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ABOUT FRESH ARTS
ONLINE SERVICES
• The Culture Guide
Online event calendar
• The Houston Artist Registry
A warehouse of local artists and
creatives
• Houston Artist Field Guide
A wealth of resources for artists
and arts administrators
PHYSICAL PROGRAMMING
• Community Supported Art
A subscription for local art
• Workshops & Professional
Development- Offered to assist
arts administrators and artists
• Exhibitions - We work exclusively
with local emerging artists
• Cultured Cocktails
Raises funds for local arts projects
• Winter Holiday Art Market
An annual holiday art market
involving over 60 local artists (Last
year we sold over $153,000 of
local art!)
• M-Lab - Marketing incubator for
small to mid-sized nonprofit
organizations
ABOUT OUR GUEST experts TONIGHT:
Bob Lawson is currently the Director of Administration and Education at Theatre
Under The Stars (TUTS). He has held this position since December 2000. In this
capacity he oversees many areas of TUTS’ business including Administration,
Human Resources, Operations, and Education. From February 1997 to November
2000 he was employed as the Director, Volunteer Services at AIDS Foundation
Houston, Inc. (AFH). In this capacity he the management of 365 individuals serving
on 10 direct and indirect client service volunteer teams. Prior to his employment at
AFH he spent 18 years with the E.I. DuPont de Nemours Company in positions of
increasing responsibility managing employees and suppliers. Bob became known as
an expert in problem resolution, negotiations, motivation, and financial
management. Bob has an extensive background in quality process management
including Steven Covey’s “Practical Leadership”. He was one of the recipients of
DuPont’s “Excellence Through People” award in 1992. Bob is a cum laude graduate
of Niagara University with a BS degree in Business Logistics.
Elaine C. Becraft is Counsel, Labor & Employment (Americas) for LyondellBasell, one
of the world’s largest plastics, chemicals and refining companies with annual
revenues of $44 billion.* LyondellBasell, a member of the S&P 500, manufactures
products at 56 sites in 18 countries. In her current role, Becraft advises her internal
business clients on all aspects of labor and employment law. She joined the
company in December 2011. Before joining LyondellBasell, Becraft was in private
practice in Seattle, Washington and Houston, Texas. Becraft is a graduate of Seattle
University School of Law and received a Bachelor of Arts degree in International
Fundamental HR &
Employment Policies for
Organizations
Bob Lawson
Director of Administration & Education
Theatre Under the Stars
Elaine C. Becraft
Counsel, Labor & Employment
LyondellBasell
DISCLAIMERS
This workshop content should not be
considered legal advice or legal
opinion. You should review
applicable law in your jurisdiction
and consult experienced counsel for
legal advice.
The Big Ideas: HR Essentials
• Human Resource Management
• Compensation and Benefits
• Recruitment and Selection
• Performance Management
• Employee Development
• Employment Law Basics
HR Priorities:
• Strategic: how to best realize your org’s mission
• Administrative: compliance, reporting, and records
• Operational: day-to-day employee relations
The BIG ideas. What we will cover:
What else we will cover
• 1099/W2 distinctions
• Benefit options
• Performance Reviews
• HR reps for small shops
• New Hire concerns
• Interns
• Employment taxes and withholding
• Outsourcing your HR Function
WHAT YOU ALREADY
KNOW AND STRUGGLE WITH
 Staff without a formal HR background
 The use of unpaid staff (volunteers)
 Limited resources/budget
 Lack of affordable training for staff
 High turnover
 Staff burnout
 Managing office administration
 Board of Directors support
Idealist.org describes the unique challenges of Human
Resources (HR) in a nonprofit setting: Support for these
needs can be hard to find, and difficult to navigate.
They include:
The nonprofit human resources function deals with
volunteers, staffs high-risk programs, and can be subject to
intense scrutiny.
These major
challenges can
be
categorized as:
o Economic
o Structural
o Legal
o Cultural
THE “ Absolute Musts " OF ANY EMPLOYEE HANDBOOK
(From April 2014 ADP HR Newsletter)
• At-will employment
• Anti-harassment & nondiscrimination
• Immigration Law compliance
• Employment classifications (full-time, part-time, exempt, non-exempt,
etc.)
• Leave of absence and time off benefits (holidays, vacation, sick, etc., as
well as policies about unused vacation)
• Attendance and time-keeping
• Paydays
• Meals and break periods (if regulated by state law; not necessary in
Texas)
• Safety and health (if regulated by state law; not necessary in Texas)
YOUR EMPLOYEE
HANDBOOK
Other handbook inclusions
to consider:
 Employee conduct
 Company history,
practices, and culture
 Use of company
equipment (including
no expectation of
privacy when using
company email, etc.)
 Emergency Closings
 Social Media
Sample policies to consider:
• Whistle-blower:
Sample language will be
emailed to you
• Internal conflict of interest:
Sample language will be
emailed to you
• Nondiscrimination
• Others?
YOUR EMPLOYEE
HANDBOOK
BASIC BEST PRACTICES FOR
INTERVIEWING/HIRING
OVERVIEW : Basic legal concerns: Elaine
Practical concerns: Bob
PREPPING FOR A NEW POSITION – Develop Job
Description
• Determine your staffing needs first; create the job descriptions second
• Avoid the common pitfall of crafting job responsibilities on the basis of
existing personnel strengths, rather than organizational needs
• Determine the benefits package for the role; are your expectations for
salary, etc. realistic and competitive in the market?
• Analyze the current staff to ensure you need to go outside the
organization to meet your needs
• Could an internal resource be developed to meet needs?
• Does bringing in an external candidate prevent a strong current
RECRUITMENT AND SELECTION
• Screen all applications received
against pre-determined criteria
i.e.:
 Do we require a degree?
 Second language?
 Prior experience using
specific skills?
PREPPING FOR A NEW POSITION – Develop Your Selection
Process
• Post jobs in a variety of places (idealist.org, local arts schools, Linked In,
etc.)
