Massive Combined Federal Campaign CFC Changes Proposed For Non-profits
Massive Combined Federal Campaign Changes Proposed For Non-profits
Most of the proposed changes are bad – These measures Throw Out the Baby with the Bathwater, and toss the tub on top for good measure.
Bill Huddleston, The CFC Coach, said that “The proposed changes to the Combined Federal Campaign (CFC) regulations will have the effect of destroying the CFC for small non-profits, whether they are local or national.”
The CFC Regulations as proposed will not help CFC charities, donors, or the people the CFC non-profits serve. In addition, huge areas of importance are not addressed at all in the proposed regulations, including the value of the CFC to the sponsoring agencies and their employees.
The regulations were published on April 7th in the Federal Register, and there is a 60 day comment period which ends June 7th. In other posts I will show you how to use the Federal Register commenting software, but if you think the CFC is worth saving, now is the time to act!
Will Cut CFC Revenues in Half
As proposed, these regulations completely eliminate the face to face aspect of the entire CFC campaign. If implemented as proposed these untested changes will have the effect of cutting CFC revenues for thousands of CFC charities in half, which is what has happened when such massive changes have been tried at the in workplace giving campaigns at the city and state level. To see how much revenue was raised in your state through the CFC, please see this worksheet I created showing the state by state totals. (see separate post)
After 50 years of being the most successful workplace giving program in the world, and the single largest source of unrestricted funds for non-profits, these proposed changes “throw the baby out with the bathwater, and then toss the tub on top for good measure!”
Massive Changes Proposed Without Adequate Discussion
The changes planned the proposed regulations are gigantic, and the proposed regulations make mistakes along the classic “New Coke” marketing debacle, when after much discussion about how to improve Coke, classic Coke was pulled from the market, and the cry went up, “Wait, you didn’t tell us you planned to destroy Coca-Cola!”
That’s the effect these new regulations will have, they will destroy the CFC, which is the single largest source of unrestricted funds for non-profits in the US. The proposed regulations contain an odd mish mash of sweeping changes with no specifics on how the changes will actually be accomplished, wipes out organizations that have been in existence for more than 50 years, and especially in time of sequestration, are divorced from reality, because in order to actually implement them, there would need to be ten times increase in the number of Federal employees working on the CFC.
CFC – 50 Commission
A little background is in order, the CFC celebrated its 50th Anniversary in 2011, and at that time the head of the Office of Personnel Management (OPM), John Berry, formed a commission, called the CFC-50 Commission, to look at ways to improve the CFC and keep it vibrant for the next 50 years. The Commission was chaired by two former members of Congress, Hon. Tom Davis, (R-VA) and Hon. Beverly Byron, (D-MD), each of whom is well respected in the Federal service, and had served on government operations committees during their Congressional tenure.
CFC -50 Commission Public Meeting Videos (on Youtube)
The CFC-50 Commission met in public meetings four different times, and videos of these meeting are available at opm.gov/cfc. http://www.opm.gov/combined-federal-campaign/cfc-50-commission (see list of videos at bottom of page).
The videos are difficult to watch because they are not optimized for viewing, there are no captions identifying who is speaking, and the speakers usually don’t identify themselves. Some of them have 10 minute spans where the sound is inaudible. There was testimony by invited participants, e.g. representatives from some of the larger charities, etc.
CFC – 50 Commission Report – 24 Recommendations
The Commission then produced their recommendations in a report, “Federal Advisory Commission Report on the Combined Federal Campaign” in July 2012, which contained 24 recommendations.
Two Good Recommendations
Some of these 24 recommendations survived intact in the proposed regulations, and some of them are good and make perfect sense, such as the ones dealing with new employees and the one dealing with disaster relief charities.
Many Proposed Regulations Do NOT Follow the Recommendations of the CFC-50 Commission
Many of the proposed regulations simply miss the mark from what the CFC-50 Commission actually recommended, had no or inadequate discussion about how some functions would actually be accomplished, and others are petty, or petty and unconstitutional.
Example of a Regulation Missing the Mark with wide negative consequences:
“Shifting the Campaign” is NOT the same as “Extending”
In the CFC-50 Commission meetings there were many people and organizations that spoke to the benefit of extending the campaign to January 15th from the current December 15th end. There are many reasons for this, including both year-end charitable giving and federal personnel schedules.
In watching all eight hours of video testimony, reading all the recommendations and appendices in the CFC-50 report, not a single person said “Shift the Campaign” from September to December to October to January. “Shifting” is not the same as “extending” and there are many negative consequences to shifting, which I will describe in detail in later posts, but since there was no mention of this at all in 4 public meetings over many months, the idea was not addressed.
The Proposed Regulations can be found here:
In later posts, I will have information on how to use the Federal Register rule making portal to make comments.
The CFC Coach