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The Regs Are Out. We Have Two Months to Comment

4/11/2013

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​At the end of last week, OPM released the proposed rules for the reform of the Combined Federal Campaign. For the next two months, the government invites our comment.
​The government has stated its aspirations on page 7 of the draft regulations:
These proposed changes will introduce efficiencies and cost savings into the CFC by leveraging technology that was not widely available just a few years ago.  They will make the CFC more efficient, more transparent, more accountable and more relevant to Federal, Postal and military service personnel who want to make the biggest impact with their donations.

While these proposals would make significant changes in the operation of the CFC, OPM remains committed to ensuring the broad participation of a multitude of charities in the CFC, and to preserving the local character, sense of community, and employee involvement that has been a hallmark of the CFC.  We welcome comments on how to best maintain these important attributes as we take steps to improve the CFC for the future
The draft regulations run to 55 pages.  We will not attempt in one posting to summarize the sweep of the changes being advanced.  But we do think it important that donors, charities and those who have been administering the CFC across the country jump into this dialog.

Our contribution today is to begin to offer resources so that those who have much at stake can understand what may be coming down the road.  First, we provide a link to the draft regs.

Second, we invite people to read coverage in the Washington Post and Federal Times [no longer available]. (These articles appeared in January of this year after the draft regs were leaked, and they are much more substantive than articles published in the past week, which say little beyond OPM’s press release. Here are links to those later articles: Washington Post; Federal Times [no longer available].)

Third, we suggest that readers note and save the following ways of commenting on the regs:
  • Mail:  Keith Willingham, Director, Combined Federal Campaign, U.S. Office of Personnel Management, Room 6484A, 1900 E Street, NW., Washington, DC 20415.
  • E-mail:  cfc@opm.gov.  Include “RIN 3206-AM68” in the subject line of the message.
  • Online comments: Regulations.gov.  Follow the instructions for submitting comments.
  • Fax:  (202) 606-5056 Attn: Keith Willingham.

Finally, please share your thoughts about the proposed regs by commenting on this blog. Have you read the regs? What do you like about them? What worries you? Do you expect to submit a formal comment to the government via one of the methods listed above? How well do you think the proposed regs serve the interests of charities, which are the entire reason for the CFC’s existence?
​
This is big stuff. Let’s talk about it. And, if you have not already done so, please register so you can be alerted when we post new material.
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    We are the Workplace Giving Alliance, a group of federations participating in the Combined Federal Campaign and dedicated to its success. These posts are written by Marshall Strauss, CEO of WGA.

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