Community Grant Policy Proposed Amendments Summary — City Council and Authorities Concurrent, December 3, 2024

Current language: To
establish a standardized
process to award grants to
qualifying non-profit
community organizations,
youth athletic groups or
organizations, educational
groups or organizations, or
individuals, for events,
activities, and competitions
that provide a public benefit
for the City of Santa Clara
and its residents.

The reasoning behind this proposed amendment
was to promote altruism, inclusivity, and effective
use of grant funds towards Community
Events/Activities that are being hosted by
applicants that have a financial need for grant
funding.

Proposed language: To establish a standardized
process to award grants to:

 Qualifying 501(c)(3) non-profit community
organizations;
 youth athletic groups or organizations;
 educational groups or organizations; and
 individuals

that have a financial need
for the use of supporting
high impact events, activities, programs,
community projects (collectively referred to in the
Policy as “Community Events/Activities”), and
youth competitions and performances in which the
main purpose is to directly benefit the City of Santa
Clara and its residents, students, and schools.

Governance and
Ethics Committee
approved this
update without
amendment.

Upon further review, staff recommends minor clarifying edits which are reflected below. If approved, the Community Grant application will be updated to include a field for applicants to explain why the grant is needed and provide supporting
documentation as necessary. The application is currently an attachment to the policy, but it is not a policy document. Rather, the application is a form intended to aid the applicant and the City Manager’s Office in the application process to ensure that staff has sufficient information to evaluate. Therefore, in an effort to streamline the grant process, staff also recommends
removing the application as an attachment to the Policy to allow for future administrative updates as necessary.

Proposed amended language: To establish a standardized
process to award grants to qualifying:

 501(c)(3) non-profit community organizations;
 youth athletic groups or organizations;
 educational groups or organizations; and
 individuals

that demonstrate a financial need for grant funding for the use of supporting high impact events, activities, programs, community projects (collectively referred to in the Policy as “Community Events/Activities”), and youth competitions and performances in which the main purpose is to directly benefit the City of Santa Clara
(City) and its residents, students, and schools.

The Community Grant Program was originally
designed to support one-time events and activities.

However, there are opportunities to promote
creativity and increase community engagement
and direct benefits to Santa Clara residents by also
supporting community projects and programs
within Santa Clara. As such, the proposed
amendments expanded the definition of eligible
Community Events/Activities to include programs
and community projects that the Community Grant
Program may consider to promote increased public
benefits to Santa Clara residents, students, and
schools.

Proposed language: … for the use of supporting
high impact events, activities, programs,
community projects (collectively referred to in the
Policy as “Community Events/Activities”), and
youth competitions and performances in which the
main purpose is to directly benefit the City of Santa
Clara and its residents, students, and schools.

Governance and
Ethics Committee
approved this
update without
amendment.

None
The current Policy outlines
the following language
regarding grant
appropriations: Annually,
and subject to availability of
funds, the City Council shall
establish grant
appropriation(s) as part of
the budget approval
process.

There were no proposed amendments to this
section in the Policy or aspect of the Community
Grant Program when presented to the Governance
and Ethics Committee.

The Governance
and Ethics
Committee
requested an update
to the Policy to
include proposed
amendments that
would allow the
remaining balance
of unused grant
funds in the
Community Grant
Program budget to
be carried over to
the next fiscal
year.

Since FY 2021/22, an average of $52,000 has been awarded annually in Community Grants, leaving on average, a remainder of $38,000 in the Community Grant Program budget per fiscal year that is absorbed back in the City’s General Fund. While the Community Grant Program has had remaining balances in past fiscal years, staff is planning to promote and expand the Community Grant Program to encourage more potential
applicants to apply which could result in more expended funds.

Consistent with City practices, staff recommends bringing forward any potential carryovers of unspent Community Grant Program funds as part of the adopted budget or budgetary year end process for City Council consideration.

Community Grant Policy Proposed Amendments Summary
Current Policy Proposed Amendments Presented to
Governance and Ethics Committee
Feedback from
Governance and
Ethics Committee
Proposed Amendments After July 2, 2024 Governance and
Ethics Committee Discussion
The current Policy outlines
the following language
regarding maximum grant
amount: Community grants,
subject to availability of
funds, shall not exceed
$10,000 per applicant, per
fiscal year.

There were no proposed amendments to this
section in the Policy or aspect of the Community
Grant Program when presented to the Governance
and Ethics Committee.

The Governance
and Ethics
Committee
requested updated
policy language to
increase the
maximum grant
award amount
annually to account
for inflation.

