# The Valuation Games: Seven Big Charities and What a Donated Good Is Worth

How a charity values a donated can of food or box of medicine decides how big it looks and how efficient it seems. Read from the filings: Feeding America at $1.97 a pound, a $3.7 billion drug foundation, and the fights in between.

Author: J.A. Watte
Published: July 4, 2026
Source: https://jwatte.com/blog/in-kind-charities-ledger/

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The [Marine Toys for Tots Foundation](/blog/marine-toys-for-tots-ledger/) taught this series a lesson worth repeating: a charity that moves donated goods can report a huge budget and a spotless efficiency ratio, because the donated goods count as both revenue coming in and program spending going out, valued at whatever price the charity assigns them. That single accounting choice, what a donated thing is worth, decides how large a charity looks and how efficient it seems. Seven big relief charities filed returns this week, and they value donated goods four different ways, from scrupulously conservative to eyebrow-raising. Read together, they are a tour of the most consequential number in charity accounting. Everything below is from the Form 990s and the public record.

## The giant, and the price of a pound

Feeding America is the largest charity in the United States by revenue, and it is [worth its own post](/blog/feeding-america-ledger/), but it sets the frame here. Its roughly $5 billion of annual support is about 90 percent donated food, and the whole edifice rests on one figure: it values that food at a national average of $1.97 per pound, set by an annual study of wholesale prices ([Feeding America financial statements](https://www.feedingamerica.org/sites/default/files/2024-12/Feeding%20America_24%20FS_Final.pdf)). Multiply a transparent per-pound price across billions of pounds and you get a multi-billion-dollar charity with a 98 percent efficiency rating from Forbes, though watchdogs who strip the donated food back out, like CharityWatch, report a lower 81 percent ([CharityWatch](https://www.charitywatch.org/charities/feeding-america)). Same charity, two efficiency numbers, and the only difference is whether you count the food. That is the valuation game in one line.

## The four ways to value a donated good

Three more charities show how much the answer can vary, and how much is at stake when a regulator disagrees.

Direct Relief, the humanitarian medical charity founded in 1948, is the conservative end. It distributes donated medicine, more than 90 percent of its roughly $2.4 billion in support, and it deliberately values those drugs at wholesale acquisition cost rather than the higher average wholesale price, a choice that understates its apparent size and earns it a reputation for rigor ([Direct Relief finances](https://www.directrelief.org/about/finance/cash-and-in-kind-contributions/)). It runs a 99.4 percent program ratio, takes no government money, and covers its overhead from investment income on a board-restricted fund so donated dollars flow straight to programs ([CharityWatch](https://www.directrelief.org/2025/11/charity-navigator-rates-direct-relief-100-for-2025/)). It is the virtuous counterexample, and it holds $1.25 billion in net assets, invested in the [same markets](/blog/the-working-ledgers/) as everyone else, precisely so the portfolio pays the overhead.

Food for the Poor is the cautionary tale. The Florida relief charity, founded in 1982, valued its donated goods at high United States prices even though the goods were shipped overseas, and built its fundraising around a claim that more than 95 percent of donations went to programs. California's attorney general called that deceptive and issued a cease-and-desist in 2019, and the fight that followed is the most important valuation case in the sector. In 2019 California passed a law, AB 1181, requiring donated goods restricted to foreign distribution to be valued at recipient-country prices, not American ones. As those rules tightened, Food for the Poor's reported revenue collapsed from roughly $942 million in 2018 to about $412 million in 2024 ([The NonProfit Times](https://thenonprofittimes.com/news/layoffs-buy-outs-at-food-for-the-poor/)). Notably, the charity fought the cease-and-desist and won, a California court vacating the order in 2021 on First Amendment grounds and an appellate court affirming in 2022 ([Food for the Poor](https://foodforthepoor.org/wp-content/uploads/ca-decision-update.pdf)). It had earlier settled with Michigan for $300,000 over the same claim. Two thirds of its revenue was donated goods, and when the law changed how those goods were priced, two thirds of its apparent size evaporated. The charity did not shrink. The valuation did.

