Can a PCFO hold a fundraiser where part of the cost goes to the
base cost and the remainder to the CFC (i.e. A golf tournament where
the entry fee is $50 with $30 to base cost of the event and $20
950.602 states, " all approved fundraising events the donor must
have the option of designating to a specific participating organization
or federation or be advised that the donation will be counted as
an undesignated contribution and distributed according to these
regulations. Therefore, a golf tournament like the above mentioned
one would have to be an open to the entire general (not just government
employees) public with the proceeds going to undesignated.
Can a fundraiser for a charity be permitted outside of the federal
agency's 6 week campaign?
NO. The CFC time frame is September 1 through December 15 annually.
However, we have established that acceptance for special solicitations
on Military Installations must meet the following criteria: 1) The
request to OPM must come directly from the Commander of the base
or a designated representative of the Commander. Requests from charitable
organizations are not acceptable. 2) All requests must adhere to
the scope of the CFC as defined in 5 CFR 950.102 which states that
The CFC is the only authorized solicitation of employees in the
Federal workplace on behalf of charitable organizations. . . Except
as provided in this section, no other solicitation on behalf of
charitable organizations may be conducted in the Federal workplace.
Upon written request, the Director may grant permission for solicitations
of Federal employees, outside the CFC, in support of victims in
cases of emergencies and disasters. These emergencies and disasters
are defined by the Federal Emergency Management Agency (FEMA). 3)
The CFC regulations do allow for the following activities, as outlined
in 5 CFR 950 102(b): The collection of gifts-in-kind, such as food,
clothing and toys or to the solicitation of Federal employees outside
of the Federal workplace as defined by the applicable Agency Head
consistent with General Services Administration regulations and
any other applicable laws or regulations. Within these acceptable
activities, the Office of Personnel Management (OPM) does include
the act of volunteering time and services. (Solicitation is clearly
defined in 5 CFR 950.101 as Any action requesting money, either
by cash, check or payroll deduction, on behalf charitable organizations.
4) We expect that the Base Commander define in the letter to OPM,
the nature of the activity and whether or not, it will occur in
the Federal workplace, as defined by the Base Commander. What is
considered Federal workplace is the interpretation of the Commander.
His/her approval or denial of the activity must also be indicated.
If the activity does NOT occur in the Federal workplace, as defined
by the Commander or applicable Agency Head, and is consistent with
any other applicable laws or regulations, OPM will concur with the
Can CFC events be underwritten by a private sector entity?
All CFC events should be budgeted for in CFC expenses. If an agency
wishes to sponsor an event they must do so in compliance with their
own Office of General Council and Ethics Office. The CFC is not
permitted to publicly endorse any entity due to underwriting. No
one organization is permitted to benefit from any underwriting of
Is it possible to make the donor brochure available electronically?
Have any campaigns done this?
All local CFC's are urged to provide the brochure electronically
as a complement to the hard copy which must be produced and distributed
to all federal employees annually. (E.g.: Denver,CO) The national
list is on the OPM CFC home page at www.opm.gov/cfc. A group of
federal employees called Employee Express is working towards automating
the entire campaign.
Is the International section of the brochure included in the annual
rotation per OPM instructions?
A. Yes. In 2002 the order will
be Local, National, then International.
Q. Can a PCFO change
the way agencies are listed in the brochure?
NO. The national and international lists must be a faithful reproduction
of the list provided by OPM. The order of the listing within each
part of the brochure must be decided by random drawing. The order
of organizations within each federation will be determined by that
federation. The order within the national and local unaffiliated
groups will be alphabetical. For more information see Part 950.401(g)(2).
Nor can these components be produced as separate brochures. OPM
will require brochures to be reprinted if sections are separately
Q. Are there any uniform
internal regulations for special events?
Special events held in conjunction with the CFC are permitted during
the six week period if approved by the appropriate agency head or
government official, consistent with agency ethics regulations.
However, in all approved fundraising events the donor must have
the option of designating his/her contribution to a specific organization
or federation or be advised the contribution will be counted as
an undesignated contribution. For more information see Part 950.602.
Because of the complexity of ethics and/or state laws, CFC special
events must be addressed on a case by case basis.
Q. Many donors only contribute
1 dollar per pay period. Has OPM considered a nationwide pledge
minimum of 2,3, or 5 dollars to increase revenue?
A. Part 950.901(e)(1) states,
The minimum amount of the allotment will be determined by the LFCC
but will not be less than $1 per payday, with no restriction in
the size of the increment above that minimum. OPM does not plan
to change the regulatory minimum since the LFCC can determine its
own minimum for their specific CFC.
