Examining the Efficacy of Accountability Systems in Preventing Nonprofit Misconduct: A Look Beyond Financial Fraud

Abstract

The purpose of our study is to broaden the investigation of nonprofit misconduct beyond financial fraud perpetrated by individual actors and to identify structural features that are more or less likely to be associated with actual misconduct. We utilize the Charity Navigator Advisory System and related press releases to identify 215 nonprofit organizations with confirmed or alleged misconduct. We also collect the IRS Form 990 information for 133 out of the 215 organizations with known misconduct and 150 organizations without known misconduct to compare their accountability structures. Our findings suggest that, while financial fraud committed by individual perpetrators against their organizations is the most frequently identified type of misconduct, a substantial number of other types of misbehaviors also commonly occur. Our comparison analysis indicates that organizations with known misconduct deviate significantly from scandal-free charities in several structural aspects.

Keywords

nonprofit misconduct fraudulent behavior mismanagement nonprofit accountability good governance

Introduction

Scholars studying misconduct in the nonprofit sector in the United States have heavily focused on financial fraud committed by individual perpetrators. This makes sense, given that about 5% of revenue across all organizations, including charities, is estimated to be lost annually due to fraud globally (Association of Certified Fraud Examiners [ACFE], 2020), and many widely publicized charity scandals involve some form of financial wrongdoing (Prakash & Gugerty, 2010). The past literature in this vein provides detailed information regarding the types of fraud and other financial wrongdoing committed, characteristics of organizations that victimize the public or were victimized by their employees, sociodemographics of perpetrators, and financial losses caused by misconduct (Archambeault et al., 2015; Greenlee et al., 2007; Holtfreter, 2008).

Despite the growing literature that sheds light on financial fraud in the nonprofit sector, however, past studies have not explored many critical questions related to nonprofit misconduct. For example, to what extent do we know about nonfinancial misbehaviors within the sector? This is an important question to ask because nonprofit accountability is fundamentally about public trust and legitimacy (Fremont-Smith & Kosaras, 2003), and nonfinancial types of offenses (such as an alleged abuse of power that does not involve financial fraud, but damages the reputation of the organization) can erode faith and confidence in charities as much as financial scandals do. Another question might be, who perpetrates wrongdoing and why? The extant literature tends to focus on individuals and their personal characteristics. But what if organizations themselves misbehave? How might misconduct on the organizational level look different from misconduct on an individual level?

A fuller understanding of the nature of nonprofit misconduct could help us design better control systems to prevent future misbehaviors. In response to rising concerns over nonprofit accountability, scholars have produced an extensive body of literature regarding charity regulation. Many studies have focused on financial accountability mechanisms, such as internal controls, independent audits, and financial disclosures, as vital structural features to prevent fraud (Keating & Frumkin, 2003; Saxton & Guo, 2011; Verbruggen et al., 2011). Others have highlighted the importance of good governance to ensure organizational accountability (Callen et al., 2010; Ebrahim, 2003, 2010; Gugerty, 2009; Ostrower, 2007). However, what has been lacking in the literature is an empirical examination of the efficacy of these accountability measures to see whether any of these structural aspects matter in mitigating misconduct (Ito & Slatten, 2018).

The purpose of our study is to broaden the investigation of nonprofit misconduct beyond financial wrongdoing perpetrated by individual actors and to identify structural features that are more or less likely associated with a broad range of actual misconduct. We utilize the Charity Navigator Advisory System (CNAS hereafter) and related press releases to identify 215 nonprofit organizations with confirmed or alleged misconduct for our analysis. We also collect the IRS Form 990 information available for 133 out of the 215 organizations with known misconduct and 150 organizations that are scandal-free to compare their accountability-related organizational structures.

Our findings suggest that, while financial fraud committed by individual perpetrators against their organizations is the most frequently identified misconduct, a substantial number of other types of misbehaviors are also common. Our comparison analysis indicates that organizations with known misconduct deviate significantly from scandal-free charities in terms of several structural aspects, including independent boards and formal processes for CEO compensation evaluation. This study adds meaningful contributions to the literature by expanding the inquiry of nonprofit misconduct beyond financial fraud, as well as seeking empirical evidence for the efficacy of accountability structures.

Literature Review

Understanding the Nature of Nonprofit Misconduct

The past literature well documents misconduct in the nonprofit sector, and the majority of these studies focus on financial fraud (Fremont-Smith & Kosaras, 2003; Greenlee et al., 2007; Holtfreter, 2008). A few studies explore beyond financial wrongdoing committed by individual perpetrators. For example, Fremont-Smith and Kosaras (2003) find that breaches of fiduciary duties by governing boards are recurring incidents. Although the types of misconduct identified are still mostly financial (such as misuse of assets for personal benefits, self-dealing, excessive compensation, excessive expenditures, or improper investment), the involvement of board members or even the board as a whole in scandals may indicate that these incidents are not always isolated events led by a few bad actors. Similarly, Gibelman and Gelman (2002, 2004) broadly identify nonfinancial misconduct that has taken place in the nonprofit sector, including physical and sexual abuse of children, inadequate housing and abandonment, cruelty to children, and sexual misconduct by organizational leaders targeting their subordinates. These nonfinancial misbehaviors are detected across a wide spectrum of nonprofit organizations—religious and secular; domestic and international—signaling the possibility that this form of misconduct might be commonly found if fully explored. More recently, McDonnell and Rutherford (2018) report a diverse set of complaints made to the government regulators against charities in the Scottish nonprofit sector. These complaints include not only financial misconduct but also various nonfinancial concerns, such as employment matters or failure to adhere to the founding document. Despite the possibility that a wide range of types of misconduct might exist in the nonprofit sector, the majority of the extant literature has been limited to and remains largely focused on financial fraud.

Another focus of previous studies is the distinction between intentional, fraudulent behaviors and mistaken or negligent actions. LeClair (2019) uses the term “corruption” to identify fraudulent and unethical behaviors, drawing a line between “hard” corruption and “soft” corruption (pp.58–59). While hard corruption encompasses outright fraud, soft corruption includes “rogue, [but] not unlawful” behaviors (p. 56), such as inappropriately using donation funds for lavish compensation. In an attempt to expand the scope of research in the area of nonprofit misconduct, we first explore the following question: What is the nature of misconduct in the nonprofit sector?

