Advance Approval of Private Foundation Grants: Supervision of grants


To be approved in advance, a foundation’s grant procedure must provide for proper follow-up by the foundation to determine whether grantees have performed the activities that the grants are intended to finance and have not diverted grant funds away from the original purposes of the grant.  A procedure meets this requirement if:

  • Periodic progress reports are made to the foundation, at least once a year, to determine whether grantees have performed the activities the grants are intended to finance,
  • The foundation investigates and takes corrective action when progress reports are not provided or there are other indications that grants are not being used as intended, and
  • The foundation keeps records relating to all grants to individuals, including: 
    • information obtained to evaluate potential grantees,
    • identification of grantees, including any relationship of the grantee to the foundation that makes the grantee a disqualified person,
    • amount and purpose of each grant, and
    • follow-up information, including required annual reports and investigation of jeopardized grants.

Requests for approval of grant-making procedures should be sent to EO Determinations, using Form 8940, Request for Miscellaneous Determination. See the Instructions to Form 8940PDF for more information.

Additional information:

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