Hill asks OMB to intervene with OPM on CFC Rules

Posted on April 17, 2014. Filed under: Combined Federal Campaign - CFC, Fundraising, Leadership, Non-profits, Office of Management & Budget (OMB), Office of Personnel Management (OPM), White House | Tags: , , , , , , , , , |

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.[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.


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).

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CFC Congressional Hearing on Wednesday, June 26, 2013

Posted on June 19, 2013. Filed under: Combined Federal Campaign - CFC, Fundraising, Leadership, Non-profits | Tags: , , , , , , , , |

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!

Thank you for your great support to Save the CFC.        Many of you responded and submitted comments to the Federal Register and       to OPM and have worked with us to connect with key members of       Congress.  This combined effort resulted in nearly 800 comments       entered into the public record and almost 20 key visits to Congressional       offices.We are pleased to announce that your work, along with our       partner federations, to Save the CFC has resulted in a Congressional       Hearing scheduled for June 26, 2013.

Hearing       Date:  June 26, 2013
Hearing Subject:        To help Congress “better understand the impact” of what       OPM is proposing for the CFC
Location:  Rayburn       House Office Building, Room 2154
Time:  1:30       p.m.
Duration:  Approximately       60-90 minutes

We encourage you and others from your organization to       attend.
A large turnout will serve as a testament to the concerns held by many       nonprofit organizations. If you plan on attending the hearing, please let       us know by emailing Geoff Rixon at GRixon@charities.org. Also, please       allow time to go through security and locate the hearing room.

It is our understanding the hearing is informational in nature and will       allow key members of Congress to become familiar with the proposed       changes and the nonprofit sector’s concerns about them.  The hearing       is under the auspices of the Federal Workforce, U.S. Postal Service, and       Census Subcommittee chaired by Rep. Blake Farenthold (R., Tex.).  It       is a subcommittee of the House Oversight and Government Reform       Committee.

Witnesses are being selected by the subcommittee staff, and we are active       in the process of making recommendations.  We anticipate witnesses       will include representatives of impacted charities, a member of the Save       the CFC federation coalition, OPM, and perhaps others.

Following the hearing we will report back to you and let you know what       actions to take.

If you have any questions, please contact Barbara Funnell at BFunnell@charities.org or Robyn Neal at RNeal@charities.org.

Thank you for helping us keep the CFC viable!

Steve Delfin
President & CEO, America’s Charities

Copyright © 2013       America’s Charities, All rights reserved.

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


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