People have recently asked us if the December 22, 2018-January 25, 2019, government shutdown has affected the availability of nonprofit data. Yes and no.
Before getting into the details of the shutdown’s impact, I should note that even during the normal business cycle, Form 990 filing deadlines delay the availability of fresh nonprofit data. I wrote about this cycle a little over a year ago.
In addition to the normal delay, another issue impacted the delivery of IRS data before the shutdown. Last fall, the IRS didn’t have the thumb drives it needed to distribute nonprofit filing images. A little-known fact is that anybody requesting 990s from the IRS gets images of the filings shipped to them each month on thumb drives. No thumb drives, no 990 images, either electronic filings (efilings) or paper filings. Fortunately, we were able to pull down and load efiled data the IRS makes available through Amazon Web Services. As a result, we have data from approximately 85 percent of fiscal year 2017 filings.
Impact of the Shutdown
In December the IRS replenished its supply of thumb drives and sent us 990-PF images from September and October. But as luck would have it, not long after these images arrived, the government shutdown began. As a result we did not receive the 990 or 990-EZ images we had been expecting for that same period. Nor have we received thumb drives in January, which would have contained November flings. November is typically one of the highest volume release months based on filing requirements. This is why you may see an increasing number of nonprofit profile pages with filing data and no corresponding filing image.
The IRS last posted efiled data to Amazon Web Services on December 22, 2018—the first day of the government shutdown. We do not expect to see any additional efiled data releases or thumb drives in the short term. Over the past few weeks, the IRS has updated the Internal Revenue Bulletin, which identifies nonprofits whose tax-exempt status has changed. It has not, however, updated the Automatic Revocation of Exemption List (the list of organizations whose status was revoked for failure to file an annual return for three consecutive years) since December 10, 2018.
Moving forward into February, we believe it is unlikely that the IRS will release a new Exempt Organization Business Master File (BMF) on schedule. This file contains a list of all nonprofits that are currently registered with the IRS. It typically includes between 6,000 and 10,000 newly approved organizations in a given month. Until the new BMF is issued, a newly exempt organization should be prepared to provide a copy of its IRS letter of determination to verify its tax-exempt status and good standing with the IRS.
One thing we know for sure—shutdown or not—is that nonprofits have a critical role to play in increasing transparency in the sector. I want to encourage every nonprofit leader to take a few minutes to update your organization’s GuideStar Profile. This is a great way to ensure that everyone has the freshest information possible about your organization at any given time. And if we haven’t received your latest 990 from the IRS, you can upload a copy to your profile.Holly Ivel is GuideStar’s director of data services.