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About MNA Public Policy News Events Public Policy Resources Projects and Campaigns
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Nonprofit Oversight and Reform on the Federal Level
June 24, 2005 Nonprofit Panel Releases Final Report The Panel on the Nonprofit Sector has released its comprehensive series of recommendations intended to strengthen the ability of the nation’s 1.3 million charities and foundations to serve as responsible stewards of the public’s generosity. This final report, which has incorporated input from thousands of people across the charitable community provided through field hearings and national conference calls, proposes a carefully integrated package of actions from charitable organizations, from Congress, and from the Internal Revenue Service. It recommends more than 120 actions to be taken by charitable organizations, by Congress, and by the Internal Revenue Service, which together would strengthen the sectors transparency, governance, and accountability. The Panel is encouraging charitable organizations to sign on to the report as a way to demonstrate to the public their commitment to the highest standards of ethical operation. Use the online form to add your organization to the list of endorsers. The Panel will offer supplemental comments in the fall on issues of financial reporting and transparency, accreditation and standard setting, and possible changes in the legal framework, including federal and state regulation of fundraising activities. The final report can be viewed online at http://www.nonprofitpanel.org/final/Panel_Final_Report.pdf. June 6, 2005 House Committee Discusses Hospitals’ Tax Exempt Status On Thursday, May 26 th, the House Ways and Means Committee held a hearing on tax exempt hospitals, specifically addressing the benefits taxpayers receive by providing nonprofit hospitals tax exempt status and comparing for-profit and nonprofit hospitals. IRS Commissioner Mark Everson testified on how tax exempt status is determined, efforts by the IRS to toughen enforcement of nonprofit criteria, and concerns about nonprofit hospitals, including joint ventures with for-profit organizations, excessive executive compensation, and unrelated business income. The investigation of nonprofit hospitals was one in a series of hearings on the nonprofit sector the House Ways and Means Committee has convened. June 6, 2005 Grassley Questions Nonprofit Hospitals As part of the Senate Finance Committee’s inquiry on the nonprofit sector, Committee Chair Charles Grassley (R-IA) recently sent a letter to ten hospitals asking for information on nonprofit issues, including charitable activities, patient billing, and ventures with for-profit organizations. Grassley has held two hearings on nonprofit oversight and recently introduced legislation with Ranking Democrat Max Baucus (D-MT), the Grassley-Baucus bill (S. 993), which would place a 100 percent excise tax on the acquisition costs of certain life insurance contracts purchased by charities that primarily benefit unrelated private investors. May 24, 2005 Federal Oversight Reform of the Nonprofit Sector The process of federal oversight reform of the nonprofit sector began as a response to high-profile scandals involving charities. In September 2004, Senate Finance Committee Chairman Charles Grassley (R-IA) and ranking member Max Baucus (D-MT) wrote a letter (.pdf, 825 kb) to INDEPENDENT SECTOR President Diana Aviv encouraging IS to convene an independent national panel to make recommendations to strengthen governance, ethical practice and accountability within the nonprofit sector. The national Panel on the Nonprofit Sector was formed on October 12, 2004, and included regional nonprofit leaders: Sam Singh, President and CEO of Michigan Nonprofit Association; William C. Richardson, President and CEO of the W.K. Kellogg Foundation; William S. White, President of the Charles Stewart Mott Foundation; Dorothy Johnson, President Emeritus of the Council of Michigan Foundations; and Jon Pratt, Executive Director of Minnesota Council of Nonprofits. On November 1, 2004, the Internal Revenue Service released the revised Form 1023, Application for Exemption Under Section 501(c)(3), the application for charitable organizations seeking tax-exempt status to streamline the application process and help the IRS spot potential fraud. On November 4, 2004, the IRS Tax Exempt and Government Entities (EO) Division released a statement that listed their accomplishments in FY2004 and set their priorities for FY2005, particularly the enforcement of regulations on tax exempt organizations. The Panel first convened on November 7, 2004, and immediately formed five Work Groups to focus on areas of central importance to the nonprofit community:
