Concerns or Questions about the PTO: 1. What is the role of the PTO at a Dodea school? In accordance to The Department of Defense Instruction memorandum, subject: Educational Advisory Committees and Councils: An association made up of parents, teachers, and students, associated with the National Parent Teacher Association and established at a DoDEA school. A PTSA is not duplicative of, or in competition with, SACs. A PTSA supports and plans such initiatives as school and community orientation programs, career awareness projects for students, special assistance to newly arrived teachers and families with school-age dependents, and fund-raising activities to secure student scholarships and supplemental instructional materials and hardware for the school. A PTSA is also referred to as a parent teacher association (PTA), or a parent teacher organization (PTO).* * Wright, J. (2012, December 7). Educational Advisory Committees and Councils. Retrieved August 29, 2015, from http://www.dtic.mil/whs/directives/corres/pdf/134215p.pdf In accordance to the PTO Constitution, Article 1, Section 1-2 Purpose: The Purpose of the ZAHS PTO is to provide support primarily to the scholastic and extracurricular programs of the Zama American High School, Camp Zama, Japan. Support may include, but not limited to, personnel, material, and financial assistance. 2. Who oversees the PTO at ZAHS? Is it Dodea or Military? Dodea oversees: The PTO is a recognized partner in the education of school aged children. All activities on school grounds or associated with ZAHS must be cleared through the principle and/or vice principle. Military oversees: All fundraising activities in accordance to installation and branch rules and regulations. For the Army is is AR210-22. For the Navy it is NAF Atsugi Instruction 1710.15N. 3. If it is military that oversees the PTO, as it is a private organization (PO), what voice does Atsugi s command have in the oversight of Zama s PTO? The only purpose for being a privately ran organization is so that the ZAHS can conduct fundraising activities on both military installations. Camp Zama:
Command maintains approving/disapproving authority in all fundraising activities on Camp Zama, Japan. This is in accordance to Army Regulation 210-22, Private Organizations on Department of the Army Installations, Chapter 2, Requirements and Procedures for On-Post Operation. Atsugi: Naval command authority regulates any fundraising activities by the PTO on Naval bases through the Staff Judge Advocate. They are the approving/disapproving authority for fundraising activities. Both military installations and their respective commands have a say in fundraising activities within their installations. That is the end of the relationship between the two unless installation rules are regulations are being broken. Commands can cancel the POs charter and dissolve the PO if illegal activity is being conducted. Only the paid members and board members have a say in what goes on within the PTO. Questions and Concerns for Fundraising: 1. Why is all fundraising At ZAHS required to go through the PTO? PTO should not be responsible for all groups and their fundraising. By giving them permission to have a fundraiser does this make PTO responsible for anything that happens at the fundraiser, and where the funding goes? All fundraising on Camp Zama, Japan are required to be handled by the PTO because it is the registered and approved PO on Camp Zama. In Accordance to AR 210-22 and AR600-29, you can only do fundraising on a military installation if you are a PO. The PTO does not decide which activities are approved or not approved. That is decided by the USAR-J Commander and Judge Staff Advocate. Funding, in accordance to the ZAHS PTO Constitution, Article IX, section 9-2 paragraph 9-2-1: The ZAHS PTO is authorized to request permission to conduct fundraisers held on, or advertised on Camp Zama, when such activities are approved at an Executive Board, General membership, or Special Meeting. The Commander, USAG-J, will review and approve, or disapprove, all requests for fundraisers that are held on, or advertised on, Camp Zama. Furthermore, in accordance to section 9-2-3 USAG-J Commander Approval. The ZAHS PTO will submit typewritten requests for permission to conduct fundraising to the appropriate USAG-J office at least 30 days prior to the event; seven days for car washes or bake sales. The appropriate USAG-J office will verify the PO s standing and forward the request to the Staff Judge Advocate (SJA) for review. The request will be forwarded to the USAG-J Commander will approval/disapproval. The approval/disapproval of the USAG-J Commander will be provided, in writing, to the PO. The written approval must be on site while the fundraiser is taking place.