• Use standard method to acknowledge receipt of applications and resumes
(i.e. have one person in charge of emailing each applicant to acknowledge
receipt)
• Reviewing Applications Checklist:
o Completeness
o Availability
o Employment eligibility
o Desired pay/position match
o Employment history
o Reasons for leaving previous employer
o Pay history
o Education
o References
o Signatures
RECRUITMENT AND SELECTION
HIRING PROCESS
• Compare and rank applicants
• If large pool of potential candidates emerges, conduct phone
interviews first
• Invite candidates to interview (Do we have one round of
interviews with internal staff and invite the finalists back to
interview with select board members?)
• Interview process:
o While interviewing, review your limitations as an interviewer: you
cannot ask questions regarding an applicant’s race, national
origin/citizenship, disability, sex/gender, military service, criminal
background, family history, religion, marital status, age (or date of birth).
o Create a list of interview questions and be consistent in asking them
of all applicants.
o Do’s & Don’ts (emailed to you)
RECRUITMENT AND SELECTION
HIRING PROCESS
• Extend an offer (provide offer letter)
• Include special conditions (Example: Hiring as
temporary employee for 3 months and then, make
full time or full-time vs. 6 months; is the offer
contingent on successfully passing a background
check?)
• Conduct reference and background checks
• Confirm offer and send new hire paperwork
• Send rejection letters (Can be good form to personally
call anyone you interviewed in person)
RECRUITMENT AND SELECTION
Employee Classification
OVERVIEW : Basic legal concerns: Elaine
Practical concerns: Bob
BASIC DISTINCTIONS BETWEEN 1099 CONTRACTOR VS W2
EMPLOYEE:
Why does it matter?
–Worker classification affects how
you pay your employee’s federal
income tax, social security and
Medicare taxes, and which tax
forms you need to file on their
behalf. Classification affects their
eligibility for social security and
Medicare benefits, employer
provided benefits and their tax
responsibilities.
Employee Classification
HOW TO KNOW THE DIFFERENCE:
• BEHAVIORAL CONTROL
– Instructions: you might be an employee if
you’re told
> How, when, or where to do the work?
> What tools or equipment to use?
> What assistants to hire to help with the work?
> Where to purchase supplies and services?
– Training: you might be an employee if you
need training to do a job a way specified by
the company
Employee Classification
HOW TO KNOW THE DIFFERENCE:
• FINANCIAL CONTROL
– Expenses (If you aren’t typically reimbursed for
expenses)
– Opportunity for profit or loss (If you can realize
a profit or incur a loss, you’re likely a
contractor)
– Compensation timing: If the nonprofit controls
the frequency of compensation, as opposed to
the worker sending an invoice after services
are performed, you’re likely an employee
Employee Classification
HOW TO KNOW THE DIFFERENCE:
• RELATIONSHIP OF THE PARTIES
– Employee benefits (If you receive benefits,
you may be an employee. However, the
reverse cannot be assumed)
– Are duties of X integral to operations of
nonprofit?
– Written contracts to define
Employee Classification
RESOURCES:
• http://www.irs.gov/pub/irs-pdf/p1779.pdf
• http://www.nonprofitrisk.org/library/enews/2009/e
news042909.htm
EXAMPLE: Independent contractors (dance
teachers)
Employee Classification
OTHER CLASSIFICATION CONCERNS:
• Do not classify people with similar duties differently
• Contractors should not get organization business cards or be
listed in staff directory
• Email addresses for contractors should have disclaimer in
footer
• Always issue IRS Form 1099s to contractors/consultants and
W-2s to employees.
• Adopt and standardize language in a written agreement that is
used with all contractors/consultants, spelling out that, “[Name
of Contractor] reserves the right to control the manner in which
services are performed and the scheduling of performance.”
Employee Classification
BASIC DISTINCTIONS BETWEEN
EXEMPT/NONEXEMPT
Why does it matter?
• Exempt employees are exempt from minimum wage and
overtime premium pay protections of the Fair Labor Standards
Act (FLSA). As such, you are not required to pay them extra
for overtime.
• Nonexempt employees must generally be paid for overtime –
at time and one half their regular rate of pay – for each hour,
or fraction thereof, in excess of 40 hours in a workweek.
(Minimum wage laws apply.)
Exemptions from the overtime requirements of the FLSA are just
that— exceptions to the rule. They are very narrowly
construed, and as the employer, you will always bear the
burden of proving that you have correctly classified an
employee as exempt.
Employee Classification
BASIC DISTINCTIONS BETWEEN
EXEMPT/NONEXEMPT
Why does it matter?
• The FLSA recognizes seven major categories
of exempt workers:
o Executive employees
o Administrative employees
o Learned professional employees
o Creative professional employees
o Computer employees
o Highly compensated employees
o Outside sales employees
Employee Classification
BASIC DISTINCTIONS BETWEEN EXEMPT/NONEXEMPT
Why does it matter?
• EXEMPT TEST: Might be exempt if the employee is paid at least $455/week on
a salary or fee basis, AND:
– Executive: Primary duty is management of the organization or
department. Regularly directs the work of two or more other employees;
AND Has authority to hire or fire other employees, OR the employee’s
suggestions as to hiring, firing, promotion or other change of status of
other employees are given particular weight.
– Administrative: Primary duty is the performance of office work directly
related to the management or general business operations of the
employer or the employer’s customers. Primary duty includes the
exercise of discretion and independent judgment in matters of
significance. Regularly exercises discretionary powers and independent
judgment in performing the job.
– Creative professional: Primary duty is the performance of work requiring
invention, imagination, originality, or talent in a recognized field of artistic
or creative endeavor.
– http://www.nibmimages.com/nibm/Audit-TestYourCompliance.pdf
Employee Classification
BASIC DISTINCTIONS BETWEEN EXEMPT/NONEXEMPT
Why does it matter?
• Determining whether or not a position is
exempt requires a detailed analysis, you
should seek legal assistance in conducting
this analysis.
• So you have a nonexempt employee, now
what?
– Timecards? (ADP Template included in resources)
– Overtime calculation http://bit.ly/overtimecalculation
Employee Classification
INTERNS
How to avoid abusing them: (Bob)
Temporary full-time employees?
According to The Department of Labor, the following six legal criteria must
be applied when making a determination if an internship is required to be
paid:
• The internship, even though it includes actual operation of the facilities of
the employer, is similar to training, which would be given, in an educational
environment.