One month later, on December 9, 2004, the Panel announced the creation of a Citizen Advisory Group. The nine members of the group, leaders of America’s business, educational, media, political, and religious institutions, were to advise the Panel as it developed its recommendations. On January 24, 2005, the Work Groups released a set of preliminary recommendations for consideration by the Panel. After seeking public comment on the Work Groups’ recommendations, the Panel released on March 1, 2005, its Interim Report. The five Work Groups and the Expert Advisory Group then held a series of meetings and email exchanges on issues addressed in the report. The Panel also convened 15 field hearings around the country to gather input from the sector, and it encouraged organizations and individuals to send in comments throughout the process. The Joint Committee on Taxation released, on January 27, 2005, a report requested by the Senate Finance Committee recommending, among other tax law changes, revenue-raising reforms for tax-exempt organizations. The report is part of the Finance Committee’s effort to reform the nonprofit sector. On April 5, 2005, the Senate Finance Committee held a hearing on Charities and Charitable Giving: Proposals for Reform. Much of the hearing focused on the operation of charities, particularly looking at how individuals may claim federal tax deductions for various types of donations. Key leaders from the nonprofit community provided testimony during the hearing, including: Diana Aviv from INDEPENDENT SECTOR; Brian Gallagher from United Way of America; and Leon Panetta from the Panetta Institute for Public Policy. All written testimony from the hearing is available on the Senate Finance Committee's Web site. The House Ways and Means Committee held a hearing on April 20, 2005, to examine the tax-exempt sector, including its legal history, size, scope, and impact on the economy. The hearing also addressed the need for congressional and IRS oversight of the sector and the steps the IRS is taking to improve nonprofits’ compliance with the law. Testimony from the hearing is available on the House Ways and Means Committee’s Web site. Between May 10 th and 19 th, the Panel invited input on new draft recommendations based on the deliberations of the Work Groups and the Expert Advisory Group. These recommendations, and the reactions to them, will help shape the Panel’s deliberations as it prepares the report it will present to the leaders of the U.S. Senate Finance Committee in June. Sources: Panel on the Nonprofit Sector; MNA Public Policy Issues Update May 24, 2005 Senate Finance Committee Plans June 8th Hearing The Senate Finance Committee has scheduled a hearing on June 8, 2005, to address issues related to charitable donations of real property, including changing the rules related to the donation of land, conservation easements, and historic façade easements. These provisions would raise revenues to cover the losses generated from charitable giving incentives in the CARE Act. The Committee is also considering modifying regulations of Type III Supporting Organizations, Donor-Advised Funds, and Charity Owned Life Insurance, but will likely delay introducing charity reform legislation until the Panel on the Nonprofit Sector releases its report in June. Regarding the nonprofit sector, the Committee is reportedly concerned about the following issues: boards’ management of their organizations; excessive compensation and travel expenses for executive staff and board members; remedies to the property donations problem that aren’t as draconian as the Joint Committee on Taxation’s recommendations; and charitable donations being siphoned away from their intended purpose. April 20, 2005 House Ways and Means Committee’s Hearing on the Nonprofit Sector The House Ways and Means Committee will hold a hearing today, Wednesday, April 20 th to examine the tax-exempt sector, including its legal history, size, scope, and impact on the economy. The hearing will also address the need for congressional and IRS oversight of the sector and the steps the IRS is taking to improve nonprofits’ compliance with the law. Witnesses will include: George Yin, Joint Committee on Taxation; the Honorable David Walker, U.S. Government Accountability Office; Douglas Holtz-Eakin, Congressional Budget Office; and legal experts. April 8, 2005 Senate Finance Committee Holds Hearing on “Charities and Charitable Giving” On April 5 th the Senate Finance Committee held a hearing on "Charities and Charitable Giving: Proposals for Reform." Much of the hearing focused on the operation of charities, particularly looking at how individuals may claim federal tax deductions for various types of donations. Key leaders from the nonprofit community provided testimony during the hearing, including: Diana Aviv from INDEPENDENT SECTOR; Brian Gallagher from United Way of America; and Leon Panetta from the Panetta Institute for Public Policy. All written testimony from the hearing is available on the Senate Finance Committee's Web site. If your organization wishes to submit comment to the Senate Finance Committee on this hearing, statements must be received by April 19, 2005. Be sure to include the title and date of the hearing in your statement. Comments should be mailed to: Senate Committee on Finance Many of the changes being considered by the Senate will be discussed at the upcoming Michigan Nonprofit Sector Town Hall Meeting, scheduled for April 27, 2005 from 1:00 p.m. to 4:00 p.m. at the Westin Southfield-Detroit. To register or for more information, please visit MNA’s Web site. March 14, 2005 Panel on the Nonprofit Sector Releases Interim Report On Tuesday, March 1 st, the Panel on the Nonprofit Sector presented to the Senate Finance Committee their Interim Report, which lists the Panel’s initial recommendations for strengthening the accountability of nonprofit organizations