Q. Can a federal employee
donate to a local agency in a neighboring CFC campaign area?
A. No. As stated in 950.103(h),
a federal employee may participate in a particular CFC only if that
employee's official duty station is located within the geographic
boundaries of that CFC. Campaign boundaries are strictly determined
and approved by OPM. (See web page at http://www.opm.gov/cfc
for a listing.)
Q. What is the latest
on solicitation of retirees? Can a retiree who wants to give do
so through payroll deduction?
A. At this time, a federal
retiree may make a one time contribution to the CFC. However, retirees
can not be solicited but are to be provided with the opportunity
to give should they wish to do so. OPM and a National Retiree Access
Committee tested retiree giving through annuity deduction during
the 2000 CFC. Future roll-out will be based on test results
and evaluations following the 2000 testing process.
Q. Can CFC donors who
give above a certain level be listed in a PCFO publication or recognition
ceremony? Do we have to get permission from all of the donors? Is
it a breach of confidentiality?
A. NO. If the federal employee
indicates he/she would like an acknowledgment from the charitable
organization to which they designated his/her gift, the PCFO must
forward those names and addresses to the recipient organizations.
The amount of the contribution SHOULD NOT be released at any time.
The PCFO may not use donor information for any other purpose. For
more information see Part 950.601.
Can new hires be asked to give when they join a federal agency
even if it is not during the campaign?
A. NO. Federal employees may
be solicited to give only during the CFC campaign period.
Q. I have heard that
the amount designated by donors wishing to be acknowledged can not
be released... is this true?
A. YES it is. Donor amounts
may never be released.
Q. Is there any problem
with extending the 6 week period for large agencies?
A. Any extensions on campaigns
past the six week period may be authorized by the LFCC. No
campaign may be extended beyond December 15 for any reason.
an LFCC required to advertise for the local application period or
keep any type of data base and mail applications to charities annually?
A. YES. Per guidance
provided by OPM in OPM Memorandum 89-3, LFCC's must ensure that
local agency's are given adequate notice of the application period
and process. LFCC's can provide such notice through various
public service announcements which include but are not limited to
local newspapers, radio and television stations, etc. The
LFCC should also ensure the PCFO maintains a mailing list of local
agencies that have requested information.
Q. Why is a d.b.a. (Doing
business as) required from the IRS for a name change? Can a State
issued d.b.a. be used instead of the IRS d.b.a.?
A. OPM will accept a d.b.a.
issued by the IRS or the State. If a nonprofit organization
elects to do business under a name different from the one on their
IRS Form 990, they must obtain a d.b.a. through either the IRS or
the State and submit it with their application. While
a charity's eligibility status will not be decided based on the
name , the name by which it is listed in the CFC
brochure, should it be found eligible, will depend on official documentation
from the IRS or State sources. Additionally, ALL charities
are required to include their Employee Identification Number (EIN)
in their 25-word statement regardless of whether they are listed
under their legal name or a d.b.a.
What is considered a "complete" IRS Form 990?
A. A completed IRS Form 990
will include the entire form 990 itself, and all applicable
supplemental/supporting statements. It must also contain all
Q. Is a local agency
required to have all independent eligibility information or are
they allowed to use national or regional materials, especially if
they are a chapter of a national organization or a site of a regional
A. Yes. Regardless or
weather the agency is a chapter or not, it must apply with information
pertaining to that particular office. This includes an independent
audit, IRS Form 990, 501(c)(3) letter, annual report, etc.
National and regional information is not permitted for local entities.
Can an applicant provide an audit on appeal if it isn't ready by
the application deadline?
A. NO. The required certifications
and documentation must have been completed and submitted prior to
the application filing deadline. Applications received that
are incomplete may not be perfected during the appeal process.
Q. If an agency is a
state chapter of a national agency is that considered statewide
A. No. An organization applying
for statewide presence must prove that it provides or conducts REAL
services, benefits, assistance or program activities covering 30
percent of a states geographic boundaries or conducting real services,
benefits, assistance or program activities affecting 30 percent
of the state's targeted population. This cannot be met solely on
the basis of services provided through an "800" telephone number
or the US Postal service.
Q. State-wide presence
vs. Local presence... please define.