And the Genentech Patient Foundation is the extreme case. It is a private operating foundation that gives free Genentech medicine to patients who cannot afford it, and it reported $3.7 billion in revenue on just $424 million in assets, because roughly $3.6 billion of that "revenue" is its parent company's own drugs, donated and booked at list price ([ProPublica](https://projects.propublica.org/nonprofits/organizations/460500266)). A pharmaceutical company donates its product to its own foundation, which distributes it free and records it at the high sticker price the company set, which makes the foundation look like one of the largest charities in America. The patients who receive the medicine are helped, genuinely. But the $3.7 billion is a number built almost entirely out of list prices, and it shows how far the valuation of a donated good can carry an organization's apparent scale.

## The cash charities, and the donated-media trick

Not every big charity runs on goods. Wounded Warrior Project, founded in 2003 for post-9/11 veterans, is overwhelmingly cash-funded, about 79 percent, and holds a $594 million investment portfolio and board-designated reserves ([Wounded Warrior Project financials](https://www.woundedwarriorproject.org/media/lcxaoj1q/2024-wounded-warrior-project-consolidated-financial-statements.pdf)). But it is famous for a different version of the same game. In 2016, CBS News and The New York Times reported lavish spending on conferences and travel, the board fired the top two executives, and the ensuing fight turned on the program ratio: the charity claimed about 80 percent to programs, while CharityWatch, stripping out roughly $80 million of donated media and joint costs the charity counted as program, put it near 54 percent ([CharityWatch](https://blog.charitywatch.org/making-sense-of-wwp39s-program-spending-which-ratio-should-you-believe-2/)). The charity has since rebuilt, restored a four-star Charity Navigator rating, and installed new leadership. But the lesson is identical to the food charities': counting donated media as program spending inflates the efficiency number, and the watchdogs who strip it out get a different, lower figure.

The International Fellowship of Christians and Jews, founded in 1983 by Rabbi Yechiel Eckstein and now led by his daughter Yael, runs on cash raised through direct mail from evangelical Christian donors to support Jewish causes and Israel, a $318 million operation whose economics are dominated by high fundraising costs rather than in-kind valuation ([Paddock Post analysis](https://paddockpost.com/2025/01/23/where-does-100-to-the-international-fellowship-of-christians-and-jews-go-2023/)). And Catholic Charities of the Archdiocese of Chicago is the outlier that runs on government: founded in 1917, it draws roughly 72 percent of its revenue from government grants and contracts, and in 2024 it deliberately ended 75 of those contracts and cut about 300 jobs because the contracts no longer covered their costs, then ended its refugee resettlement in 2025 as [federal refugee funding froze](/blog/the-standing-institutions/) ([National Catholic Reporter](https://www.ncronline.org/news/catholic-charities-chicago-strategic-plan-ends-75-government-contracts)). A government-funded charity is exposed to the government the same way a [refugee resettlement agency](/blog/the-standing-institutions/) is, and Catholic Charities is quietly walking away from the dependency.

## The number that decides everything

The lesson under all seven is that a charity's size and its efficiency, the two numbers donors look at first, are both largely determined by a choice most donors never see: what a donated good is worth, and what counts as program. Value donated drugs at list price and you are a $3.7 billion charity; value them at wholesale and you are honest and smaller. Count donated media as program and your efficiency is 80 percent; strip it out and it is 54. This is not usually fraud. It is accounting, and the rules genuinely allow a wide range. But it means the headline numbers on a charity's tax return are softer than they look, and the interesting question is never how big or how efficient a charity says it is. It is how it got to that number. The cash the charities do hold in reserve, meanwhile, sits in the same markets as every institution in this series, which is the one number that does not depend on a valuation choice at all.

## Related reading

- [The Biggest Charity in America Runs on Donated Food](/blog/feeding-america-ledger/): Feeding America in full, and the $1.97 that holds it up.
- [Half a Billion Dollars, Almost All of It Toys](/blog/marine-toys-for-tots-ledger/): the Marine Toys for Tots Foundation, the in-kind charity that started this thread.
- [The Standing Institutions](/blog/the-standing-institutions/): the refugee agency and the federal-funding cliff that also hit Catholic Charities.
- [The Working Ledgers](/blog/the-working-ledgers/): the market underneath every reserve these charities hold.

