CFC Regulation Implementation
CFC Pledge History
19641966
19681970
19721974
19761978
19801982
19841986
19881990
19921994
19961998
20002002
20042006
20082010
2012$0
$50,000,000
$100,000,000
$150,000,000
$200,000,000
$250,000,000
$300,000,000
$350,000,000
$400,000,000
Nominal ValueReal Value
Campaign Year
Tota
l Ple
dges
(mill
ions
)
CFC Participation History
19651967
19691971
19731975
19771979
19811983
19851987
19891991
19931995
19971999
20012003
20052007
20092011
0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
Participation Rate1965 - 2012
All Employees Solicited Employees
Ideas to Strengthen the CFC
• Established by charter September 1, 2011 by Director John Berry
• Purpose was to advise the Director on strengthening the integrity, the operation and the effectiveness of the Combined Federal Campaign (CFC) to ensure its continued growth and success
• Co-Chaired by two former members of Congress: Beverly Byron (D-MD) and Tom Davis (R-VA)
• 26 Additional Members including:• 4 LFCC Representatives• 4 PCFO Representatives• 4 Federal Employees• 4 National and Local Charity Representatives• 4 National and Local Federation Representatives• 2 Federal Employee Association Representatives• 4 Accountability Organization Representatives
CFC-50 Commission
• Held 4 Public Meetings (videos available at www.opm.gov/cfc)• September 13, 2011 – Washington, DC• December 6, 2011 – Washington, DC• March 2, 2012 – San Antonio, TX• May 29, 2012 – Washington, DC
• Report Issued July 20, 2012• 24 Recommendations
• Draft Regulations Issued for 60 Day Public Comment Period – April 8, 2013• Incorporated Commission Recommendations Requiring Regulatory
Changes• 1,382 Comments Received
• Final Rule Issued April 17, 2014• Revisions Made Based on Public Comments• Effective January 1, 2016
CFC-50 Commission
CFC Stakeholder Relationships in 2015
OPM
LFCC
PCFO
Donors Charities
National/International Charity Applications
Local Charity Applications
CFC Contributions
Materials & Events
Pledge Forms
CFC Stakeholder Relationships in 2016
OPM
CCA
LFCCOC
Donors Charities
CFC Contributions
Applications & Fees
Outreach Activities
Charity Fairs
2015 CFC Boundaries(147 Zones)
2016 CFC Boundaries(40 Zones)
LFCC Responsibilities2015 2016
Select PCFO Select OC
Review Local Charity Applications
Review Local Charity Applications (online and pre-screened by CCA)
Name LFCC Chair/Co-Chair and Maintain Minutes
Name LFCC Chair/Co-Chair and Maintain Minutes
Adjudicate Local Charity Appeals
N/A
Review Local Marketing Materials
Review Local Marketing Materials
Determine Recognition Items/Awards
Determine Recognition Items/Awards
Review Audit of PCFO N/A
N/A LFCC Training (online)
LFCC Responsibility Changes in 2016
• Minimum of 3 LFCC Members Per Zone
• LFCC Chair and Co-Chair Terms Limited to 3 Consecutive Years
• No Longer Responsible for Audit and Corrective Actions of PCFO
• Members Must Complete Annual Online Training
• Reduced Application Review Responsibilities
LFCC FAQ’s• Which LFCC is responsible for the audit of
the 2014 and 2015 campaign periods?
• How do LFCCs negotiate changes to the boundaries?
• What is the process by which the consolidated LFCCs develop bylaws, select chairs, etc.?
• Can the LFCC develop its own rules?
• Can LFCCs still use Loaned Executives?
Loaned Executives
• Established in 1971 via Executive Order 11584
“Loaned Executive program permits temporary assignment of Federal employees to work directly with the voluntary organizations in conducting the combined campaign within the Federal service.”
LFCC Responsibility Changes in 2016
Any Additional Questions Related to the LFCCs?
OC Responsibilities2015 (PCFO) 2016 (OC)
Apply to LFCC Apply to LFCC
Assist in Charity Application Receipts/Completeness Reviews
N/A
Enter Data in Charity Registry N/A
Prepare/Distribute Local Marketing Materials
Prepare/Distribute Local Marketing Materials
Arrange CFC Events and Fundraisers
Arrange CFC Events
Train Loaned Executives, Agency Coordinators and Keyworkers
Train Loaned Executives, Agency Coordinators and Keyworkers
Processes Pledge Forms, Cash, Checks and Credit Cards
N/A
Disburses CFC Funds to Charities N/A
Engage CPA for AUPs N/A
OC Responsibility in 2016
• Does Not Process Pledges or Disburse Funds*
• Does not Complete AUP
• Does Not Arrange Fundraising Events
* No Longer has to be a 501(c)(3)
OC FAQ’s
• Can an LFCC hire more than on OC?
