The Small Nonprofit and the Strings-Attached Grant
You are the only social worker at a small nonprofit serving 180 immigrant families. A local foundation offers a $75,000 one-year grant, roughly 30 percent of your operating budget. The grant letter specifies that services must be delivered to 'documented residents only,' that staff must collect and share immigration status information with the funder for reporting, and that the organization must not 'engage in political advocacy.' Your current practice serves anyone who walks in and does not record immigration status. Your board chair is enthusiastic and says 'we can figure out the details later.' Your executive director asks for your recommendation. Two staff members are themselves from mixed-status families.
1. What is your recommendation, and what is the ethical reasoning?
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Recommend not accepting the grant as written, and propose a counterproposal. Reasoning:
- The eligibility restriction conflicts with the agency's mission and with social work values. Excluding undocumented families from a service designed for immigrant families abandons the most vulnerable segment of the population and would require turning people away at the door.
- Collecting and sharing immigration status is a serious confidentiality and safety risk. Immigration status is sensitive data. Sharing it with a funder creates a record that could be subpoenaed or misused, and it will predictably deter families from seeking help - including families with citizen children.
- The 'no advocacy' clause may be an unlawful or overbroad condition depending on whether the funder is a government entity or private foundation and on how 'political advocacy' is defined. Even for private funders, a blanket ban on advocacy can conflict with the agency's obligation to advocate for clients. Clarify the definition in writing.
- Staff with mixed-status families face a direct conflict. Requiring them to collect status data may endanger their own relatives and creates a coercive workplace situation.
Counterproposal:
- Report aggregate, de-identified service numbers rather than individual status.
- Replace 'documented residents only' with 'immigrant families in the service area.'
- Narrow the advocacy clause to partisan electioneering, which is already restricted for nonprofits.
- Ask for a written opinion from counsel before signing anything.
Do not accept 'figure out the details later.' Grant conditions are enforceable once signed.
2. The board chair overrides you and accepts the grant. What are your options and obligations now?
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You do not have veto power, but you have professional obligations that survive the board's decision.
Options and obligations:
- Get the conditions in writing and get legal review. Confirm exactly what data must be collected, who receives it, and how 'advocacy' is defined. Ambiguity is the biggest risk.
- Document your objection in writing to the executive director and board, including the specific ethical and legal concerns and the fact that you raised them before acceptance. This is not insubordination; it is professional record-keeping.
- Refuse to personally participate in the harmful act. If the grant requires you to collect and transmit immigration status, you may decline that specific task and say why. You may not sabotage the grant or secretly withhold required reporting.
- Mitigate harm within your role. Push for the narrowest possible data collection, secure storage, a written data-sharing agreement, and a clear notice to clients about what is collected and why - so families can make informed choices.
- Know your limits. If the agency's core practice becomes excluding people based on status, that may cross a line where you must consider leaving or reporting to a licensing board, depending on your jurisdiction's rules.
- Support affected staff - offer supervision, confidentiality assurances, and a route to raise concerns without retaliation.
The exam distinction: you are accountable for your own conduct, not for the board's decision, but you are accountable for how clearly and early you objected.