Customer Support Ruling
Travel Arrangements – Recreational or Religious Event
UPDATED January 2017
This Customer 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 USPS Marketing Mail (nonprofit) prices of postage.
The specific 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.
Domestic Mail Manual (DMM) 703.1.6.4c provides that nonprofit prices 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 prices, 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 USPS Marketing Mail prices.
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