Yes, this does make the PTO responsible for all approved fundraising requests. Every request the PTO submits is responsible to the PTO. This is why POs are required to maintain insurance policies covering, but not limited to loss, damage, etc. This in accordance to the ZAHS PTO Constitution, Article XI, Section 11-1 and also in accordance to AR 210-22, Chapter 3 Restrictions on POs Approved to Operate on Army Installations, Section 3-2, paragraphs a, b. The funds from the event go to the student activity (see DODEA Regulation 7240.1) account by the adult representative to the student activity group. The PTO does not control the funds of fundraising activities, unless the PTO is hosting the event. In this case, the funds will be distributed according to how all parties decide in advance at General PTO meetings or Special Sessions. 2. According to the PTO, the only fundraisers that can be done on Camp Zama are car washes and bake sales. Why is ZAHS not allowed to have other fundraising options? There is no set rule in place on what fundraising activities can be done, however the PTO is required to follow AR 210-22 and be in noncompetition with the Armed Forces Exchange Services and Moral, Welfare and Recreation organizations per AR210-22, Chapter 5, Section 5-2, Paragraph (2). As a result this limits the activities that can be done. An example of a success event is the Fall Festival conducted during the Fall of 2013 and 2014. Then PTO president, Kelly Brown was able to draft a plan for the event and was approved by all capacities involved. ZAHS can conduct similar fundraising, but it needs to be submitted 30 days prior to the event. In short, car washes and bake sales, are the quick methods of getting fundraising approved. The PTO is held to two car washes a month because it is a courtesy by MWR. There is a car wash facility located on Camp Zama that is run by MWR and they feel that student car washes are in direct competition to their car wash facility, however, they are giving us a courtesy of two a month. In fact, all POs registered on Camp Zama are held to two car washes a month. 3. If this is the case (from previous question) why is the PTO allowed to run a retail store at the school? Kelly Brown, previous PTO President, recognized a lack of options and opportunity for the PTO to raise money on its own. She drafted a fundraising idea to run a thrift store on a constant bases as a means to produce funds to the PTO. She received approval for the thrift store by the USAR J Commander, Joy Curriera on January 15, 2014. All approving authority granted permission for this to be a permanent fundraiser. Meaning the store is 100% volunteer and 100% of the profits go to the PTO to be distributed in accordance to the PTO s constitution. The reason why it is called a permanent fund raiser, is because the PTO does not have to submit an application for fundraising every time the doors are open. The agreement for the store expires when the PTO charter expires, October 2016. At that time the request must be resubmitted to continue operations.
4. Treasure Trove Who oversees this store other than the PTO? Operation of the store falls onto the shoulders of the PTO. The only authority that oversees the thrift store are those who enforce AR 210-22 because this is considered a fundraising activity on Camp Zama, Japan. As it is listed as a fundraiser, we must abide by all of AR 210-22 and the approved SOP. 5. Treasure Trove -- Who is responsible for monitoring who is coming into the store? There are parents that are concerned about the safety of the students. I took this question up with Dr. Mowen, ZAHS Principle, and we both came to agree that anyone whom is on Camp Zama has been registered at the front gate. There is a recording of their presence on Camp Zama. Since the location of the store is on the edge of the property, and there is no disturbance to class room activities, patrons will not have to register at the front door. 6. Treasure Trove -- Who makes the rules for this store concerning the health and safety of donations? According to the Treasure Trove SOP, section VI, paragraph c: The TTT Manager (PTO President) and the ZAHS PTO Vice President are jointly responsible for proper maintenance of TTT Thrift Shop to include cleaning, security, outside donation bin area kept clean, managing property coming in and out of the building, etc. Maintenance issues go through Ken-san, ZAHS and ZAMS maintenance manager. Any health issues (i.e. mold) are handled by Ken-san and require us to take immediate action. This may mean closing the operations until the issue is resolved. The volunteers at the Treasure Trove take every possible measure to sell items that are safe for patrons to buy. This means throwing out items that cannot be sold (broken electronics, under garments, etc) Our rule of thumb is if we wouldn t put it in our house, we wouldn t expect someone else to put it in theirs. 7. Who, other than the PTO oversees finances, taxes etc., for the store? The maintaining of accounting procedures are the responsibility of the PTO and only the PTO. The funds from the Treasure Trove are deemed the same as funds from any other fundraising event. At the end of the fiscal year (June), the PTO is required to go through an audit. Camp Zama requires an audit every two years, AR 120-22 Chapter 3 paragraph 3-3. Atsugi requires us to turn in an audit every January and due no later than the 15 th of February per NAFATSUGIINST 1710.15N, SEC 7. Also, when the treasurer position changes, an audit is required per the PTO constitution. The Treasure Trove is a fundraising activity and not considered a business. As a result the monies collected are non-taxable and non-taxed income. The PTO is not required to submit a tax return unless the income exceeds IRS regulation. If the Treasure Trove exceeds this income barrier, it will have to file a return under tax exempt status. The Treasure Trove does not pay employees so it does not have to file income taxes. It is advised that the PTO look at filing with
the IRS as a Tax Exempt organization, 501(c)(3). Also, in accordance to AR210-22, Chapter 3, section 3-3.
References: Depart of Defense Education Activity Administration of Student Activity Funds; DoDEA Regulation 7240.1 Tolleson, R. (1999, October 28). Department of Defense Education Activity. Retrieved September 27, 2015, from http://www.dodea.edu/offices/regulations/loader.cfm?csmodule=security/getfile&pagei d=92769 Department of Defense Instruction; Subject: Educational Advisory Committees and Councils; Number 1342.15 Wright, J. (2012, December 7). Department of Defense INSTRUCTION. Retrieved July 12, 2015, from http://www.dtic.mil/whs/directives/corres/pdf/134215p.pdf Department of the Navy; Subject Recognition/control of Private Organizations; NAFATSUGIINT 1710.15N (A copy of this was sent to me from the Staff Judge Advocate s Office.) Private Organizations on Department of the Army Installations Hudson, J. (2001, November 1). Private Organizations on Department of the Army Installations. Retrieved July 9, 2015, from http://www.apd.army.mil/pdffiles/r210_22.pdf