with initiatives inside the sector and reforms to regulations outside the sector. The recommendations are divided into three sections, listed below with a summary of each: Recommendations to Improve Transparency in Charitable Organizations IRS Information Returns : the IRS should require the Form 990 series signed by the CEO; failure to file complete and/or accurate returns should result in full enforcement of existing financial penalties; the IRS should be authorized to suspend tax-exempt status if penalties to not result in compliance for two consecutive years or more; existing penalties for tax preparers should be extended to those who prepare Form 990 series; the IRS should move forward with mandatory e-filing of Form 990 series while accommodating organizations with limited funds or access to comply; federal e-filing efforts should be coordinated with state filing requirements; the IRS should require that Form 1023 be e-filed. Financial Audits and Reviews : charitable organizations required to file a Form 990 should be required by law to have an audit; charitable organizations required to have audited financial statements should be required to attach their financial statements to their annual information return. Annual Notification Requirement : all 501(c)(3) organizations exempt from filing an annual information return should be required to file an annual notice with the IRS listing the organizations name, contact information, taxpayer identification number, name and address of a principal officer, mission statement, total revenues and expenditures, and an indication whether the organization has terminated operations; charitable organizations should be required to notify the IRS if and when they cease operations; the IRS should be required to suspend the tax-exempt status of organizations that fail to file the required notice for three consecutive years. Recommendations to Enhance Governance of Charitable Organizations Conflict of Interest Policy Disclosure : all charitable organizations should adopt and enforce a conflict of interest policy defining the conflict of interest, identifying the individuals covered by the policy, specify procedures to manage conflicts of interest, and facilitate disclosure of information that might lead to conflicts of interest; there should be a sector-wide effort to encourage all charitable organizations to adopt and enforce a conflict of interest policy. Audit Committees : charitable organizations should include individuals with some financial literacy on their board of directors; there should be a sector-wide effort to educate charitable organizations about the importance of the auditing function. Reporting of Suspected Misconduct or Malfeasance : all charitable organizations should develop policies and procedures that encourage individuals to come forward with credible information on illegal practices or violations of adopted policies of the organization, with the outside parties to whom such information can be reported, at least one way to protect the anonymity of the person providing the information, and protection from retaliation for the individual who makes the report; a sector-wide education initiative should be undertaken to inform charitable organizations about establishing such policies and procedures. Recommendations to Strengthen Government Oversight of Charitable Organizations Donor-Advised Funds : public charities should be required to disclose on their Form 990 aggregate financial information about donor-advised funds they hold; the term “donor-advised fund” should be statutorily defined to provide a basis for targeted rules addressing potential abuses of donor-advised funds, and the definition should make clear that a donor-advised fund is a separately identified fund or account consisting of assets owned by a public charity with respect to which there is an understanding between the donor and the charity that the charity will consider non-binding advice from the donor regarding investments or distributions of the amount held in the fund, and the definition should exclude specific arrangements in which advisory rights are substantially more limited than in the typical donor-advised fund; public charities should be prohibited from making grants to private non-operating foundations from assets held in donor-advised funds; public charities holding donor-advised funds should be subject to minimum activity rules to ensure that funds are not permitted to remain in inactive accounts indefinitely, including contacting the donor of funds that have been inactive for a period of years to request advice and making distributions or revoking advisory privileges if there has been no activity for a specified time period; public charities should be prohibited from knowingly using assets held in a donor-advised fund to reimburse donors for expenses incurred by them in an advisory capacity for the selection of grantees, compensate the donor for services rendered if all or most of such compensation is paid from the relevant donor-advised fund, and make grants to the donor or related parties; public charities that own and administer donor-advised funds should be required to include on forms used to recommend potential grantees a donor certification that the grant will not provide any substantial benefit to or relieve any obligation of the donor or