Fundraising
Hill asks OMB to intervene with OPM on CFC Rules
Thanks to all the CFC charities and non-profit leaders who have kept expressing their concerns about the proposed changes to the Combined Federal Campaign (CFC). OPM sent their proposed final rule to the Federal Register but has still not released the actual text of the proposed rule. From a press release statement, OPM did make some adjustments, but kept many of the ill thought out provisions as well. The new Director of OPM, Katherine Archuleta has not been forthcoming about how harmful the proposed regulations would be to the Combined Federal Campaign (CFC).
Many of you contacted your members of Congress to express your concern, and the members of the House Committee that oversees OPM have asked that the Office of Management and Budget review OPM’s actions.
Thanks for your continued leadership in the non-profit sector!
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The pdf version with signatures of the letter sent to OMB can be found here:
http://democrats.oversight.house.gov/uploads/Issa%20EEC%20et%20al%20to%20OMB%2004-15-14.pdf
The notice from the committee is below, as well as the text of the letter:
Reps. Issa, Cummings, Farenthold, Lynch, and Reichert
Write to OMB About Concerns with CFC Regulations
Washington, D.C. (Apr. 17, 2014)—This week, Reps. Darrell E. Issa, Elijah E. Cummings, Blake Farenthold, and Stephen F. Lynch, the Chairmen and Ranking Members of the House Committee on Oversight and Government Reform and the Subcommittee on Federal Workforce, U.S. Postal Service, and the Census, as well as Rep. David G. Reichert sent a letter to the Office of Management and Budget sharing concerns raised by stakeholders regarding the proposed final rule amending the Combined Federal Campaign regulations.
The full text of the letter is available here and included below.
April 15, 2014
The Honorable Sylvia Matthews Burwell
Director
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
Dear Ms. Burwell:
On April 8, 2013, the Office of Personnel Management (OPM) published a proposed rule that would amend regulations governing the Combined Federal Campaign (CFC). OPM received approximately 1,400 comments during the public comment period which ended on June 7, 2013.[1] The Subcommittee on Federal Workforce, the U.S. Postal Service, and the Census held a hearing to review the proposed rule on July 10, 2013. Through their comments and testimony, a number of charities, donors, and watchdog groups raised significant concerns with several aspects of the proposed rule, especially with respect to charity application fees, electronic pledging and donations, and the local governance structure of the CFC campaigns.
We understand that OPM recently transmitted its recommendations for a final rule to the Office of Management and Budget, which is reviewing them as part of the interagency clearance process. Although OPM made some revisions based on the comments it received, CFC stakeholders continue to express concerns. As your office reviews OPM’s recommendations for the final rule, we write to urge that every reasonable consideration be given to the concerns stakeholders have raised.
The CFC is the largest workplace charity program in the world and now encompasses 200 campaigns and more than 20,000 participating charities. More than 850,000 federal employees contributed more than $250 million to the CFC in 2012.
We commend efforts to increase accountability and transparency regarding the administration of the CFC. The final rule proposed by OPM would extend the solicitation period, enable new employees to donate immediately after being hired instead of requiring them to wait until the next campaign period, and create a disaster relief program to enable employees to begin contributing to relief efforts within hours of a disaster. These provisions would enhance employees’ access to the CFC and appear to have widespread support among CFC stakeholders.
However, other provisions continue to raise substantial concerns for CFC stakeholders, including proposals for: (1) non-refundable charity application and listing fees; (2) electronic pledging and donation procedures; and (3) charity support organization operations.
OPM’s proposed final rule requires a charity seeking to participate in the CFC to pay a non-refundable application fee. A charity approved to participate would be required to pay an additional nonrefundable annual listing fee. Under the proposed rule, OPM would divide the prior campaign period’s costs by the number of participating charities. There is no indication in the rule that the fees assessed to a charity might vary depending on the size of a charity or other unique characteristics. Charities and watchdog groups agree that the charity application fees may disproportionately affect smaller charities and make it more difficult for them to participate in the CFC. As a result, although the rule was intended to increase donor participation, it could have the opposite effect.
Charities, donors, and watchdog groups are also concerned that requiring employees to submit donation pledges online—rather than by check, cash, money order, or paper pledge—may substantially reduce the amount of contributions the CFC will raise. In the 2012 CFC, 10% of all donations—$27 million—were made via cash, check, or money order rather than through payroll deductions, and about 80% of donors made paper pledges rather than online pledges.[2]
CFC stakeholders are also concerned about provisions that would substantially limit the local nature of the CFC and change the way charity support organizations and federations conduct their operations. The proposed final rule would eliminate nonprofit Principal Combined Fund Organizations, which administer local campaigns on a day-to-day basis, and transfer their functions to Outreach Coordinators and Central Campaign Administrators.
