Why Does the Combined Federal Campaign (CFC) Matter?

Posted on May 21, 2013. Filed under: Combined Federal Campaign - CFC, Fundraising, Leadership, Non-profits, Office of Personnel Management (OPM), Volunteer |

Why Does the Combined Federal Campaign (CFC)  Matter?

Why Does OPM Want to Kill the Golden Goose of American Philanthropy?

By Bill Huddleston, The CFC Coach

The Combined Federal Campaign (CFC) matters because through it, and the generosity of the hundreds of thousands of Federal public servants who are the CFC donors, millions of Americans and others throughout the world are helped by the actions and services provided by  the more than 25,000 non-profits that are enrolled in the Combined Federal Campaign.  In the fall 2012 campaign,  more than $258 million dollars were raised, and in terms of actual giving, if the CFC were a foundation, it would be the 14th largest foundation in the USA.   Over  the past five years, the CFC has generated more than $1 billion of unrestricted revenue for thousands of local, national and international CFC charities, which makes it the single largest source of unrestricted funds in the non-profit sector.

The CFC, which was established in 1960, is the federal government’s workplace giving program, and is administered by the Office of Personnel Management (OPM).  The CFC used to have both a vision statement and their mission statement  on the CFC Operations home page that were succinct and inspiring:

CFC Vision Statement:

A government that encourages and enables active employee participation in community and that fosters collaboration with business and the nonprofit sector to achieve this goal.

CFC Mission Statement:

To promote and support philanthropy through a program that is employee focused, cost-efficient, and effective in providing all federal employees the opportunity to improve the quality of life for all.

Sometime in the last decade, OPM removed the vision statement, and they seem to have forgotten what the mission statement really means, having just completed an analysis of the proposed changes to the Combined Federal Campaign regulations, that are massive and harmful to the CFC if implemented as proposed, but let’s first look at the present setup.

Workplace giving is a unique type of fundraising in the non-profit sector, and it’s important to understand the complex synergy that exists among all the parts.   In the current structure of Combined Federal Campaign, these are the major components:

  • Recipients of services from CFC Charities  – the people and other beneficiaries of the services provided by the 25,000 CFC charities. (Millions of people ).
  • CFC Donors  -The Federal Public Servants who are the CFC Donors (more than 800,000).
  • CFC Charities – The 25,000 non-profits that are enrolled in the CFC, including approximately 1500 that are national or international in scope, and about 22,000 local charities.
  • Federations – Federations are special types of CFC charities, consisting of groups of 15 or more charities with something in common, e.g. the member of Community Health Charities federation are all health related, EarthShare has environmentally oriented non-profits as its members, and the members of Children’s Charities of America deal with issues affecting children to mention just a few.  Federations can be national, international or local.  Federations assist their members with their CFC applications, provide joint marketing support, and provide other campaign related services.
  • U.S. Federal agencies , that conduct the CFC campaigns, and this means anywhere in the world where there is a US Federal installation, (including places like Afghanistan and Iraq) there is a CFC campaign, as well as all civilian, military and U.S. Postal service facilities in the U.S.
  • CFC Campaign Volunteers – The thousands of Federal employees who volunteer each year to help run their agency’s CFC campaign, solicit funds, organize charity fairs, and conduct the overall management of a campaign within a Federal agency.    When the CFC campaigns are conducted each fall, the CFC is the
  • CFCs are organized regionally, and currently there are 184 CFC regions:
    • Local Federal Coordinating Committee (LFCC ) Each region has a Federal “Board of Directors” called the LFCC that is responsible for reviewing and approving applications for local charities to enroll in the CFC; and it is responsible for the selection of the Principal Combined Fund Organization (PCFO) which are contractors to the government  and there is a one to one match, so currently there are 184 PCFOs.
    • Principal Combined Fund Organization (PCFO) has two major responsibilities: the overall management of the CFC campaign in its region; and the fiduciary responsibility of sending the CFC donors gifts to the CFC charities they designated.  PCFOs are 501(c) (3) non-profits.  In the 184 regions, the PCFOs in the larger areas (e.g. major metropolitan areas, and areas with large Federal installations (e.g. Army, Navy, Marine, Air Force, Veteran Affairs hospitals, Postal Service regional centers, etc.), have larger staffs than in the more sparsely populated regions.
  • Office of Personnel Management (OPM) has overall responsibility for the Combined Federal Campaign, including the CFC regulations and any appeals from non-profits that had their applications denied.   The OPM CFC office has a small staff of less than twenty.  It approves the applications of national and international charities, which currently number about 1500.
  • Federal Executive Boards (FEB) and Federal Executive Associations ( FEAs).   In areas outside of the Washington DC area, regional entities responsible for regional government wide operations, and often have the LFCC function as part of their responsibilities.
  • CFC-50 Commission  On the occasion of the 50th Anniversary of the CFC in 2011, there was a special commission formed that was chaired by two respected former Congressmen,  the Hon. Tom Davis (R) from Virginia and the Hon. Beverly Byron (D) from Maryland, each of whom had experience with the government reform committee when in Congress.  There CFC-50 Commission conducted a series of meetings, and issued a final report in July 2012 that contained 24 recommendations to OPM on ways to improve the CFC. 

 

  • Federal Retirees:  Retirees currently cannot have CFC designations deducted from their retirement pay, although the projections are that thousands of Federal retirees would participate in the CFC if they could.