To answer this question, our study systematically explores the underlying elements of nonprofit misconduct along the following dimensions: individual-organizational, financial-nonfinancial, and internal-external. Our examination of individual-organizational draws from the field of management, which has comprehensively explored the dark side of organizational behavior with a multidimensional understanding of human aggressions and other types of corrupt behaviors in workplaces (Greve et al., 2010; Griffin et al., 2004). Ashforth et al. (2008), for example, discuss corrupt behavior in microlevel and macrolevel terms, that is, individual perpetrators as bad apples and corrupt organizations and industries as bad barrels (see also Huberts & de Graaf, 2014, for their concept of micro-, meso-, and macro-level corruption). Similarly, Pinto et al. (2008, p. 685) conceptually separate “organizations of corrupt individuals” from “corrupt organizations.”

Distinguishing misconduct on the individual level from the organizational level helps us understand possible causes for misbehavior and potential preventive measures. For example, researchers frequently cite biological traits and predispositions (e.g., moral identity, self-control) for individual transgression while attributing organizational-level misconduct to leadership failure and corrupt organizational culture (Greve et al., 2010). Interestingly, an increasing number of researchers are turning their attention to situational factors to explain individual misconduct, opening the possibility that organizational control systems or accountability mechanisms might play a role in mitigating both individual-level and organizational-level misbehavior. Public choice theorists, for instance, argue that individuals engage in misconduct based on their calculation of the benefits and costs of such behavior. A comprehensive system of control that involves surveillance and monitoring will increase an individual’s chances of getting caught for the misbehavior, pushing the costs of the misdeed higher than the potential benefits they might receive from it (De Graaf, 2007). Other scholars recognize the influence of organizational culture on individuals where individual employees might acquire corrupt attitudes and behaviors from co-workers and leaders via social learning processes (Ashforth et al., 2008). Again, enhancing organizational control mechanisms could discourage misbehaviors at the individual level in this context.

Another dimension we consider in understanding the nature of nonprofit misconduct is whether it is financial or nonfinancial. It should be noted that “being financial in nature” is different from having financial implications. Any misbehavior in nonprofit organizations can lead to negative financial consequences such as loss of donations and lawsuits. In fact, in their discussions of risk management in the nonprofit sector, Zietlow et al. (2007) identify a wide range of potential liabilities that can be caused by actions of fiduciaries, executives, staff, and volunteers, resulting in financial risks for organizations. We limit our definition of “being financial in nature” to an act, in and of itself, that involves financial aspects such as embezzlement or poor asset management. This financial versus nonfinancial distinction is useful because a significant presence of nonfinancial misconduct would highlight that improving financial accountability mechanisms alone may not effectively stem malfeasance in nonprofit organizations.

As previously noted, the past literature on nonprofit misconduct primarily focuses on financial fraud. From these studies, we know that misappropriation of assets, such as fraudulent cash disbursement and fraudulent billing schemes (Greenlee et al., 2007), and various embezzlement activities, including check and credit card–related fraud (Archambeault et al., 2015), are common.

Given the near absence of in-depth research regarding nonfinancial types of misconduct in the nonprofit literature, theories developed in the management field are enlightening. Of particular interest is research delving into various forms of human aggressions and antisocial behaviors manifested in workplaces, such as violence, discrimination, sexual harassment, retaliation, and incivility (Baron, 2004; Fritz, 2014; Paetzold, 2004). Anti-corruption and integrity-related theories are also illuminating as this body of literature recognizes various nonfinancial types of misbehavior at the individual and organizational level. Examples include, but are not limited to, conflict of interest; favoritism; improper use of authority; misuse or manipulation of information; indecent treatment of colleagues, citizens, or customers; and waste and abuse of organizational resources (Huberts & Lasthuizen, 2014). Exploring the theories involved in each of these behaviors, however, is beyond the scope of our study.

Control Systems

The second question we explore in this study is: What are the control systems that contribute to the prevention of misconduct? Largely based on the principal-agent framework, scholars focus on governing boards’ roles and the types of command and control systems they develop to constrain potentially opportunistic behaviors of agents (Cornforth, 2004; Coule, 2015; Jensen & Meckling, 1976). The range of a board’s safeguarding activity can be broad. For example, Greenlee et al. (2007) address the importance of both sound financial accountability mechanisms (e.g., separation of financial handling, annual audits, and training of staff about fraudulent activities) and good governance (e.g., culture of ethics, audit committees) as ways to enhance nonprofit organizations’ defense systems against fraud (see also Grasse & Neely, 2020, regarding the use of the COSO [Committee of Sponsoring Organizations] framework for the enhancement of internal controls). They also discuss Sarbanes–Oxley Act–related reform ideas to improve board accountability by citing the recommendations (such as independent board members and the prohibition of personal loans to officers and directors) made by the Independent Sector’s (2005) Panel on the Nonprofit Sector. Similarly, Archambeault et al. (2015) emphasize the critical roles played by internal controls and robust board oversight in preventing fraud. Particularly, they highlight the importance of the board’s role in overseeing the hiring and monitoring of executives, noting that people who held executive positions committed 60% of the frauds identified in their study. Some scholars search for more encompassing concepts, such as “organizational governance” (Ebrahim, 2010, p. 8) or “organizational accountability” (Reiser, 2004, p. 215), so as to capture a holistic system of accountability structure and operation for an organization.

Despite the large body of literature available regarding nonprofit accountability, empirical research directly examining its efficacy in reducing misconduct has been surprisingly rare. Instead, scholars focus on exploring the determinants for adopting accountability measures, such as organizational size and resources (Blodgett & Melconian, 2012; Nezhina & Brudney, 2010). Others examine the impacts of weak internal control systems on donation and government grants rather than misconduct per se (Petrovits et al., 2011). A few studies investigate an actual link between control systems and misconduct. Beasley (1996), for example, examines the extent to which the inclusion of larger proportions of outside members on the board reduces the likelihood of financial statement fraud. Christensen (2016) analyzes and finds supporting evidence for a negative association between Corporate Social Responsibility (CSR) reporting and corporate lawsuits concerning allegations of bribery, kickbacks, or discrimination in public corporations.

Christensen’s (2016) study is particularly interesting, given how it justifies CSR reporting as a proxy for the quality of the organization’s overall control systems. His main reasoning relies on the process of producing a CSR report, as it compels an organization to self-assess not only its economic, social, and environmental performance but also its potential risky behaviors, such as corruption, discrimination, or regulatory violations (Christensen, 2016). Through this internal evaluation process, the organization learns of its mistakes and raises awareness regarding potential misconduct. Studies empirically examining the effects of accreditation (Carman & Fredericks, 2013) or voluntary guidelines and codes of ethics (Bromley & Orchard, 2016) on ethical practices assume similar internal learning processes.