• Is the LFCC required to hire an OC?
• What happens if the OC spends more than the OPM budget cap?
• Will OPM consider the variances in the cost of doing business in different zones?
OC Responsibility in 2016
Any Additional Questions Related to Outreach Coordinators?
CFC Outreach Now and Future
%
2014 & 2015 2016 - 2020 2021+
Paper Pledge Forms & Charity Lists
Cash Checks * *Fundraising Events
Charity Fairs Loaned Execs Keyworkers
Agency Coordinators
* E-Checks Only
Current CFC Disbursement Process
New CFC Disbursement Process
CCA Responsibilities2015 (PCFO) 2016 (CCA)
Receive Local Charity Applications/Conduct Completeness Reviews
Receive Local Charity Applications/Conduct Completeness Reviews
Assign Charity Codes Assign Charity Codes
Maintain CFC Website Maintain CFC Website
N/A Compiles and Posts UG List
N/A Collects Fees
Processes Pledge Forms, Cash, Checks and Credit Cards
Processes Pledge Forms, Checks and Credit Cards
Reconciles Payroll Receipts Reconciles Payroll Receipts
Disburses Designations to Charities
Disburses Funds to Charities
Prepares Campaign Results Prepares Campaign Results
CCA Responsibility in 2016
• Processes Pledges from All Employees Served by a Shared Service Center
• Collects Fees
• Develops and Maintains Online Charity Application System
• Automates Completeness Reviews
CCA FAQ’s
• Who hires the CCA?
• Will there be a CCA for each zone?
• How will the CCA reimburse OCs?
CCA Responsibility in 2016
Any Additional Questions Related to Central
Campaign Administrators?
OPM Responsibilities2015 2016
N/A Select CCA(s)
N/A Determine OC Budgets
Review Charity Applications Review Charity Applications
Adjudicate Charity Application Appeals
Adjudicate Charity Application Appeals
Conduct LFCC and PCFO Training Develop Online Training Modules
N/A Determine Fee Structure
Publish Annual Calendar of Events Publish Annual Calendar of Events
Provide Campaign Oversight Provide Campaign Oversight
OPM Responsibility Changes in 2016
• Contracts with One or More 501(c)(3) entities to serve as CCA
• Determine Annual Fee Structure
• Develop Online Training
OPM Responsibility in 2016
Any Additional Questions Related to OPM?
Changes for Participating Charities2015 2016
Send Application to OPM or Local Campaign
Send Application to CCA
Varying Deadlines One Deadline
Paper Applications Online Applications
Denial Letters Sent Via Certified Mail
Denial Letters Sent Via Email
All Expenses are Deducted from Designations
Application, Listing and Distribution Fees
25-Word Statements 256 Character Statements
FSYPs Not Eligible FSYPs are Eligible
New Charity Application Process• National Application Deadline
• Electronic Submissions Only
• Fees are Due at Time of Submission
• Online LFCC Review
• No LFCC-Level Appeals
• 3-Year Application Cycle
New Charity Application Process
New Audit Thresholds
Total Revenue (Per IRS Form 990)
GAAS Audit
GAAS Audit or Review
Account IAW GAAP
Certification that Controls are in Place
$250,000 or More $100,000 - $249,999 Less Than $100,000
Charity Application CycleFull Application• Required Once in a 3 Year Cycle for
Returning Charities• Required of New Charities• Required of Charity That Did Not Participate
in the Prior Campaign Period
Verification Application• Required Twice in a 3 Year Cycle• Consists of Certifications and IRS Form 990
(or pro forma version)
Charity Application Cycle
Code Full Application Verification Application
10000 – 39999 2016 2017 & 2018
40000 – 69999 2017 2016 & 2018
70000 – 99999 2018 2016 & 2017
Final Methodology to be determined.
A sample process:
Charity Application FAQ’s
• Has OPM determined the fee model? When will it be announced?
• Will paper application be permitted?
• Who will do the completeness reviews?
Charity Application Changes in 2016
Any Additional Questions Related to Charity Applications?
