Transcript OPM CFC Workshop Chicago, Illinois

Welcome to
2015 CFC Charity Guide
Application Training for Local
Independent Charities
Introductions
Kim Kessler – Director, PCFO
Kevin Readey - Relationship Manager, PCFO
Nora Lyons – Campaign Associate, PCFO
PCFO – Principle Combined Fund Organization
PCFO Responsibilities
Campaign Management
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Honor employee designations
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Help to ensure no employee is coerced
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Train Loaned Executives, Coordinators & Keyworkers
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Ensure no employee is questioned as to his or her
designation
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Prepare campaign materials (with LFCC approval)
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Fiscal Management & Audit Responsibilities
Structure
OPM
CABINET
Sets Policy & Procedures
Leadership of LFCC
(Local Federal Campaign Committee)
LFCC
Conducts Local Campaign
PCFO
Area
Federal
Agencies
Loaned
Executive
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Manages Local Campaign
(Principal Combined Fund Organization)
Local, National
and
International
Charities
What is the CFC?
• CFC is the world’s largest and most successful annual
workplace fundraising campaign.
• There are 151 CFC’s throughout the country and internationally
that raise millions of dollars each year.
• To date federal employees have collected over $7 billion dollars
for local, national, and international charitable organizations.
• Pledges made by Federal civilian, postal and military donors
during the campaign season support eligible non–profit
organizations that provide health and human service benefits
throughout the world.
• The Central Ohio and WV CFC raised over $1.2 million dollars
during the 2014 campaign.
33 County Giving Area
Adams, Athens, Brown, Coshocton, Delaware, Fairfield, Franklin, Gallia,
Guernsey, Highland, Hocking, Jackson, Lawrence, Licking, Logan, Madison,
Marion, Meigs, Morgan, Morrow, Muskingum, Perry, Pickaway, Pike, Ross,
Scioto, Union, Vinton, and Washington counties in Ohio.
Cabell, Wayne and Wood counties in West Virginia.
Campaign Overview
- 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 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/Unaffiliated Organization - An organization that applies to
the CFC on its own behalf. Local unaffiliated organizations apply to
the Local Federal Coordinating Committee (LFCC).
*International, National or Local
Campaign Overview
Each organization that is deemed eligible to participate in the CFC is
entitled to only one listing in the CFC brochure, regardless of the number
of federations to which that organization belongs, with the exception that a
national organization and its local affiliate may both be listed if the
requirements of 5 CFR § 950.401(i) are met. (EXAMPLE Boy Scouts)
If it comes to the attention of the Local Federal Coordinating Committee
(LFCC) that an organization has applied more than once, the LFCC will
contact the organization directly to request written confirmation of the one
application to be considered.
In the absence of a satisfactory response, all of the applications may be
denied.
Review Process – All Applicants
Completeness Review & LFCC Review
• Applications must be physically received at 360 S. Third
Street, Columbus, OH 43215 by or postmarked by 5pm,
March 2, 2015 to qualify for consideration – no late
applications will be accepted
• PCFO conducts “Pre-Screening” and reviews for
administrative oversights; contacts Charity for reply (March 2
– March 23)
• LFCC Application Committee – will meet for several days as
needed between March 23 and March 27 to review all apps
• LFCC notifications (Approved/Denied) sent by April 30
Review Process – All Applicants
Completeness Review & LFCC Review – cont’d
• Replies from Charities to denial letters due by EOB day,
Thursday, May 7
• LFCC Application Committee – Final Appeals Meeting (all
denial replies are reviewed) held on May 14; Final
notifications sent to Charities no later than June 4
• OPM Ruling on Appeals– July 31, 2015
What The Application
Process is About
Slowly Review Exact Needs
Compiling & Labeling Documents
Taking your Time
Double Check Every Item
Contact our office for help
Application Timeline
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February 2 to March 2 - open application period
February 4 – Local Independent training
February 6 – Huntington, WV Ind. training
March 2, 5pm – absolute closing – app must be
postmarked or received by this time
March 23 to March 27 – App Reviews by LFCC
April 24 – Denial Letter send via certified mail
April 30 (likely earlier) – Approval Letter sent
May 7 – Final day to submit REPLY to denial letter
May 14 – Final Appeals meeting by LFCC
June 4 – Final day PCFO to mail findings
Getting Started
• Obtain hard copy of CFC Charity Guide
Application from Training Session
• Download from Central Ohio & WVA website:
www.cowvcfc.org
• Look for “Local Independent Charities”
Attachments Required
Here’s a ‘Heads Up’ on what you need to
include….