Whether and to what extent specific features of control systems might be associated with particular types of misconduct is not clear, although the findings from Harris et al. (2017) and Khadra and Delen (2020) suggest that governing practices such as independent audits and independent boards are less likely to be associated with an incidence of asset diversion. Generally, given that the overall focus of control systems is largely on financial accountability, we may expect to see a negative association between financial accountability features and financial types of misconduct. Similarly, there is a possibility that good governance practices may be related to preventing misconduct on the organizational level, as opposed to the individual level.

Methodology

To explore the questions regarding the nature of nonprofit misconduct and the effectiveness of control systems, we utilize multiple data sources including CNAS, the Charity Navigator rating system, and IRS Form 990s. We discuss the details of data collection, measurement, and analytical techniques below.

Data

Identifying misconduct cases

We rely on CNAS to identify nonprofit misconduct cases. CNAS collects information about “alleged or confirmed illegal activity or ethical breaches” by nonprofit organizations that may concern donors (Charity Navigator, 2016). Depending on the severity of the misconduct and whether the misconduct is alleged as opposed to confirmed, CNAS places organizations under low, moderate, or high advisories. We drew our misconduct sample across different advisory levels for a diverse representation of cases. As of April 23, 2019, CNAS listed 546 organizations on its Advisory System. We include 215 of them (45 low level, 83 moderate level, and 87 high level) in our analysis. The cases were selected chronologically, starting from the newest to the oldest listed in each level of the Advisory System. The moderate and high advisory cases were chosen only from the period of March 2018 to April 2019. However, owing to the limited number of cases available in the low advisory list, all of the low advisory cases (n = 45) were selected. For this reason, 20% of the low advisory cases were from the period between September 2016 and March 2018. Along with the name of the organization, the Advisory System provides a link to source material (mostly newspaper articles) that allows us to determine the nature of the misconduct.

The majority of past empirical studies on nonprofit misconduct used either the ACFE reports on occupational fraud (Greenlee et al., 2007; Holtfreter, 2008) or LexisNexis All News (Archambeault et al., 2015; Fremont-Smith, 2004; Fremont-Smith & Kosaras, 2003; Gibelman & Gelman, 2002, 2004) to identify misconduct cases. We argue that relying on CNAS, which utilizes Google Alerts (based on Google News) and Meltwater (media monitoring tool), serves us better, given that the purpose of our study is to identify nonprofit misconduct as broadly as possible. While the ACFE survey provides detailed information regarding fraud, the scope of its inquiry is strictly limited to financial misconduct. Furthermore, the survey includes only a small number of nonprofits that are large and affluent enough to hire Certified Fraud Examiners, which indicates its lack of representativeness because the nonprofit sector is dominated by small organizations (Boris & Steuerle, 2006). Regarding LexisNexis All News, Weaver and Bimber (2008) compare the effectiveness of LexisNexis All News with Google News in capturing stories on selected topics and find that LexisNexis All News missed half or more of the news stories captured in Google News (see also Ridout et al., 2012). The range of search terms used by CNAS to identify relevant cases is another reason why it is a suitable source for our study. As Table 1 shows, the majority of past studies utilized a narrow set of search terms to identify fraud. However, CNAS employs a wider range of key words to broadly scan potential cases not only for nonprofit misconduct to capture financial fraud but also for other types of misconduct such as scam charities, abuse of clients, and legal sanctions.

Table 1.

Search Terms Used by Previous Studies on Nonprofit Misconduct.

Study	Search term	Data source/Search engine
Archambeault et al. (2015)	nonprofit, not-for-profit, charity, charitable AND fraud, theft, scandal, embezzle, embezzlement, or corruption	LexisNexis All News; 115 cases; 2008–2011.
Gibelman & Gelman (2001)	“charities and fraud” and a variety of variations: nongovernmental organizations and allegations; NGOs and fraud; charities and allegations; and third sector and dishonesty	Lexis Nexis All News and ProQuest; number of cases unknown; 1998–2000.
Gibelman & Gelman (2002)	“religious charities” and variations including faith-based groups, churches and social services.	Lexis-Nexis and ProQuest; number of cases unknown; 1995–2001.
Gibelman & Gelman (2004)	“charities and fraud” and variations including NGOs and allegations, NGOs and fraud, charities and scams, third sector and dishonesty	Lexis-Nexis and ProQuest: U.S. and international cases; number of cases unknown; 2001–2004.
Fremont-Smith & Kosaras (2003)	nonprofit, charity, scandal, investigation, embezzlement, theft, fiduciary duty, attorney general.	Lexis Nexis-English-language news sources; 152 cases; 1995–2002.
Fremont-Smith (2004)	charity, nonprofit, non-profit, not for profit, scandal, theft, embezzle, arrest, employee, pilfering, larceny	Lexis Nexis-English-language news sources; 32 cases; 2003.
Charity Navigator	charity OR nonprofit AND bankruptcy, dissolution, embezzlement, scandal, abuse, animal abuse, child abuse, attorney general, conspiracy, federal trade commission, fraud, investigation, lawsuit, sanctions, scam, theft; fake charity	Google Alerts (based on Google News) and Meltwater; Charity Navigator users (who identify accountability concerns and report to CN).
Studies utilizing sources other than search engines/newspaper databases
LeClair (2019)	Charity Navigator; 450 organizations, using a random number generator
Holtfreter (2008)	ACFE; 128 organizations (39 from 1997 to 1998 and 89 from 2001 to 2002)
Greenlee et al. (2007)	ACFE; 58 cases of nonprofit fraud from 2004
Krishnan et al. (2006)	National Center for Charitable Statistics (NCCS) and GuideStar; 114 organizations

Note. NGO = nongovernmental organization; CN = Charity Navigator; ACFE = Association of Certified Fraud Examiners; NCCS = National Center for Charitable Statistics.

Accountability features

To empirically assess the efficacy of control systems in preventing misconduct, we compare organizations from CNAS with 150 four-star organizations identified through random sampling of Charity Navigator’s highest rated charities (four star, as of July 24, 2019). While we do not know their entire organizational history, four-star organizations can be said to be scandal-free at the time of their rating evaluation. Organizations with known misconduct, whether alleged or confirmed, are flagged and placed under CNAS without ratings. Once we obtained the CNAS and four-star organization samples separately, we manually located the IRS Form 990 for both types of organizations to compare their accountability structures (see Table 2). Only 133 out of 215 CNAS organizations are included for the comparison analysis due to the limited Form 990 availability, while all 150 four-star organizations are included. For the majority of the organizations examined (n = 283), the most recent Form 990 available for analysis was the 2017 return (for the 2016 fiscal year).¹

Table 2.