any related party; public charities that own and administer donor-advised funds should not be permitted to knowingly make grants from that fund to satisfy a legally binding charitable pledge of the donor to adhere strictly to the principle that assets in donor-advised funds may not be used in ways that confer substantial benefits on donors or advisors. Rules for Valuation of Property Contributions : the appropriate valuation and disposition of non-cash contributions should be addressed in the context of all public charities, rather than developed for specific types of assets or funds that are held by charities. Penalty Taxes on Self-Dealing and Other Violations : foundation managers and disqualified persons who knowingly participate in self-dealing transactions should be subject to increased first-tier excise taxes; the Secretary’s authority to abate first-tier taxes on managers participating in self-dealing transactions should be extended to include abatement of taxes imposed on foundation managers and disqualified persons who have participated in a self-dealing transaction, the standards for abatement should be clarified, and the language of the abatement provision in Internal Revenue Code section 4962 should be revised to more closely coordinate with the language of the penalty provisions in sections 4941 through 4945 and 4958; the standard for imposition of first-tier excise taxes on organization managers should be modified to provide a realistic possibility that such penalty taxes will be imposed on managers who fail to meet their fiduciary duties in approving or failing to oppose a prohibited transaction, and should be tailored so as not to unnecessarily deter qualified individuals from serving as managers of charitable organizations for fear that penalty taxes would be imposed unfairly. Type III Supporting Organizations : targeted anti-abuse rules, accompanied by appropriate penalties, should be enacted to eliminate the inappropriate use of Type III supporting organizations while maintaining the availability of such organizations for legitimate charitable purposes. Tax Shelters : appropriate anti-abuse must be developed and should be sufficient to deter charitable organizations from participating in a listed transaction. State Enforcement of Federal Laws : states should be encouraged to incorporate federal tax standards for charitable organizations into state law. Funding for Federal and State Enforcement : Congress should increase the resources allocated to the IRS for oversight and enforcement of charitable organizations; the Panel would strongly support efforts by Congress to earmark funds derived from penalties, fees, and excise taxes imposed on charitable organizations for improved oversight and education activities of the Exempt Organization Division of the IRS. Information Sharing Between Federal and State Officials : Congress should pass legislation to allow state attorneys general and any other state officials charged by law with overseeing charitable organizations the same access to IRS information currently available by law to state revenue officers, under the same terms and restrictions. Public Disclosure of IRS Determinations : the Panel was unable to reach a consensus on whether the IRS should be required publicly to disclose without redaction closing agreements between the IRS and a charitable organization and related audit results. The Panel is encouraging charities and foundations to consider adding their names to the list of organizations that have already signed on to the Interim Report by using their sign-on form. The Michigan Nonprofit Association has signed on to the Interim Report. February 11, 2005 Joint Tax Committee Report Recommends Changes for Nonprofits On January 27 th the Joint Committee on Taxation released a report requested by the Senate Finance Committee recommending, among other tax law changes, revenue-raising reforms for tax-exempt organizations. The report, like the Panel on the Nonprofit Sector’s draft of Work Group Recommendations, is part of the Finance Committee’s effort to reform the nonprofit sector. The report’s recommendations include and address:
The report concludes with the estimated revenue effects of its proposals. The Finance Committee is accepting comments on the recommendations until March 1, 2005. The full text of the report is available on the Joint Finance Committee’s Web site. A summary of the report prepared by the committee’s democratic staff is available on Independent Sector’s Web site. January 28, 2005 Panel on the Nonprofit Sector Seeks Comments on Recommendations The Panel on the Nonprofit Sector, which was formed by Independent Sector with the encouragement of the Senate Finance Committee, released on January 24 th a list of Work Group Recommendations, the result of seven weeks of discussions among the Panel’s five work groups and its expert advisory group. The recommendations have not yet been reviewed by the Panel on the Nonprofit Sector. They will be part of the deliberations by the Panel as it prepares its interim report. The Panel encourages the nonprofit community to comment on the recommendations by February 18 th. A summary of each of the Work Group’s Recommendations: Improving Transparency and Financial Management
Improving Government Oversight and Enforcement
Improving Governance and Self-Regulation
