2014 combined federal campaign (cfc) application training

2014 Combined Federal Campaign (CFC)

Application Training

• Barbara Barfield, CFC Director [email protected]; (415) 571-4149

• Antoinette (Toni) Taylor, Norcal Charity [email protected] Phone - TBA

www.norcalcfc.org

Presenters

mailto:[email protected]

mailto:[email protected]

Application Timeline

March 21 – Deadline for 2014 Pikes Peak region application period

April 30 – Deadline for LFCC to notify local organizations of eligibility decisions in writing

June 4 – Deadline for decisions by LFCC on all local organization appeals

July 31 – OPM completion of local appeal reviews

• Federal Government’s employee charitable giving program

• Federal employees raise millions of dollars through CFC• One campaign, one time of year, one ask • Designation campaign – donors selects the charity(s)

they wish to give to; The campaign DOES NOT collect contributions to be distributed to all participating charities

• Contributions through payroll deductions, cash, check or credit card

Combined Federal Campaign Orientation

• The solicitation occurs in the Fall; Designations are distributed quarterly starting the following April.

• Charities must apply annually• Charities must meet eligibility requirements• Charity is verified by the IRS to be in their data base • Final authorization to list a charity and code

assignment by the Office of Personnel Management (OPM)

• The Combined Federal Campaign is the only authorized solicitation of employees in the Federal

workplace on behalf of charitable organizations.

Orientation

Norcal CFC Organizational Chart

Local Federal Agencies

Local Federal Coordinating Committee(Local Campaign Oversight)

Office of Personnel Management(Government Regulators & Oversight)

Principal Combined Fund Organization

(administration)Charitable Agencies

Federal Agency Loaned Representatives

Federal Agency Campaign Coordinators

Keyworkers

Donors

• All aspects of the CFC, including eligibility for participation, are strictly governed by Federal regulation. • The US Office of Personnel Management (OPM) has the overall responsibility for regulating the management of the CFC.

• OPM reviews and provides guidance and technical advice on regulations, and has the authority to conduct compliance audits on any CFC local campaign fiscal records. This applies to participating federations and independent charities.

CFC Structure

Campaign Overview

• The CFC is divided into federations and independent organizations.

• Federation - group of charitable human health and welfare organizations established for the purpose of supplying common fundraising, administrative, and management services to its members.

• Independent Organization - organization that applies to the CFC on its own behalf. Local independent organizations apply to the Local Federal Coordinating Committee.

• International, National or Local

• Federal employees who voluntarily choose to donate through the Combined Federal Campaign may give their money to a federation, to an organization under a federation, or to an independent organization.

• Private foundations and most units of government are not eligible to participate in the CFC. OPM will verify each applicant’s I.R.S. Code § 501(c)(3) tax-exempt status with the IRS.

Campaign Overview

• Charities that want to receive funds generated by the campaign are required to submit to a substantial review of their financial and governance practices prior to acceptance. This eligibility review is in line with community norms, but it has helped set standards for participation in giving initiatives that transcend the community.

Campaign Accountability

Review ProcessSampling of Federation Members

• Federations MUST submit full applications of all members not approved for participation in 2013, regardless of if they were approved as an independent charity in 2013.

• 20% Sampling of federation membership

PCFO Completeness Review • Available for all charities upon request

prior to pre-screen deadline & provision of indemnification statement

• PCFO will contact applicant regarding administrative oversights

Key Application Documents

Att. A 2013 Service

Description

Att. BIRS

Determination Letter

Att. C (if appl.) Audited

Financial Statements

Att. DIRS Form 990

(same period as audit)

2014 CFC Application

Certifications

CFC Application Cover Page

• Organization address must be a physical mailing address. No P.O. Boxes

• Contact info may include P.O. Boxes

• Use of Electronic Funds Transfer (EFT) by PCFO – submit banking information

CFC Certification Statement #1Local, Adjacent, or Statewide Presence

• Local – Office in local campaign area open 15 hours per week with a dedicated phone line

• Adjacent – Local presence (above) within an adjacent campaign area

• Statewide – Provided services to 30% of target population or in 30% of state’s geography


