As an existing 501(c)3 operating as a medical clinic in Florida, can we open a soup kitchen as a dba under the same status?

We organized as a nonprofit free medical clinic and received our 501(c)3 in 2007. We would now like to open a soup kitchen as a separate entity. Is that permitted? Must the soup kitchen have its own tax ID?

Generally, when you form a not-for-profit entity, you have to state the specific public purpose of the entity--for example, "a clinic to provide medical services at no charge to people living below the poverty line." You cannot mix your purposes . . . and operating a soup kitchen does not usually fall under the kinds of activities run by a free medical clinic.

Unless the Florida secretary of state has already approved of including "soup kitchen" among the variety of services that the center will offer at no charge, you must create a separate entity.

You cannot use a DBA for the soup kitchen activities under these circumstances. However, every state’s formation laws can differ. Make sure to consult with an attorney who specializes in not-for-profit organizations before you take your next step.