Special Considerations of Small Organizations
For the complete list of recommendations, visit the Panel on the Nonprofit Sector’s Web site. Source: INDEPENDENT SECTOR www.independentsector.org. January 14, 2005 Panel on the Nonprofit Sector National Conference Call On January 26 th at 2:00 p.m. EST, the Panel on the Nonprofit Sector will hold a conference call on the recommendations it is developing to submit to the U.S. Senate Finance Committee in February. Co-conveners Paul Brest and Cass Wheeler, along with executive director Diana Aviv, will ask the leaders of the Panel's Expert Advisory Group and five Work Groups to share their initial recommendations on improving the oversight and governance of nonprofit organizations. The call is open to all staff and board members of public charities, corporate philanthropy programs, and private foundations. November 19, 2004 Independent Sector Fleshes Out Advisory Panel On November 1, Independent Sector (IS) announced the creation of an eight-member Expert Advisory Group that will advise the new Panel on the Nonprofit Sector, formed by IS at the request of the U.S. Senate Finance Committee. A week later, at its inaugural meeting, the Panel created five Work Groups to assist the Panel’s preparation of recommendations for Congress on improving nonprofit oversight. The Work Groups and their assigned topics are: Financial Accountability and Transparency – disclosure measures, such as reform of Form 990 and 990PF, audits and reviews, and electronic filing of tax returns. Governance and Fiduciary Responsibilities – conflict of interest policies, fundraising, and board size, composition, and compensation. Legal Framework – donor advised funds, investment rules, prevention of self-dealing and other conflicts of interest, and tax regulation. Oversight and Self-Regulation – enforcement and improvement of existing legal standards, and areas best enforced by self-regulation. Small Organizations – special concerns related to administrative expenses, board requirements, disclosure issues, financial audits and reporting, user fees, and supporting organizations. Visit the IS Web site for further information on the Expert Advisory Group or the Work Groups. Visit the MNA Web site for further information on MNA and the Panel on the Nonprofit Sector October 25, 2004 Singh Joins Advisory Panel on the Nonprofit Sector Sam Singh, President and CEO of Michigan Nonprofit Association; William C. Richardson, President and CEO of the W.K. Kellogg Foundation; William S. White, President of the Charles Stewart Mott Foundation; Dorothy Johnson, President Emeritus of the Council of Michigan Foundations; and Jon Pratt, Executive Director of Minnesota Council of Nonprofits, have joined other nonprofit leaders to form a “ Panel on the Nonprofit Sector.” The recently-formed panel, chaired by Diana Aviv, President and CEO of Independent Sector (IS), will recommend legislative options to the Senate Finance Committee to increase nonprofit accountability. The panel will establish two advisory groups, one of prominent community leaders, including those from other sectors. The second advisory group will include a range of academic and legal experts. The panel also will create five working groups to study and provide recommendations on issues involved in governance, transparency and financial accountability, oversight of sector organizations, the legal framework for regulating charities and foundations, and specific recommendations concerning small organizations. The finance committee asked that the panel provide a report of its initial findings and recommendations by February 2005 and a final report later that spring. Independent Sector is urging all nonprofits to give the committee input because any new regulations will affect the entire sector. July 29, 2004 Senate Roundtable on Charitable Governance As many of you already know the U.S. Senate Finance Committee held a hearing in June regarding Nonprofit Accountability. In response to the hearing and the discussion paper released by the Committee - Senator Charles Grassley (R-IA), Chair of the Senate Finance Committee, recently held a Roundtable on Charitable Governance with prominent nonprofit leaders. During the Roundtable, Senator Grassley indicated that while he does not expect a complete reform of charitable oversight by the end of this session, he does expect some action after the summer recess. Specific suggestions in the discussion draft include:
For additional information - the full discussion draft paper can be viewed at http://www.senate.gov/~finance/hearings/ Comments submitted by Roundtable participants can be viewed on the Web at http://finance.senate.gov/sitepages/round.htm. A summary on the Roundtable, prepared by NCNA can be viewed at http://www.ncna.org/index.cfm?fuseaction July 22, 2004 Summary of Senate Finance Committee Roundtable The staff of the Senate Finance Committee held a Roundtable on Charitable Oversight on July 22, 2004. Dean Zerbe, Senior Counsel and Tax Council for the Majority Staff and Jonathan Selib, Democratic Tax Counsel served as moderators of the meeting. There were approximately one hundred people at the Roundtable, eighteen of whom were asked by Committee staff to submit white papers and present their thoughts on the Staff Discussion Draft. The comments were followed by a question and answer