• Hours of Operation

• Location – County/State

• 2013 Human Health and Welfare Services


• WHO received the service, benefit, or assistance

• WHAT the service, benefit, or assistance is

• WHEN it was delivered

• WHERE it was delivered


Factors OPM/LFCC will consider:

• Nature and extent of the service, benefit, assistance, or program activity

• Frequency, continuity, and duration of services• Impact on, or benefit to, beneficiaries• Number of beneficiaries


Applicants should avoid…

• Generalized statements• Listing “offered” services• Listing location of members, affiliates, or board

members• Listing the residences of visitors to a facility• Listing services provided by the service recipient

or other entity• Fundraising activities as a service

CFC Certification Statement #1Local or Adjacent Presence

Examples of Qualifying Attachment A:

GeorgiaAthens, November 1-3, 2013 ABC Charity held its

annual meeting. ABC Charity staff made presentations on new research, provided advocacy training to attendees, and facilitated a discussion between policymakers and medical researchers. 120 healthcare industry professionals attended the three-day conference

CFC Certification Statement #1Statewide Presence

Example of Qualifying Attachment A:

Georgia – Calendar Year 2013 (scholarships awarded bimonthly)

• Charity International awarded scholarships to the following Georgia high school students pursuing a degree in computer technology to attend the college or university of their choice:A. Smith, Baker County ($1,800) J. Doe, Warren County ($5,000)B. Callahan, Chattahoochie County ($1,200)D. Johnson, Cobb County ($800)C. Jones, Gwinnett County ($900)

CFC Certification Statement #1Local or Adjacent Presence

Examples of Non-Qualifying Attachment A:

Americus, GA Charity Central holds an annual health fair to promote healthier lifestyles in our community.

Atlanta, GA November 2013 ABC Charity’s Georgia chapter held a workshop for local families interested in learning more about ABC’s research programs. Presentations were made by ABC Charity Georgia’s Executive Director and Vice President of Research.


Example of Non-qualifying Statewide Attachment A:

Atlanta 2013 ABC Charity coordinates free ground transportation for cancer patients by encouraging rental car companies to donate vehicles to the patients. The counties and number of individuals served in calendar year 2013were:

Cobb County (18 beneficiaries)Jefferson County (1 beneficiary)Johnson County (2 beneficiaries)Lamar Country (1 beneficiary)


Example of Non-qualifying Attachment A:

Atlanta The Philanthropy Museum, based in San Diego, recorded 300 visitors from 27 Georgia counties since 2009.

Macon August 10, 2013 XYZ Institute conducted a fundraiser at the Macon Independence Day celebration that raised $22,000. 250 Georgian residents, representing 45 counties contributed.

CFC Certification Statement #2Tax-Exempt Status

501(c)(3)Tax-

Exemption

Not part of group exemption

Has own IRS letter

Part of Group ExemptionName may not be uniqueEIN listed in IRS BMF

Chapter/AffiliateLetter from CEO Name and EIN may be

same as the parent org.


Family support and youth activities (also known as Morale, Welfare and Recreation organizations or “MWRs”) must meet criteria outlined at 5 CFR 950.204(d).

Commanding officer’s letter must specify that organization is a “Non-Appropriated Fund Instrumentality that supports the installation MWR/FSYA program.”

Day care centers located on Federal property may not participate under these guidelines.


Any charity that has not been verified by OPM as having 501(c)(3) tax-exempt status cannot be approved by the LFCC. MAY NOT approve a charity contingent on OPM’s verification at a later date.

CFC Certification #3Affiliation Status (cont.)

• I certify the organization named in this application is a bona-fide chapter or affiliate which operates under a national organization’s single corporate tax-exemption.

Name and EIN will be the same as nationalMust provide certification letter from national dated on or after Oct 1, 2013

CFC Certification #3Affiliation Status

• Choose one of three options:I certify the organization named in this

application is not part of a group exemption;Name and EIN on IRS Determination letter will be unique

I certify the organization named in this application is part of a group exemption; Name may or may not be uniqueOrganizations using this certification should have an EIN that is different from the EIN on the national group exemption letter

Must have certification letter from national organization dated on or after Oct 1, 2013.