Measurement Summaries for Comparison Analysis.

Variable	Measure	Source
Age	Age of the organization as of 2020	Line L in form 990
Size	Total number of employees	Part I, Line 5
Revenue	Total revenue in current year	I, 12
Independent Audit	“1” if the organization obtained separate, independently audited financial statements; “0” if not	IV, 12a
Financial Assistance to Insider	“0” if the organization provided financial assistance to inside stakeholders (officers, etc.) and their family members; “1” if not	IV, 27
Business Transaction With Officer	“0” if the organization had business transaction with current or former officer/director/employees, their family members, or entity related to them; “1” if not	IV, 28a
Business Transaction With Family		IV, 28b
Business Transaction With Entity		IV, 28c
Independent Board	“1” if independent voting members are equal to or greater than 5 and comprise a voting majority; “0” if not	I, 3,4
Officer Having Family or Business Relation	“0” if any officer, director, trustee, or key employee has family or business relationship with other officer, director, trustee, or key employee; “1” if not	VI, 2
Delegate Control	“0” if the organization delegated control to a management company regarding governance-related decisions; “1” if not	VI, 3
Board Meeting Minutes	“1” if the organization documented meetings of the governing body; committees; “0” if not	VI, 8a
Committee Minutes		VI, 8b
Provide Board 990	“1” if the organization provided a copy of 990 to the members of the governing body; “0” if not	VI, 11a
Conflict of Interest Policy	“1” if the organization has a conflict of interest policy; “0” if not	VI, 12a
Disclose Conflict of Interest	“1” if the organization required officers, directors, or key employees to disclose conflict of interest; “0” if not	VI, 12b
Monitor Compliance of Conflict of Interest	“1” if the organization monitored compliance of the conflict of interest policy; “0” if not	VI, 12c
Deficit	Deficit is calculated by subtracting total expenses from total revenues; “0” if deficit occurred; “1” if no deficit	I, 19
Whistleblower Protection	“1” if the organization has a whistleblower; record retention policy; “0” if not	VI, 13
Record Retention		VI, 14
Process for CEO Compensation	“1” if the organization has an adequate process for determining CEO compensation; key employees’ compensation; “0” if not	VI, 15a
Process for Staff Compensation		VI, 15b
Post 990 on Own Website	“1” if the organization posts 990 on own website; “0” if not	VI, 18
Presence of Misconduct	“1” if a scandal-free organization; “0” if an organization reported under CNAS	CNAS
Misconduct Type	“1” if misconduct took place at the individual level; “0” if at the organizational level
	“1” if misconduct is financial in nature; “0” if nonfinancial
	“1” if misconduct was targeted internally against the organization, its staff, or its clients; “0” if targeted externally to the public, government, or other external stakeholders

Source. IRS Form 990 for the 2016 return.

Note. CNAS = Charity Navigator Advisory System.

Measurement

Misconduct types

Based on the literature we reviewed, we adopt the individual-organizational, internal-external (see Archambeault et al., 2015, for similar classification), and financial-nonfinancial dimensions to examine misconduct types. The individual-organizational dimension separates an act committed by an isolated individual or a group of individuals from the leaders’ behavior or an organizational culture that widely permeates through governing and management practices of the organization. The distinction between financial and nonfinancial misconduct is largely self-explanatory, with the latter capturing a broad range of human aggressions and operational deficiencies, such as inadequate policies and procedures. We classify a case as internal when the misconduct is targeted internally toward the organization, its staff, or its clients. In comparison, externally oriented misconduct is aimed at the general public, government, or other external stakeholders.

Classifying the misconduct cases (n = 215) based on the three dimensions was first independently completed by two of the authors (Cohen’s kappa = .941, .961, and .972 for the individual-organizational, financial-nonfinancial, and internal-external dimensions at the final round of intercoder reliability, respectively). To resolve the disputed cases between the two original coders and then with the rest of the authors, multiple rounds of discussions among all the authors took place until reaching unanimous consensus on all cases.

Accountability features

To measure organizational characteristics relating to accountability, we focus on the following aspects that we extracted conceptually from the accountability literature: financial accountability mechanisms, good governance, and responsible management practices. Although the IRS Form 990 provides relevant information regarding some of these aspects, it should be noted that this data source has its limitations. Table 2 provides detailed descriptions of the accountability measures obtained from Form 990 and the coding procedures taken for our analysis.

Findings

Misconduct Types

Table 3 summarizes the results of the content analysis, identifying eight distinctive types of misconduct based on the three dimensions we conceptualize.

Table 3.

Content Analysis of Nonprofit Misconduct Types.

Individual (137)	Financial (107)	Internal (68)	Embezzlement (64)Property Theft (2)Accounting Inaccuracies (1)Conflict of Interest (1)
	Financial (107)	External (39)	Scam Charity (31)Fraudulent Fundraising (2)Fraudulent Billing (2)Bribery (1)Conflict of Interest (1)Fraudulent Services (1)Inappropriate Gift (1)
	Nonfinancial (30)	Internal (29)	Sexual Assault (13)Sexual Harassment (6)Failure to Follow Procedures (4)Animal Cruelty (3)Conflict of Interest (1)Exploitation of Clients (1)Physical / Verbal Abuse (1)
	Nonfinancial (30)	External(1)	Conflict of Interest (1)
Organizational (78)	Financial (61)	Internal (19)	Misuse of Funds (9)Dissolution / Bankruptcy (4)Accumulation of Debt (2)Conflict of Interest (2)Improper Paycheck Deduction (1)Lawsuit / Contract Failure (1)
		External (42)	Fraudulent Fundraising and Misuse of Solicited Funds (18)Failure to File 990 (10)Fraudulent Services (4)Accounting Inaccuracies (3)Conflict of Interest (2)Scam Charity (2)Lawsuit / Contract Failure (2)Bribery (1)
	Nonfinancial (17)	Internal (15)	Failure to Follow Procedures (4)Discrimination (3)Inadequate Procedures (3)Animal Cruelty (1)Conflict of Interest (1)Failure to Fulfill Mission (1)Physical / Verbal Abuse (1)Sexual Harassment (1)
	Nonfinancial (17)	External (2)	Failure to Follow Procedures (1)Zoning Violation (1)

Overall, our findings suggest that individuals committing financial misconduct against their organization (i.e., individual-financial-internal), such as embezzlement, is the most common type (32%) discovered. The second most frequent offense is financial misconduct committed by either individuals (18%) or organizations (20%) targeting mostly the general public, but also occasionally government and other external stakeholders. Attempting to defraud the public through scam charities is the most typical example of externally oriented individual-level financial misconduct, while similarly deceptive fundraising practices or misuse of solicited funds is frequently observed at the organizational level. For nonfinancial types, misconduct takes place mostly inside the organizations, whether they are committed at the individual (14%) or organizational (7%) level. Various forms of sexual misconduct targeting either clients or employees largely explain individual-level nonfinancial misconduct, while inadequacy of or noncompliance with rules and policies is the common problem at the organizational level.