In the Community Grant application, applicants must specify the amount of grant funds requested. Upon confirming that the requested grant funds will be spent toward eligible expenses, grant amounts have ranged from $900 to the maximum award amount of $10,000 for an average grant amount of $8,715 per approved applicant from FY 2021/22 through FY 2023/24. Staff’s recommendation is to leave the current policy language in its current form and re-visit this provision if necessary to increase the grant amount to account for inflation if the $10,000 maximum award proves to be insufficient over time due to inflation.

Additionally, if there is a need for more grant funds, then Council can approve those funds through the budget process or through a bud
get amendment, consistent with current City practice.

The current Policy outlines
the following language
regarding application
submittal: Applications will
be evaluated by the City
Manager’s Office on a
case-by-case and “first
come-first served” basis,
throughout the fiscal year.

There were no proposed amendments to this
section in the Policy or aspect of the Community
Grant Program when presented to the Governance
and Ethics Committee.

The Governance
and Ethics
Committee
requested proposed
amendments to
allow for a portion of
the Community
Grant Program
budget to be
reserved for later in
the year for Youth
Competitions /
Performances.

Before the Community Grant Program absorbed the
Championship Team Trust Fund, $36,000 was budgeted
annually for youth participation in championship games. In FY 2023/24, $18,265 was awarded for youth participation in competitions and performances (inclusive of sports, academics, etc.). Staff recommends leaving the current Policy language in its current form and re-visiting this in the future if the program budget is exhausted before youth groups/individuals have a chance to apply upon advancement to their respective
competition or performance.

Grant requirements are clearly communicated
through the approved grant application and
corresponding grant approval letter provided to
grant recipients under the grant approval process.

The proposed amendments include language that
aims to promote accountability and increase
protections for the City by setting clear instructions
on how grant funds can be spent and what needs
to be submitted to the City for auditing.

Proposed language: An applicant that receives
grant funds may be required to return awarded
grant funds, in part or in full, and considered
ineligible to submit a new grant request after the
conclusion of their event/activity/competition should
any of the following occur:

• Misuse of grant funds,
• Failure to provide documentation demonstrating
that grant funds were spent in the manner they
were approved by the City,
• Failure to follow the terms outlined under this
Policy and in the approved grant application; and
• Major changes to the event, activity, or
competition without prior City approval.

The Governance
and Ethics
Committee
approved staff’s
recommendation
with an additional
request that staff
consider term limits
for suspension
based on the
severity of the policy
and demonstration
of organizational
change by which the
infraction occurred.

Staff reviewed the Committee’s request and propose a period of one year upon resolution of outstanding issues. A term limit of one year provides a grant recipient sufficient time and opportunity to review the requirements in the Policy in preparation of an application submittal as a recurring applicant, if desired.

Proposed amended language: An applicant that receives grant funds (grant recipient) may be required to return awarded grant funds, in part or in full, and considered ineligible to submit a new grant request after the conclusion of their Community
Event/Activity or Youth Competition/Performance should any of the following occur:

• Misuse of grant funds,
• Failure to provide documentation demonstrating that grant funds were spent in the manner approved by the City,
• Failure to follow the terms outlined under this Policy and in the approved grant application; and
• Material changes to the Community Event/Activity or Youth Competition/Performance without prior City approval.

Grant recipients that are ineligible to apply for a Community Grant in the future due to incompliance with this Policy, may apply again in one year after resolution of outstanding issues.

Community Grant Policy Proposed Amendments Summary
Current Policy Proposed Amendments Presented to
Governance and Ethics Committee
Feedback from
Governance and
Ethics Committee
Proposed Amendments After July 2, 2024 Governance and
Ethics Committee Discussion
The current Policy’s
eligibility criteria require
applicants to demonstrate
how the request for grant
funding aligns with City
Council Goals which are
established as part of the
City Council’s Priority
Setting process and are
intended to set goals and
priorities of the City which
may not always be directly
applicable to the
Community Grant Program.

Current language:
a) Provides a benefit to
Santa Clara residents
b) Contributes positively to
the recognition and image
of the City of Santa Clara
c) If the grant is for an
event, then the event will be
open to the general public
and does not discriminate
on the basis of race,
gender, religion, sexual
orientation, or any other
protected characteristic
under state or federal law
d) Aligns with established
Council Goals
e) Grant Funds will not be
used for political or religious
purposes
f) If the event or activity is a
fundraising event, that the
proceeds from the
fundraising activity will
support programs, services
or events for residents of
the Cit
y of Santa Clara
Staff recommended replacing the Council Goals
with grant focus areas to better assist applicants
with identifying how the proposed Community
Event/Activity or Youth Competition/Performance
aligns with priorities central to the Community
Grant Program. Staff also recommended updating
the policy with a clearer definition of political and
religious purposes for consistency with state and
federal laws.