CFC Certification Statement #4

I certify the organization named in the application is a human health and welfare organization providing services, benefits, or assistance to, or conducting activities affecting human health and welfare.

2013 human health/welfare service must be in Attachment A.

CFC Certification Statement #5Audited Financial Statements

Total Revenue Per 990

>$250k $100-250k

<$100k

Accrual Accounting (GAAP)

Audited Annually

Submit Audit

CFC Certification Statement #5Audited Financial Statements

• Audit must cover the fiscal period ending on or after June 30, 2012 (18 months prior to January 2014)

• Audit must state organization accounts for its funds in accordance with generally accepted accounting principles (GAAP) and it was audited in accordance with generally accepted auditing standards (GAAS)“except for” statements may cause denial

• Audit report must be signed, dated and be on the audit firm’s letterhead

CFC Certification Statement #6Include as ATTACHMENT D a copy of the most recently completed IRS Form 990, including signature in the box marked “signature of Officer. The preparer’s signature alone is not sufficient

•Must cover same time period as audited financial statements

•Copies of IRS Forms 990 filed electronically are acceptable if IRS Form 8879-EO or 8453-EO is also provided. (See CFC Memo 2007-11)

•If organization is not required to file the form 990, it must still provide a pro forma Form 990

Any organization’s IRS Form 990 that does not include a complete list of the officers, Board of Directors, trustees and key employees, and their compensation, if any, is incomplete and will result in a denial. The number of voting members on page 1 must be equal to or less than the number of individuals identified as a director or trustee in Part VII (see CFC Memo 2010-5).

If page 1 lists more voting members than are listed in Part VII, the organization must either provide an explanation of the difference or submit an amended IRS Form 990

CFC Certification Statement #6990 vs. Pro Forma 990

IRS Form 990• Filed with IRS• Match FY of Audit• FY ended on or

after 6/30/12• Officer’s Signature• All sections

Pro Forma 990•Download 990 from IRS website•FY ended on or after 6/30/12•Officer’s Signature•Parts I, II, VIIA, VII, VIII, IX and XII only

CFC Certification Statement #7I certify the administrative and fundraising rate for the

organization named in this application is __ __ .__%

Regulatory Formula

Regulatory Formula:In Part IX (Statement of Functional Expenses, ADD

Line 25, Column C to the amount in Line 25, Column D. Divide the sum by Part VIII (Statement of Revenue, Line 12, Column A (Total Revenue).

The regulatory formula must be used. No other calculations/methods are allowed

CFC Certification Statement #8Governing Body

“I certify that an active and responsible governing body, whose members have no material conflict of interest and a majority of whom serves without compensation, directs the organization named in this application.”

• The number of voting members on page 1 must be equal to or less than the number of individuals identified as a director or trustee in Part VII (see CFC Memo 2010-5).

• If page 1 lists more voting members than are listed in Part VII, the organization must either provide an explanation of the difference or submit an amended IRS Form 990

CFC Certification Statement #8 (cont.)

• An organization’s IRS Form 990 that does not include a complete list of the officers, Board of Directors, trustees and key employees, and their compensation, if any, is incomplete and will result in a denial.

• Uncompensated members must have a -0- in the compensation column or the box above the table in Part VII must be checked.

CFC Certification Statement #8 (cont.)

CFC Certification Statement #9Sale/Lease of Contributor Information

I certify the organization named in this application prohibits the sale or lease of CFC contributor lists.

– Donor names and addresses may be used to acknowledge the contribution. CFC regulations prohibit the sale or lease of this information.


I certify the organization named in this application conducts publicity and promotional activities based upon its actual program and operations, these activities are truthful and non-deceptive, include all material facts, and make no exaggerated or misleading claims.


I certify the organization named in this application effectively uses the funds contributed by Federal personnel for its announced purposes.

