Travel Arrangements – Recreational or
UPDATED January 2006
Support Ruling is a case study of the eligibility of a travel
arrangement advertisement for a recreational or religious event in a
mailing at the Nonprofit Standard Mail (nonprofit) rates of postage.
example in this case study is a “Gospel Cruise”; however, the same
general guidance and analysis would be applicable to any travel
arrangement that includes recreational elements.
Mail Manual (DMM) 703.1.6.4c provides that nonprofit rates may
not be used for the entry of material that advertises, promotes,
offers, or for a fee or consideration, recommends, describes, or
announces the availability of any travel arrangement, unless the
organization promoting the arrangement is authorized to mail at the
nonprofit rates at the entry post office; the travel contributes
substantially (aside from the cultivation of members, donors, or
supporters, or the acquisition of income or funds) to one or more of
the purposes that constitute the basis for the organization’s
authorization to mail at the nonprofit rates; and the arrangement is
designed for and primarily promoted to the members, donors,
supporters, or beneficiaries of that organization.
The nonprofit organization holds a
valid nonprofit authorization as a nonprofit religious organization
and the “Gospel Cruise” travel was “primarily promoted to the
members, donors, supporters, or beneficiaries” of the organization.
Thus, the remaining issue is whether the travel “contributes
substantially” to the purposes of the authorized organization.
Generally, the application of the DMM
standard requires an examination of the specific nature of the
travel arrangement. Initially, it is important to examine the
mailpiece itself. The post office’s decision in this case focused on
the apparent “recreational” nature of the travel, as described in
the advertisement. Indeed, when consideration is limited to the
advertisement in this case, it is not surprising that the mailpiece
was initially considered ineligible for the nonprofit rates, since
the advertisement focused on available recreational activities on
the trip, including opportunities for shopping and relaxation.
In order to determine the eligibility
of the cruise to qualify as a travel arrangement that “contributes
substantially” to the qualifying purposes of the religious
organization, a more in-depth inquiry is necessary. Such analysis
often requires a much fuller description of the trip than is
available from the advertisement, which may be supplied through
other evidence, such as a detailed explanation and itinerary of the
travel arrangement. This information may be provided by the mailer
at acceptance or, as in this case, through an appeal.
In the case of the “Gospel Cruise,”
the additional information clearly demonstrated that the nature of
the travel arrangement was consistent with the organization’s
purpose. For example, the information provided evidence that the
emphasis during the cruise would be advance Bible teaching, praise
and worship with some anointed groups, daily intercessory prayer
time, and encouragement to witness to others both on and off the
ship. The religious organization rented 100% of the ship for this
trip. There also was a daily cruise bulletin providing the teaching
and worship schedule, daily bible verses, information about the
ministry, and special religious events.
Although, as described in the
advertisement, recreational activities were available, some of the
typical recreational activities associated with an “off the shelf”
commercial travel arrangement were not present. For example, the
ship’s usual entertainers did not perform, but were replaced for the
tour with spiritual music entertainers. The religious organization
compensated both the regular entertainers and the cruise line for
the change in itinerary.
On balance, when the arrangement was
closely examined, it was demonstrated that the religious activities
associated with the cruise were substantial. Accordingly, it was
concluded that the travel arrangement did indeed contribute
substantially to the religious purposes of the authorized
organization, and the advertisement was found to be eligible for the
Nonprofit Standard Mail rates.
United States Postal Service
Washington DC 20260-3436