Part VIII-A. Summary of Direct Charitable Activities

List the foundation's four largest programs as measured by the direct and indirect expenses attributable to each that consist of the direct active conduct of charitable activities. Whether any expenditure is for the direct active conduct of a charitable activity is determined, generally, by the definitions and special rules of section 4942(j)(3) and the related regulations, which define a private operating foundation.

Except for significant involvement grant programs, described below, don't include in Part VIII-A any grants or expenses attributable to administering grant programs, such as reviewing grant applications, interviewing or testing applicants, selecting grantees, and reviewing reports relating to the use of the grant funds.

Include scholarships, grants, or other payments to individuals as part of an active program in which the foundation maintains some significant involvement. Related administrative expenses should also be included. Examples of active programs and definitions of the term “significant involvement” are provided in Regulations sections 53.4942(b)-1(b)(2) and 53.4942(b)-1(d).

Don't include any program-related investments (reportable in Part VIII-B) in the description and expense totals.

Include qualified set-asides for direct charitable activities reported on line 3 of Part XI. Also, include in Part VIII-A amounts paid or set aside to acquire assets used in the direct active conduct of charitable activities. Don't include current-year expenditures of amounts previously reported as set-asides in Part VIII-A.

Expenditures for direct charitable activities include, among others, amounts paid or set aside to:

1. Acquire or maintain the operating assets of a museum, library, or historic site or to operate the facility;

2. Provide goods, shelter, or clothing to indigent or disaster victims if the foundation maintains some significant involvement in the activity rather than merely making grants to the recipients;

3. Conduct educational conferences and seminars;

4. Operate a home for the elderly or disabled;

5. Conduct scientific, historic, public policy, or other research with significance beyond the foundation's grant program that doesn't constitute a prohibited attempt to influence legislation;

6. Publish and disseminate the results of such research, reports of educational conferences, or similar educational material;

7. Support the service of foundation staff on boards or advisory committees of other charitable organizations or on public commissions or task forces;

8. Provide technical advice or assistance to a governmental body, a governmental committee, or subdivision of either, in response to a written request by the governmental body, committee, or subdivision;

Instructions for Form 990-PF (2025) 29

9. Conduct performing arts performances; or

10. Provide technical assistance to grantees and other charitable organizations. This assistance must have significance beyond the purposes of the grants made to the grantees and must not consist merely of monitoring or advising the grantees in their use of the grant funds. Technical assistance involves the furnishing of expert advice and related assistance regarding, for example:

a. Compliance with governmental regulations, b. Reducing operating costs or increasing program accomplishments,

c. Fundraising methods, and d. Maintaining complete and accurate financial records.

Report both direct and indirect expenses in the expense totals. Direct expenses are those that can be specifically identified as connected with a particular activity. These include, among others, compensation and travel expenses of employees and officers directly engaged in an activity, the cost of materials and supplies utilized in conducting the activity, and fees paid to outside firms and individuals in connection with a specific activity.

Indirect (overhead) expenses are those that aren't specifically identified as connected with a particular activity but that relate to the direct costs incurred in conducting the activity. Examples of indirect expenses include:

• Occupancy expenses;

• Supervisory and clerical compensation;

• Repair, rental, and maintenance of equipment;

• Expenses of other departments or cost centers (such as accounting, personnel, and payroll departments or units) that service the department or function that incurs the direct expenses of conducting an activity; and

• Other applicable general and administrative expenses, including the compensation of top management, to the extent reasonably allocable to a particular activity.

No specific method of allocation is required. The method used, however, must be reasonable and must be used consistently.

Examples of acceptable allocation methods include:

• Compensation allocated on a time basis;

• Employee benefits allocated on the basis of direct salary expenses;

• Travel, conference, and meeting expenses charged directly to the activity that incurred the expense;

• Occupancy expenses allocated on a space-utilized basis; and

• Other indirect expenses allocated on the basis of direct salary expenses or total direct expenses.