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National Park Service: Donations and Related Partnerships Benefit Parks, but Management Refinements Could Better Target Risks and Enhance Accountability

GAO-09-386 Published: Jun 16, 2009. Publicly Released: Jul 16, 2009.
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The National Park Service (Park Service) in the Department of the Interior (Interior) annually receives hundreds of millions of dollars in donated funds, goods, and services to support its 391 parks and other sites. But concerns have been raised about potential accompanying risks, such as undue donor influence, new long-term maintenance costs, or commercialization of parks. To address these concerns, the Park Service has developed and refined policies for managing donations, but questions remain about the agency's ability to do so effectively. GAO was asked to examine (1) how donations and related partnerships have supported the Park Service, (2) the policies and processes the agency uses to manage donations and how well they are working, and (3) what the agency could do to enhance its management of donations and related partnerships. GAO reviewed applicable legal and policy documents, interviewed Interior and Park Service officials and partner organizations, and visited selected national parks.

Donations from individuals, nonprofit organizations, corporations, and others have provided significant support to park projects and programs, and related partnerships have amplified the value of those donations with countless other benefits. The collective value of these donations is substantial--including over $500 million since 1986 at a single park and over $100 million for six recent construction projects, for example--but their total worth is difficult to quantify, in part because of the numerous and often indirect ways in which parks receive donations. Donations support park programs and projects, such as interpretation and education, new construction, repair of facilities, and cultural resource management and protection. Park partners also provide other benefits that go beyond dollar values or a simple tally of projects. These benefits include enabling projects and programs that would not otherwise have been possible, accomplishing projects more quickly, and expanding parks' connections with their communities. The Park Service's donations and fund-raising policy includes directives in key areas to protect the agency against risks, but their effectiveness is diminished because parks do not always follow these program requirements, and the agency has no systematic process to monitor conformance. Agency officials acknowledged some cases of nonconformance but believed they were justified because they involved parks and partners with long track records of success and therefore did not pose significant risks to the agency. While reasonable, this justification indicates that the policy's requirements (and the resource investment needed to meet them) are not always commensurate with the level of risk to the agency. The Park Service has made improvements to its partnership construction process to address past accountability concerns, but remaining gaps leave the agency exposed to risks in some situations, such as when operations and maintenance costs increase for new construction. To enhance management of donations and related partnerships, GAO believes the Park Service could take a more strategic approach, further refine its information on donations, and increase employees' knowledge and skills for working with nonprofit and philanthropic partners. The agency could benefit from a long-range vision of the desired role of donations and related partnerships, but despite growing indications of the need for one, the Park Service has neither a strategic vision nor a plan for how to achieve it. Also, by enhancing its information on donations, which is currently limited, the agency could better support such a strategic approach. For various reasons, agencywide information on donations from some of its partners is incomplete, out of date, and based on inconsistent determinations of support. Finally, by improving its employees' skills in understanding the culture, policies, and constraints of nonprofit and philanthropic partners, the agency could better manage the risks that accompany donations. Park Service employees and partners say they face challenges and are not sufficiently skilled in this area, although they believe the skills are critical.