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Attachment A – Who, What, When, Where
Attachment B – IRS Determination Letter
Attachment C – Independent Audit (may/may not)
Attachment D – IRS Form 990 (full or Pro Forma)
Attachment E – 25 Words & Taxonomy codes
Application – Page 8
• OPM Form 1647-C (fancy for “2015 Application Instructions for Local
Independent Organizations and Members of Federations”)
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Pages 1-7 are instructions/guidelines
Pages 8-12 makeup the actual application
Organization legal name and EIN
Include 5 Digit Code (if previously participated)
Organization Address: MUST be a physical mailing address,
NO PO BOX ADDRESSES CAN BE USED HERE!
Contact info – Who is responsible for the application?
Contact can be different than the certifying official
Website address
Electronic Funds Transfer (EFT) – NOT APPLICABLE – UWCO
does not send electronic transfers – please leave blank
Box 1 – Page 9
CHECK THE BOX!!!
This THE ONLY change to the application for 2015 from
2014. Due to the implementation of Universal Giving,
all approved charities are considered “local” so long as
all criteria are met
The great news is that charities only need to apply to
ONE CFC, because of Universal Giving
So, you must be able to demonstrate that your charity
has a substantial ‘local’ presence – meaning…
Apply to 1 CFC – NICE!!
Local presence is defined as:
• A staffed facility, office or portion of a residence dedicated exclusively to that organization and is
located within the COWV CFC campaign area
• Available to members of the public seeking its services or benefits
• The facility must be open at least 15 hours a week
• Have a telephone dedicated exclusively to the organization
• May be staffed by volunteers; Substantial local presence cannot be met on the basis of services
provided solely through an “800” telephone number, the internet, the U.S. Postal Service or a
combination thereof
All approved ‘Local’ COWV charities will be listed among all charities available via OPM
website, the COWVCFC.com website and online platforms. Only approved local charities
within the Central Ohio West Virginia campaign will be listed in the printed paper Charity
Guide
• Once you’ve checked the box,
• List office address – if different from previous
page
• Include standard hours of operation
• Include dedicated phone number
• Include County and State office is located
Attachment A
“ATTACHMENT A” provides support to your
local presence/declaration.
ASKS YOU TO DESCRIBE:
• WHO received the service, benefit, assistance, or program
activity in 2014
• WHAT the service, benefit, assistance, or program activity
• WHEN it was delivered in 2014
• WHERE it was delivered in 2014
Attachment A
Factors OPM/LFCC will consider from Attachment A
– Nature and extent of the service, benefit,
assistance, or program activity
– Frequency, continuity, and duration
– Impact on, or benefit to, beneficiaries
– Number of beneficiaries
Attachment A
Applicants should avoid
– Generalized statements
– Listing “offered” services
– Listing location of members, affiliates, or board
members
– Listing the residencies of visitors to a facility
– Listing services with no detail (who, what , qty, etc)
– Repetitive text
– Fundraising activities as a service
Attachment A
Example of a “Qualifying” Attachment A
Ohio
Columbus 1-3, 2014 ABC Charity conducted a national
conference on cancer research and treatment in New
Orleans. 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
Attachment A
Example of a “Non-Qualifying” Attachment A:
Columbus, OH Charity Central holds an annual health fair to
promote healthier lifestyles in our community.