• The internship experience is for the benefit of the intern.
• The intern does not displace regular employees, but works under close
supervision of existing staff.
• The employer that provides the training derives no immediate advantage
from the activities of the intern; and on occasion its operations may actually
be impeded.
• The intern is not necessarily entitled to a job at the conclusion of the
internship.
• The employer and the intern understand that the intern is not entitled to
wages for the time spent in the internship.
Employee Classification
INTERNS
Are interns considered employees and does it
matter?
• A temporary intern DOES count as an employee, UNLESS:
– 1.) the person is interning as a part of a "school sponsored"
program;
OR
– 2.) the intern works for less than 20 weeks (about 4 months) out
of the year with the organization.
• (NOTE: the Texas Workforce Commission counts toward the 20
weeks full- and part-time work performed in any day.)
It matters towards employee totals for certain reporting!
Employee Benefits &
CompensationOVERVIEW
To consider: Legal requirements + Employee retention
TYPES OF BENEFITS
» Compensation
» Health insurance (dental, vision, etc.)
» Unemployment compensation
» Worker’s Comp
» Life insurance
» Investment Plans
» Flex time
Employee Benefits &
Compensation
COMPENSATION
• Minimum wage in Texas: $7.25/hour
• Issues of competitiveness?
• Restrictions about timing of pay (must pay regular basis, set out in
writing, final pay within 5 days if you fire)
For perspective: From the 2008-2009 United Way of Houston Wage & Benefit Survey
For orgs with budget under $350K
» Executive Director compensation (Median $48,000 / Mean $51,111)
» Program Director compensation (Median $29,000 / Mean $30,467)
» Marketing Director compensation (Median $43,000 / Mean $43,000)*
For orgs with budget between $350-599K
» Executive Director compensation (Median $60,000 / Mean $62,288)
» Program Director compensation (Median $40,000 / Mean $38,041)
» Marketing Director compensation (Median $26,500 / Mean $28,500)*
* The Marketing Director pay rate
discrepancy (the Marketing Director at
slightly larger org making less) is due to
small number of respondents.
For a national
perspective: 2013
Nonprofit Times Wage &
Benefit Survey:
http://www.thenonprofitti
mes.com/wp-
content/uploads/2013/02/
1359731596_2-1-
13_SalaryBenefits.pdf
Employee Benefits &
Compensation
HEALTH INSURANCE
• You must be consistent in offering benefits. If you offer benefits to
one full-time employee, you must offer benefits to ALL full-time
employees.
• ACA (Affordable Care Act or Obamacare) as it pertains to nonprofits:
http://www.councilofnonprofits.org/resources/resources-
topic/affordable-care-act-faqs
– There is NO requirement on employers to provide health
insurance -- but there is a penalty (that is only applicable to
employers with 50 or more full-time employees) under the ACA’s
employer “shared responsibility” provisions effective starting in
2015 if the employer does not provide a minimum level of
insurance coverage to their full-time employees
– Look-back provision (documenting how many hrs a week
average over 3 month or a year-- depending on company size
Employee Benefits &
Compensation
HEALTH INSURANCE
• SHOP (Small Business Health Options Program)
Marketplace
– Insurance solutions specifically for small employers
– In Texas, must be handled through agent, broker, or insurance
company
– Starting in 2014, small employers can claim the Small Business
Health Care Tax Credit only for coverage purchased through the
SHOP Marketplace.
– Basic eligibility: business address or primary workplace, at least
one common-law employee on payroll (not including sole proprietor
or spouse), and less than 50 full-time or FTE
employees.http://marketplace.cms.gov/getofficialresources/publicati
ons-and-articles/who-can-use-shop.pdf
– Premium Estimate Tool: https://www.healthcare.gov/find-premium-
estimates/
Employee Benefits &
Compensation
HEALTH INSURANCE
• Small Business Healthcare Tax Credit
http://www.councilofnonprofits.org/small-employer-credit
– Eligibility: pay at least 50% of healthcare costs, Less than
25 FTE employees, must be able to calculate average
salaries (The credit is decreased as you approach an
average salary of $50K.)
– Nonprofits are eligible, but must file Form 990-T
Employee Benefits &
Compensation
UNEMPLOYMENT COMPENSATION
The Texas Unemployment Compensation Act (TUCA) requires liable Texas
employers - including sole proprietorships, partnerships and corporations, and
other entities registered with the Secretary of State - to pay unemployment
insurance tax. Employers become liable if they: Are a 501(c)(3) nonprofit
organization (excluding churches and religious organizations) and have at least
four employees for part of a day or more each week for 20 weeks.
• In Texas, the maximum amount of taxable wages per employee, per
calendar year is set by statute and is currently $9,000.
• Entry level unemployment tax rate is 2.7%
• Texas Workforce Commission policies on unemployment taxes:
http://www.twc.state.tx.us/ui/tax/unemployment-tax-program-overview.html
• Reimbursement method:
http://www.guidestar.org/rxa/news/articles/2005/alternatives-to-
unemployment-taxes-for-501c3.aspx
Employee Benefits &
Compensation
WORKER’S COMPENSATION
Optional in Texas
• However, company must notify all employees of decision
to NOT offer worker’s comp at time of hire
• Notice of NOT providing coverage must be posted
prominently:
http://www.tdi.texas.gov/pubs/factsheets/noncoveremp.p
df
• Must report non-coverage to Texas Department of
Insurance via DWC Form-005
RESOURCES:
http://www.tdi.texas.gov/wc/employer/index.html#aboutw
c
Employee Benefits &
Compensation
BASIC REQUIRED STEPS FOR NEW HIRES
http://www.twc.state.tx.us/news/efte/new_hire_paperwork.html
• Attorney General in Texas:
https://portal.cs.oag.state.tx.us/wps/portal/EmployerHome
– Federal & state law require employers to report new hires/rehires
within 20 calendar days from date employee starts earning wages
• I-9 report (confirms that employee is eligible to work in the US)
• W-4 Form
• Notice of worker’s compensation coverage (or confirmation that
there is no coverage)
• Written consent for background checks
BASIC REQUIRED STEPS FOR NEW HIRES – CONT’D
Notice of Coverage Options (Affordable Care Act)
What: Under the Affordable Care Act (ACA), employers must provide a
Notice of Coverage Options (“Notice”) to all new hires.
