Transcript Slide 1

2014 Combined Federal
Campaign (CFC)
Application Training
Presenters
• Barbara Barfield, CFC Director
[email protected]; (415) 571-4149
• Antoinette (Toni) Taylor, Norcal Charity
Coordinator
[email protected] Phone - TBA
www.norcalcfc.org
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
Combined Federal Campaign Orientation
• 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
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.
Norcal CFC
Organizational Chart
Office of Personnel Management
(Government Regulators & Oversight)
Local Federal Coordinating Committee
(Local Campaign Oversight)
Local Federal Agencies
Principal Combined
Fund Organization
(administration)
Federal Agency
Loaned Representatives
Federal Agency
Campaign Coordinators
Keyworkers
Donors
Charitable Agencies
CFC Structure
• 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.
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
Campaign Overview
• 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 Accountability
• 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.
Review Process
Sampling 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
Att. C (if appl.)
2013 Service
Description
Att. B
2014 CFC
Application
Certifications
IRS
Determination
Letter
Audited
Financial
Statements
Att. D
IRS Form 990
(same period
as audit)
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 #1
Local, 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
CFC Certification Statement #1
Local, Adjacent, or Statewide Presence
• Hours of Operation
• Location – County/State
• 2013 Human Health and Welfare Services
CFC Certification Statement #1
Local, Adjacent, or Statewide Presence
• WHO received the service, benefit, or assistance
• WHAT the service, benefit, or assistance is
• WHEN it was delivered
• WHERE it was delivered
CFC Certification Statement #1
Local, Adjacent, or Statewide Presence
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
CFC Certification Statement #1
Local, Adjacent, or Statewide Presence
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 #1
Local or Adjacent Presence
Examples of Qualifying Attachment A:
Georgia
Athens, 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 #1
Statewide 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 #1
Local 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.
CFC Certification Statement #1
Local, Adjacent, or Statewide Presence
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)
CFC Certification Statement #1
Local, Adjacent, or Statewide Presence
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 #2
Tax-Exempt Status
Not part of group
exemption
 Has own IRS letter
Part of Group
Exemption
 Name may not
be unique
 EIN listed in IRS
BMF
501(c)(3)
TaxExemption
Chapter/Affiliate
 Letter from CEO
 Name and EIN may be
same as the parent org.
CFC Certification Statement #2
Tax-Exempt Status
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.
CFC Certification Statement #2
Tax-Exempt Status
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 #3
Affiliation 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 taxexemption.
Name and EIN will be the same as national
Must provide certification letter from national
dated on or after Oct 1, 2013
CFC Certification #3
Affiliation 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 unique
Organizations 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 #5
Audited Financial Statements
Total Revenue
Per 990
Accrual
Accounting
(GAAP)
Audited
Annually
Submit Audit
>$250k

$100250k




<$100k
CFC Certification Statement #5
Audited 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 #6
Include 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 #6
990 vs. Pro Forma 990
IRS Form 990
Pro Forma 990
• Filed with IRS
• Match FY of Audit
• FY ended on or
after 6/30/12
• Officer’s Signature
• All sections
•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 #7
I 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 #8
Governing 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 #8
(cont.)
CFC Certification Statement #9
Sale/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.
CFC Certification Statement #10
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.
CFC Certification Statement #11
I certify the organization named in this application
effectively uses the funds contributed by Federal
personnel for its announced purposes.
CFC Certification Statement #12
Sanctions 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
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)5551234 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 services 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
Federation Attachment A
•
•
•
•
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.
Federation Attachment A
•
•
•
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
Federation Attachment A
•
•
•
•
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
Eligibility Appeals
• 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.
Questions
?