Community Benefit

Splitting Costs Between Community Benefit and Marketing

Please Take Note: The information provided does not constitute legal or tax advice. The material is provided for informational/educational purposes only. Please consult with counsel regarding your organization's particular circumstances.

Question: Can we split the cost of an activity if it serves both a community benefit and marketing purpose?

Recommendation: Yes, it is possible to assign some cost to community benefit if an activity is designed primarily to achieve a community benefit objective. Any marketing objectives should be secondary. Here are some things to consider:

  • Activities or programs should not be counted as community benefit if a "prudent layperson" would not agree that they benefit the community more than the organization, for example if a newsletter is published primarily and clearly for marketing purposes.
  • If the original purpose of the program was to achieve one or more community benefit objectives, then the entire program cost can be assigned to community benefit, even if the program also has a marketing side effect. Ways to determine if meeting community need was the original purpose include (a) meeting notes that the program was developed in response to community need, and/or (b) the idea for the program came from a community group or the community benefit team — rather than the marketing department.
  • If the original purpose of the program was marketing and/or if the program originated from the marketing department, we recommend caution in including any portion of the program as community benefit. However, in some cases a portion can be counted. For example, if a facility held an open house with health screening, the cost of the open house such as food and publicity would not count, but the cost of screening materials and staff conducting the screening could count.
  • If the program is truly a joint marketing and community benefit activity, then the cost could be split. Program records should describe the rationale for how the split was determined.