Comparison Between Nonprofits With Known Misconduct and Four-Star Nonprofits

To examine whether and to what extent nonprofits with known misconduct deviate from those with four-star ratings in terms of accountability features, we first conduct a series of bivariate analyses (t-test).² Table 4 shows that the two groups are reasonably comparable in terms of size (measured by the number of employees and total revenues) and age. One significant demographic difference is found in deficit rates. The organizations with reported misconduct are much less likely to be financially sound (only 51% have no deficit, compared with 72% for nonprofits without reported misconduct or four-star rated; p < .001).

Table 4.

Comparing Accountability Features of Organizations With Known Misconduct and Four-Star Organizations.

Organizational and accountability features^a	Organizations with known misconduct (n = 135)^b	Four-star organizations (n = 150)	Difference
Organizational and accountability features^a	M (SD)	M (SD)	Difference
Organizational Features
Age	41 (27.142)	37 (22.743)	4
Size	150 (604.327)^c	68 (139.294)	82
Revenue	US$77,592,539^c (529,063,150)	US$18,941,197 (44,331,586)	58,651,342
Sound Financial Accountability Mechanism
Independent Audit	.34 (.475)	.87 (.334)	.53***
No Financial Assistance to Insider	.99 (.087)	.99 (.082)	0
No Business Transaction With Officer	.94 (.240)	.96 (.197)	.02
No Business Transaction With Family	.95 (.209)	.93 (.250)	.02
No Business Transaction With Entity	.93 (.253)	.93(.250)	0
Good Governance Policies
Independent Board	.78 (.418)	.99 (.115)	.21***
Director Not Having Family or Business Relation	.85 (.357)	.76 (.429)	.09*
No Delegation of Control	.95 (.223)	.99 (.082)	.04*
Board Meeting Minutes	.97 (.170)	1.00 (0)	.03*
Committee Meeting Minutes	.92 (.275)	.95 (.212)	.03
Provide Board 990	.84 (.367)	.99 (.082)	.15***
Conflict of Interest Policy	.80 (.403)	1.00 (0)	.2***
Disclose Conflict of Interest	.72 (.449)	1.00 (0)	.18***
Monitor Compliance of Conflict of Interest	.73 (.445)	1.00 (0)	.17***
Responsible Management Practices
No Deficit	.51 (.502)	.72 (.451)	.21***
Whistleblower Protection	.65 (.479)	.99 (.115)	.34***
Record Retention	.64 (.481)	.97 (.162)	.33***
Process for CEO Compensation	.66 (.477)	.99 (.115)	.33***
Process for Staff Compensation	.52 (.501)	.75 (.433)	.23***
Post 990 on Own Website	.13 (.341)	.69 (.463)	.56***

T-test results to show whether the problematic and scandal-free organizations differ in organizational and accountability characteristics: *p < .05. **p < .01. ***p < .001. ^bThe number of cases for each variable slightly differ (130–135) for the organizations with known misconduct due to various numbers of missing cases for certain variables. Similarly, the number of cases for the high-performing organizations range from 149 to 150 due to similar issues. ^cThe seemingly substantial mean differences in size (although statistically indifferent) are caused by large variances.

Organizations with known misconduct deviate significantly from organizations without on several accountability features. For example, while an independent board governs nearly all scandal-free charities (99%), an independent board governs a significantly lower percentage of nonprofits with known misconduct (78%) (p < .001). The difference between the two groups is starker when it comes to obtaining independently audited financial statements. Only 34% of the organizations with known misconduct do so, compared with 87% of the charities without known misconduct (p < .001). The organizations with known misconduct also fall significantly behind their counterparts in establishing accountability-related policies and procedures to prevent or at least mitigate fraud and other types of misconduct. Specifically, nonprofits with known misconduct are less likely to have conflict of interest policies (including requirements for directors and officers to disclose conflicts of interest and subject themselves to monitoring compliance), as well as whistleblower and record retention policies (p < .001).

Establishing due process for determining CEO compensation is also a notable area where there is a significant deviation between organizations with known misconduct and organizations without (66% and 99%, respectively; p < .001). However, even for scandal-free charities, ensuring transparency and public disclosure by making Form 990 annual reports readily available to the public on their website is not a widely held management practice. Nonetheless, they met this expectation at higher rates (69%) than organizations with reported misconduct (13%) (p < .001).

Determinants for the Likelihood of Misconduct

To estimate which accountability features are independently influential in determining the likelihood of misconduct, we employ a multivariate logistic regression.³ Our findings (Table 5) indicate that having an independent board, obtaining independently audited financial statements, having the governing board review Form 990, establishing due process for determining CEO compensation, and making Form 990 available on their website are all significant factors that uniquely contribute to increasing the odds that an organization is scandal-free. An organization with an independent board, for example, is 28 times more likely to be a scandal-free, four-star rated organization than an organization without an independent board. Similarly, the odds of being a scandal-free organization as opposed to an organization with known misconduct increases 30 times for organizations that provide Form 990s to their board for review, 41 times for organizations that establish due process for determining CEO compensations, and so on.

Table 5.

Logistic Regression for the Determinants of Scandal-Free Organizations.