Who: All employers subject to the Fair Labor Standards Act (which
encompasses almost all employers) must provide the Notice,
regardless of whether the employer offers health coverage.
What it must contain: (The Notice must be provided in writing and may be hand
delivered, sent by first-class mail, or sent electronically as long as the U.S.
Department of Labor's electronic disclosure safe harbor rules are met.)
– Information about the services provided by the Marketplace;
– How to contact the Marketplace;
– Information about the employer, including any employer-sponsored health coverage available;
– The potential impact on the employee if he or she purchases coverage through the Marketplace
(including that the employee may be eligible for a premium tax credit under section 36B of the
Internal Revenue Code; that he or she may lose any employer contribution toward health benefits
offered by the employer; and that all or a portion of such contribution may be excludable from
income for Federal income tax purposes); and
– Information the employee will need to gather in order to apply for coverage through the
Marketplace.
See details: 29 CFR 2520.104b-1(c), Disclosures through Electronic Media.
Employee Benefits &
CompensationBASIC OPTIONAL (BUT RECOMMENDED) STEPS FOR
NEW HIRES
• Acknowledgment of receipt of employment handbook
• Agreements regarding pay, wage deductions, benefits,
schedule, work location, and so on (with employment-at-will
disclaimers)-- this can be handled in the offer letter
– Employment at Will Disclaimer: I understand that this agreement
concerning my compensation and benefits does not modify the at
will employment relationship between myself and ABC Company;
does not constitute a commitment by ABC Company to employ
me for any particular length of time; does not commit me to
remain with ABC Company for any particular length of time; and
does not restrict either ABC Company or myself from ending the
employment relationship at any time for any reason, with or
without notice.
• Consent for drug testing
• Consent for video surveillance
Employee Benefits &
Compensation
OTHER NECESSARY STEPS WHEN HIRING
• Enter employee into payroll system
• Enroll employee in any benefits
• Issue equipment or supplies necessary for job
(consider using aproperty return security deposit
agreement to minimize the risk of damage or non-
return of property, like laptop, etc.)
Operations Concerns
EMPLOYEE TAXES
• How to know which payroll taxes apply:
http://www.bizfilings.com/toolkit/sbg/tax-info/payroll-
taxes/determining-payroll-taxes-for-employees.aspx
• Typically: Federal Income Tax Withholding + FICA (Social
Security + Medicare)
• Payroll Tax Calculator (ADP): http://www.adp.com/tools-and-
resources/calculators-and-tools/payroll-calculators.aspx
• IRS Withholding Calculator http://www.irs.gov/Individuals/IRS-
Withholding-Calculator
Operations Concerns
PAYROLL TOOLS
• RESOURCE: ADP
http://www.adp.com/~/media/PDF/Payroll%20Packages.ashx
– Basic (Essential) Plan:
• Semi-monthly for 2 employees $58+/pay period or
4 employees $64/pay period
• Monthly for 1 $69
• RESOURCE: Tobin & Associates
Operations Concerns
REVIEWS: YOU NEED TO DO THEM
REGULARLY
• Employee reviews (timing + actually have them +
documentation needed)
• Employee review of director by board
• 360 review of director
Operations Concerns
DO YOU HAVE A HUMAN RESOURCES REP ON THE
BOARD?
• HR advocate on board of directors for smaller nonprofits
(i.e. to provide an additional outlet for reporting HR
problems)
• Division of Board / Staff HR responsibilities:
http://hrcouncil.ca/docs/Table_HR_Resp.pdf
• Board’s involvement in HR:
http://www.blueavocado.org/content/nonprofit-boards-
role-hr
• Board Planning toolkit: http://hrcouncil.ca/hr-
toolkit/planning-board-role.cfm
OUTSOURCING YOUR
HR
• The advantages and timing
of outsourcing, rather than
handling HR in house
Operations Concerns
Common employment law
mistakes
• Misclassifying employees as independent
contractors.
• Misclassifying non-exempt employees as exempt.
• Not complying with state wage payment laws.
These rules include providing new employees with
written notice of their rate of pay and regular pay
date; prohibiting deductions from wages unless for
the employee's benefit and authorized in writing;
requiring written contracts for commissioned
salespersons; and providing terminated employees
with written notice of their last day of work, their
last day of benefits, and their right to apply for
unemployment benefits.
Common employment law
mistakes• Not having an employee handbook.
• Not documenting employee job performance.
• Not training supervisors regarding EEO laws.
• Not providing reasonable accommodations for disabled
employees.
• Not obtaining releases from terminated employees where
appropriate.
• Not protecting confidential business information.
• Not consulting a qualified employment law attorney.
Directly from: http://warshawskylawfirm.com/lawyer/2010/12/04/Employment-Law/Ten-
Common-Employment-Law-Mistakes-Made-By-Businesses._bl1518.htm
http://www.employmentlawgroup.com/wp-
content/uploads/Employers_Common_Mistakes_Encouraging_Employees_Seek_Legal
_Advise.pdf
Resources
• Jody Blazek: HR Handbook
• TX Workforce Commission (handbook samples-- policies)
• “Especially for Texas Employers” - TWC webpage:
http://www.twc.state.tx.us/news/efte/tocmain2.html
• ACA as it pertains to nonprofits:
http://www.councilofnonprofits.org/resources/resources-
topic/affordable-care-act-faqs
http://commongoodvt.org/nonprofit-101/human-resources/
IN YOUR INBOX TOMORROW
 This PowerPoint
 Example docs and resources
 Info about upcoming workshops including
Development Finance and Operation Basics
for the Jack-of-All Arts Administrator
(Gift Acceptance, Disclosure Rules & Basic Financial
Reporting)
Wednesday, June 4, from 4-6 p.m.@ Fresh Arts
Meet Your Media
With Joel Luks, Molly Glentzer, Bill Davenport
Tuesday, July 8, 6-8 p.m. @ Diverseworks Artspace
 Link to a post-workshop survey

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Fresh Arts Fundamental HR/Employment Policies for Organizations 2014

  • 1.