A. Local presence is defined
as a staffed facility, office or portion of a residence dedicated
exclusively to that organization, available to members of the public
seeking its services or benefits. The facility must be open at least
15 hours a week and have a telephone dedicated exclusively to the
organization. State wide presence is acquired when an organization
proves it provides or conducts real services, benefits, assistance
or program activities covering 30 percent of a state's geographic
boundaries or affecting 30 percent of a state's population. For
more information, see 5 CFR Part 950.204. (The strongest case for
state-wide and local presence should be made to the LFCC. OPM prefers
that this assessment be appropriately decided at the local level;
however, applicants still have the right to appeal if necessary.)
Q. How does the contiguous
rule differ from the state-wide?
A. Contiguous rule is when
a charitable organization provides services in a geographical area
which expands into two or more CFC geographical boundaries. That
organization would then meet local presence requirements in both
CFC areas. Statewide presence is when a charitable organization
provides real services, benefits, assistance or program activities
covering 30 percent of a state's geographic boundaries or affecting
30 percent of a state's population
Q. If a charitable organization
lists with a federation during a campaign, is that federation required
to complete the cycle of distribution. If the Charitable organization
signed up with another Federation can the new federation take over
distribution payments before the cycle ends?
A. When a charitable organization
joins a federation it must allow that federation to complete one
full campaign cycle involving distribution payments. This
does not prevent the charitable organization from signing with a
new federation but the original federation must complete the distribution
cycle. For example, a member organization of a federation
in the 2000 CFC must allow that federation to complete its distribution
for that member through January, 2002. The member organization is
permitted to signed with another federation during 2001 but it may
not take the distribution away from the original federation.
Q. Can a local federation
participate in more than one campaign... particularly neighboring
A. Yes. However, it must separately
apply to all CFC's and meet the local presence or statewide presence
Q. What does the moratorium
on national and international federations mean?
A. The moratorium prevents
any new national or international federation form joining the CFC.
This does not effect charitable organizations agencies in the CFC.
Any organization can still join an existing federation or join the
CFC as an unaffiliated. However, the moratorium
that was in place for the 1998-2000 campaigns will be lifted for
2001 . This means any new federation may now
apply for eligibility.
Q. Can a federation apply
for inclusion in the CFC brochure without including its member organizations?
A. Not as a federation. It
can be listed as an unaffiliated if it meets all required criteria.
Q. Since a local or regional
federation can be in more than one CFC, if one CFC accepts the federation
can the neighboring campaign accept the application without having
to review all the applications of all its members?
A. NO. Each LFCC must fully
review any and all charitable organizations applying for eligibility
regardless of their status in other campaign areas.
Q. Can you have a local federation
with less than 15 eligible member organizations? What if they have
15 eligible member organizations but one member organization elects
to list with another federation taking them to 14 agencies?
A. A federation must have 15
qualifying member organizations to be deemed eligible for participation
in any CFC. In cases where federations have the same organizations
eligible, the organization must write a letter to the PCFO determining
which federation they want to be listed under during the campaign.
Federations are only listed if they have 15 eligible members on
their listing. If a federation falls to 14 or fewer member organizations,
they should request the member organizations be listed as unaffiliated.
Q. Who can the PCFO call to
get answers to questions regarding checks from the US treasury when
the check only has a number to identify the payroll office and not
A. OPM provided a list of payroll
centers on the web page for download by all PCFOs. If the PCFO has
made every attempt and is unable to locate the correct payroll office
they may call OPM for assistance. DO NOT FORWARD CHECKS TO THE OPM/CFC
Q. When will Electronic Funds
Transfer (EFT) be required by the government?
A. Initially, federal payments
were required to be made by EFT as of January 2, 1999 in compliance
with the Debt Collection Improvement Act of 1996. While this deadline
has been extended, we fully anticipate it going into action at any
time. OPM has providing a listing of federal payroll offices
to all PCFO's. It is the PCFO's responsibility to forward their
EFT information to the appropriate payroll offices. The PCFO MUST
provide payroll offices with their EFT information or they WILL
NOT receive their pledges.
Q. Is there a limit on the
amount that can be paid in a one time disbursement?
A. The LFCC determines the
Q. Who is required to complete
a compliance assessment guide for CFC?
A. The compliance assessment
guide must be completed by the LFCC and the PCFO and signed by a
certifying official of the LFCC. The financial report
must be completed by a certified public accountant or CPA firm,
must be conducted in accordance with generally Accepted Accounting
Standards and must end in conformity with Generally Accepted Accounting
Principles. However, the compliance assessment guide is intended
as an internal document and should not be part of the CPA audit.
OPM will request a copy of the compliance assessment guide from
time to time.
Q. Who is the proper person
to approve and sign a compliance audit for CFC?