Recommendations for Executive Action

Agency Affected Recommendation Status
Department of the Interior To more effectively uphold the Park Service's integrity, impartiality, and accountability while promoting positive partnerships, the Secretary should direct the Park Service Director to tailor the Park Service's donations and fund-raising policy requirements to be commensurate with the level of risk to the agency; for example, allow parks and partners that meet certain conditions to follow a modified process.
Closed – Implemented
On December 28, 2016, the National Park Service finalized a revised Director's Order 21 (DO-21) that guides philanthropic giving and partnerships. In this update, the agency allows for different levels of review for fundraising projects based on dollar amounts of fundraising goals and whether the employee has obtain specific philanthropic certification and training. It also modified the threshold for Director level review from $1 million to $5 million for fundraising related construction projects, provided there is not federal contribution of funds to the project. In addition, the Park Service develop model fundraising agreements that could facilitate swifter review of the agreements by expediting the process for fundraising projects with lower dollar value goals. According to Park Service officials, these model agreements were developed and reviewed by the Office of the Solicitor to ensure that they are legally sufficient and include required provisions.
Department of the Interior To more effectively uphold the Park Service's integrity, impartiality, and accountability while promoting positive partnerships, the Secretary should direct the Park Service Director to develop a systematic approach to oversight, including a comprehensive method for monitoring whether parks and partners are following policy requirements on all partnership projects that call for fund-raising agreements--for example, through completion and expansion of the database used for partnership construction projects--and delegation of oversight responsibilities on the basis of risk level to the Park Service.
Closed – Implemented
The National Park Service (NPS) has developed and uses a variety of tools to oversee and monitor partnership projects that call for fundraising agreements. For example, NPS required that a revised Project Review Report to be submitted to the Development Advisory Board for all construction projects that are $1 million and greater. In addition, NPS has implemented the use of a Project Status Tracking Matrix and Partnership Questionnaire to be used as a guide to overseeing ongoing projects. Among other things, the Partnership Questionnaire details the scope of the projects and delineates roles and responsibilities of the partnership parties and includes a schedule for regular updates and discussions. In addition, the tracking devices developed will help ensure key dates are adhered to and diversions are documented.
Department of the Interior To more effectively uphold the Park Service's integrity, impartiality, and accountability while promoting positive partnerships, the Secretary should direct the Park Service Director to ensure that all partnership construction projects contain estimates of operations and maintenance costs and, when partners agree to pay all or a portion of such costs, require that written agreements be executed.
Closed – Implemented
The National Park Service (NPS) has reinforced their current requirement to include estimates of operations and maintenance costs, clarifying that cost estimates supplied in the Development Advisory Board project submissions should be backed up by appropriate data. Moreover, approval of such projects by the Washington Office of NPS is contingent on written agreements in which partners have agreed to pay all or a portion of operations and maintenance costs. NPS also finalized and received approval from Interiors Solicitor's office of a Partner Construction Agreement Template, which delineates the responsibilities identified in this recommendation and put such requirements in writing. In addition, NPS requires the use of a Project Review Report, which tracks estimates of operations and maintenance costs and is reviewed and certified by the Regional Director or Associate Regional Director. Finally, in March 2010, a workshop on NPS Philanthropic Partnerships was held for NPS Regional Partnership Coordinators and Interior Solicitors. Among the topics this workshop covered was a reiteration of the administrative requirements involved in maintaining partnerships.
Department of the Interior To increase transparency and efficiency, the Secretary should direct the Solicitor to work with the Park Service Director to expedite finalization of the draft model agreements related to donations and fund-raising.
Closed – Implemented
The National Park Service (NPS) finalized a model agreement tool in June 2009 to assist NPS staff in drafting Comprehensive Fundraising Agreements. Fundraising includes donations of money, as well as in-kind goods and services. The Comprehensive Model Fundraising Agreement is used to authorize Friends Groups or other NPS partners to undertake a fundraising campaign to support specific NPS projects or programs, such as fundraising for a new visitor center, endowing a park education program, or rehabilitating a trail system. The previously established Basic Model Fundraising Agreement is to be used where the fundraising goal is more than $25,000 but less than $100,000, and where funds will not be placed in an endowment or investment account. In addition to these two tools, NPS also developed a Model Friends Group Agreement to formalize relationships between NPS and Friends Groups and to authorize general (not project-specific) fundraising activities for the benefits of NPS, such as annual membership fundraising drives. All these model fundraising agreements can be found in an online reference guide.
Department of the Interior To better position Congress and the agency to make informed decisions and plan for the future, the Secretary should direct the Park Service Director to collaborate with representatives of friends groups, cooperating associations, and the National Park Foundation, to develop a strategic plan that defines the agency's vision for donations and related partnerships; sets short- and long-term management goals; delineates desired roles and responsibilities for agency offices and employees involved in managing donations and partnerships, so as to maximize efficient allocation of resources; and identifies steps to take in the short and long terms to achieve agency goals.
