[PAO] Ice Bucket Challenge

[Lt Col Paul Hertel]

CAPR 173-4 26 DECEMBER 2012

SECTION A – GENERAL INFORMATION Page 2

2. No Air Force Involvement. It is important that no suggestions or inference be made in 

any CAP fund-raising program that the Air Force is involved or would benefit. Therefore, wear 

of the Air Force-style CAP uniform in fund raising activities is limited to cadets. Advertising and 

promotional matter should clearly identify CAP as a distinct organization from the Air Force. 

(See also paragraph 15f.)

 

My take on the regulation is, paragraph 2 is for fund raising for CAP NOT for charities outside of CAP. 

 

What Paul said, no fundraising of this sort in the USAF style uniform. A CAP T-shirt can go a long way. 

As always, consult your chain of command and the regulations. (knowledge base). 

 

 

V/R

 

PAUL HERTEL, Lt Col, CAP 

Chief of Staff
Public Affairs Officer

Illinois Wing

618-416-5180

 

 

"I may only be one person, but I can be one person that makes a difference."

 

From: cap-pao-bounces at lists.sempervigilans.org [mailto:cap-pao-bounces at lists.sempervigilans.org] On Behalf Of Cianciolo, Lt Col, Paul
Sent: Wednesday, August 20, 2014 4:24 PM
To: CAP PAO Listserv; NatCap Public Affairs
Subject: [PAO] Ice Bucket Challenge

 

PAOs,

I recently received the email below from the NASA social media team about the Ice Bucket Challenge <http://en.wikipedia.org/wiki/Ice_Bucket_Challenge> . Some if you may have seen this going around on social media already, but before you film dumping a bucket of icy water on your wing commander's head, take note. Even though it's for a good cause, it is considered fundraising. That means no Air Force style uniforms -- like on cadets doing this on their own. Now as for CAP supporting this in other ways ... that's up to the chain of command. The take away here is no fundraising with anything perceived to be Air Force.

 

 

We've had multiple NASA centers, programs, and missions ask about the Ice Bucket Challenge and doing it here. Even the NASA Administrator has been challenged, as have the astronauts on the ISS. We've sought out the guidance of our general counsel here since this is a charity fundraiser event. NASA's general counsel strongly advises us against participation in an official capacity. Here's counsels official reasons why:

 

Doing the Challenge in an official capacity as a NASA employee or in the workplace implicates some of the legal prohibitions on fundraising.  First, employees may not participate in fundraising activities in their official capacity.  This means that employees may not use their NASA title, position, or authority to fundraise.   For example, if an employee were to identify themselves as a NASA employee in the video, this could run afoul of the prohibition.   This could also create problems under other ethics provisions that restrict employees from using their Government title, position, or authority to endorse a product, service, or enterprise OR to imply the Government sanctions or endorses their personal activities or those of another.  In addition, participation may violate prohibitions on engaging in fundraising activities outside of the Combined Federal Campaign in the Federal workplace.  Finally, employees should not use official resources, such as Agency social media accounts, to support or promote a fundraiser.  

 

This does not prohibit employees from participating in the Challenge in their personal capacity off-site and on their own time.  One last thing to keep in mind is that, regardless of the context, employees must avoid soliciting funds from subordinates or from prohibited sources, i.e., entities that do business with NASA or are seeking to do so.  Thus, if an employee did participate in the Challenge, he or she should not nominate subordinates or Agency contractors.  It is also worth noting that the 2014 CFC season will soon begin, providing many opportunities within the Federal workplace for employees to support their favorite charities.

 

This guidance has been provided by the Office of General Counsel at NASA HQ. Figured I'd share in case you are working with your lawyers on similar guidance at your agencies. Obviously our counsel's guidance may not apply at your agency but it may be useful to have.

  



v/r
--
PAUL S. CIANCIOLO, Lt Col, CAP
Public Affairs Officer
National Capital Wing

Cell: 301-751-2011

Work: 202-385-9599 (@FAA)

 

  _____  

Civil Air Patrol National Capital Wing
"Citizens Serving Communities: Above and Beyond"

CFC Charity #26757
 <http://www.NatCapWing.org> www.NatCapWing.org

 

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