Finally, the proposed rule would prohibit federations from deducting their fees before remitting CFC contributions to their members. This rule would have a significant impact on the CFC as 60% of charities participate in the CFC through federations. Currently, most federation members prefer paying their share of federation expenses by having the expenses deducted from the distribution of campaign contributions. The proposed rule would require federations to issue invoices to each of their members. Stakeholders believe that this practice may increase administrative costs and decrease transparency as federation fees, if separated from CFC expenses, may not be included in records that would be accessible to OPM.
It is in the federal government’s interest to ensure that any changes to the CFC will not negatively impact the program’s ability to serve those in need in our communities, while at the same time promoting efficiencies that help reduce unnecessary costs by modernizing the administration of the CFC. We therefore ask that OMB carefully consider the public comments submitted on the proposed rule prior to issuing a final rule. OMB also may want to consider pilot testing some of the changes to gage the potential impact on the CFC.
Sincerely,
Darrell E. Issa Elijah E. Cummings
Chairman Ranking Member
Blake Farenthold Stephen F. Lynch
Chairman Ranking Member
Subcommittee on Federal Workforce, Subcommittee on Federal Workforce,
U.S. Postal Service, and the Census U.S. Postal Service, and the Census
David G. Reichert
Member of Congress
[1] Office of Personnel Management, Solicitation of Federal Civilian and Uniformed Service Personnel for Contributions to Private Voluntary Organizations, 78 Fed. Reg. 20820 (Apr. 4, 2013) (proposed rule) (online at www.federalregister.gov/articles/2013/04/08/2013-08017/solicitation-of-federal-civilian-and-uniformed-service-personnel-for-contributions-to-private).
[2] Office of Personnel Management, Report C-17 CFC 2012 Pledge Report (Apr. 18, 2013).
Read Full Post | Make a Comment ( None so far )Washington Post Federal Diary – CFC Changes Worry Charity Leaders
Folks,
There is an important article about the Combined Federal Campaign in the Federal Diary column in today (February 7, 2014) Washington Post. I’m putting the link to Mr. Joe Davidson’s column here:
“As new rules on federal giving show, public’s reaction to plans don’t always yield changes”
This is the title of the online version.
The title of the print version (of the same column) is:
Planned changes in rules for giving by government workers worry some charity leaders.
My second post today will be my response to the Federal Diary column, and it will make more sense if you read the Federal Diary column first.
Thanks,
Bill Huddleston
Read Full Post | Make a Comment ( None so far )CFC Congressional Hearing on Wednesday, June 26, 2013
Bill Huddleston on June 19, 2013
Late breaking news – Update on Proposed Changes to CFC Regulations:
The Office of Personnel Management (OPM) received more than 800 comments about the proposed changes to the CFC regulations and there is a Congressional Hearing scheduled for Wednesday, July 26th at 1:30 pm in the Rayburn House Office building to “Help Congress Better Understand the Impact of what OPM is proposing for the CFC.”
If you’re in the DC area, please plan on attending, if you’re in another part of the country or can’t attend, please contact your Representative to let them know the damaging impact the new regulations will have if adopted as proposed. House.gov lists addresses and phone numbers for all Members of Congress by name and by state, if needed.
To see my complete analysis of the proposed regulations, “Back to the Drawing Board! – An Analysis and Recommended Responses to the Proposed Changes to the Combined Federal Campaign (CFC) Regulations” please go here:
I am reprinting it in its entirety the letter from the SavetheCFC coalition, organized by America’s Charities, please follow its directions for location and time of the hearing:
Hope to see you there!
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PDF – BACK TO THE DRAWING BOARD – Section by Section Analysis of Proposed CFC Regulations
Back to the Drawing Board!-CFC ANALYSIS -by Bill Huddleston_Final
Read Full Post | Make a Comment ( 3 so far )Why Does the Combined Federal Campaign (CFC) Matter?
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.
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
Read Full Post | Make a Comment ( None so far )HOW TO COMMENT ON THE PROPOSED COMBINED FEDERAL CAMPAIGN (CFC) REGULATIONS
MASSIVE CHANGES PROPOSED TO
COMBINED FEDERAL CAMPAIGN (CFC)
WILL HARM NON-PROFITS IF IMPLEMENTED AS PROPOSED
By Bill Huddleston, The CFC Coach, billhuddleston@verizon.net, 703-434-9780
NON-PROFITS WHO CARE ABOUT THE SINGLE LARGEST SOURCE OF UNRESTRICTED FUNDS IN USA – THE COMBINED FEDERAL CAMPAIGN – PLEASE READ AND COMMENT TO SAVE THE CFC!
