (GIA), and they confirmed that they’ve been developing the language to implement new epilogue provisions in the GIA Bill for this year.  They expected to be mailing out the letter on Thursday, July 10th to GIA Award Recipients.  This is the same epilogue language I mentioned in my July 1st blog post.

I did recommend clarifications for the letter, but they had already prepared the mailing at that time. However, they confirmed my understanding of two points that you may have questions about, so I'd like to share them with you in the interest of being prepared and informed. 

GIA Clarification #1

They confirmed the below pertaining to letter point #1:

If funds are directly deposited electronically by ACH, the GIA funds should be transferred to a separate account in a reasonable timeframe.

Follow Generally Accepted Auditing Standards of the American Institute of CPAs (GAAS) for restricted grant accounting.

In cases where the GIA funds are combined with other sources to cover payroll or other program expenses, you simply need to be able to show the transfers from the GIA account.  So an accounting journal entry may be:  "Payroll transfer out of GIA Account to General Account for portion of payroll expense as described/approved in GIA Budget Application and Award." 

GIA Clarification #2

They also confirmed the below pertaining to letter point #3: 

The “Random Assessment” will be focused on the “performance measures and program evaluation” proposed in the recipient nonprofit’s GIA proposal/application, not agency-wide "performance measures and program evaluations."  The “Random Assessment” will have the authority to look at all aspects of the organization’s operations.

This statement is taken from the GIA letter, and describes the new random assessments "review of the agency’s performance measures and program evaluation metrics." 

I clarified this because the GIA recipient nonprofits may not have agency-wide “performance measures and program evaluations” for all other programs that are funded by other sources; e.g. funded by individual donations and fundraisers or grants that don’t require measures.

As always you can contact me with any questions or comments at or 302.777.5500

- John

Tags:  budget  Grant-in-Aid  nonprofits 

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No Cuts to Grant-In-Aid; Held Level with 2015

Posted By John Baker, Wednesday, July 1, 2015

The Joint Finance Committee (JFC) held funding at the 2015 level, something that seemed impossible and unimaginable just a few weeks ago.  Your efforts in mobilizing your colleagues, boards and volunteers made this possible!

Just prior to the last DEFAC report (economic forecast) on June 15th, I was hearing some extreme thoughts that GIA cuts could exceed 20%, then with a better DEFAC report the talk around Dover became 10%.  After your continued calling and writing, I began hearing a steady 5% last week.  But you pulled out all the stops and the good people of JFC found this “one-time” $2,380,000 from a bank-related settlement to restore a 5% cut that they had made in their draft.  This restored GIA in support of all the great work you do day-in-and-day-out.

Additional details that came out of last night’s session include further requirements down the road as JFC continues to evolve the GIA Application and Process.  They will be meeting again this fall, as they have for the past two years.  The topic this year will be “audits.”  JFC instituted an audit requirement last year and they’ll be considering this more fully this year, recognizing the cost of this. They will consider requiring more cost-effective mechanisms for smaller nonprofits that don’t already have audits required under other funding sources.

The major addition for this year will be “Random In-Depth Assessments” of GIA recipients by the Controller General’s office.  Along with this, the epilogue language of the GIA Bill requires that GIA funds be kept in a separate account from other organizational funds.  More details on this will come to you in your GIA award letter.  The Random Assessment is an effort to increase accountability, while trying to be more accommodating and flexible with the Audit Requirements.

The GIA Application will be online for the fall of 2017, so not this November, but next November.

Congratulations for all your efforts and please take a moment to share this good news with your colleagues.  Please also share a hearty “Thank You” from the DANA Team. We couldn’t have done it without all of you!

As I’m sure you saw, we were vocal over the last weeks about what needed to be done. Here’s one example of the many initiatives we used to raise the profile of the nonprofit sector and the awareness of the public and legislators with regards to our concerns.

The mobilizing and engagement that we achieved this year will need to be redoubled for next year and we’ll need to coordinate our efforts and communications like never before to continue to build our relationships and the public awareness of the consistent value we deliver to Delawareans.  We must continue to diversify our funding sources, and de-emphasize GIA.  For the next several years I expect that government funding sources will continue to constrict.  More broadly, we need to work to change the government’s conversations, from ones of starvation, to ones of responsibility to all the citizens of Delaware and the Nation.  We at DANA are looking forward to working with you to build these initiatives and have these conversations.  Just one of these successful conversations, over time, has resulted in the OMB Uniform Guidance on Indirect Costs that helps to break the “Starvation Cycle” among nonprofits.  We provided a webinar last fall on this topic and will be hosting a training and webinars on “Indirect Costs” this fall.  Together we can work on Delaware-specific themes, and more broadly we can work on sector-wide matters.

