Transcript Slide 1
CFC Regulation Implementation
$400 $350 $300 $250 $200 $150 $100 $50 $0
CFC Pledge History
Campaign Year
Nominal Value Real Value
CFC Participation History
Participation Rate
1965 - 2012
90,0% 80,0% 70,0% 60,0% 50,0% 40,0% 30,0% 20,0% 10,0% 0,0% 1965 1967 1969 1971 1973 1975 1977 1979 1981 1983 1985 1987 1989 1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 2011 All Employees Solicited Employees
Ideas to Strengthen the CFC
CFC-50 Commission
• 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 Stakeholder Relationships in 2015
OPM LFCC National/International Charity Applications Donors Materials & Events PCFO Pledge Forms Local Charity Applications CFC Contributions Charities
CFC Stakeholder Relationships in 2016
OPM CCA OC Donors Outreach Activities LFCC Applications & Fees CFC Contributions Charity Fairs Charities
2015 CFC Boundaries
(147 Zones)
2016 CFC Boundaries
(40 Zones)
LFCC Responsibilities
2015
Select PCFO Review Local Charity Applications Name LFCC Chair/Co-Chair and Maintain Minutes Adjudicate Local Charity Appeals Review Local Marketing Materials Determine Recognition Items/Awards Review Audit of PCFO N/A
2016
Select OC Review Local Charity Applications (online and pre screened by CCA) Name LFCC Chair/Co-Chair and Maintain Minutes N/A Review Local Marketing Materials Determine Recognition Items/Awards N/A LFCC Training (online)
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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 Responsibilities
2015 (PCFO)
Apply to LFCC Assist in Charity Application Receipts/Completeness Reviews Enter Data in Charity Registry Prepare/Distribute Local Marketing Materials Arrange CFC Events and Fundraisers Train Loaned Executives, Agency Coordinators and Keyworkers Processes Pledge Forms, Cash, Checks and Credit Cards Disburses CFC Funds to Charities Engage CPA for AUPs
2016 (OC)
Apply to LFCC N/A N/A Prepare/Distribute Local Marketing Materials Arrange CFC Events Train Loaned Executives, Agency Coordinators and Keyworkers N/A N/A 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
Paper Pledge Forms & Charity Lists Cash Checks Fundraising Events Charity Fairs Loaned Execs Keyworkers
2014 & 2015
%
2016 - 2020
*
2021+
* Agency Coordinators * E-Checks Only
Current CFC Disbursement Process
New CFC Disbursement Process
CCA Responsibilities
2015 (PCFO)
Receive Local Charity Applications/Conduct Completeness Reviews Assign Charity Codes Maintain CFC Website N/A N/A Processes Pledge Forms, Cash, Checks and Credit Cards Reconciles Payroll Receipts Disburses Designations to Charities Prepares Campaign Results
2016 (CCA)
Receive Local Charity Applications/Conduct Completeness Reviews Assign Charity Codes Maintain CFC Website Compiles and Posts UG List Collects Fees Processes Pledge Forms, Checks and Credit Cards Reconciles Payroll Receipts Disburses Funds to Charities 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 Responsibilities
2015
N/A N/A Review Charity Applications Adjudicate Charity Application Appeals Conduct LFCC and PCFO Training N/A Publish Annual Calendar of Events Provide Campaign Oversight
2016
Select CCA(s) Determine OC Budgets Review Charity Applications Adjudicate Charity Application Appeals Develop Online Training Modules Determine Fee Structure Publish Annual Calendar of Events 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 Charities
2015
Send Application to OPM or Local Campaign Varying Deadlines Paper Applications Denial Letters Sent Via Certified Mail All Expenses are Deducted from Designations 25-Word Statements FSYPs Not Eligible
2016
Send Application to CCA One Deadline Online Applications Denial Letters Sent Via Email Application, Listing and Distribution Fees 256 Character Statements 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
$250,000 or More $100,000 - $249,999 Less Than $100,000
GAAS Audit or Review Account IAW GAAP Certification that Controls are in Place
Charity Application Cycle
Full 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
Final Methodology to be determined. A sample process:
Code
10000 – 39999 40000 – 69999 70000 – 99999
Full Application
2016 2017 2018
Verification Application
2017 & 2018 2016 & 2018 2016 & 2017
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
Fall 2015
Timeline
(Subject to Change)
Application Fee Structure Announced December 2015 December 2015 January 2016 January 2016 February – May 2016 February 2016 May - June 2016 June 2016 September 2016 Online Charity Application System Opens LFCCs Advertise OC Positions Charity Application Deadline LFCC Training Module Available OPM & LFCC Application Review Period LFCC Selections of OCs OPM Appeal Review Period Release of 2016 Approved Charity Lists Online E-Giving System Opens on CFC Website
2016 by Functional Area
Campaign 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 Area
Charity 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 Area
Marketing/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 Area
Pledge 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 regulations
Campaign Period Date Documents Can be Destroyed
2011 2012 2013 2014 2015 April 1, 2016 April 1, 2017 April 1, 2018 April 1, 2019 April 1, 2020
CFC Budget/Expenses
CFC 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
LFCC Review of 2015 Expenses 1 st Distribution of 2015 Funds IPA Performs 2015 Audit Guide Procedures 2 nd Distribution of 2015 Funds LFCC submits 2014 CFC Audit Documentation to OPM 3 rd Distribution of 2015 Funds LFCC Final Review of 2015 Expenses Final Distribution of 2015 Funds LFCC submits 2015 CFC Audit Documentation to OPM
Date
January – March 2016 April 1, 2016 Summer 2016 July 2016 September 2016 October 2016 January – March 2017 March 2017 September 2017
Transition
Any Additional Questions Related the Transition to the New CFC?