HOW TO COMMENT ON THE PROPOSED COMBINED FEDERAL CAMPAIGN REGULATIONS
The Office of Personnel Management (OPM) has proposed massive changes to how the Combined Federal Campaign works. There are more than 40 pages of proposed regulations, and my analysis of the changes can be found at the SAVETHECFC Linked-In Group and on my blog at www.cfctreasures.wordpress.com. There is a public comment period for all proposed government regulations, and the comment period concerning the Combined Federal Campaign proposed regulations closes June 7, 2013.
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
Shorter URL: https://federalregister.gov/a/2013-08017
Here’s one example of a proposed change that will have negative impacts on CFC charities, the Federal CFC donor, and most importantly the people that receive the services from the many CFC charities.
Example of a Proposed 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.
Will Cut CFC Revenues in Half:
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. https://cfctreasures.wordpress.com/2013/05/02/combined-federal-campaign-2012-results-by-state
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 $260 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.
Read Full Post | Make a Comment ( None so far )COMBINED FEDERAL CAMPAIGN 2012 RESULTS BY STATE
| Combined Federal Campaign (CFC) | ||||||
| 2012 RESULTS BY STATE | ||||||
| Note: All CFC monies are unresticted | ||||||
| ALABAMA | $5,987,002 | NEBRASKA | $1,497,137 | |||
| ALASKA | $1,406,798 | NEVADA | $752,622 | |||
| ARIZONA | $3,759,035 | NEW HAMPSHIRE, VERMONT | $958,917 | |||
| ARKANSAS | $1,160,469 | NEW JERSEY | $1,846,414 | |||
| CALIFORNIA | $16,986,872 | NEW MEXICO | $1,765,967 | |||
| COLORADO | $5,352,033 | NEW YORK | $4,425,540 | |||
| CONNECTICUT | $798,324 | NORTH CAROLINA | $5,456,346 | |||
| DELAWARE | $433,244 | NORTH DAKOTA | $422,146 | |||
| FLORIDA | $10,226,824 | OHIO | $8,095,316 | |||
| GEORGIA | $8,247,388 | OKLAHOMA | $4,245,444 | |||
| HAWAII | $5,764,902 | OREGON | $1,639,158 | |||
| ILLINOIS | $4,304,315 | PENNSYLVANIA | $4,937,918 | |||
| INDIANA | $1,390,976 | RHODE ISLAND | $1,054,066 | |||
| IOWA | $611,413 | SOUTH CAROLINA | $3,028,794 | |||
| KANSAS | $447,603 | SOUTH DAKOTA | $445,332 | |||
| KENTUCKY | $2,190,295 | TENNESSEE | $5,395,505 | |||
| LOUISIANA | $2,345,817 | TEXAS | $18,802,381 | |||
| MAINE | $396,980 | UTAH | $2,828,564 | |||
| MARYLAND | $7,642,681 | VIRGINIA | $9,749,833 | |||
| MASSACHUSETTS | $2,162,187 | WASHINGTON | $7,091,300 | |||
| MICHIGAN | $2,954,134 | WEST VIRGINIA | $731,943 | |||
| MINNESOTA | $1,100,954 | WISCONSIN | $1,043,972 | |||
| MISSISSIPPI | $1,521,899 | WYOMING | $256,830 | |||
| MISSOURI | $7,482,330 | PUERTO RICO | $1,243,784 | |||
| MONTANA | $600,557 | Washington, DC Natl Cap Area | $61,616,748 | |||
| (DC, northern VA, sub. MD) | ||||||
| OVERSEAS CFC – DOD | $ 13,646,352 | Defense Department Deployed Personnel | ||||
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.
Click to access 2012-report.pdf
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:
https://s3.amazonaws.com/public-inspection.federalregister.gov/2013-08017.pdf.
In later posts, I will have information on how to use the Federal Register rule making portal to make comments.
Thanks,
Bill Huddleston
The CFC Coach
703-443-9780.
Read Full Post | Make a Comment ( None so far )Bill Huddleston, The CFC Coach, commends the Thousands of Federal and Non-profit Volunteers who Make the Combined Federal Campaign A Success Each Year
Huddleston said, “The CFC is actually one of the largest volunteer programs in the country, and that in addition to the thanking the donors that contribute to a particular charity, that there are thousands of federal volunteers who each fall work together to run successful workplace giving campaigns in their agencies. It’s absolutely fitting during National Volunteer Week to honor all the program and fundraising volunteers that help make the American non-profit sector the most vital in the world.”
