The CFC federations of the Workplace Giving Alliance today submitted comments to OPM regarding the agency’s draft Combined Federal Campaign regulations. We expressed our support for some of the suggested changes and our concern about other aspects of the draft regulations.
We support OPM’s proposals to:
We also express our support for “universal giving” – a new system that will allow donors to support charities whether they are nearby or remote. At the same time, we are concerned that OPM has not fully considered the technical challenges involved in establishing this system, however appealing it may be in principle.
We call on OPM to revise the formula by which the administrative overhead of charities is calculated. We believe the current formula unfairly characterizes the finances of many charities, making it appear that they are spending far more on overhead than is actually the case.
We conclude by urging OPM to re-engage the CFC community in a full dialogue. Our observation is that OPM staff have felt constrained in their ability to talk with all of us regarding the future of the CFC. The lawyers have basically told OPM staff to shut up while the reg comment period is underway. (OK. Maybe they used more polite words.) We think it time to ask the lawyers to leave the room and for all of us to talk openly about where the campaign is going. We need to consider the CFC’s strengths and challenges, and together develop an effective way forward.
Right now, OPM staff can only read and listen. Perhaps next week they can begin to talk again.
Here is a link to our comment.
- Ease the requirement that smaller charities need to submit a copy of a full audit
- Require federations to more clearly invoice their member charities
- Consolidate back-office functions of the CFC.
- The institution of a charity application fee, believing it will discourage the participation of many organizations
- The elimination of the print directory and traditional methods of giving such as cash and checks, believing these changes will reduce donor participation and the amount of money raised
- The elimination of the PCFO structure because we worry that critical institutional memory and personal relationships will be lost.
We also express our support for “universal giving” – a new system that will allow donors to support charities whether they are nearby or remote. At the same time, we are concerned that OPM has not fully considered the technical challenges involved in establishing this system, however appealing it may be in principle.
We call on OPM to revise the formula by which the administrative overhead of charities is calculated. We believe the current formula unfairly characterizes the finances of many charities, making it appear that they are spending far more on overhead than is actually the case.
We conclude by urging OPM to re-engage the CFC community in a full dialogue. Our observation is that OPM staff have felt constrained in their ability to talk with all of us regarding the future of the CFC. The lawyers have basically told OPM staff to shut up while the reg comment period is underway. (OK. Maybe they used more polite words.) We think it time to ask the lawyers to leave the room and for all of us to talk openly about where the campaign is going. We need to consider the CFC’s strengths and challenges, and together develop an effective way forward.
Right now, OPM staff can only read and listen. Perhaps next week they can begin to talk again.
Here is a link to our comment.
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