The proposed new CFC regulations in their original form are 55 pages of legal and administrative language. You can read them at http://federalregister.gov/a/2013-08017.
Because some may find the original document a bit forbidding, we have created the following summary. We touch on only major changes and do not address every detail, nor do we try to explain how the changes will be implemented. We plan to discuss issues raised by the regs extensively in this blog.
Because some may find the original document a bit forbidding, we have created the following summary. We touch on only major changes and do not address every detail, nor do we try to explain how the changes will be implemented. We plan to discuss issues raised by the regs extensively in this blog.
The new regulations change how the campaign will be administered:
| Current: The CFC is administered in 184 independent geographical zones of varying sizes, each overseen by a committee of federal employees (the “LFCC”) which reviews local charity applications and hires a staff (the “PCFO”) to print the catalog, promote the campaign through kick-off events and other means, process pledges and distributions, and provide training to and field questions from both federal workers and charities. Proposed: The new regulations abolish the PCFOs. The old LFCCs become the Regional Coordinating Committees for an unspecified number of larger geographical regions. Each RCC may hire marketing support – though this is not required. Admissions and pledging will be centralized on a website run by a Central Campaign Administrator, a tax-exempt nonprofit that does not itself solicit contributions through the CFC. CFC donations will be distributed by the CCA or federal payroll offices (the regulations allow for both possibilities). All applications from independent organizations (national and local) will be submitted electronically to the CCA and reviewed by OPM with assistance from the RCCs. Charities may also apply through federations. Charities will be allowed to submit abbreviated applications in two of every three years to reduce the burden of paperwork. |
The new regulations change how the campaign will be paid for:
| Current: Each local zone of the campaign is financed by its PCFO, which pays for its campaign staff, paper catalog, marketing, accounting and audit. The money each PCFO fronts to run the campaign is repaid using the first donations received. While local costs vary widely, the countrywide average is 10% of what is raised. Charities therefore currently receive about 90% of actual donations made, whether they receive a large or small share of the total. Proposed: The new regulations will fund CFC costs by charging charities an up-front non-refundable application fee which will be used to pay the Central Campaign Administrator and to reimburse local RCC expenses.
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The new regulations change eligibility requirements:
| Current: Among the eligibility and accountability provisions in the current regulations is the requirement that all local CFC charities with revenue over $100,000 have an audit. All national charities, regardless of size, must have an audit. Proposed: Most eligibility and accountability provisions remain unchanged, although some requirements that now appear only in OPM guidance will be incorporated into the regulations. Audits will no longer be required for any charity (national or local) with revenue under $250,000. Charities with revenue between $100,000 and $250,000 must have at least a review. |
Other Changes of Note:
| Current | Proposed |
| Pledge period runs from September 1 through December 15. | Pledge period will run from October 1 through January 15. New employees will be invited to pledge when they are hired if they are hired outside that period. |
| Retirees and contractors cannot pledge. | Retirees, contractors and others on federal premises may make single electronic donations. |
| Employees may pledge by paper or online systems. Paper pledges currently account for well over half of CFC pledges. Some estimates suggest that 8-9% are made by cash or credit card or are associated with a fundraising event. | The paper catalog and paper pledges are eliminated. Donors will search for charities and make pledges electronically on the central website. They may give by payroll deduction or credit card, but not by cash or check. Donations at campaign events will no longer be permitted. |
| Donors may give to any national or international charity but only to local charities in their own area. | Donors may give to any CFC charity—national, international or local—no matter where it is located. |
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