wwwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780Back to ...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
wwwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780Why Does...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by B...
Back to the Drawing Board! Analysis of OPM Proposed CFC Changes
Back to the Drawing Board! Analysis of OPM Proposed CFC Changes
Back to the Drawing Board! Analysis of OPM Proposed CFC Changes
Back to the Drawing Board! Analysis of OPM Proposed CFC Changes
Back to the Drawing Board! Analysis of OPM Proposed CFC Changes
Back to the Drawing Board! Analysis of OPM Proposed CFC Changes
Back to the Drawing Board! Analysis of OPM Proposed CFC Changes
Back to the Drawing Board! Analysis of OPM Proposed CFC Changes
Back to the Drawing Board! Analysis of OPM Proposed CFC Changes
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Back to the Drawing Board! Analysis of OPM Proposed CFC Changes

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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.

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Back to the Drawing Board! Analysis of OPM Proposed CFC Changes

  1. 1. wwwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780Back to the DrawingBoard!An Analysis and Recommended Responses to theProposed Changes to theCombined Federal Campaign (CFC) Regulationsby Bill Huddleston, The CFC Coach
  2. 2. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 2IntroductionMy name is Bill Huddleston, and I have an extensive background with the CFC in both Federal and non-profitroles and I have significant concerns about proposed changes to the regulations that govern the CombinedFederal Campaign (CFC).I believe that as proposed, they will cause great harm to the CFC, especially small non-profits, whether local ornational, and in many instances the proposed regulations are either in direct contradiction or ignore thetestimony presented during the CFC-50 Commission Open Meetings, or include massive changes to the CFCoperations that were never discussed in the open meetings, and thus no one had a chance to address theseissues.I know that Congressman Davis and Congresswoman Byron did an excellent job of chairing the CFC-50Commission, but the many of the regulations proposed by OPM either ignore the work of the CFC-50Commission, or go far beyond what was discussed in the CFC-50 Open Meetings. The charge to the CFC-50Commission was to work on ways to improve the CFC for its next 50 years, not to destroy it, which is what theproposed regulations will do, if implemented.What follows are a brief primer on how the CFC is currently organized and structured, and then a section bysection analysis of the proposed regulations, along with what I recommend as the recommended action, whichin many cases is to have OPM go “Back to the Drawing Board!”In addition to this document, I have created open groups on Facebook and LinkedIn, named SAVETHECFC as aplace for people to comment and share information about the proposed changes to the CFC and the impact thatthey would have.Bill HuddlestonThe CFC CoachMPA in Nonprofit Management, George Mason University
  3. 3. wwwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780Why Does the CFC Matter?Why Does OPM Want to Kill the Golden Goose ofAmerican Philanthropy?Background on Combined Federal Campaign and theproposed changes to the CFC regulationsIn order to help people understand how massive and far-reaching theproposed changes are to the current structure and methods of the CFC,this is a brief synopsis of the current structure, plus some backgroundon the work of the CFC-50 Commission, which was established by OPMin 2011 and issued its recommendations for improvements to the CFC inJuly, 2012.The Combined Federal Campaign (CFC) matters because through it, andthe generosity of the hundreds of thousands of Federal public servantswho are the CFC donors, millions of Americans and others throughoutthe world are helped by the actions and services provided by the morethan 25,000 non-profits that are enrolled in the Combined FederalCampaign. In the fall 2012 campaign, more than $258 million dollarswere raised, and in terms of actual giving, if the CFC were a foundation,it would be the 14thlargest foundation in the USA. Over the past fiveyears, the CFC has generated more than $1 billion of unrestrictedrevenue for thousands of local, national and international CFC charities,which makes it the single largest source of unrestricted funds in thenon-profit sector.The CFC, which was established in 1960, is the federal government’sworkplace giving program, and is administered by the Office ofPersonnel Management (OPM). The CFC used to have both a visionstatement and their mission statement on the CFC Operations homepage that were succinct and inspiring:CFC Vision Statement:A government that encourages and enables active employeeparticipation in community and that fosters collaboration withbusiness and the nonprofit sector to achieve this goal.CFC Mission Statement:To promote and support philanthropy through a program that isemployee focused, cost-efficient, and effective in providing allfederal employees the opportunity to improve the quality of lifefor all.Sometime in the last decade, OPM removed the vision statement, andthey seem to have forgotten what the mission statement really means,having just completed an analysis of the proposed changes to theCombined Federal Campaign regulations, that are massive and harmfulto the CFC if implemented as proposed, but let’s first look at the presentsetup.Workplace giving is a unique type of fundraising in the non-profit sector,and it’s important to understand the complex synergy that exists amongall the parts. In the current structure of Combined Federal Campaign,these are the major components: Recipients of services from CFC charities - the people and otherbeneficiaries of the services provided by the 25,000 CFCcharities. (Millions of people).