Or
Columbus, OH November 2014 ABC Charity’s Ohio chapter held
a workshop for local families interested in learning more about
ABC’s research programs. Presentations were made by ABC
Charity Ohio’s Executive Director and Vice President of
Research.
Attachment A
Example of a “Qualifying” Attachment A
Columbus – Calendar Year 2014 (scholarships awarded bimonthly)
Charity awarded scholarships to the following Columbus high
school students pursuing a degree in computer technology to
attend the college or university of their choice:
 A. Smith, Grandview Heights ($1,800)
 J. Doe, St. Charles Preparatory ($5,000)
 B. Callahan, Whitehall City ($1,200)
 D. Johnson, Pickerington South ($800)
 C. Woods, Brookhaven ($900)
Attachment A
Web-Based Service Requirements
– Records indicating geographic distribution of users
– Describe scope of services received
– Document 2 of the following:
• Evidence that users registered for the service
• Summary reports documenting customer feedback
• Evidence that users paid a fee
Box 2 – Page 9
CHECK THE BOX!!!
If you are here, you must be a 501(c)(3) organization
Include a copy of the most recent IRS determination letter as ATTACHMENT B
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Must be 501(c)(3) tax-exempt organization
Units of government are not eligible
OPM will verify applicant’s current 501(c)(3) status with the IRS
If name on IRS letter, IRS Form 990, or audit is different from
applicant, official documentation from IRS or state government
must be included stating relationship
• FEDERATIONS – Must submit all member charity 501c3 letters
Attachment B
501(c)(3) Status:
CFC regulations at 5 CFR §950.202 require an applicant charity to
certify it is recognized by the Internal Revenue Service as
tax-exempt under 26 U.S.C. 501(c)(3) and to which contributions
are tax-deductible pursuant to 26 U.S.C. 170(c)(2)
Any charity that has not been verified as having 501(c)(3) taxexempt status cannot be approved by the LFCC
You MUST have it or don’t waste postage
Attachment B
Bona-Fide Chapters and Affiliates of a National Organization
• Include certification from CEO or equivalent (of parent) verifying
that applicant is in good standing with the national organization
and is covered by the national organization’s 501(c)(3)
determination.
• If organization name on IRS letter or IRS Form 990 is different,
official documentation from IRS or state government must be
included
Attachment B Errors
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Typographical Errors in Employer Identification Number (EIN) provided
Proper Legal Name not provided (insufficient “Doing Business As”
(DBA) documentation)
Governmental entity without 501(c)(3) recognition
Charity moved (or address changed) and IRS was not notified
Merger with another organization – EIN changed
IRS Form 990 was marked “Final Return”
NEED A NEW IRS FORM?:
– Contact the IRS Tax-Exempt Division at: (877) 829-5500.
– Request an “Affirmation Letter” and submit the letter to the CFC
with application.
Box 3 – Page 9
Choose one of three options:
OPTION ONE
I certify that the organization named in this application is not part of a group
exemption;
- Name and EIN on IRS Determination letter will be the same
OPTION TWO
I certify that the organization named in this application is part of a group
exemption;
- Name may or may not be the same
- Organizations using this certification WILL have an EIN that is different
from the EIN on the national group exemption letter
- Must have group number, usually a four digit number. This number
comes from the national organization and is mentioned in 501c3 letter.
- Must have certification letter from national organization verifying group
exemption dated on or after 10/1/13.
Box 3
OPTION THREE
I certify that the organization named in this application is a
bona-fide chapter or affiliate that operates under a national
organization’s single corporate tax-exemption.
- Name and EIN will be the same as national
- Must provide certification letter from national office dated
on or after 10/1/14 stating your affiliation
Box 4 – Page 9
Human Health & Welfare Statement
Check the Box!!!
I certify that 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.
