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!
The pdf version with signatures of the letter sent to OMB can be found here:
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
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. 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.
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.
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
 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).
 Office of Personnel Management, Report C-17 CFC 2012 Pledge Report (Apr. 18, 2013).Read Full Post | Make a Comment ( None so far )
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!
Non-profits are not businesses. That simple fact is being ignored in the vast majority of economic mumbo jumbo currently written about non-profits. Non-profits can, of course, be businesslike in their operations: they can have efficiently run organizations and a well-trained staff, and they can certainly deliver superior results.
Non-profits are not businesses in that people give money to non-profits with no possibility of getting it back. Donating to a charity is not the same as investing in the stock market or putting money in a savings account or money market fund.
Non-profits are not businesses in that people volunteer to work at non-profits. Volunteers at a non-profit are actually making a double contribution. Not only are they working for free, they pay a personal “opportunity cost,” missing out on money they could be earning and time they could spend elsewhere if they were not donating time and talent to the non-profit. Most importantly, for many non-profits, if the volunteers were not there to help deliver the services, the non-profit simply could not exist.
Non-profits are not businesses in that people care so passionately about the non-profit’s mission they willingly donate time, money and energy to help the charity succeed. When was the last time you went to your local supermarket and said, “Hi, I’m here to work for you for free, where do I start?” Or, “Since you only charged me $80 for my groceries, let me give you an additional $20 just because I’m glad you’re here.”
When you apply the norms of non-profits to businesses, it becomes immediately apparent that non-profits bear little resemblance to typical businesses.
Non-profits are not businesses in that they are more complex than businesses, needing to satisfy many more stakeholders and constituencies before they are able to say, “Yes, we are successful.” Businesses really only need to satisfy their owners (and their customers), and yes, of course, they need to operate within the law. It’s also true that many businesses are good corporate citizens and donate lots of money to various charities; indeed, some of the best encourage volunteerism in their employees, and I applaud all of them.
The point, however, is that non-profits are more complex entities than businesses, and have many more constituencies than owners or shareholders. Non-profits must also satisfy the community; their board of directors; their service recipients; their donors; their volunteers; and their professional staff. Some that provide services on behalf of government contracts have many additional sets of requirements for service delivery, reporting, and government auditing regulations for contractors. Non-profits must also meet the legal requirements of being a non-profit (as defined by law and IRS regulations).
Some of the current efforts to come up with the dollar value of donated time or count the hours that one donates cheapen the whole concept of the non-profit sector. These efforts are doomed to failure because they miss the fundamental point of “Why?” Why does someone volunteer? Why does someone give money? I believe that the short, truthful, and unifying answer for all donors and volunteers is the response, “I care!”
Donors and volunteers naturally want recognition, and to know that their gifts (monies or personal effort) are being used effectively; they may give more because of the tax codes at certain times of the year. But the first and fundamental response is always, “I care, that is why I give,” or “I care, that is why I donate my time to this great non-profit.”
That is to be absolutely applauded and celebrated, and it is one of the unique and unifying qualities of being an American. We are the most generous people on earth, with Americans giving more than $260 billion in 2005 according to Giving USA. That fact should be recognized, celebrated, and applauded.
What Do All Non-profits Share?
So if non-profits are not businesses, what are they? All non-profits share a common purpose, and it is actually a very simple concept. They exist to make their community and the world a better place. Now granted, the exact definition of what constitutes “a better place” is not easily agreed upon, and differs widely among these non-profits. That’s fine. There are more than 1.4 million non-profits in the United States, and there are probably 1.4 million different answers to that question. I have decided to not list all 1.4 million mission statements from these organizations, but even without having read all of them, if you look for the common ground you’ll see that they believe that accomplishing their mission would make the world a better place.
To learn more about the ways that workplace giving can promote the common good, as well as provide leadership development opportunities, please go to http://www.cfcfundraising.com and request my special report about the Combined Federal Campaign (CFC).Read Full Post | Make a Comment ( None so far )
Nonprofit Leadership Development-Where is the best place to practice leadership skills?