period from the audience. Staffers from most of the Committee members and the Joint Committee on Taxation were also present. Chairman Charles Grassley, (R-IA) stopped by to give brief comments to help set the tone and give an insight into his thoughts on these issues. Senator Grassley assured those in attendance that the draft paper was really for discussion and that the Committee wanted to take this opportunity to learn from the nonprofit sector. He evoked President Herbert Hoover and the writings of Alexis de Tocqueville to praise the vital role of charities in the United Sates. He said that there might be some movement on these issues by legislators this year, but with only twenty-five days left in the session, more substantial action will take more time and will not happen until next year. At the opening of the Roundtable, Zerbe said that there were five broad categories that the Committee was interested in hearing discussion on:
Highlights of the discussion:
The Committee is open to receiving comments and suggestions from the nonprofit sector as it moves forward. It is vital that Committee members hear from the sector, especially those representing small to mid-sized organizations, so that any legislation that comes from this will benefit the sector without making it harder for nonprofits to operate. Source: National Council of Nonprofit Associations June 25, 2004 Senate Finance Committee Hearings On June 22 the U.S. Senate Finance Committee held a hearing regarding oversight and reform. Chaired by Senator Chuck Grassley (R-IA), the committee focused its hearing on the following issues:
Prior to the hearing a white paper on possible policy changes was released by Senate staff. It is expected that segments of this draft will move quickly into legislation and that the Senate will work with national organizations and take comment on the draft in the summer. The discussion draft can be viewed online at http://www.senate.gov/~finance/hearings/ All of those that spoke commented on the important role nonprofits play in communities across the country. The Senate Finance Committee Members as well as those that testified indicated their desire to address the accountability concerns within the sector without requiring cumbersome regulations that would limit the ability of charities to fulfill their missions. As was the title of the hearing, “Charity Oversight and Reform: Keeping Bad Things from Happening to Good Charities," committee members focused many of their questions on understanding the breadth of the sector, the capacity of the IRS to regulate charities, and grappling with the extent of problems such as excessive compensation of nonprofit executives; car donation scandals; tax activities that may and may not currently be considered allowable; and more. Individuals or groups may still submit written statements for the hearing record. The statement must be a typewritten, single-spaced statement, not exceeding 10 pages in length. Title and date of the hearing, and the full name and address of the individual or organization must appear on the first page of the statement. Statements must be received no later than two weeks following the conclusion of the hearing. Statements should be mailed to: Senate Committee on Finance If your organization sends comments to the Senate regarding the hearing or if you have concerns/questions regarding the discussion draft please share your comments with MNA either via email at skeneeri@mnaonline.org or via fax at 517/492-2410. Those testifying were split into three panels. The following is a list of those who testified and links to their written statements: Panel I The Honorable Mark Everson Commissioner, Internal Revenue Service, Washington, DC Mr. William Josephson, Assistant Attorney General-in-Charge, Charities, State of New York Office of the Attorney General, New York, NY Mr. Mark Pacella, President, National Association of State Charity Officials, Harrisburg, PA Panel II Mr. Jay D. Adkisson, Editor of Quatloos.com and Director of Private Client Services Select Portfolio Management, Inc., Aliso Viejo, CA Ms. J. J. MacNab, CFP CLU QFP, Analyst, Insurance Barometer, LLC, Bethesda, MD Mr. Car, Confidential witness to discuss fundraising Mr. House, Confidential Witness to discuss exploitation of charitable assets for private gain Panel III Ms. Diana Aviv, President and CEO, Independent Sector, Washington, DC Mr. Derek Bok, President Emeritus, harvard University, Cambridge, MA Mr. Willard L. Boyd, Professor of Law and President Emeritus, University of Iowa, Director, Iowa Nonprofit Resource Center, and Chair, The Iowa Governor's Task Force on the Role of Nonprofit Organizations in Iowa, Iowa City, IA Mr. Rick Cohen, Executive Director, National Committee for Responsive Philanthropy, Washington, DC Mr. Herman Art Taylor, President and CEO, BBB Wise Giving Alliance, Arlington, VA Mr. Rock Ringling, Managing Director, Montana Land Reliance, Helena, MT Comments by Senator Grassley and Ranking Committee Member Senator Max Baucus (D-MT) can also be viewed online: Charles Grassley, IA Click here to hear the full committee hearing via Web cast compliments of the Kaiser Family Foundation Sources: United States Senate Committee on Finance, Independent Sector and National Council of Nonprofit Associations. |
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