2014 human health/welfare service(s) must be explained in
Attachment A
Box 5 – Page 10
Audit & Reporting
Choose one of three options:
1. Revenues over $250,000:
– accounts for its funds on the accrual basis in accordance with
generally accepted accounting principles (GAAP); and,
– has an audit annually by an independent certified public
accountant in accordance with generally accepted auditing
standards (GAAS) for FYE June 30, 2013 or more recent
- Include as Attachment C (most current auditors
report & financial statements)
- CHAPTERS - If using national organization information,
you must provide a certification letter from CEO of affiliated
national organization for FYE June 30, 2013 or more
recent
OR
Box 5 – Page 10
2. Revenues between $100,000 and $250,000:
- Accounts for its funds on an accrual basis in accordance
with generally accepted accounting principles (GAAP);
and,
- Has an audit annually by an independent certified public
accountant in accordance with generally accepted
auditing standards (GAAS)
- Provide charity tax form IRS 990 or modified Pro-Forma
990 for period ending no earlier than June 30, 2013
Do not need to provide actual audit, but must be available if
requested by LFCC/OPM
OR
Box 5 – Page 10
3. I certify the organization named in this application reports total
revenue of less than $100,000 on its IRS Form 990 (or pro
forma IRS Form 990) covering a period ending no earlier than
June 30, 2013 and has controls in place to ensure funds are
properly accounted for and it can provide accurate timely
financial information to interested parties.
Box 5
IMPORTANT INFO RE: FINANCIALS….
Audit must cover the fiscal period ending not more than 18 months
prior to the January of the campaign year to which the organization is
applying (January 2015 – 18 months = June 30, 2013)
Audit must state that the 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. Copies are accepted
Box 6 – Page 10
OPTION ONE
TWO OPTIONS
I certify that the organization named in this application prepares
and submits to the IRS a complete copy of the organization’s IRS
Form 990
 Include a copy of the complete IRS Form 990 for a period
ending no earlier than June 30, 2013, including signatures in
the box marked “Signature of Officer” as Attachment D .
 Tax Form 990 – Signature needed on Page 1 (Copy is
accepted)
 Schedule B of 990 is not required, but all other supporting
schedules are required.
Box 6 – Page 10
OPTION TWO
I certify that the organization named in this application is not
required to prepare and submit an IRS Form 990 to the IRS
This does NOT mean you do not have to provide any financial
documentation…..
You must submit a Pro-Forma 990 for a period ending no earlier
than June 30, 2013
Box 6 – Page 10
IF YOU CHECK THE SECOND BOX, YOU NEED TO PROVIDE A
“PRO FORMA 990”
If the organization’s fiscal period ended on or after June 30, 2013,
application must include a pro forma IRS Form 990 (or summary
report) of the most current financials and MUST include the
following from an IRS Form 990:
• Page 1 (Part I, Summary and Part II, Signature Block)
• Pages 7 and 8 (Part VII, Compensation section A)
• Page 9 (Part VIII, Statement of Revenues)
• Page 10 (Part IX, Statement of Functional Expenses)
• Page 12 (Part XII, Financial Statements and Reporting)
Box 6 – Page 10
IMPORTANT INFOMRATION
Any organization’s IRS Form 990 (or Pro Forma 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
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 a letter of explanation of the difference
or submit an amended IRS Form 990
Box 6 – Page 10
Box 6 – Page 10
Boxes 7, 8, 9,10,11 & 12
Important Certifications toward your application
READ, THEN CHECK EACH BOX!!!
Box 7 – Page 11
I certify the administrative and fundraising rate for the organization
named in this application is __ __ .__%
Regulatory Formula
• Use 990: Add the amount in Part IX (Statement of Functional
Expenses), Line 25, Column C (Management and General
Expenses) to the amount in Line 25, Column D (Fundraising
Expenses), & dividing the sum by Part VIII (Statement of
Revenue), Line 12, Column A (Total Revenue).