Key Dates in New Campaign Timeline
(Subject to Change)Fall 2015 Application Fee Structure Announced
December 2015 Online Charity Application System Opens
December 2015 LFCCs Advertise OC Positions
January 2016 Charity Application Deadline
January 2016 LFCC Training Module Available
February – May 2016
OPM & LFCC Application Review Period
February 2016 LFCC Selections of OCs
May - June 2016 OPM Appeal Review Period
June 2016 Release of 2016 Approved Charity Lists
September 2016 Online E-Giving System Opens on CFC Website
2016 by Functional AreaCampaign Oversight
• OPM sets campaign policies• OPM Sets Fees and OC Budget Limits• LFCC for Each Zone• LFCC Set its Own By-Laws• LFCC Names Chair and Co-Chair (term limits)• LFCC Maintains Meeting Minutes• LFCC Selects OC• LFCC Members Complete Annual Online Training• LFCC Members Review Charity Applications• LFCC Recruits Loaned Executives (optional)
2016 by Functional AreaCharity Eligibility
• OPM Prepares Video Training• CCA Operates Call-Center• CCA Administers Online Application Process• CCA Collects Fees• CCA Conducts Automated Completeness Review• OPM Distributes Application Review Assignments to
LFCCs• LFCCs Review Applications Online• CCA Assigns Codes to Approved Charities• OPM Reviews All Appeals• CCA Issues Final Approved Lists
2016 by Functional AreaMarketing/Outreach
• CCA Maintains Single CFC Website and Social Media• OPM Approves National Theme/Artwork• LFCCs Hire OC• OC Develops and Disseminates Local Materials• LFCC Selects Local Incentive Items and Awards• OC Distributes Local Incentive Items and Awards• OPM Engages National Leadership• LFCC Engages Local Leadership• LFCC and OC Trains Agency Coordinators, Keyworkers
and Loaned Executives
2016 by Functional AreaPledge Processing
• CCA Develops and Maintains E-Pledge System• OCs Print and Distribute Paper Pledge Forms and
Charity Lists• Donor Mails Paper Pledge Form to CCA• Donor Sends Payroll Copy to Payroll Office• CCA Process Paper Pledge Forms, E-Checks and Credit
Cards• CCA Issues Pledge and Donor Reports to Charities• CCA Receives Funds from Payroll Offices and
Distributes to Designated Charities• CCA Reconciles Payroll Receipts• CCA Reimburses OCs for All LFCC-Approved Expenses
Transition
• Physical Assets– Provide complete inventory of physical
assets purchased with CFC funds to LFCC for review and verification
– Determine which will be needed by current PCFO to complete responsibilities for 2014 and 2015 campaigns
– Determine which can be used by the LFCC for the new region and arrange for transfer
Transition
• Physical Assets (cont.)– Determine which of the remaining assets
have been fully depreciated and may be disposed of
– Remaining assets should be sold and funds distributed as undesignated funds in the 2015 campaign
– Assets being used by PCFO should be sold upon completion of duties and funds transferred to CCA for expenses
Transition
• Pledge, Receipt and Distribution Records– All records must be transferred to OPM in
Excel format – Complete pledge data (donor name,
Federal agency, amount pledged, organizations pledged to, contact information, release information, etc.)
– Complete, detailed receipt and disbursement information
Transition
PCFO retention requirements• Must still retain records in accordance
with regulationsCampaign Period Date Documents Can be Destroyed
2011 April 1, 2016
2012 April 1, 2017
2013 April 1, 2018
2014 April 1, 2019
2015 April 1, 2020
CFC Budget/ExpensesCFC budgets must reflect the expenses incurred to administer that activities related to that period.
Examples of items that must be included in the 2015 budget are:– Agreed Upon Procedures (to be incurred in 2017)– Staffing, postage, etc. for distribution of 2015 funds to
designated charities (2016-2018)
If needed, LFCCs can approve revised 2015 budgets to include these items. PCFOs will not be reimbursed by the 2016 CCA for expenses related to the 2015 CFC.
2015 CFC Expense Timeline
Activity Date
LFCC Review of 2015 Expenses January – March 2016
1st Distribution of 2015 Funds April 1, 2016
IPA Performs 2015 Audit Guide Procedures Summer 2016
2nd Distribution of 2015 Funds July 2016
LFCC submits 2014 CFC Audit Documentation to OPM
September 2016
3rd Distribution of 2015 Funds October 2016
LFCC Final Review of 2015 Expenses January – March 2017
Final Distribution of 2015 Funds March 2017
LFCC submits 2015 CFC Audit Documentation to OPM
September 2017
Transition
Any Additional Questions Related the Transition to
the New CFC?