Variable	Coefficient (robust SE)	Odds ratio	p value
Organizational Features
Age	−0.018 (0.012)	0.98	.136
Size	−0.003 (.006)	1.00	.623
Revenue	−0.001(0.001)	1.00	.277
Sound Financial Accountability
Mechanism Independent Audit	2.464 (0.517)***	11.75	.000
Financial Assistance to Insider	−1.649 (1.422)	0.19	.246
Business Transaction With Officer	2.155 (1.110)	8.62	.052
Business Transaction With Family	−0.671 (0.749)	0.511	.370
Business Transaction With Entity	0.213 (1.076)	1.24	.843
Good Governance
Independent Board	3.346 (1.135)**	28.39	.003
Director Having Family or Business Relation	−0.983 (0.709)	0.37	.165
Delegate Control	1.860 (1.038)	6.42	.073
Provide Board 990	3.413 (0.775)***	30.37	.000
Responsible Management Practices
Deficit	1.231 (0.484)*	3.42	.011
Whistleblower Protection	0.489 (1.310)	1.63	.709
Record Retention	0.489 (0.817)	1.63	.550
Process for CEO Compensation	3.718 (1.323)**	41.17	.005
Process for Staff Compensation	0.732 (0.558)	2.08	.189
Post 990 on Own Website	3.083 (0.576)***	21.82	.000
Constant	−14.484 (2.461)***	5.12e–07	.000
N of observations	272
Wald’s chi-square	84.14
Pseudo R²	.6368

Note. CEO = chief executive officer.

p < .05. **p < .01. ***p < .001.

One key organizational characteristic (deficit) that was a significant factor in t-tests is also a statistically significant variable in predicting the likelihood of misconduct. Table 5, for example, indicates that organizations without deficits are about 3 times more likely to be a scandal-free organization. Notably, whistleblower and record retention policies, which were significant factors in the bivariate t-tests, are not independently influential in predicting the likelihood of misconduct. A series of financial accountability–related practices (e.g., granting financial assistance to directors, officers, or key employees) rarely took place in either group, so are not influential factors in the multivariate model.

Determinants for Misconduct Types

Finally, we examine whether any accountability measures are systematically associated with particular types of misconduct. Table 6 reports three logistic regression models with the individual-organizational, financial-nonfinancial, and internal-external types of misconduct as dependent variables. The results suggest that only a few accountability features are significantly linked to certain types of misconduct. For example, an independent audit is almost 3 times less likely to be associated with organizational-level misconduct than individual-level misconduct. Monitoring conflict of interest policy compliance and record retention policy compliance are much less likely to be associated with internal misconduct than externally oriented misconduct. Interestingly, most accountability measures do not predict whether misconduct is financial as opposed to nonfinancial, except for having a formal process for evaluating staff compensation. The organizations with this process are more likely to be associated with financial misconduct than nonfinancial misconduct. Some of these results do not immediately or intuitively make sense and call for further investigations with larger samples in the future.

Table 6.

Logistic Regression for the Determinants of Misconduct Types.

Variable	Individual-organizational	Financial-nonfinancial	Internal-external
Variable	Odds ratio (robust SE)	Odds ratio (robust SE)	Odds ratio (robust SE)
Independent Board	3.18 (1.91)^a	0.38 (0.35)	3.11 (2.28)
Independent Audit	2.95 (1.54)*	0.43 (0.24)	3.53 (2.39)^a
Provide Board 990	3.05 (1.85)^a	0.88 (0.49)	1.54 (1.17)
Disclose Conflict	4.04 (4.15)	1.91 (1.27)	3.08 (3.06)
Monitor Conflict	0.15 (0.18)	0.28 (0.24)	0.04 (0.05)**
Whistleblower Protection	2.36 (2.81)	0.59 (0.58)	16.97(20.43)*
Record Retention	0.21 (0.24)	1.41 (1.56)	0.07 (0.08)*
Process for CEO Compensation	2.09 (1.47)	0.70 (0.50)	1.27 (1.07)
Process for Staff Compensation	0.64 (0.40)	3.51 (2.09)*	0.45 (0.36)
Post 990 on Own Website	0.30 (0.19)^a	0.51 (0.41)	0.37 (0.28)
Revenue	1.00 (0.001)	1.00 (0.00)	1.00 (0.002)
Age	1.02 (0.009)^a	1.01 (0.01)	1.02 (0.01)
Size	1.00 (.001)	1.00 (0.002)**	1.00 (0.003)
Constant	0.15 (0.11)**	20.31 (24.12)*	2.45 (2.23)
N of observations	122	122	122
Wald’s chi-square	28.52	25.53	27.63
Pseudo R²	.20	.25	.26

Marginally significant at p < .1.

p < .05. **p < .01. ***p < .001.

Discussion and Conclusion

Our findings contribute to the nonprofit misconduct literature in several ways. First, a close examination of publicized scandals (n = 215) through the lens of individual-organizational, financial-nonfinancial, and internal-external dimensions expands our understanding of the nature of nonprofit misconduct beyond the more limited focus of existing studies. By doing so, we learn that, just as is the case with financial misconduct, nonfinancial misconduct occurs widely across the individual and organizational dimension. In addition, our findings bring attention to understudied types of misbehaviors. Particularly, the frequency of sexual misconduct is notable in light of serious scandals from Oxfam and other international nongovernmental organizations (NGOs) that have shocked the international aid community (Phillips, 2020). Similarly, the considerable number of scam charities identified in our findings might indicate that this type of problem, which has scarcely attracted scholarly attention, is rising in the sector and thus calls for regulatory measures (Federal Trade Commission, 2018).

Second, scholars in the past solely focused on asset diversion when examining the effects of governing practices on nonprofit misconduct (Harris et al., 2017; Khadra & Delen, 2020), despite the concern that this piece of information is often severely underreported (Archambeault et al., 2015). Our study widens the scope of inquiry by exploring a much more broadly defined set of nonprofit misbehaviors. It is interesting to note that our results, by and large, support the findings from the more narrowly focused studies—namely, good governance policies and oversight matter in reducing fraud and other misconduct. In terms of advancing theory, these findings suggest that principal-agent theory still provides a useful conceptual framework, especially, in studying determinants of misconduct prevention, despite the recent criticism leveled against its embedded top-down, unitary view on governance (Coule, 2015).

Finally, Table 5 reveals several accountability measures that set apart the organizations with and without known misconduct. In particular, independent oversight by the board (such as evaluating CEO compensation) and transparency (publicly posting IRS Form 990) seem to play significant roles in separating these two groups. However, the results also show that certain popular accountability features, such as having a whistleblower policy or record retention policy, do not meaningfully predict whether the organization is likely to suffer from reported misconduct or not. Reformers as well as outside charity watchdog organizations might be interested in these high and low efficacies for the various accountability measures.