• No other methods may be used to calculate this percentage. All
percentages must be listed to the tenth of a percent (i.e. 10.0%
or 15.5%).
Box 8 – Page 11
I certify that an active and responsible governing body, whose
members have no material conflict of interest and a majority of
which serve without compensation, directs the organization named
in this application.
Listing of Board terms of office and meeting dates/locations
required of Federations only.
Box 9 – Page 11
I certify that 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
Box 10 – Page 11
I certify that the organization named in this application
conducts publicity and promotional activities based
upon its actual program and operations, that these
activities are truthful and non-deceptive, include all
material facts, and make no exaggerated or misleading
claims.
Box 11 – Page 11
I certify that the organization named in this application
effectively uses the funds contributed by Federal
personnel for its announced purposes
Box 12 – Page 11
I certify that the organization named in this application is in
compliance with all statures, Executive order, and regulations
restricting or prohibiting US persons from engaging in transactions
and dealings with countries, entities, or individuals subject to
economic sanctions….
Sanctions compliance is required
The list of countries, entities, or individuals referenced in the
certification can found at www.treasury.gov/ofac.
Guidance in CFC Memorandum 2005-13
Item 13 – Attachment E
Include as Attachment E a 25-word statement for listing in the
campaign brochure and taxonomy code specification. (See
Instructions Item 13 for additional required information and the new
optional taxonomy codes.)
We encourage you to list what county you provide service to or
where county office resides if not in Franklin County
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
Automatic pens and/or signature stamps MAY be used
Federations may provide photocopies for member charities
Applicants must check the box next to each statement to
demonstrate agreement to comply with the statement
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 OPM 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
Appeals may not be used to supplement applications that had
missing or outdated documents
Automatically Denied From Campaign
All required documents and attachments must be complete and
submitted before the application deadline
Missing or out of date documents will not be accepted during the
appeals process
The CFC will not accept applications with modifications to any of
the certification statements
Most Common Mistakes
• One of more of the certifications does not have a box checked.
• IRS Form 990 not signed by an Officer on page 1 (June 30,
2013 or current)
• IRS Form 990 and Audit time periods do not match. (June 30,
2013 or current)
• IRS Form 990 and Audit are prepare using two different
accounting methods; one is prepared using cash method of
accounting; one is prepared using accrual method of
accounting. (Must be accrual accounting method)
Most Common Mistakes
• IRS From 990 is incomplete – does not include all supplemental
statements and schedules
• Agency with income over $100,000 did not use accrual method
of accounting
• Board member count and list does not match or is less than
stated
• Agency does not provide adequate documentation of Human
Health and Welfare 2014 as defined by the regulations.
(Attachment A)
Completeness Statement
The PCFO is not required to offer an application pre-screening and that the
PCFO is not responsible for ensuring the application is complete or correct
by pre-screening it. The PCFO will pre-screen the application only as a
courtesy and will pre-screen for completeness, not correctness. It is the
responsibility of the applicant to verify the information submitted is correct.
Should the PCFO note an application or application information that is not
complete, it may notify the applicant of such discrepancy (ies) as a
courtesy but is not required to do so and is not responsible should a
notation of a discrepancy not be noted by the PCFO. It is the responsibility
of the applicant to correct or not correct any application discrepancies
noted by the PCFO as it deems appropriate. If an applicant resubmits an
application or application information it is the responsibility of the applicant
to confirm with the PCFO that it was received prior to the application
deadline and included in their application file.
What’s Next?
Double check everything
Make sure it arrives by mail only (electronic/faxed
applications are not accepted)
Make sure the package is postmarked no later
than 5pm Monday, March 2, 2015
Where to Send?
Send your completed application packet to:
2015 CFC Applications
c/o UWCO
Attn: Kevin Readey
360 S. Third Street
Columbus, Ohio 43215
A Word about what is happening with the
CFC beginning with the 2016 campaign….
Campaign Website
www.cowvcfc.org