Great question, CindyS. I've seen some of these entities structured different ways, so it is all going to depend on how the entity is structured. If it is registered as a non-profit, the control prong will apply. If it is an (un-registered) unincorporated association, BO won't apply. If it is an extension of the government, then the government exemption would apply.
The bottom line is that you are going to need to know exactly how the entity is structured and then go from there.
_________________________
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com