There are certain limitations that should be taken into consideration in interpreting and generalizing our findings. One limitation is using unmatched samples for comparison because not all CNAS organizations with misconduct would have been rated as four stars if not for their known misconduct. This lack of matching might have drawn greater contrasts in accountability features. Another limitation concerns time constraints. Compared with previous studies on nonprofit misconduct that examined misconduct cases over multiple years, our sample spans about a year in length (2018–2019). Owing to the broader scope of misconduct that we explore and the extensive list of search terms utilized by CNAS, however, the number of cases we identify and analyze (n = 215) is fairly comparable to past studies. Similarly, the time gap between accountability structures observed (mostly 2016 fiscal year) and the reported misconduct (mostly 2018–2019) could pose a potential concern. However, we argue that organizations’ structural arrangements are slow to change and the 2-year gap (in most cases) might not be sufficiently long enough to cause any substantial concerns. Furthermore, reasonable arguments can be made for the lagged effects of accountability features on manifested behavioral patterns (i.e., misconduct).

We conclude our study with suggestions for future research on nonprofit misconduct. First, we should further examine both the theoretical and empirical connection between misconduct behavior and control systems as we seek to better understand problems and their potential solutions. Our examination of three-dimensional aspects of misconduct and associated accountability mechanisms could be a start. However, future research must work with larger samples to be able to discern meaningful relationships. Second, future research must delve into cultural, as well as structural, explanations for misconduct because these two organizational dimensions often closely interact with each other, either promoting or impeding the effectiveness of management reform efforts (Hill & Lynn, 2015). In the past, scholars have turned their attention almost exclusively to structural reform to address misconduct, neglecting to explicitly recognize and assess the potential roles played by organizational culture. We hope future researchers are mindful of this interface and incorporate both dimensions.

Footnotes

Declaration of Conflicting Interests

The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author(s) received no financial support for the research, authorship, and/or publication of this article.

ORCID iDs

Meeyoung Lamothe

Ani Ter-Mkrtchyan

Notes

Author Biographies

Meeyoung Lamothe is an associate professor in the Department of Political Science at the University of Oklahoma. Her main research interests include nonprofit advocacy and accountability, local service delivery arrangements, and government contracting for social services.

Ani Ter-Mkrtchyan is an assistant professor in the Department of Government at New Mexico State University. Previously, she worked as a practitioner in the international nongovernmental organization sector. Her main research interests include public and nonprofit accountability, performance measurement, and governance.

Travis B. Ruddle is a PhD candidate in political science at the University of Oklahoma. His primary research interests are government and nonprofit accountability, sector differences, organizational reputation, and government contracting for public services.

Kayleigh Kuyon is currently a J.D. candidate at Berkeley Law. She previously attended the University of Oklahoma, where she majored in Public and Nonprofit Administration.

References

Archambeault

D. S.

Webber

Greenlee

(2015). Fraud and corruption in US nonprofit entities: A summary of press reports 2008-2011. Nonprofit and Voluntary Sector Quarterly, 44(6), 1194–1224.

Ashforth

B. E.

Gioia

D. A.

Robinson

S. L.

Trevino

L. K.

(2008). Re-viewing organizational corruption. Academy of Management Review, 33(3), 670–684.

Association of Certified Fraud Examiners. (2021). Report to the nations, 2020 global study on occupational fraud and abuse. https://acfepublic.s3-us-west-2.amazonaws.com/2020-Report-to-the-Nations.pdf

Baron

R. A.

(2004). Workplace aggression and violence: Insights from basic research. In Griffin

R. W.

O’Leary-Kelly

A. M.

(Eds.), The dark side of the organizational behavior (pp. 23–61). Jossey-Bass.

Beasley

M. S.

(1996). An empirical analysis of the relation between the board of director composition and financial statement fraud. Accounting Review, 71(4), 443–465.

Blodgett

M. S.

Melconian

(2012). Health-care nonprofits: Enhancing governance and public trust. Business and Society Review, 117(2), 197–219.

Boris

Steuerle

. (2006). Scope and dimensions of the nonprofit sector. In Powell

Steinberg

(Eds.), The nonprofit sector: A research handbook (pp. 66–88). Yale University Press.

Bromley

Orchard

C. D.

(2016). Managed morality: The rise of professional codes of conduct in the US nonprofit sector. Nonprofit and Voluntary Sector Quarterly, 45(2), 351–374.

Callen

J. L.

Klein

Tinkelman

(2010). The contextual impact of nonprofit board composition and structure on organizational performance: Agency and resource dependence perspectives. Voluntas: International Journal of Voluntary and Nonprofit Organizations, 21(1), 101–125.

10.

Carman

Fredericks

(2013). Nonprofits and accreditation: Exploring the implications for accountability. International Review of Public Administration, 18(3), 51–68.

11.

Charity Navigator. (2016). CN advisories. https://www.charitynavigator.org/index.cfm?bay=content.view&cpid=5593#advisories

12.

Christensen

D. M.

(2016). Corporate accountability reporting and high-profile misconduct. Accounting Review, 91(2), 377–399.

13.

Cornforth

(2004). The governance of cooperatives and mutual associations: A paradox perspective. Annals of Public and Cooperative Economics, 75(1), 11–32.

14.

Coule

T. M.

(2015). Nonprofit governance and accountability: Broadening the theoretical perspective. Nonprofit and Voluntary Sector Quarterly, 44(1), 75–97.

15.

De Graaf

. (2007). Causes of corruption: Towards a contextual theory of corruption. Public Administration Quarterly, 31(1), 39–86.

16.

Ebrahim

(2003). Making sense of accountability: Conceptual perspectives for northern and southern nonprofits. Nonprofit Management and Leadership, 14(2), 191–212.

17.

Ebrahim

(2010). The many faces of nonprofit accountability. In The Jossey-Bass handbook of nonprofit leadership and management (pp. 101–123). http://www.hbs.edu/faculty/Publication%20Files/10-069.pdf

18.

Federal Trade Commission. (2018). FTC and states combat fraudulent charities that falsely claim to help veterans and servicemembers. https://www.ftc.gov/news-events/press-releases/2018/07/ftc-states-combat-fraudulent-charities-falsely-claim-help

19.

Fremont-Smith

M. R.

(2004). Pillaging of charitable assets: Embezzlement and fraud. Exempt Organization Tax Review, 46(33), 333–346.

20.

Fremont-Smith

M. R.

Kosaras

(2003). Wrongdoing by officers and directors of charities: A survey of press reports 1995-2002 (Hauser Center for Nonprofit Organizations Working Paper, No.20). https://cpl.hks.harvard.edu/files/cpl/files/working_paper_20.pdf

21.

Fritz

(2014). Organizational misbehavior. In Lipinski

Crothers

L. M.

(Eds.), Bullying in the workplace: Causes, symptoms, and remedies (pp. 3–16). Routledge.