## Fact-check notes and sources

- **All financial figures** are from each charity's most recent IRS Form 990 or audited statements via [ProPublica's Nonprofit Explorer](https://projects.propublica.org/nonprofits/): [Feeding America](https://projects.propublica.org/nonprofits/organizations/363673599) (EIN 36-3673599), [Wounded Warrior Project](https://projects.propublica.org/nonprofits/organizations/202370934) (EIN 20-2370934), [Food for the Poor](https://projects.propublica.org/nonprofits/organizations/592174510) (EIN 59-2174510, revenue $412M), [Direct Relief](https://projects.propublica.org/nonprofits/organizations/951831116) (EIN 95-1831116, revenue $2.4B, net assets $1.25B), [Catholic Charities of the Archdiocese of Chicago](https://projects.propublica.org/nonprofits/organizations/362170821) (EIN 36-2170821), [the International Fellowship of Christians and Jews](https://projects.propublica.org/nonprofits/organizations/363256096) (EIN 36-3256096, revenue $318M), and [the Genentech Patient Foundation](https://projects.propublica.org/nonprofits/organizations/460500266) (EIN 46-0500266, revenue $3.7B).
- **Feeding America's roughly 90 percent donated food valued at $1.97 per pound, and the CharityWatch 81 percent versus Forbes 98 percent efficiency figures**: [Feeding America's financial statements](https://www.feedingamerica.org/sites/default/files/2024-12/Feeding%20America_24%20FS_Final.pdf) and [CharityWatch](https://www.charitywatch.org/charities/feeding-america).
- **Direct Relief's conservative wholesale-acquisition-cost valuation and 99.4 percent program ratio**: [Direct Relief](https://www.directrelief.org/about/finance/cash-and-in-kind-contributions/).
- **Food for the Poor's revenue falling from about $942 million (2018) to $412 million (2024) as California's AB 1181 required recipient-country valuation, the 2019 cease-and-desist it later defeated on First Amendment grounds (2021, affirmed 2022), and the $300,000 Michigan settlement**: [The NonProfit Times](https://thenonprofittimes.com/news/layoffs-buy-outs-at-food-for-the-poor/) and [Food for the Poor's own account of the California decision](https://foodforthepoor.org/wp-content/uploads/ca-decision-update.pdf). No federal FTC action against the charity was found.
- **The Genentech Patient Foundation's roughly $3.6 billion of donated Genentech medicine booked at list price on $424 million of assets**: [ProPublica](https://projects.propublica.org/nonprofits/organizations/460500266) and [Cause IQ](https://www.causeiq.com/organizations/genentech-access-to-care-foundation,460500266/).
- **Wounded Warrior Project's 2016 spending scandal, the firing of its top two executives, and the program-ratio dispute (about 80 percent claimed versus roughly 54 percent per CharityWatch)**: [CharityWatch](https://blog.charitywatch.org/making-sense-of-wwp39s-program-spending-which-ratio-should-you-believe-2/) and its [consolidated financial statements](https://www.woundedwarriorproject.org/media/lcxaoj1q/2024-wounded-warrior-project-consolidated-financial-statements.pdf).
- **Catholic Charities of Chicago's roughly 72 percent government funding and its 2024 decision to end 75 contracts and about 300 jobs**: [National Catholic Reporter](https://www.ncronline.org/news/catholic-charities-chicago-strategic-plan-ends-75-government-contracts). **The International Fellowship of Christians and Jews' direct-mail model and leadership succession**: [Paddock Post](https://paddockpost.com/2025/01/23/where-does-100-to-the-international-fellowship-of-christians-and-jews-go-2023/) and [Wikipedia, "Yael Eckstein"](https://en.wikipedia.org/wiki/Yael_Eckstein), attributed.

*This post is informational, not financial or charitable-giving advice. All figures are reproduced from public filings and the public record. Organizations and individuals are discussed from the public record as nominative fair use, with no affiliation implied and nothing endorsed by any of them. Characterizations of accounting choices describe public filings and reporting, not allegations of wrongdoing.*


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