Further Comments on Proposed CFC Regs

​At a meeting yesterday of the National Combined Federal Campaign Committee, CFC Director Keith Willingham explained a bit more how the government will handle the comments now being received from the public regarding the proposed new CFC regulations.

The official comment period will end on June 7, 2013.  After it has digested the public feedback, OPM will forward to the Office of Management and Budget the proposed final regs including, of course, any adjustments to the original text. OMB will then decide if the regs should be published as final or whether there should be an opportunity for still more comment by the public or other government agencies, or both.

How long this will take is anyone’s guess.

Mr. Willingham also explained that OPM will release the comments received by the agency after June 7.

Here in Salem MA, we are receiving a handful of comments which others have been kind enough to forward.  In the hope that our readers will find these documents helpful, we will continue to share them. Today, we post two – one by Patrick Maguire whose firm supports the administration of numerous CFC federations and the other by Lawrence Cummings, writing on behalf of Medical Research Charities, a CFC federation supported by us here in Salem.

The Maguire Letter

At the end of last week, Patrick Maguire copied us on a letter he had sent to OPM in his “capacity as a member of the CFC-50 Commission.”  In his letter he offered two proposals:

• The government should create a Federal Family Season of Sharing.  Each fall, federal employees would be encouraged to send into the government copies of receipts reflecting non-CFC donations.  These would be added to the CFC donations to create a more complete report on employee giving.

• The government should invite federal employees to nominate their own favorite charities to the CFC.  Each such charity would be allowed to participate in the CFC without being charged during its first year in the program.  The goal would be to generate even more excitement for the campaign within the workforce and expand support to additional groups.

They’re both intriguing ideas.

Read the entire letter.

The MRC Letter

In his letter, Lawrence Cummings notes that MRC is a “federation of charities that fund or conduct research to find treatments and cures for diseases,” adding that his organization and its members “strongly support OPM’s goal to strengthen the integrity, streamline the operations, and increase the effectiveness of the Combined Federal Campaign.”

Cummings identifies four aspects of the proposed regs that could prove problematic for the CFC:

1. Elimination of the paper booklet listing participating charities, as well as the paper pledge forms.
2. Adoption of an unspecified, non-refundable upfront “application” fee to charities, sufficient to cover the costs of the campaign including a marketing effort.
3. Strong centralization of the campaign, and the elimination of nearly 200 local campaign entities.
4. Shifting campaign expense recovery from donors to the charities.

Read the entire letter.