22.

Gibelman

Gelman

S. R

. (2001). Very public scandals: Nongovernmental organizations in trouble. Voluntas: International Journal of Voluntary and Nonprofit Organizations, 12(1), 49–66.

23.

Gibelman

Gelman

S. R.

(2002). Should we have faith in faith-based social services? Rhetoric versus realistic expectations. Nonprofit Management and Leadership, 13(1), 49–65.

24.

Gibelman

Gelman

S. R.

(2004). A loss of credibility: Patterns of wrongdoing among nongovernmental organizations. Voluntas: International Journal of Voluntary and Nonprofit Organizations, 15(4), 355–381.

25.

Grasse

N. J.

Neely

D. G.

(2020). The essential nature of internal controls. In Anheier

H. K.

Toepler

(Eds.), The Routledge companion to nonprofit management (pp. 234–248). Routledge.

26.

Greenlee

Fischer

Gordon

Keating

(2007). An investigation of fraud in nonprofit organizations: Occurrences and deterrents. Nonprofit and Voluntary Sector Quarterly, 36(4), 676–694.

27.

Greve

H. R.

Palmer

Pozner

J. E.

(2010). Organizations gone wild: The causes, processes, and consequences of organizational misconduct. Academy of Management Annals, 4(1), 53–107.

28.

Griffin

R. W.

O’Leary-Kelly

Pritchard

R. D.

(2004). The dark side of organizational behavior. Jossey-Bass.

29.

Gugerty

M. K.

(2009). Signaling virtue: Voluntary accountability programs among nonprofit organizations. Policy Sciences, 42(3), 243–273.

30.

Harris

Petrovits

Yetman

M. H.

(2017). Why bad things happen to good organizations: The link between governance and asset diversions in public charities. Journal of Business Ethics, 146(1), 149–166.

31.

Hill

Lynn

(2015). Public management: Thinking and acting in three dimensions. SAGE.

32.

Holtfreter

(2008). Determinants of fraud losses in nonprofit organizations. Nonprofit Management and Leadership, 19(1), 45–63.

33.

Huberts

De Graaf

(2014). Why it goes wrong: Causes of corruption. In Huberts

(Ed.), The integrity of governance: What it is, what we know, what is done and where to go (pp. 144–166). Palgrave Macmillan.

34.

Huberts

Lasthuizen

(2014). What goes wrong: Integrity violations. In Huberts

(Ed.), The integrity of governance: What it is, what we know, what is done and where to go (pp. 110–143). Palgrave Macmillan.

35.

Independent Sector. (2005). Panel on the nonprofit sector strengthening transparency, governance, accountability of charitable organizations. https://www.finance.senate.gov/imo/media/doc/datest040505.pdf

36.

Ito

K. L.

Slatten

L. A. D.

(2018). Nonprofit ethics and accountability: Synthesizing research on nonprofit regulation programs. Journal of Leadership, Accountability & Ethics, 15(4): 183–194.

37.

Jensen

M. C.

Meckling

W. H.

(1976). Theory of the firm: Managerial behaviour, agency costs and ownership structure. Journal of Financial Economics, 3(4), 305–360.

38.

Keating

E. K.

Frumkin

(2003). Reengineering nonprofit financial accountability: Toward a more reliable foundation for regulation. Public Administration Review, 63(1), 3–15.

39.

Khadra

H. A.

(2020). Nonprofit organization fraud reporting: Does governance matter? International Journal of Accounting & Information Management, 28, 409–428.

40.

Krishnan

Yetman

M. H.

Yetman

R. J.

(2006). Expense misreporting in nonprofit organizations. The Accounting Review, 81(2), 399–420.

41.

LeClair

M. S.

(2019). Malfeasance in the charitable sector: Determinants of “soft” corruption at nonprofit organizations. Public Integrity, 21(1), 54–68.

42.

McDonnell

Rutherford

A. C.

(2018). The determinants of charity misconduct. Nonprofit and Voluntary Sector Quarterly, 47, 107–125.

43.

Nezhina

T. G.

Brudney

J. L.

(2010). The Sarbanes—Oxley act: More bark than bite for nonprofits. Nonprofit and Voluntary Sector Quarterly, 39(2), 275–301.

44.

Ostrower

(2007). Nonprofit governance in the United States: Findings on performance and accountability from the first national representative study. The Urban Institute. http://www.urban.org/url.cfm?ID=411479

45.

Paetzold

R. L.

(2004). Sexual harassment as dysfunctional behavior in organizations. In Griffin

R. W.

O’Leary-Kelly

A. M.

(Eds.), The dark side of the organizational behavior (pp. 159–186). Jossey-Bass.

46.

Petrovits

Shakespeare

Shih

(2011). The causes and consequences of internal control problems in nonprofit organizations. The Accounting Review, 86(1), 325–357.

47.

Phillips

S. D

. (2020). A changing management context: The US, UK, Canada and Australia. In Anheier

Toepler

(Eds.), The Routledge companion to nonprofit management. Routledge.

48.

Pinto

Leana

C. R.

Pil

F. K.

(2008). Corrupt organizations or organizations of corrupt individuals? Two types of organization-level corruption. Academy of Management Review, 33(3), 685–709.

49.

Prakash

Gugerty

M. K.

(2010). Trust but verify? Voluntary regulation programs in the nonprofit sector. Regulation & Governance, 4(1), 22–47.

50.

Reiser

D. B.

(2004). Enron.org: Why Sarbanes–Oxley will not ensure comprehensive nonprofit accountability. UC Davis Law Review, 28(1), 205–280.

51.

Ridout

T. N.

Fowler

E. F.

Searles

(2012). Exploring the validity of electronic newspaper databases. International Journal of Social Research Methodology, 15(6), 451–466.

52.

Saxton

G. D.

Guo

(2011). Accountability online: Understanding the web-based accountability practices of nonprofit organizations. Nonprofit and Voluntary Sector Quarterly, 40(2), 270–295.

53.

Verbruggen

Christiaens

Milis

(2011). Can resource dependence and coercive isomorphism explain nonprofit organizations’ compliance with reporting standards? Nonprofit and Voluntary Sector Quarterly, 40(1), 5–32.

54.

Weaver

D. A.

Bimber

(2008). Finding news stories: A comparison of searches using LexisNexis and Google news. Journalism and Mass Communication Quarterly, 85(3), 515–530.

55.

Zietlow

Hankin

J. A.

Seidner

A. G.

(2007). Financial management for nonprofit organizations: Policies and Practices. John Wiley.