CFC Certification Statement #12Sanctions Compliance

Sanctions compliance certification is required

Wording in CFC application provided by OPM must be used

The list of countries, entities, or individuals referenced in the certification can be found at www.treas.gov/ofac.

Guidance in CFC Memorandum 2005-13

http://www.treas.gov/ofac

Certifying Official’s Signature

• Certifying official does not have to be Executive Director, but must be individual in a position to verify the validity of the application and all attachments.

• Applicants must check the box next to each statement to demonstrate agreement to comply with the statement

Attachment E 25 Word Statement

• Include as ATTACHMENT E a 25-word statement for listing in the campaign brochure. (See Instructions Item 13 for additional required information and the taxonomy codes.)

EXAMPLE: 0000 Name of Organization (legal name of organization, if applicable) (202)555-1234 www.opm.gov/cfc EIN#123456789 The description will contain no more than 25 words. It should be worded so the donor understands the program ser vices provided. 4.2% B,V,O

Federation Requirements

• Listing of Eligible Member Organizations (Legal name, DBA, EIN, AFR, and Local Presence Category)

• Submission of Audit Regardless of Size Audit must include verification organization is honoring

designations

• Board Terms and Meeting Dates/Locations

• Annual Report Must contain a full description of the federation’s activities and supporting

services during the year covered by the report Identify its directors and chief administrative personnel Describe Dues and/or Fees Arrangements The annual report must cover the fiscal year ending not more than 18

months prior to January of the campaign year to which the federation is applying or the preceding calendar year.

Federation Attachment A

• OPM initiated an annual charity verification process following a Government Accounting Office investigation of charities.

• As of December 2013, OPM has pre-verified all charities in their data base since 2006 for the 2014 application season.

• Confirm OPM was able to verify your member

charities


• Use the provided OPM L3 Report. • Sort the list for your Federation. • Do not make any changes to the charity name,

legal name or EIN number used to verify charities in the IRS data base. EVEN IF IT IS MISSPELLED, is in UPPER CASE or is listed differently than the Federation lists it

• It is in the report as it is recognized in the IRS master file.


• Update contact information, website, AFR, 25 word statement, and taxonomy information as needed in bold BLUE font to stand out on the report for returning member charities.

• For new charities, insert the required information for all fields at the bottom of the list in bold GREEN font. Use the same formatting as listed charities for EIN number and telephone number.

• If a charity is listed that is no longer a member of the Federation Highlight it in BLACK:

Charity ABC 840411209 Charity ABC


• Rename the file to your Federation’s name • Save the renamed file to your hard drive• Attached it to an e-mail with the Federation Name

and Attachment A in the Subject line to: Antoinette (Toni) Taylor, Norcal CFC Charity Coordinator at: [email protected]

• Copy file to a diskette and submit it with your Federation Application

Common Application Mistakes

• Application not signed.• Incorrect certification for local presence, adjacent campaign

presence or statewide presence.• Agency does not provide adequate documentation of Human

Health and Welfare as defined by the regulations. (Attachment A)

• Missing or incomplete board information included on IRS for 990.

• IRS Form 990 not signed by an Officer.• There were more voting members listed on part 1 line 3 of IRS

Form 990 than were listed in Part VII, and the organization did not provide an explanation of the difference or submit an amended IRS form 990.

Appeals Process

• LFCC must provide information on how to appeal at the local and national levels

• Appeals limited to the facts justifying the reversal of the original decision

• No oral arguments. All appeals are in writing only.

• Appeals may not be used to supplement applications with missing or outdated documents

• All organizations that apply for local eligibility and are found ineligible have only one opportunity to appeal to the LFCC.

• If found ineligible on appeal by the LFCC, the organization will have only one opportunity to appeal to the Director of OPM.

• The Director's decision is final for administrative purposes.

• Appellants should insure that their appeals are complete and responsive to the actual reasons for the LFCC denial decision.

Eligibility Appeals

?Questions

2014 combined federal campaign (cfc) application training

Documents

local federal employees

cfcone campaign

campaign overviewcharities

federal workplace

federal regulation

cfc director

cfc structurecampaign

local organization appealsjuly