A. The compliance audit must
be signed by a certifying member of the LFCC.
Q. Can the PCFO charge the
current rate of interest to the CFC for dollars that the PCFO lends
to it for the campaign expenses?
A. If the PCFO obtains a commercial
loan to pay for costs associated with running the campaign, the
amount of a reasonable rate of interest is an allowable campaign
expense, subject to the approval of the LFCC when the PCFO budget
is submitted. For more information see Part 950.106.
Q. What is required by OPM
when a recipient agency does not cash their CFC check(s)?
A. The PCFO must make every
attempt to contact the charitable organization and determine if
it is still viable. If the charitable organization no longer exists,
the PCFO must determine an organization which provides services
most like the organization in question and write to OPM requesting
the funds be distributed to the replacement organization. If no
organization within a CFC provides similar services, the PCFO should
write to OPM requesting permission to distribute the funds in an
Q. What is the role of a Loaned
Executive and how was the program initiated?
A. The Loaned Executive program
was initiated in 1971 by Presidential Order. A Loaned Executive
is a Federal Employee that is "loaned" by their agency to work on
the CFC. The Loaned Executive is usually relieved of all work
duties for the period they are working on the CFC. The role
of a Loaned Executive is to conduct all solicitations among the
federal employees in a campaign area. They are usually trained by
the PCFO and work out of the PCFO for about a 2 - 3 month period.
Q. Is there any regulatory
reason why Loaned Executives are rotated every year?
A. No. The agreement must be
between the Loaned Executive and his/her supervisor. This issue
must be addressed at the LFCC level.
Q. Can a federal retiree be
asked to serve as a Loaned Executive?
A. No. A retiree can volunteer
to help on the campaign but cannot represent any government entity
or solicit federal employees.
Q. Can Loaned Executives serve
part time on CFC and part time on PCFO work?
A. NO. Federal employees acting
as Loaned Executives for the CFC are prohibited from working on
any other campaigns.
Q. Which part of Loaned Executive
training can be done in conjunction with the PCFO?
A. General training which does
not include any detailed information on the PCFO, its agencies or
solicitation practices on its behalf.
LOCAL FEDERAL COORDINATING
COMMITTEE (LFCC) and PRINCIPAL COMBINED FUND ORGANIZATION (PCFO)
Q. Can the CFC announce/set
an annual financial goal?
A. The overall national CFC
does not set a financial goal. Locally, the LFCC can set a financial
goal for that CFC area. Each federal agency may also set a financial
Q. Are LFCC's required to
hold public meetings to announce local eligibility decisions?
A. No. Local organizations
which meet all criteria and are eligible must be notified via facsimile
or US Postal Service within 15 business days after the closing date
of the application period. Denial of the application by the LFCC
must be sent via US Postal Service certified or registered mail
with a return receipt
Q. Is it permissible to have
your own CFC logo?
Q. Can a PCFO charge CFC the
interest lost for paying campaign expenses?
A. A PCFO may ONLY charge interest
to CFC if the PCFO obtained a commercial loan. Any loaned
obtained by the PCFO must first be approved by the LFCC.
Q. If a federation is accepted
by the LFCC one year with all of its member organizations can the
federation just re-certify the members organization without filling
out the application even if they go above 25% administrative costs?
A. A federation must apply
on an annual basis to the CFC and, after the first year, all of
its existing member organizations application should be kept on
file at the federation. The LFCC can request any or all of these
applications at any time. If an existing member does not meet an
eligibility criteria the federation must include that information
in their annual application. The LFCC may also request the full
application of any new member organizations be submitted with the
Q. Can the LFCC waive and/or
redefine OPM regulations?
A. NO. An appeal and/or waiver
(whichever is appropriate) must be specifically addressed to OPM.
Q. Do CFC Managers also handle
A. Some CFC Managers also manage
other accounts for the PCFO. However, all expenses related to work
done on behalf of the PCFO must be separate from the CFC budget.
This includes the salary of the CFC Manager and all related expenses.
Q. As an LFCC member, should
the travel, per diem, and registration fee related to this workshop
be paid out of CFC funds or by my employing agency?
A. Travel on CFC business should
be budgeted for when the LFCC approves the PCFO annual budget.
Q. Can an Agency Head not
allow his/her agency to be involved because they themselves do not
believe in CFC?
A. The Combined Federal Campaign
was established by Presidential Order. Once a campaign has been
established, agency heads may not discontinue solicitation of federal
Employees within their agency without the written approval of the
Director of OPM.
Q. Can agencies (local) speak
about their programs at CFC events?