Click here for the link to the full GIA Bill, which was just released this morning.

As always you can contact me with any questions or comments at or 302.777.5500

- John

Tags:  budget  Delaware  Grant-in-Aid  Joint Finance Committee  nonprofits  om 

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Notes from Dover - June 23, 2015

Posted By John Baker, Wednesday, June 24, 2015

As you most likely know, Grant-In-Aid (GIA) is a funding source that has developed as a mechanism for the legislature to fund critical programs in Delaware.  Of the $45.5 million total:

  • $22.6 million goes to “Government Units & Senior Centers”
  • $16.5 million goes to “One-Times and Community Agencies” – Nonprofits / Charities
  • $5.9 million goes to Fire Companies

The DEFAC reports in March, April and May did not improve the revenue projections dramatically and the State has been left with an approximate $85 million gap to fill, and the JFC is charged with delivering a balanced budget to the General Assembly.  They have made various cuts and reduced the gap to $66 million.  When the June 15 DEFAC report came in with a projected increase in revenue of $33 million, JFC was left with approximately $30 million to cut.

As of earlier this week, we learned that $2 million of that cut is slated to come out of GIA.  I’ve also heard that “pass-throughs” in certain department budgets may see a 5% cut, while GIA cuts will be more “surgical” and not “across the board”…we’ll see on Tuesday, June 30th.

Our goal as a nonprofit sector over the past months, and more broadly over the years, has been to communicate the value of the partnership between government and nonprofits in delivering high quality, cost-effective services to all Delawareans.  We believe that our elected officials have heard our message and value our partnership, but it doesn’t hurt to keep that message flowing.

In these last days of the General Assembly’s and Joint Finance Committee’s meetings, please continue to express your support of the nonprofits that you are passionate about, work for, volunteer with, and fund with your personal contributions.  Here is a link to contact information to voice your support for the Nonprofit Sector and the great work of those you support:   

For more background and JFC contact information check out my blog post from last week HERE.

Thank you for all you do, and you know how to reach me.


Tags:  charities  DEFAC  Delaware  Grant-in-Aid  Joint Finance Committee  nonprofits 

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Grant-In-Aid Joint Finance Committee Assignments and Possible Cuts – Forecast up $33 Million, but not enough!

Posted By John Baker, Tuesday, June 16, 2015

Hi folks,

The Joint Finance Committee will meet to begin bill drafting sessions on the F.Y. 2016 Operating Budget on Monday, June 22 - 10:00 am in the JFC Meeting Room in Legislative Hall, Dover.  This is a bit later than in recent years, but with the budget gap, it was critical to wait for the DEFAC forecast numbers that came out yesterday, Monday, June 15th.  The forecast went in the right direction, but still leaves JFC with an approximate $30 million gap to fill. 

I hope you took the opportunity during DANA’s Virtual Nonprofit Advocacy Days, June 1-7, to connect with your legislators. 

For those of you who have Grant-In-Aid applications submitted, I am continuing to hear that there may be a 10% across the board Grant-In-Aid cut this year, so please take the time and contact your Joint Finance Committee members, as well as you General Assembly members, and express your concern about this possible cut.  I have been expressing our disappointment since I first heard about this possible cut.  The most current assignments are below.  

Thanks for reading this blog! As always, feel free to reach out to me with any questions or comments.



Ask of the Joint Finance Committee (JFC) Members and/or your members of the General Assembly (they can relate your message to JFC):

·         We are asking JFC to preserve the current level of Grant-In-Aid funding.

·         But, if they must make a cut, limit it to 5% not the 10% that’s been mentioned.

(History – In the past when DANA and the nonprofit community convened about proposed GIA cuts of 10%, the feeling was that if JFC had to cut, this was more manageable for recipients and their budgets).

Note: This “Ask” is in the absence of a true merit-based system,  that the JFC has been working on developing, on which many nonprofit leaders have presented their experience and thoughts, to JFC at their request.