  • 2. ABOUT FRESH ARTS ONLINE SERVICES • The Culture Guide Online event calendar • The Houston Artist Registry A warehouse of local artists and creatives • Houston Artist Field Guide A wealth of resources for artists and arts administrators PHYSICAL PROGRAMMING • Community Supported Art A subscription for local art • Workshops & Professional Development- Offered to assist arts administrators and artists • Exhibitions - We work exclusively with local emerging artists • Cultured Cocktails Raises funds for local arts projects • Winter Holiday Art Market An annual holiday art market involving over 60 local artists (Last year we sold over $153,000 of local art!) • M-Lab - Marketing incubator for small to mid-sized nonprofit organizations
  • 3. ABOUT OUR GUEST experts TONIGHT: Bob Lawson is currently the Director of Administration and Education at Theatre Under The Stars (TUTS). He has held this position since December 2000. In this capacity he oversees many areas of TUTS’ business including Administration, Human Resources, Operations, and Education. From February 1997 to November 2000 he was employed as the Director, Volunteer Services at AIDS Foundation Houston, Inc. (AFH). In this capacity he the management of 365 individuals serving on 10 direct and indirect client service volunteer teams. Prior to his employment at AFH he spent 18 years with the E.I. DuPont de Nemours Company in positions of increasing responsibility managing employees and suppliers. Bob became known as an expert in problem resolution, negotiations, motivation, and financial management. Bob has an extensive background in quality process management including Steven Covey’s “Practical Leadership”. He was one of the recipients of DuPont’s “Excellence Through People” award in 1992. Bob is a cum laude graduate of Niagara University with a BS degree in Business Logistics. Elaine C. Becraft is Counsel, Labor & Employment (Americas) for LyondellBasell, one of the world’s largest plastics, chemicals and refining companies with annual revenues of $44 billion.* LyondellBasell, a member of the S&P 500, manufactures products at 56 sites in 18 countries. In her current role, Becraft advises her internal business clients on all aspects of labor and employment law. She joined the company in December 2011. Before joining LyondellBasell, Becraft was in private practice in Seattle, Washington and Houston, Texas. Becraft is a graduate of Seattle University School of Law and received a Bachelor of Arts degree in International
  • 4. Fundamental HR & Employment Policies for Organizations Bob Lawson Director of Administration & Education Theatre Under the Stars Elaine C. Becraft Counsel, Labor & Employment LyondellBasell
  • 5. DISCLAIMERS This workshop content should not be considered legal advice or legal opinion. You should review applicable law in your jurisdiction and consult experienced counsel for legal advice.
  • 6. The Big Ideas: HR Essentials • Human Resource Management • Compensation and Benefits • Recruitment and Selection • Performance Management • Employee Development • Employment Law Basics HR Priorities: • Strategic: how to best realize your org’s mission • Administrative: compliance, reporting, and records • Operational: day-to-day employee relations The BIG ideas. What we will cover: What else we will cover • 1099/W2 distinctions • Benefit options • Performance Reviews • HR reps for small shops • New Hire concerns • Interns • Employment taxes and withholding • Outsourcing your HR Function
  • 7. WHAT YOU ALREADY KNOW AND STRUGGLE WITH
  • 8.  Staff without a formal HR background  The use of unpaid staff (volunteers)  Limited resources/budget  Lack of affordable training for staff  High turnover  Staff burnout  Managing office administration  Board of Directors support Idealist.org describes the unique challenges of Human Resources (HR) in a nonprofit setting: Support for these needs can be hard to find, and difficult to navigate. They include: The nonprofit human resources function deals with volunteers, staffs high-risk programs, and can be subject to intense scrutiny. These major challenges can be categorized as: o Economic o Structural o Legal o Cultural
  • 9. THE “ Absolute Musts " OF ANY EMPLOYEE HANDBOOK (From April 2014 ADP HR Newsletter) • At-will employment • Anti-harassment & nondiscrimination • Immigration Law compliance • Employment classifications (full-time, part-time, exempt, non-exempt, etc.) • Leave of absence and time off benefits (holidays, vacation, sick, etc., as well as policies about unused vacation) • Attendance and time-keeping • Paydays • Meals and break periods (if regulated by state law; not necessary in Texas) • Safety and health (if regulated by state law; not necessary in Texas) YOUR EMPLOYEE HANDBOOK
  • 10. Other handbook inclusions to consider:  Employee conduct  Company history, practices, and culture  Use of company equipment (including no expectation of privacy when using company email, etc.)  Emergency Closings  Social Media Sample policies to consider: • Whistle-blower: Sample language will be emailed to you • Internal conflict of interest: Sample language will be emailed to you • Nondiscrimination • Others? YOUR EMPLOYEE HANDBOOK
  • 11. BASIC BEST PRACTICES FOR INTERVIEWING/HIRING OVERVIEW : Basic legal concerns: Elaine Practical concerns: Bob PREPPING FOR A NEW POSITION – Develop Job Description • Determine your staffing needs first; create the job descriptions second • Avoid the common pitfall of crafting job responsibilities on the basis of existing personnel strengths, rather than organizational needs • Determine the benefits package for the role; are your expectations for salary, etc. realistic and competitive in the market? • Analyze the current staff to ensure you need to go outside the organization to meet your needs • Could an internal resource be developed to meet needs? • Does bringing in an external candidate prevent a strong current RECRUITMENT AND SELECTION
  • 12. • Screen all applications received against pre-determined criteria i.e.:  Do we require a degree?  Second language?  Prior experience using specific skills? PREPPING FOR A NEW POSITION – Develop Your Selection Process • Post jobs in a variety of places (idealist.org, local arts schools, Linked In, etc.) • Use standard method to acknowledge receipt of applications and resumes (i.e. have one person in charge of emailing each applicant to acknowledge receipt) • Reviewing Applications Checklist: o Completeness o Availability o Employment eligibility o Desired pay/position match o Employment history o Reasons for leaving previous employer o Pay history o Education o References o Signatures RECRUITMENT AND SELECTION
  • 13. HIRING PROCESS • Compare and rank applicants • If large pool of potential candidates emerges, conduct phone interviews first • Invite candidates to interview (Do we have one round of interviews with internal staff and invite the finalists back to interview with select board members?) • Interview process: o While interviewing, review your limitations as an interviewer: you cannot ask questions regarding an applicant’s race, national origin/citizenship, disability, sex/gender, military service, criminal background, family history, religion, marital status, age (or date of birth). o Create a list of interview questions and be consistent in asking them of all applicants. o Do’s & Don’ts (emailed to you) RECRUITMENT AND SELECTION
  • 14. HIRING PROCESS • Extend an offer (provide offer letter) • Include special conditions (Example: Hiring as temporary employee for 3 months and then, make full time or full-time vs. 6 months; is the offer contingent on successfully passing a background check?) • Conduct reference and background checks • Confirm offer and send new hire paperwork • Send rejection letters (Can be good form to personally call anyone you interviewed in person) RECRUITMENT AND SELECTION
  • 15. Employee Classification OVERVIEW : Basic legal concerns: Elaine Practical concerns: Bob BASIC DISTINCTIONS BETWEEN 1099 CONTRACTOR VS W2 EMPLOYEE: Why does it matter? –Worker classification affects how you pay your employee’s federal income tax, social security and Medicare taxes, and which tax forms you need to file on their behalf. Classification affects their eligibility for social security and Medicare benefits, employer provided benefits and their tax responsibilities.