Proposed language:
a) Must be held within the City of Santa Clara
b) Provides a community benefit to the residents of
Santa Clara
c) Must be open to the general public, and does
not discriminate on the basis of race, gender,
religion, sexual orientation, or any other protected
characteristic under state or federal law
d) Aligns with the following grant focus areas:
• Santa Clara
Identity/Culture/Representation/Equity
• Santa Clara Youth
• Community Service
e) Consistent with applicable federal and state laws
regarding limitation on use of public funds. Public
funds shall not be used for the following:
• Religious Purposes. Grant funds shall not be
used to conduct religious services or ceremonies.

A grantee shall not spend any portion of the grant
to inhibit or promote religion, nor to convey a
religious message.
• Political Purposes. Grant funds shall not be used
for political purposes, such as political advocacy
efforts whether for or against a political candidate,
ballot measure, or bill.
f) If the event or activity is a fundraising event, that the proceeds from the fundraising activity will
support programs, services or events for residents
of the City of Santa Clara

Governance and
Ethics Committee
approved this
update without
amendment.

The proposed amendments presented to the Governance and Ethics Committee removed eligibility requirement (b) for Community Events/Activities in an effort to reduce any potential redundancy in the amended Policy. However, this eligibility requirement remained intact for Youth
Competitions/Performances. Since the eligibility requirements for the two grant categories have been separated for clarity, staff recommends adding this eligibility requirement back into the proposed Policy amendments under Community
Events/Activities for consistency, in addition to the
recommended clarifying edits reflected below.

Proposed amended language:
a) Must be held within the City of Santa Clara
b) Contributes positively to the recognition and image of the City of Santa Clara
c) Provides a community benefit to the residents of Santa Clara d) Must be open to the general public, and does not discriminate on the basis of race, gender, religion, sexual orientation, or any other protected characteristic under state or federal law e) Aligns with one of the following grant focus areas:
• Santa Clara Identity/ Culture/Representation /Equity
• Santa Clara Youth
• Community Service
f) Must be consistent with applicable federal and state laws regarding limitation on use of public funds. Public funds shall not be used for the following:
• Religious Purposes. Grant funds shall not be used to conduct religious services or ceremonies. A grantee shall not spend any portion of the grant to inhibit or promote religion, nor to convey a religious message.
• Political Purposes. Grant funds shall not be used for political purposes, such as political advocacy efforts whether for or against a political candidate, ballot measure, or bill. g) If the event or activity is a fundraising event, the proceeds from the fundraising activity will support programs, services or events for residents of the City of Santa Clara

Current language:

Allowable expenses shall
be defined as: City permits,
Fees and Services, Venue,
Food and Beverage,
Trash/Recycling, and
Stage/Tent Rentals. Grant
funds requested for Food
and Beverage do not
exceed 15% of the total
grant amount or $1,500.

The City Manager’s Office has not historically
approved grant funds for give-away items,
consultant fees, and other expenses that would
otherwise violate the current Policy or any other
City policies. Conversely, staff aims to promote
successful Community Events/Activities and
consider reasonable requests for grant funds
towards expenses essential to the success of the
event, provided that they do not violate the current
Policy or any other City policies. As such, staff
proposed the amendments below:

Grant funds may only be used for the following
eligible expenses for the Community Event/Activity:

• City permits, fees and services,
• Venue rental fees and related insurance;
• Food and non-alcoholic beverage (Food and
beverage costs should not exceed 15% of the total
grant request amount)
• Trash and recycling
• Stage, tent and equipment rentals
• Marketing, promotion, and advertising (excluding
consultant services and marketing materials
production)
• Incidental, one-time related expenses specifically
for the Community Event/Activity

Grant funds shall not be used for costs related to
the following:
• Gifts and giveaway items (e.g., gift cards, raffle
baskets, and prizes)
• Programmatic expenses such as applicant’s staff
time, overhead costs, consultant services, and
payment of hired staff
Governance and
Ethics Committee
approved this
update without
amendment.

Staff proposed further amendments to the eligible expenses to include other permits, fees, and services from other public agencies and other “similar” event rentals and further clarify marketing and promotional expenses, consistent with prior City approval of such grant expenses.

