BOR has not established policies and procedures applicable to solicitations conducted by Employee Associations (EAs). However, pursuant to Personnel Bulletin (PB) 17-07 and 5 CFR 2635.808(c), EAs may
- Fundraise in areas that are not on Department property or leased by the Department. However, the fundraising activities need to be outside work hours, not involve government time or resources, or solicitation of prohibited sources. b. Charge membership fees. Reasonable use of government resources such as phones, copiers, and e-mail to conduct the association activities and to encourage communication as allowed in PB 17-07 and the DOI's Limited Use policy is permitted.
- Hold events limited to EA members only.
- Charge participants for events and may charge non-members a fee equal to that of an EA membership for non-members to participate.
- Send employee members (not all employees) e-mails from an official email to notify them of events and meetings with approval from management.
- Use bulletin boards to advertise for events.
- Use government space for meetings.
BOR employees must consult with their AECs for guidance before engaging in any activities with EAs.
Crowdsourced funding or “crowdfunding” is the practice of soliciting contributions or services from a large group of people (i.e., the online community – platforms such as GoFundMe, GiveSmart, IndieGoGo, or Kickstarter). While crowdsourced funding is not strictly prohibited by the gift rules, the nature of this type of fundraising is complex and demands that extra care be taken to ensure that BOR employees do not solicit or accept prohibited gifts. For example, the gift rules apply equally to crowdsourced donations. Specifically, BOR employees cannot solicit or accept gifts from prohibited sources or given because of their official position, unless a relevant exception applies. Evaluating whether a crowdsourced donation is given because of your official position or from a prohibited source, or whether such exception applies, can be complex. Therefore, BOR employees must work closely with their AECs to determine whether crowdsourced donations were given by a prohibited source or because of their official position, and, if so, to determine whether any exception to the gift rule applies.
If you are a financial disclosure filer, your annual report must include any gifts aggregating over the reporting threshold (currently $415) received from a single source during the reporting period. This financial disclosure requirement includes donations received through crowdsourced fundraising campaigns. It is prudent for public filers considering a crowdsourced fundraising campaign to notify potential donors that their identity will be listed on a publicly available financial disclosure report if the donation exceeds the reporting threshold.
1See Crowdsourcing, Merriam-Webster Dictionary (11th ed., 2016); “crowdsourcing” for yourself or on your
behalf in this context is distinct from “fundraising” as defined in 5 C.F.R. § 2635.808.
2 5 C.F.R. §§ 2634.304, 907(g). When reporting gifts, you must report the individual donors who contributed to the crowdsourced fundraising campaign.