Closed – Implemented
The National Park Service (NPS) and the Department of the Interior (Interior) have taken a number of actions related to taking a more strategic approach for donations and related partnerships, delineating goals to strive for, and to more efficiently using the resources at the agency's disposal. Specifically, in February 2011, the "America's Great Outdoors (AGO)" report was jointly issued by Interior, USDA, EPA, and CEQ. This report was cited by NPS officials as being the primary place in which the agency's vision, goals, roles and responsibilities, and management for donations and partnerships are clarified. Specifically, Chapter 10 of this report lays out two goals, the second of which is to create the Partnership for the AGO initiative. Among the goals of this initiative are to broaden partnerships to coordinate nonprofit, private, and government sector focus on goals, explore alternative financing for operations and maintenance needs of federal agencies, and develop ways to evaluate success. In order to accomplish the goals and vision of the Partnership for the AGO, agencies plan to engage diverse leaders from philanthropy, the private sector, conservation, recreation, historic preservations, state and local government, tribes, and community groups. In its October 2011 follow up report, "America's Great Outdoors Progress Report," Interior highlights accomplishments related to the goal of making the federal government a more effective conservation partner. Specifically, it highlighted the establishment of the interagency AGO Council and the Council's creation of six interagency working groups. It also highlights engaging the congressional chartered foundations (including the National Park Foundation, National Fish and Wildlife Foundation, and the National Forest Foundation) to establish The Partnership for AGO. These foundations play an advisory role in advising the Partnership on effectively focusing philanthropy and supporting AGO priorities. Finally, it discussed a survey of lead AGO agencies to assess engagement with tribes in carrying out AGO-related activities and ways to expand these activities in tribal communities. The update also mentions its plans to continue working with these Congressional chartered foundations to examine ways to expand partnerships with businesses, non-profits, philanthropic organizations, and a variety of other partners. Finally, in August 2011, the National Park Service issued "A Call to Action: Preparing for a Second Century of Stewardship and Engagement." This report demonstrated additional strategic planning activities related to partnerships, among other more broad goals for the agency. Specifically, the report identifies 4 themes, goals for each of those themes, and a series of actions to reach those goals. The theme of "Preserving America's Special Places" contains the goal of "collaborate with other land managers and partners to create, restore, and maintain landscape-scale connectivity." There are a number of actions listed by the NPS for achieving this goal by 2016, one of which is called "Posterity Partners." Specifically, this action states "Engage the power of philanthropy and volunteerism to provide legacy support for the NPS, both nationwide and at the individual park level. To do so we will launch a public awareness campaign linked to the Centennial, and develop a $1 billion National Park Service second-century endowment through multiple partnerships with the National Park Foundation and national park friends groups."
Department of the Interior To better position Congress and the agency to make informed decisions and plan for the future, the Secretary should direct the Park Service Director to refine data collection procedures to improve estimates of support provided by friends groups and work with Congress to identify any additional reporting on donations it needs to be fully informed and to ensure accountability and transparency.
Closed – Implemented
The National Park Service has refined its data collection procedures by requiring an annual submission of monetary and non-monetary contributions that cooperative and interpretative associations provide to federal agencies. To facilitate data collection, the agency has developed a consolidated federal report form, which will enable agencies to establish and enforce consistent reporting requirements for non-profit cooperators that have formal cooperative or assistance agreements with one or more agencies. In addition, such practices have been incorporated into financial management guidance for Friends Group Agreements. This guidance also requires that the partner ensure that any funds raised under Friends Group Agreements are accounted for and tracked independently from other funds raised. Further, this guidance requires that partners annually provide NPS with a copy of its IRS 990 form, which is used for tax exempt organizations to report the amounts donated by a nonprofit organization during the fiscal year to a Federal Land Management Agency.
Department of the Interior To create and sustain more-effective partnerships with organizations that make donations, the Secretary should direct the Park Service Director to improve Park Service employees' knowledge, skills, and experience about fund-raising and partnerships with nonprofit organizations--and encourage employees to improve nonprofits' understanding of the Park Service--through targeted training, resource allocation, recruiting, and promotion practices.
Closed – Implemented
To enhance National Park Service (NPS) employee knowledge, skills, and experience, NPS has conducted partnership training and workshop sessions, such as a webinar for new park superintendents that provides an understanding of how nonprofit organizations function, which is critical for NPS partnerships to be successful. Our report was cited specifically by agency officials as the impetus for such training. The training also stresses the role that understanding non-profit financials play in this relationship. NPS has also hired a Partnership Construction Program Coordinator, a Partnership Program Coordinator, and a Program Analyst specifically to develop and implement partnership programs and activities, consistent with our recommendation about resource allocation and recruiting. In addition, NPS promoted and hired a number of staff with partnership experience, making the Park Service more adept at working with partnerships. NPS has also publicly recognized and rewarded staff who have participated in successful partnership projects and initiatives.

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