Proposed amended language: Grant funds may only be used for the following eligible expenses for the Community Event/Activity:

• Permits, fees and services from the City of Santa Clara and other public agencies
• Venue rental fees and related insurance;
• Food and non-alcoholic beverage (Food and beverage costs should not exceed 15% of the total grant request amount) • Trash and recycling
• Rental of stage, tents, and similar equipment
• Marketing and promotion of the Community Event/Activity such as printing expenses of promotional materials and fees related to advertising to the public (excluding third-party services to design marketing materials)
• Incidental, one-time related expenses specifically for the Community Event/Activity

Grant funds shall not be used for costs related to the following:
• Gifts and giveaway items such as gift cards, raffle baskets, and prizes
• Programmatic expenses such as applicant’s staff time, overhead costs, consultant services, and payment of hired staff Community Grant Policy Proposed Amendments Summary
Current Policy Proposed Amendments Presented to
Governance and Ethics Committee
Feedback from
Governance and
Ethics Committee
Proposed Amendments After July 2, 2024 Governance and
Ethics Committee Discussion
The current Policy does not
require grant recipients to
provide additional
information surrounding
community impact of the
event.

Within thirty (30) days upon the conclusion of the
Community Event/Activity or Youth
Competition/Performance, grant recipients must
complete a post event process in which receipts
and invoices are submitted for verification that
grant funds were spent in the manner they were
approved. This requirement in the current Policy
allows the City Manager’s Office to measure a
grant recipient’s past success when weighing
whether to approve or deny a future request for
grant funding. Staff recommended including
language in the Policy requiring grant recipients to
submit additional documentation during the post
event process to collect information that could be
used to measure the success of the event,
including attendance numbers, fundraising actuals
(if applicable), and community impact.

Proposed language: If the applicant received grant
funding, the applicant shall submit within 30 days
after the Community Event/Activity documentation
of:

• Proof of all allowable expenses incurred (e.g.,
receipts and invoices) and demonstrate that the
grant funds have been spent in the manner and for
the purposes stated in the approved application
• Attendance numbers
• Community Impact
• Fundraising actuals, if applicable

The Governance
and Ethics
Committee
approved the
proposed
amendments with an
additional request
that grant recipients
submit a five
hundred (500) word
description of how
the event went to be
included on the
City’s website.

Staff included updated language to expand the community impact requirement that would allow the City to post grant recipients’ community impact statements on the City’s website in addition to minor clarifying edits as shown below:

Grant recipients shall submit within thirty (30) days after the Community Event/Activity documentation of:

 Proof of all allowable expenses incurred (e.g., receipts and invoices submitted in an organized fashion that clearly demonstrates that the grant funds have been spent in the manner and for the purposes stated on the approved
application. Unspent grant funds, if any, should be identified.  Attendance numbers
 A community impact statement that describes how the event impacted the Santa Clara community (not to exceed five
hundred words). The community impact statement may be
used for the purposes of posting on the City’s website.

Staff also recommends applying the same requirements to Youth Competitions/Performances:

Grant recipients shall submit within thirty (30) days after the Youth Competition/Performance documentation of:

 Proof of all allowable expenses incurred (e.g., receipts and invoices submitted in an organized fashion that clearly demonstrates that the grant funds have been spent in the manner and for the purposes stated on the approved
application. Unspent grant funds, if any, should be identified.  Attendance numbers confirming the number of students and coaches/chaperones that attended the Youth
Competition/Performance
 A community impact statement that describes how the
competition/performance impacted the youth
groups/organizations or individuals (not to exceed five hundred words). The community impact statement may be
used for the purposes of posting on the City’s website.

The proposed amendments included language
outlining the grant recipient’s responsibility in the
post event process to provide the required
documentation in full and on time:

Proposed language:

It is the responsibility of the
applicant to return any unspent grant funds within
the required time frame. A grant recipient may be
deemed ineligible to apply for future grant
opportunities through the Community Grant
Program for late return or failure to return the
unspent grant funds.

It is the responsibility of the applicant to submit the required documentation within the required
timeframe. A grant recipient may be deemed
ineligible to apply for future grant opportunities
through the Community Grant Program for late
submission of documentation,
incomplete/insufficient documentation, or failure to
submit documentation.

Governance and
Ethics Committee
approved this
update without
amendment.

Upon further review, staff is proposing additional clarifying updates to the language to consolidate and clearly describe the procedure:

Proposed updated language: City Manager’s Office will review the submitted documentation outlined above for compliance and notify the grant recipient to confirm if any funds must be returned to the City. It is the responsibility of the grant recipient to submit the required documentation within the required timeframe within thirty (30) days after the City’s confirmation. A grant recipient may be deemed ineligible to apply for future grant opportunities through the Community Grant Program for late or incomplete documentation, failure to submit documentation, or late return or failure to return grant funds as required by the City.

City Council and Authorities ConcurrentDecember 3, 2024

City Council and Authorities Concurrent
December 3, 2024