Essential Insights on IRS Form 990 and Effective Governance and Compliance

Each month, the Wyoming Nonprofit Network highlights a specific topic impacting the nonprofit sector in the What We Are Learning email series. In April 2025, WNN is evaluating the IRS Form 990 and the governance policies that the filing requires a charitable nonprofit to adopt. 

Start Thinking About the IRS Form 990 and Related Policies 

The information provided and policy requirements on the IRS Form 990 are essential for compliance and can support the organization’s governance practices. Consider the pre-learning questions below related to your organization’s understanding of the annual notice:  

1. Within the organization, who is responsible for ensuring that the Form 990 is accurate and submitted on time?

2. What training has organizational leadership, and the board of directors received for reviewing the organization’s Form 990 before it is submitted?

3. Has the organization discussed how donors or the public might use information shared by the Form 990?

Policies Every Organization Should Have 

In addition to the financial documentation, the Form 990 requests information about an organization’s adoption of four specific governance policies, which include:

• Written Conflict of Interest Policy: A conflict of interest policy requires those with a conflict or who believe they may have a conflict to disclose the conflict appropriately and prohibit interested board members from voting on any matter in which there is a conflict.

• Written Whistleblower Protection Policy: A whistleblower protection policy defines the internal process for addressing complaints about financial practices that protect whistleblowers from retaliation, assist organizations in complying with state and federal laws, and ensure that if there is a concern, it will be investigated and resolved.

• Written Document Retention and Destruction Policy: A document retention and destruction policy identifies the record retention responsibilities of staff, volunteers, board members, and other key stakeholders in maintaining, documenting, and destroying the organization’s records.

• Written Gift Acceptance Policy: A gift acceptance policy governs the receipt of "non-cash" gifts, such as gifts-in-kind and unusual gifts, which may include land, vehicles, or artwork.

More information and resources to develop these policies are available through the National Council of Nonprofits.  

Resources

• What questions does the organization have about its annual filing requirements? Access the “Form 990 Overview” from the IRS for information critical to maintaining tax-exempt status.

• To support the board of directors' review of the completed Form 990, download the checklist prepared by BoardSource pertaining to governance.

• Nonprofit Quarterly suggests “the board may give it a cursory look before signing off on it, but few look carefully at areas that might be seen as red flags to the IRS - never mind reporters and donors.” Watch “Making the Most of Your 990: A Red Flag Guide for Nonprofits,” a recorded webinar from GuideStar USA, to better understand what your organization should be reviewing on its annual IRS filing. 

What You Want to Learn Matters

Email Director of Learning and Development Tess Mittelstadt at tmittelstadt@wynonprofit.org with your feedback on the What We Are Learning email and suggestions on future topics.

The Wyoming Nonprofit Network amplifies, cultivates, and advocates for Wyoming's nonprofits.

Wyoming Nonprofit Network
822 West 23rd St., Unit A, Cheyenne, WY 82001
307-772-9050
wynonprofit.org