Through the CFC, federal public servants have given more than $1 billion of their money to thousands of local, national and international charities over the past five years. In terms of actual giving, if the CFC were a foundation it would be the 14th largest foundation in the United States.
All CFC funds are unrestricted which means that the CFC is the single largest source of unrestricted funds for non-profit in the world. The general rule of thumb in the non-profit world is that unrestricted funds are three times as valuable as restricted funds.
Some of the articles about the CFC results have focused on the drop in donations, Huddleston said, “What should be recognized is that even after three years of pay freezes, and bashing by politicians that Federal public servants know that the contributions they make through the CFC really do make a difference.”
Read Full Post | Make a Comment ( None so far )Religious vs. Secular Non-profit Giving – An Apples to Oranges Comparison
Didn’t Anyone Ever Go to Sunday School?
The study done by the Chronicle of Philanthropy about the different levels of giving in the country is informative and interesting, but there are limitations inherent in tackling such a large and complicated subject. The first limitation is that since the study limited itself to taxpayers who itemize (in general, households earning more than $50,000) it ignores the level of generosity by households that don’t itemize on their tax returns, so I think all the statistics probably under report the actual level of American generosity.
The second problem is the one of comparing religious giving versus secular giving, which is at best an apples to oranges comparison, and in reality is an “apple-orange” to “orange-apple” comparison, by which I mean that there are elements of both in each type of giving. Sometimes when I read posts about religious giving in the non-profit forums, I really get the impression that the writers never attended Sunday School, and don’t really fundamentally understand how churches operate. If the principles of non-profit fundraising are applied to religious giving, it would be considered an abject failure and ludicrous. I can only speak about practices typical in Protestant denominations, but let’s take a look at it through the non-profit fundraising lens and you’ll see how ridiculous it looks from that perspective:
- We will solicit our members in person 60 times per year. There are 52 weeks of worship services, plus about 8 special offerings throughout the year (Christmas, Easter, One Great Hour of Sharing, etc.)
- We will publicly ask for your contribution in front of other people. (It’s called passing the plate during the offering).
- We will not provide individual thank yous (we will offer group thank yous).
- We expect you to fill out a card at the start of each year (a pledge) where you specify how much you will give each week/month/year. This is not really optional, and we will make a big show of you publicly turning in your pledge cards as part of the offering process.
If as a consultant on non-profit fundraising I presented that plan to one of my clients, I’d be laughed at the room, and probably never invited back.
Here’s what the difference is: Religious giving is not a charitable solicitation, it is an act of worship, and hence has a different set of social norms and customs. By definition, becoming a member of a church requires a “leap of faith” and the purpose of this essay is not to debate why someone chooses to become a member of a congregation, and why someone else does not. Each person makes their own choice about that.
Here are some examples of how there are elements of both secular and religious giving in each category. The Salvation Army is usually and deservedly credited with being one of the most efficient and effective charities in America, which it is. It is however, a church, the word “Salvation” in its name is not talking about the furniture and clothing salvaged and donated to it, it’s refers to saving their member’s souls. Many churches that I know of gather food donations which are then transported to local food banks, and often make up a significant portion of a local’s food banks supply. This doesn’t get counted in the IRS reports because it’s not a financial contribution, and since there’s no receipt (unlike donations to Goodwill, Salvation Army, Amvets, etc.) this act of giving doesn’t get recorded anywhere except as a food donation at the food bank. Obviously some portion of religious giving goes to support the physical plant and salaries of ministers and staff, but there are often community benefits that are not captured anywhere, but are of value. For example, in northern Virginia where I live, many churches’ Sunday School classrooms are used during the week by secular day care and pre-school non-profits. In my church there is an award winning pre-school that’s been there for forty years, and could not exist without the physical plant provided by the church, but that asset never shows up on the pre-school’s financials because it’s not theirs.
The apples to apples comparison is that both offerings to religious institutions and gifts to charity are tax deductible, but after that fact, trying to draw distinctions about differences and similarities is problematic.
I think it’s more important and productive to figure out ways where religious institutions and charities can more effectively work together. Another under-tapped resource in my opinion are the potential volunteers that religious congregations may be able to provide to charities that effectively use volunteers in accomplishing their mission.
Regards,
Bill
Bill Huddleston
The CFC Coach
MPA in Nonprofit Management, George Mason University
703-560-1825
P.S. Here’s the link to the Chronicle study:
http://philanthropy.com/article/How-The-Chronicle-Compiled-Its/133667/
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