By Bill Huddleston
Did you learn to swim by reading a book?
The answer of course is no, even if you did read about the different strokes, breathing methods and different types of kicks. Sooner or later, you actually had to get into the water.
In the realm of leadership development, the same principle applies. You can take very valuable and informative courses, you can read books, articles and blogs about the subject and talk to people as well as observe leaders in action. You can participate in valuable organizations that teach you and give you some experiential opportunities (such as Toastmasters International – which I highly recommend). To actually develop your leadership skills you have to lead people.
So where can you get practical experience in actually doing this? Eli Manning and Peyton Manning did not play their first football game in the Superbowl; Yo Yo Ma did not have his first concert at Carnegie Hall.
Even the best in the world find a good place to practice before the performance, and they devote the time and energy necessary to developing their skills before they go on stage whatever the specific type of stage is, including leadership in the non-profit sector.
Most leadership experts would agree that these skills are fundamental for all leaders:
• Interpersonal skills (including Team Building).
• Oral communication
• Written Communication
• Continual Learning
I would add that project management principles and skills are necessary for success in the 21st Century.
In the non-profit sector, whether you are an emerging leader eager to develop your own skills, or someone responsible for the leadership development program of your organization, there exists a unique opportunity to develop these skills, by participating in workplace giving campaigns, such as the Combined Federal Campaign (CFC), Americas Charities Campaigns, and United Way campaigns, etc.
Workplace giving is a unique method of fundraising within the non-profit sector, and many think of it only in terms of fundraising. But workplace giving campaigns have unique benefits – which I call “Hidden Treasures.” Briefly, in workplace giving, the actual solicitations are performed by the employees of the organization, during the workday, hence the name “workplace giving.”
Some of the other “Hidden Treasures” of workplace giving campaigns include conducting inexpensive market research, leverage of your development efforts, and exposure to a much wider audience than is possible on your own, plus developing multiple year revenue streams.
However, the focus of this article is leadership development, and in workplace giving campaigns there are campaign events known as “charity fairs.” In a charity fair, selected charities from the workplace giving catalog are invited to come to the organization’s offices, and staff a table with their representatives, give out their materials, and answer any questions that the potential donors might ask. One of the biggest “hidden treasures” of workplace giving campaigns is that they can be the ideal “practice field” for emerging non-profit leaders.
Charity fairs are one of the best leadership development opportunities that exist in the non-profit world. Non-profits that have learned how to integrate workplace giving campaigns into their overall leadership development efforts can use them to provide low risk, high value opportunities to their staff in a number of areas, including project management, public speaking, and team building. For example, the skills that can be developed and practiced through participation in charity fairs include:
Oral Communication – public speaking skills –you can practice your “elevator speech” dozens of times in the course of a campaign.
Team Building – the non-profit action officer can get practical experience in creating and leading a team, whether they are paid staff or volunteers.
Listening Skills – the non-profit team will have the opportunity to listen to hundreds of people in your community – what are they saying, what’s most important to them, etc. These are your potential donors and supporters – does your mission resonate with them, are they aware of your organization, etc.?
Written Communication – there are multiple opportunities to develop one’s writing ranging from simple memos to an analysis of the comments from the members of the community that were made at the charity fairs that is prepared for the executive and board leadership.
The paradox of workplace giving programs is that precisely because they are not a high risk or high cost program they can be an ideal “practice field or rehearsal hall” for leadership development. No one is going to “blow” a major gift solicitation at a charity fair, but the future leader can gain experience in “reading people.”
To learn more about the world’s largest workplace giving campaign, the Combined Federal Campaign (CFC), please go to the http://www.cfcfundraising website and request your copy of my free report about the CFC, which includes a brief description of how to apply for inclusion in America’s largest workplace giving campaign, the CFC.
Bill Huddleston, CFC Expert
MPA in Nonprofit Management