Charity Town Hall Meeting

Proposed CFC Regulations

To educate charity stakeholders on proposed changes to Combined

Federal Campaign (CFC)

Meeting Purpose

• 2011 – CFC 50 Commission Formed

• Purpose: Study the CFC and make recommendations for:

– Improving Accountability

– Increasing Transparency

– Making the CFC More Affordable

Background

• July 2012– Delivered report with 24 recommendations

in the following areas• Donor participation• CFC Infrastructure• Standards of accountability &

transparency

Background

• April 8, 2013 – Proposed Regulations issued for public comment

• Reported intention of proposed regulation changes– Strengthen the integrity of the campaign– Streamline the operations– Increase effectiveness of the program

Background

Donor Participation

Current Regulations Current federal employees can be solicited only from Sept 1 – Dec 15 Retirees and federal contract employees can give only through check or cash

950.102 Campaign solicitation timeframe Oct 1 – Jan 15 Retirees and federal contract employees can give through credit card New employees can pledge within 30 days of hiring outside campaign

How could this change impact your charity?

• Additional donors = additional income

• Campaign dates shouldn’t have much effect

Donor Participation

Current Regulations Employees may pledge by paper or online systems Currently paper pledges account for well over half of the CFC pledges Some areas report upwards to 12% of donations made by cash or credit card or through fundraising events

950.401, 950.402 & 950.502 Pledges can be made only electronically Prohibits fundraising at events and activities

How could this change impact your charity?

• In 2012 58% of Intermountain CFC donors gave using paper pledge forms. Eliminating a paper giving option may dramatically reduce donations to your charity.

• May dramatically reduce the number of CFC events where charities have typically been invited = less face time with federal employees.

Donor Participation

Current Regulations Donors may give to any national or international charity but only to local charities in their CFC area

950.103 Donors may give to any CFC charity – national, international or local Donors must designate to a charity on the online charity list Undesignated pledges are prohibited

• Universal giving would be a positive change. Under this system donors who moved out of our area could still donate to your organization if they wished.

How could this change impact your charity?

CFC InfrastructureCurrent Regulations 184 independent geographic zones of varying size Each CFC area is overseen by a committee of federal employees (“LFCC”)

950.103 LFCCs become the Regional Coordinating Committee (RCC) with unspecified larger geographic zones Each RCC may hire marketing support – though not required

How could this change impact your charity?

• Increasing the duties of our volunteer federal employees and removing its partnership with the PCFO could be a dangerous move. Staffing the volunteer positions will require substantially more work and may be a challenge.

• Finding a suitable organization that could serve as an RCC may be complicated.

CFC InfrastructureCurrent RegulationsLFCC hires a staff (“PCFO”)

1) Print catalog2) Promote campaign through kick-offs, charity fairs, etc3) Process pledges & distributions4) Provides training5) Field questions from federal workers & charities

950.105 Abolish PCFOs Creates Central Campaign Administrators (CCA) Admissions & pledging on centralized website Local charity applications (national, international & local) online and reviewed by OPM and RCCsCharities can still apply through federations

Abolishing the PCFO will remove your local CFC point of contact – that’s huge! •The personal touch and local flavor will be lost. •Customer service response times will increase.•Applications will only be accepted using an online system •The special care and one-on-one guidance through the application process will be lost.

How could this change impact your charity?

TransparencyCurrent Regulations Each CFC area is financed by PCFO which pays for staff, paper catalog, marketing, account, audit PCFO fronts cost and gets repaid using first donations National average cost 10%

950.107 Fund CFC costs by charging charities up-front, non-refundable application fee to pay for CCA and RCC expenses No details about fee structure except annually determined by OPM based on proposed campaign budget

• Many charities cannot afford upfront fees • Could push smaller charities out if fees are not

structured appropriately• Upfront fees are not refundable • No guarantees that your charity will receive

any donations (same as always); you will still have to pay even if you receive zero pledges

How could this change impact your charity?

TransparencyCurrent Regulations Annual eligibility for charitiesAll local CFC charities with revenue of $100,000+ must have auditAll national and international charities, regardless of size, must have an audit

950.203One “main” application every two years

Abbreviated application in year 2

Audits will be required for revenues $250,000+ Only financial reviews are required for revenues between $100,000-$250,000

These are positive changes!•Charities with revenues between $100k - $250k can save money with the review requirement.•Reduced time spent applying

How could this change impact your charity?

Unknown• Implementation Dates• Number of RCCs, CCAs•How donors without computer access will pledge•How CCA will plan for and respond to calls/questions/concerns from federal employees and charities•How charity application fees will be determined & what the fees will be•How RCC and CCA will support hundreds (thousands?) of charities during application period

Possible Outcomes• Using the Following Estimate …..

Gov’t sets nationwide CFC budget at $10M Charge to charities is the same Application fee = $425

• Using the Following Estimate ….. Gov’t sets nationwide CFC budget at $15M Charge to charities is the same Application fee = $638

Dropout Scenario

Charity Drop-Out Due to Not Making Enough to cover fee in Pledges in Previous Year

• 177 local charities received less than the estimated fee of $425 last year. ($10M budget)• 230 charities received less than the estimated fee of $638 last year. ($15M budget)

Dropout Scenario

• If local charities want to make at least $750 through CFC, then 247 charities would drop

• If local charities want to make at least $1,000 through CFC, then 284 charities would drop – that’s 57% of all local orgs

Dropout Scenario

• 495 local charities received designations out of a total of 713 local charities in the campaign

• Best Case Scenario …. 268 (38%) of total local charities in the campaign would apply, based on 2012 results (based on $10M annual budget and assumption that they must

stand to make at least $200)

Call to Action• Goal: 200 comments from Intermountain CFC charities by June 1st

Engage your clients and board in the process and education efforts

• Legislative face-to-face visits

Call to ActionFOLLOW THIS PROCEDURE:• Use this link to submit comments:http://www.regulations.gov/#!documentDetail;D=OPM-2013-0006-0001

• If submitting via email, send to cfc@opm.gov and use this subject line: RIN 3206-AM68• Identify comments by regulation identifier number (RIN)• (If desired) BCC Bruce Jacobs (bjacobs@uwnu.org)

Questions ????

Thank you!