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Charity Town Hall Meeting Proposed CFC Regulations. Meeting Purpose. To educate charity stakeholders on proposed changes to Combined Federal Campaign (CFC). Background. 2011 – CFC 50 Commission Formed Purpose: Study the CFC and make recommendations for: Improving Accountability
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Charity Town Hall Meeting Proposed CFC Regulations
Meeting Purpose To educate charity stakeholders on proposed changes to Combined Federal Campaign (CFC)
Background • 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
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
How could this change impact your charity? • 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.
CFC Infrastructure • Current 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 Infrastructure • Current Regulations • LFCC hires a staff (“PCFO”) • 1) Print catalog • 2) Promote campaign through kick-offs, charity fairs, etc • 3) Process pledges & distributions • 4) Provides training • 5) 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 RCCs • Charities can still apply through federations
How could this change impact your charity? • 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.
Transparency • Current 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
How could this change impact your charity? • 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
Transparency • Current Regulations • Annual eligibility for charities • All local CFC charities with revenue of $100,000+ must have audit • All national and international charities, regardless of size, must have an audit • 950.203 • One “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
How could this change impact your charity? • These are positive changes! • Charities with revenues between $100k - $250k can save money with the review requirement. • Reduced time spent applying
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 Action • FOLLOW 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.govand use this subject line: RIN 3206-AM68 • Identify comments by regulation identifier number (RIN) • (If desired) BCC Bruce Jacobs (bjacobs@uwnu.org)