  • 16. Employee Classification HOW TO KNOW THE DIFFERENCE: • BEHAVIORAL CONTROL – Instructions: you might be an employee if you’re told > How, when, or where to do the work? > What tools or equipment to use? > What assistants to hire to help with the work? > Where to purchase supplies and services? – Training: you might be an employee if you need training to do a job a way specified by the company
  • 17. Employee Classification HOW TO KNOW THE DIFFERENCE: • FINANCIAL CONTROL – Expenses (If you aren’t typically reimbursed for expenses) – Opportunity for profit or loss (If you can realize a profit or incur a loss, you’re likely a contractor) – Compensation timing: If the nonprofit controls the frequency of compensation, as opposed to the worker sending an invoice after services are performed, you’re likely an employee
  • 18. Employee Classification HOW TO KNOW THE DIFFERENCE: • RELATIONSHIP OF THE PARTIES – Employee benefits (If you receive benefits, you may be an employee. However, the reverse cannot be assumed) – Are duties of X integral to operations of nonprofit? – Written contracts to define
  • 19. Employee Classification RESOURCES: • http://www.irs.gov/pub/irs-pdf/p1779.pdf • http://www.nonprofitrisk.org/library/enews/2009/e news042909.htm EXAMPLE: Independent contractors (dance teachers)
  • 20. Employee Classification OTHER CLASSIFICATION CONCERNS: • Do not classify people with similar duties differently • Contractors should not get organization business cards or be listed in staff directory • Email addresses for contractors should have disclaimer in footer • Always issue IRS Form 1099s to contractors/consultants and W-2s to employees. • Adopt and standardize language in a written agreement that is used with all contractors/consultants, spelling out that, “[Name of Contractor] reserves the right to control the manner in which services are performed and the scheduling of performance.”
  • 21. Employee Classification BASIC DISTINCTIONS BETWEEN EXEMPT/NONEXEMPT Why does it matter? • Exempt employees are exempt from minimum wage and overtime premium pay protections of the Fair Labor Standards Act (FLSA). As such, you are not required to pay them extra for overtime. • Nonexempt employees must generally be paid for overtime – at time and one half their regular rate of pay – for each hour, or fraction thereof, in excess of 40 hours in a workweek. (Minimum wage laws apply.) Exemptions from the overtime requirements of the FLSA are just that— exceptions to the rule. They are very narrowly construed, and as the employer, you will always bear the burden of proving that you have correctly classified an employee as exempt.
  • 22. Employee Classification BASIC DISTINCTIONS BETWEEN EXEMPT/NONEXEMPT Why does it matter? • The FLSA recognizes seven major categories of exempt workers: o Executive employees o Administrative employees o Learned professional employees o Creative professional employees o Computer employees o Highly compensated employees o Outside sales employees
  • 23. Employee Classification BASIC DISTINCTIONS BETWEEN EXEMPT/NONEXEMPT Why does it matter? • EXEMPT TEST: Might be exempt if the employee is paid at least $455/week on a salary or fee basis, AND: – Executive: Primary duty is management of the organization or department. Regularly directs the work of two or more other employees; AND Has authority to hire or fire other employees, OR the employee’s suggestions as to hiring, firing, promotion or other change of status of other employees are given particular weight. – Administrative: Primary duty is the performance of office work directly related to the management or general business operations of the employer or the employer’s customers. Primary duty includes the exercise of discretion and independent judgment in matters of significance. Regularly exercises discretionary powers and independent judgment in performing the job. – Creative professional: Primary duty is the performance of work requiring invention, imagination, originality, or talent in a recognized field of artistic or creative endeavor. – http://www.nibmimages.com/nibm/Audit-TestYourCompliance.pdf
  • 24. Employee Classification BASIC DISTINCTIONS BETWEEN EXEMPT/NONEXEMPT Why does it matter? • Determining whether or not a position is exempt requires a detailed analysis, you should seek legal assistance in conducting this analysis. • So you have a nonexempt employee, now what? – Timecards? (ADP Template included in resources) – Overtime calculation http://bit.ly/overtimecalculation
  • 25. Employee Classification INTERNS How to avoid abusing them: (Bob) Temporary full-time employees? According to The Department of Labor, the following six legal criteria must be applied when making a determination if an internship is required to be paid: • The internship, even though it includes actual operation of the facilities of the employer, is similar to training, which would be given, in an educational environment. • The internship experience is for the benefit of the intern. • The intern does not displace regular employees, but works under close supervision of existing staff. • The employer that provides the training derives no immediate advantage from the activities of the intern; and on occasion its operations may actually be impeded. • The intern is not necessarily entitled to a job at the conclusion of the internship. • The employer and the intern understand that the intern is not entitled to wages for the time spent in the internship.