CFC – The Golden Goose of American Philanthropy

 

When I give workshop presentations about the CFC, my workshop title is: “CFC—The Golden Goose of American Philanthropy.” I use that title because, just like the farmer in that fairy tale, most people do not understand how the CFC works; they just know it produces money for their non-profit, if they know anything at all about it. Depending upon their non-profit, it may produce a lot, or it may produce a little, and non-profit leaders are often not sure how it works, and what if anything they can do to improve their CFC results.  But just like the golden goose, the fundamental fact about the CFC is that it does work, and works well.  I’m not saying that it can’t be improved, but in the “results oriented” culture of today, the CFC , as it is currently structured, produces results that help millions of people every year, having generated $258 million in 2012.  And in, a miracle of government function, it actually has less red tape than almost any grant.

The synergy that exists among the component parts that I outlined means that in the current, decentralized structure, the workload is spread out among many different players, and that there are benefits to each.

Massive Proposed Changes to CFC Regulations by OPM

The Office of Personnel Management has proposed sweeping, and massive changes to the regulations governing the Combined Federal Campaign, and even though they say that they basing the proposed changes on the CFC-50 report, it many cases what they’re proposing was never discussed, or goes far beyond what was discussed in the CFC-50 Open Meetings and Final Report, or ignores what the CFC-50 Report recommended.

The proposed regulations are an odd combination of massive overreach; destruction of hundreds of private sector non-profit jobs in lieu of new Federal positions (which have not been approved or budgeted); hiding important sections in illogical sections of the proposed regulations, while simultaneously making multi-million dollar errors in the same section (in the section dealing with Federal retirees); making small irritating changes that are harmful to the CFC donors information gathering and make things harder for both the donor and the CFC charities; the destruction of multiple business models that have been successful for decades without adequate discussion,  and there are a few good ideas as well.   In many areas the proposed regulations are contradictory with significant differences about what the stated purpose is, and what the actual effect will be.

As proposed, the regulations are:

  • Harmful to CFC charities, both large and small, and will definitely drive smaller charities whether local, national, or international out of the CFC.
  • Harmful to CFC donors
  • Harmful to CFC Federations
  • Harmful to Federal agencies, including the leadership development of their workforce
  • Harmful to the non-profit employees of the PCFOs, where all 184 private sector organizations are eliminated which means that at least 450 non-profit jobs now go to Federal positions.
  • Harmful to the beneficiaries of the services provided by the CFC charities.  When just one of the items in the proposed regulations has been tried at the municipal or state level (going all electronic) there has been 50% drops in revenue.  If the regulations are implemented as proposed, a 75% drop in revenues is likely.
  • Presume a massive transfer of functions from the private sector, non-profit PCFOs to the Federal workforce.

Hidden Regulations – Federal Retirees Section

Some of the proposed regulations are poorly organized, with no logic behind them, and they have the effect of hiding significant and important changes.  For example, the section dealing with Federal retirees instead of being in a “Donors” section is hidden in the “establishing Regional Committees” section, ignores the CFC-50 Commission recommendations, and makes a multi-million dollar error in judgment, all in less than a paragraph.   Here’s the link to the section that deals with retirees, hidden in the phrase “and also eliminates restriction on soliciting non-Federal personnel.”   950.103 Establishing Regional Coordinating Committees.

I have posted my analysis of the proposed CFC Regulations on the CFCTreasures.wordpress .com site and on the SAVETHECFC Linked in site.  It’s  50 plus pages with the regulations links, OPM’s analysis, my analysis, and recommended actions in a table form.

 Federal Government Public Comment Period Closes June 7, 2013.

This is the bad news, the good news is that these are proposed regulations, and we are in the Public Comment Period, which closes June 7, 2013.  By law Federal agencies must put out proposed regulations for public comment, and they must respond to all issues raised before implementing the regulations.  This is your opportunity to affect public policy in a meaningful way, and to stop the regulations from being implemented as proposed.   I think the overall message is that the regulations as proposed are harmful, and OPM needs to go back to the drawing board.

There are two ways to comment:  Send a written letter to the OPM’s Director of the Combined Federal Campaign, Keith Willingham or submit your comments via the electronic comment function of the Federal Register.   My recommendation is to use the Federal Register method because other members of the non-profit community will also be able to see your comments.

Subject: RIN 3206-AM68, Solicitation of Federal Civilian and Uniformed Service Personnel for Contributions to Private Voluntary Organizations

Reference Number: RIN 3206-AM68

Dates:    OPM must receive comments on or before June 7, 2013

Here are the links to the proposed changes to the CFC regulations.

URL: https://www.federalregister.gov/articles/2013/04/08/2013-08017/solicitation-of-federal-civilian-and-uniformed-service-personnel-for-contributions-to-private

Shorter URL:   https://federalregister.gov/a/2013-08017

HERE IS THE SPECIFIC PAGE TO COMMENT ON THE PROPOSED CFC REGULATIONS: http://www.regulations.gov/#!docketDetail;rpp=100;so=DESC;sb=docId;po=0;D=OPM-2013-0006

Contact info for Bill Huddleston:

If you have questions or concerns about how you can help save the CFC as one of the most useful programs for millions of Americans who benefit from the $258 million dollars generated annually by the CFC, please don’t hesitate to contact me at BillHuddleston@verizon.net or by phone at 703-434-9780.

Email: billhuddleston@verizon.net

Phone: 703-434-9780

http://www.cfctreasures.wordpress.com

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    Fundraising and Leadership Development through workplace giving, CFC = Combined Federal Campaign

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