There are many benefits provided by private organizations, or POs. They’re a great way to meet people with common interests, improve camaraderie, and provide a support network for service members. They can also foster volunteerism, increase base or civic involvement, and support a wide array of charitable interests. But if POs are so great, why all the restrictions on fundraising?
First and foremost, guidelines for POs can be found in Air Force Instructions 34-223 Private Organizations Program and 36-3101 Fundraising within the Air Force. This article is intended to provide general information only. This article should not be construed as legal advice. In fact, local Judge Advocate Generals are specifically prohibited from establishing an attorney to-client relationship with and providing legal advice directly to POs as part of the base legal assistance program.
AFI 34-223 states, “POs are self-sustaining special interest groups, set up by people acting exclusively outside the scope of any official capacity as officers, employees, or agents of the Federal Government.”
That is to say all POs are non-federal entities. See DoD 5500.7-R, Joint Ethics Regulation. Because they are non-federal entities, the Air Force cannot officially sanction any PO or even appear to officially sanction any PO. It necessarily follows that there can be no appearance of official sanction of PO fundraising events. As we all know, perception is reality.
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Some of the restrictions on POs include a prohibition against using DoD seals, logos and insignia and the requirement that all PO print and electronic media prominently display a disclaimer that the PO is a private organization, is not part of the DoD or any of its components, and has no governmental status. Fundraising activities must be conducted while off-duty and out of uniform. Additionally, POs may not use official resources such as government email, mail, computers, or copiers to provide notice of unofficial off-installation fundraising campaigns. However, with appropriate approval, certain resources such as "unofficial" bulletin boards may be used.
There are some other prohibitions that frequently trip up PO fundraising events. Generally speaking, POs are prohibited from engaging in any conduct which has the effect of advertising for, making referrals to, or encouraging use of any commercial business concerns. POs may not provide public recognition for gifts or donations they have received such as printing a business’ name or logo on promotional materials or T-shirts. A PO may not use the commercial sponsorship program for recognition of donors and may not create the appearance donors are being provided special treatment by the Air Force.
The 375th Force Support Squadron is the only organization on Scott Air Force Base authorized to use commercial sponsorship to offset program and event expenses. The exclusivity of this program is vital to the success of Morale, Welfare, and Recreation events for Scott AFB personnel and their families. It’s also key for long term events such as the 2017 Centennial Celebration to include the airshow and open house in June.
When a PO provides unauthorized advertising, sponsorship, and access to the Air Force market to local business, it syphons off funds those businesses budgeted for the benefit of the Scott AFB community at large, potentially reducing base-wide MWR programs. From the perspective of a local business, this can reduce the efficacy of the business’s donation and create distrust of personnel from Scott AFB. Being upfront and honest with local businesses about the limitations on POs and their status as a non-federal entity can help avoid this scenario.
The prohibitions above are not exhaustive, yet despite these restrictions, POs are still wildly successful in raising funds for social events or other activities. If you have questions, please refer to the AFIs mentioned above, the PO handbook on the 375th FSS website, and 375th FSS/FSR.