  • 26. Employee Classification INTERNS Are interns considered employees and does it matter? • A temporary intern DOES count as an employee, UNLESS: – 1.) the person is interning as a part of a "school sponsored" program; OR – 2.) the intern works for less than 20 weeks (about 4 months) out of the year with the organization. • (NOTE: the Texas Workforce Commission counts toward the 20 weeks full- and part-time work performed in any day.) It matters towards employee totals for certain reporting!
  • 27. Employee Benefits & CompensationOVERVIEW To consider: Legal requirements + Employee retention TYPES OF BENEFITS » Compensation » Health insurance (dental, vision, etc.) » Unemployment compensation » Worker’s Comp » Life insurance » Investment Plans » Flex time
  • 28. Employee Benefits & Compensation COMPENSATION • Minimum wage in Texas: $7.25/hour • Issues of competitiveness? • Restrictions about timing of pay (must pay regular basis, set out in writing, final pay within 5 days if you fire) For perspective: From the 2008-2009 United Way of Houston Wage & Benefit Survey For orgs with budget under $350K » Executive Director compensation (Median $48,000 / Mean $51,111) » Program Director compensation (Median $29,000 / Mean $30,467) » Marketing Director compensation (Median $43,000 / Mean $43,000)* For orgs with budget between $350-599K » Executive Director compensation (Median $60,000 / Mean $62,288) » Program Director compensation (Median $40,000 / Mean $38,041) » Marketing Director compensation (Median $26,500 / Mean $28,500)* * The Marketing Director pay rate discrepancy (the Marketing Director at slightly larger org making less) is due to small number of respondents. For a national perspective: 2013 Nonprofit Times Wage & Benefit Survey: http://www.thenonprofitti mes.com/wp- content/uploads/2013/02/ 1359731596_2-1- 13_SalaryBenefits.pdf
  • 29. Employee Benefits & Compensation HEALTH INSURANCE • You must be consistent in offering benefits. If you offer benefits to one full-time employee, you must offer benefits to ALL full-time employees. • ACA (Affordable Care Act or Obamacare) as it pertains to nonprofits: http://www.councilofnonprofits.org/resources/resources- topic/affordable-care-act-faqs – There is NO requirement on employers to provide health insurance -- but there is a penalty (that is only applicable to employers with 50 or more full-time employees) under the ACA’s employer “shared responsibility” provisions effective starting in 2015 if the employer does not provide a minimum level of insurance coverage to their full-time employees – Look-back provision (documenting how many hrs a week average over 3 month or a year-- depending on company size
  • 30. Employee Benefits & Compensation HEALTH INSURANCE • SHOP (Small Business Health Options Program) Marketplace – Insurance solutions specifically for small employers – In Texas, must be handled through agent, broker, or insurance company – Starting in 2014, small employers can claim the Small Business Health Care Tax Credit only for coverage purchased through the SHOP Marketplace. – Basic eligibility: business address or primary workplace, at least one common-law employee on payroll (not including sole proprietor or spouse), and less than 50 full-time or FTE employees.http://marketplace.cms.gov/getofficialresources/publicati ons-and-articles/who-can-use-shop.pdf – Premium Estimate Tool: https://www.healthcare.gov/find-premium- estimates/
  • 31. Employee Benefits & Compensation HEALTH INSURANCE • Small Business Healthcare Tax Credit http://www.councilofnonprofits.org/small-employer-credit – Eligibility: pay at least 50% of healthcare costs, Less than 25 FTE employees, must be able to calculate average salaries (The credit is decreased as you approach an average salary of $50K.) – Nonprofits are eligible, but must file Form 990-T
  • 32. Employee Benefits & Compensation UNEMPLOYMENT COMPENSATION The Texas Unemployment Compensation Act (TUCA) requires liable Texas employers - including sole proprietorships, partnerships and corporations, and other entities registered with the Secretary of State - to pay unemployment insurance tax. Employers become liable if they: Are a 501(c)(3) nonprofit organization (excluding churches and religious organizations) and have at least four employees for part of a day or more each week for 20 weeks. • In Texas, the maximum amount of taxable wages per employee, per calendar year is set by statute and is currently $9,000. • Entry level unemployment tax rate is 2.7% • Texas Workforce Commission policies on unemployment taxes: http://www.twc.state.tx.us/ui/tax/unemployment-tax-program-overview.html • Reimbursement method: http://www.guidestar.org/rxa/news/articles/2005/alternatives-to- unemployment-taxes-for-501c3.aspx
  • 33. Employee Benefits & Compensation WORKER’S COMPENSATION Optional in Texas • However, company must notify all employees of decision to NOT offer worker’s comp at time of hire • Notice of NOT providing coverage must be posted prominently: http://www.tdi.texas.gov/pubs/factsheets/noncoveremp.p df • Must report non-coverage to Texas Department of Insurance via DWC Form-005 RESOURCES: http://www.tdi.texas.gov/wc/employer/index.html#aboutw c
  • 34. Employee Benefits & Compensation BASIC REQUIRED STEPS FOR NEW HIRES http://www.twc.state.tx.us/news/efte/new_hire_paperwork.html • Attorney General in Texas: https://portal.cs.oag.state.tx.us/wps/portal/EmployerHome – Federal & state law require employers to report new hires/rehires within 20 calendar days from date employee starts earning wages • I-9 report (confirms that employee is eligible to work in the US) • W-4 Form • Notice of worker’s compensation coverage (or confirmation that there is no coverage) • Written consent for background checks
  • 35. BASIC REQUIRED STEPS FOR NEW HIRES – CONT’D Notice of Coverage Options (Affordable Care Act) What: Under the Affordable Care Act (ACA), employers must provide a Notice of Coverage Options (“Notice”) to all new hires. Who: All employers subject to the Fair Labor Standards Act (which encompasses almost all employers) must provide the Notice, regardless of whether the employer offers health coverage. What it must contain: (The Notice must be provided in writing and may be hand delivered, sent by first-class mail, or sent electronically as long as the U.S. Department of Labor's electronic disclosure safe harbor rules are met.) – Information about the services provided by the Marketplace; – How to contact the Marketplace; – Information about the employer, including any employer-sponsored health coverage available; – The potential impact on the employee if he or she purchases coverage through the Marketplace (including that the employee may be eligible for a premium tax credit under section 36B of the Internal Revenue Code; that he or she may lose any employer contribution toward health benefits offered by the employer; and that all or a portion of such contribution may be excludable from income for Federal income tax purposes); and – Information the employee will need to gather in order to apply for coverage through the Marketplace. See details: 29 CFR 2520.104b-1(c), Disclosures through Electronic Media.
