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Apr 09, 2020 News
The Government of India has constituted a special group in order to solicit support for COVID-19 related activities from the Private Sector, NGOs and international Organizations. In this regard, Ministry of Home affairs (MHA) vide its letter dated 1st April, 2020 had sent a notice to some of the FCRA Registered organizations asking for reporting (in a specific format) of the support that is being provided by the organization in response to COVID-19 Pandemic. The scanned copy of such reporting format had to be sent via e-mail by 9th April. 2020. However, MHA in a subsequent notice dated 7th April, has asked the associations to report COVID-19 related support activities through online forms which is available at the fcraonline.nic.in.
The notices and the formats are more in the form of an appeal and not a directive. It is an appeal to all the NGOs to come forward and support the nation in dealing with this pandemic by providing relief support in various forms and reporting thereof.
However, there has been a lot of confusion as well as questions among the Organisations with regard to submission of the form and subsequent reporting. We have tried to list a few common questions that we have received in this regard. Our response has been provided through this communication:
Q1. Whether it is compulsory to submit such reports?
A1. It can be inferred that such reporting is not compulsory for any organization. It is more in the nature of appeal. However, it is advised to report the support related to COVID-19 in the said format and be actively involved in the process.
Q2. What if our organization has not provided any support?
A2. As mentioned above, this is not a compulsory reporting and hence, may be avoided if no support is being provided by the organization.
Q3. Whether such reporting/non-reporting is linked to FCRA renewal of our organization.
A3. In our opinion, the notice and the reporting formats do not suggest any linkage with FCRA Renewal. On the other hand, in case your organization is not reporting, it does not hamper your FCRA renewals due in 2021. However, it is advised that the Organisations support and engage actively in this pandemic of such magnitude.
Q4. Our organization has not received the notice in our registered e-mail id. Can we still report the relief support that is being provided?
A4. Yes, the form is available online at the website fcraonline.nic.in
Q5. Whether we need to report FC funded support or all the support that is provided?
A5. Upon review of the Form, it clearly mentions to report that all the support provided till date needs to be mentioned. It does not differentiate between FC funds or local funds and hence, it is advised all the cumulative support provided till date (whether from FC Funds or Local funds) should be reported in this form. In such case, you can disclose the fact that the support is being provided from Local and FCRA Funds. The relevant text in the format has been reproduced as under
“At the time of updation, the latest details and figures (inclusive of all support provided till date) should be entered. In other words, cumulative total support provided should be entered as on date during each updation”
Q6. Do I need to report if our organization has been engaged in in-kind distribution and not spending cash directly?
A6. Yes, the reporting format includes the type of support that is being provided. Therefore, in case your organization is engaged in in-kind distribution, such as distribution of food, clothes, santizers, soaps etc, then the same should be reported as well. Further, an estimated value of goods distributed needs to be mentioned in the amount column in the said format.
Q7. Our organization has planned for distribution in the upcoming days; however, we have not provided any support till date. Do I need to report the planned activities?
A7. The earlier format provided that the planned activities and the estimated amount needs to be reported.
However, the form has been revised subsequently. Now, the reporting formats suggests that the organization needs to report the actual support provided till date and not the planned activities. The organization can report through the online portal by the 15th of every month regarding the activities completed till such reporting date.
Q8. There is a list of activities mentioned in the Notice. Do we need to confine our reporting only to such activities?
A8. No, you can report any kind of support that is being provided by your organization. The list of activities are only suggestive in nature and not exhaustive. You can mention the type of support that is being provided in the reporting format irrespective of whether such support is being included in the notice or not. Further, an estimated value of such support in monetary terms can be mentioned in the space provided for such information.
Q9. Can I update the support related information once it has been filed at the online portal?
A9. Yes, it should be noted here that the reporting format requires to ‘save and update’ and there is no option for upload. This implies that we can update the information multiple times as and when required. However, as suggested in the notice, we should update the information prior to 15th of every month at the online portal.
Q10. Can we provide funds to other organization who is in relief work related to COVID-19 and report it hereof.
A10. Yes, technically this is possible, since funds have been provided for COVID-19 response. However, the donor organization should take care of the following things while reporting such support
· Donor Organization should state in writing about the support related to COVID-19 to the recipient organization in its donation letter
· In case, FC funds are being provided, the recipient organization should have a valid FCRA registration and 12A registration to receive FC Funds
· In case, local funds are provided, the recipient organization should have a valid 12A registration to receive tax-free donations