Current JFC Challenge:

  • The Joint Finance Committee is faced with drafting a budget that closes a $30+million revenue gap.
  • They just received the final Delaware Economic and Financial Advisory Council (DEFAC) forecasts on Monday, June 15th.  So just know that they will probably say this.
  • Monday’s DEFAC report leaves them with a $30+ million gap to fill.

Some Supporting Points:

The nonprofit sector in Delaware, and the nation, has grown to meet the needs of our citizens.   Services historically provided by government have been contracted to nonprofits that have been acknowledged as providing services more cost-effectively.  As many nonprofit leaders have highlighted;  the State made a “Business Decision” and a commitment to the Nonprofit Sector.  Nonprofits have become important government partners.

Nonprofits are the State’s partners in providing Direct Services to Delawareans.  When you make cuts to NP Funding you make cuts to Delawareans who count on the services of NPs for Health, Education, Hunger-Relief, and so much more.

Any additional cuts will further weaken our safety net and the services to our most vulnerable – our youth our poor and our ill.

Delaware Nonprofits employ over 63,000 people, and are supported by even more volunteers. However, the economic challenges and funding cuts have resulted in 38% of Delaware nonprofits being  forced to operate in the red over the past several years (according to Urban Institute and Nonprofit Finance Fund reports).  Meanwhile, Delaware’s nonprofits continue to meet the call of serving evermore Delawareans.

Grant-In-Aid for “One-Time and Community Agencies” in the Delaware State Fiscal Year 2015 (ending June 30, 2015) was $16,540,724, of a total GIA Bill of $45,379,100 (SB266).  The total FY 2015 Delaware State Budget (SB255) was $3.8095 Billion, the Governor’s proposed FY 2016 Delaware State Budget was balanced at $3.9000 Billion.  Since the Governor proposed his budget in January, revenue projections have fallen.


Aging/Senior Centers/Fire Companies /Veterans
Analyst – Stewart  
Sen. McDowell & Rep. Smith 
Analyst – Jackson
Sen. Lawson. & Rep. Carson
Health/Disabled and Labor
Analyst – Griffith
Sen. Bushweller & Rep. Heffernan
Family and Youth Services
Analyst – Reinagel-Nietubicz
Sen. Cloutier and Rep. Johnson
Alcohol/Drug Abuse 
Analyst – Nestlerode
Sen. Peterson & Rep. Kenton
Neighborhood and Community Services 
(American Red Cross to Kingswood)
Analyst – Nestlerode
Sen. Peterson & Rep. Kenton
Neighborhood and Community Services 
(La Esperanza to YWCA) 
Analyst – Griffith  
Sen. Ennis & Rep. Miro 


Tags:  budget  Delaware  Grant-in-Aid  Joint Finance Committee  nonprofits 

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OMB Uniform Guidance is now the law of the land

Posted By John Baker, Thursday, January 15, 2015

Hi All –

I come to you today with an update on Nonprofits and Indirect Costs in Contract/Grant Applications and Proposals.

OMB Uniform Guidance is now the law of the land, but turning its promise of better treatment of charitable nonprofits into reality will take even more work going forward. Nonprofits in particular will need to take action to own their own costs, learn their rights under the new rules, and protect those rights through advocacy, both on their own behalf with each grant and contract, as well as by engaging with DANA’s efforts.

I post the below articles to make you aware of the OMB Uniform Guidance and inform you of the progress described in them.  The articles describe your rights under the new federal grantmaking rules.  We encourage you to take advantage of these rights. Here are three items we feel are most helpful in getting nonprofits the tools they need to get started:

·      The Word for Today is “Overhead”: OMB Uniform Guidance Takes Effect,” by Rick Cohen, National Correspondent (Nonprofit Quarterly, Jan. 13, 2015).

·      Know Your Rights … and How to Protect Them, an overview of the rights nonprofits now enjoy (when governments fully comply) and answers/solutions to anticipated challenges that may arise.

·      Uniform Guidance Implementation Report Form, designed to generate information from nonprofits in the field about compliance with the Uniform Guidance – whether positive or negative – that will help in monitoring compliance, compiling data and observing patterns that can be addressed at a government-wide level, as well as identifying good processes and solutions that can be used elsewhere to help nonprofits across the country meet their missions.

Again, I thank you for your support and look forward to working with you to see that these promises for change transform into reality.

As always you can contact me with any questions or comments at or 302.777.5500

- John

Tags:  charities  National Council of Nonprofits  nonprofits  OMB 

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