  • 36. Employee Benefits & CompensationBASIC OPTIONAL (BUT RECOMMENDED) STEPS FOR NEW HIRES • Acknowledgment of receipt of employment handbook • Agreements regarding pay, wage deductions, benefits, schedule, work location, and so on (with employment-at-will disclaimers)-- this can be handled in the offer letter – Employment at Will Disclaimer: I understand that this agreement concerning my compensation and benefits does not modify the at will employment relationship between myself and ABC Company; does not constitute a commitment by ABC Company to employ me for any particular length of time; does not commit me to remain with ABC Company for any particular length of time; and does not restrict either ABC Company or myself from ending the employment relationship at any time for any reason, with or without notice. • Consent for drug testing • Consent for video surveillance
  • 37. Employee Benefits & Compensation OTHER NECESSARY STEPS WHEN HIRING • Enter employee into payroll system • Enroll employee in any benefits • Issue equipment or supplies necessary for job (consider using aproperty return security deposit agreement to minimize the risk of damage or non- return of property, like laptop, etc.)
  • 38. Operations Concerns EMPLOYEE TAXES • How to know which payroll taxes apply: http://www.bizfilings.com/toolkit/sbg/tax-info/payroll- taxes/determining-payroll-taxes-for-employees.aspx • Typically: Federal Income Tax Withholding + FICA (Social Security + Medicare) • Payroll Tax Calculator (ADP): http://www.adp.com/tools-and- resources/calculators-and-tools/payroll-calculators.aspx • IRS Withholding Calculator http://www.irs.gov/Individuals/IRS- Withholding-Calculator
  • 39. Operations Concerns PAYROLL TOOLS • RESOURCE: ADP http://www.adp.com/~/media/PDF/Payroll%20Packages.ashx – Basic (Essential) Plan: • Semi-monthly for 2 employees $58+/pay period or 4 employees $64/pay period • Monthly for 1 $69 • RESOURCE: Tobin & Associates
  • 40. Operations Concerns REVIEWS: YOU NEED TO DO THEM REGULARLY • Employee reviews (timing + actually have them + documentation needed) • Employee review of director by board • 360 review of director
  • 41. Operations Concerns DO YOU HAVE A HUMAN RESOURCES REP ON THE BOARD? • HR advocate on board of directors for smaller nonprofits (i.e. to provide an additional outlet for reporting HR problems) • Division of Board / Staff HR responsibilities: http://hrcouncil.ca/docs/Table_HR_Resp.pdf • Board’s involvement in HR: http://www.blueavocado.org/content/nonprofit-boards- role-hr • Board Planning toolkit: http://hrcouncil.ca/hr- toolkit/planning-board-role.cfm
  • 42. OUTSOURCING YOUR HR • The advantages and timing of outsourcing, rather than handling HR in house Operations Concerns
  • 43. Common employment law mistakes • Misclassifying employees as independent contractors. • Misclassifying non-exempt employees as exempt. • Not complying with state wage payment laws. These rules include providing new employees with written notice of their rate of pay and regular pay date; prohibiting deductions from wages unless for the employee's benefit and authorized in writing; requiring written contracts for commissioned salespersons; and providing terminated employees with written notice of their last day of work, their last day of benefits, and their right to apply for unemployment benefits.
  • 44. Common employment law mistakes• Not having an employee handbook. • Not documenting employee job performance. • Not training supervisors regarding EEO laws. • Not providing reasonable accommodations for disabled employees. • Not obtaining releases from terminated employees where appropriate. • Not protecting confidential business information. • Not consulting a qualified employment law attorney. Directly from: http://warshawskylawfirm.com/lawyer/2010/12/04/Employment-Law/Ten- Common-Employment-Law-Mistakes-Made-By-Businesses._bl1518.htm http://www.employmentlawgroup.com/wp- content/uploads/Employers_Common_Mistakes_Encouraging_Employees_Seek_Legal _Advise.pdf
  • 45. Resources • Jody Blazek: HR Handbook • TX Workforce Commission (handbook samples-- policies) • “Especially for Texas Employers” - TWC webpage: http://www.twc.state.tx.us/news/efte/tocmain2.html • ACA as it pertains to nonprofits: http://www.councilofnonprofits.org/resources/resources- topic/affordable-care-act-faqs http://commongoodvt.org/nonprofit-101/human-resources/
  • 46. IN YOUR INBOX TOMORROW  This PowerPoint  Example docs and resources  Info about upcoming workshops including Development Finance and Operation Basics for the Jack-of-All Arts Administrator (Gift Acceptance, Disclosure Rules & Basic Financial Reporting) Wednesday, June 4, from 4-6 p.m.@ Fresh Arts Meet Your Media With Joel Luks, Molly Glentzer, Bill Davenport Tuesday, July 8, 6-8 p.m. @ Diverseworks Artspace  Link to a post-workshop survey

Editor's Notes

  1. Sufficient investment in infrastructure must be made to enable staff to perform financial and general operations effectively
  2. Free
  3. Daily transaction log--gift; Amy to bring weekly activity report; Best practices is that 72 hours (but deposits are non-negotiable) and immediate acknowledgment in some fashion will help set you apart Report template: TY language
  4. Documentation of what you do– organic doc that changes over time– especially things that happen once a year
  5. Documentation of what you do– organic doc that changes over time– especially things that happen once a year
  6. Create a sample timeline?
  7. Create a scaled down version of this for a small org?
  8. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  9. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  10. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  11. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  12. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  13. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  14. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  15. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  16. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  17. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  18. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  19. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  20. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  21. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  22. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  23. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  24. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  25. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  26. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  27. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  28. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  29. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  30. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  31. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  32. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  33. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  34. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  35. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  36. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  37. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)
  38. Gift them example text; building trust with donors; directed to whoever’s name was on check (what is donor advised funds?)