  4. 4. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, TheCFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 4 CFC Donors -The Federal Public Servants who are the CFCDonors (more than 800,000). CFC Charities - The 25,000 non-profits that are enrolled in theCFC, including approximately 1500 that are national orinternational 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 incommon, e.g. the member of Community Health Charitiesfederation are all health related, EarthShare hasenvironmentally oriented non-profits as its members, and themembers of Children’s Charities of America deal with issuesaffecting children to mention just a few. Federations can benational, international or local. Federations assist theirmembers with their CFC applications, provide joint marketingsupport, and provide other campaign related services. U.S. Federal agencies , that conduct the CFC campaigns, andthis means anywhere in the world where there is a US Federalinstallation, (including places like Afghanistan and Iraq) there isa CFC campaign, as well as all civilian, military and U.S. Postalservice facilities in the U.S. CFC Campaign Volunteers - The thousands of Federalemployees who volunteer each year to help run their agency’sCFC campaign, solicit funds, organize charity fairs, and conductthe overall management of a campaign within a Federal agency. CFCs are organized regionally, and currently there are 184 CFCregions:o Local Federal Coordinating Committee (LFCC ) Eachregion has a Federal “Board of Directors” called theLFCC that is responsible for reviewing and approvingapplications for local charities to enroll in the CFC; and itis responsible for the selection of the PrincipalCombined Fund Organization (PCFO) which arecontractors to the government and there is a one toone match, so currently there are 184 PCFOs.o Principal Combined Fund Organization (PCFO) has twomajor responsibilities: the overall management of theCFC campaign in its region; and the fiduciaryresponsibility of sending the CFC donors gifts to the CFCcharities 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 largeFederal installations (e.g. Army, Navy, Marine, Air Force,Veteran Affairs hospitals, Postal Service regionalcenters, etc.), have larger staffs than in the moresparsely populated regions. Office of Personnel Management (OPM) has overallresponsibility for the Combined Federal Campaign, including theCFC regulations and any appeals from non-profits that had theirapplications denied. The OPM CFC office has a small staff ofless than twenty. It approves the applications of national andinternational charities, which currently number about 1500.
  5. 5. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, TheCFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 5 Federal Executive Boards (FEB) and Federal ExecutiveAssociations (FEAs). In areas outside of the Washington DCarea, regional entities responsible for regional government wideoperations, and often have the LFCC function as part of theirresponsibilities. CFC-50 Commission On the occasion of the 50thAnniversary ofthe CFC in 2011, there was a special commission formed thatwas chaired by two respected former Congressmen, the Hon.Tom Davis (R) from Virginia and the Hon. Beverly Byron (D) fromMaryland, each of whom had experience with the governmentreform committee when in Congress. The CFC-50 Commissionconducted a series of open meetings, and issued a final reportin July 2012 that contained 24 recommendations to OPM onways to improve the CFC. Videos of the open meetings areavailable on YouTube, go to opm.gov/cfc and choose the CFC-50heading to get to the links to the videos. Federal Retirees: Retirees currently cannot have CFCdesignations deducted from their retirement pay, although theprojections are that thousands of Federal retirees wouldparticipate in the CFC if they could.CFC – The Golden Goose of American PhilanthropyWhen I give workshop presentations about the CFC, my workshop titleis: “CFC—The Golden Goose of American Philanthropy.” I use that titlebecause, just like the farmer in that fairy tale, most people do notunderstand how the CFC works; they just know it produces money fortheir non-profit, if they know anything at all about it. Depending upontheir non-profit, it may produce a lot, or it may produce a little, andnon-profit leaders are often not sure how it works, and what if anythingthey 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 resultsthat help millions of people every year, having generated $258 million in2012. And in a miracle of government function, it actually has less redtape than almost any grant.The synergy that exists among the component parts that I outlinedmeans that in the current, decentralized structure, the workload isspread out among many different players, and that there are benefits toall.Massive Proposed Changes to CFC Regulations by OPMThe Office of Personnel Management has proposed sweeping, andmassive changes to the regulations governing the Combined FederalCampaign, and even though they say that they basing the proposedchanges on the CFC-50 report; in many cases what they’re proposingwas never discussed; or goes far beyond what was discussed in the CFC-50 Open Meetings and Final Report; or ignores what the CFC-50 Reportrecommended.The proposed regulations are an odd combination of massiveoverreach; destruction of hundreds of private sector non-profit jobs inlieu of new Federal positions (which have not been approved orbudgeted); hiding important sections in illogical sections of theproposed regulations, while simultaneously making multi-million dollarerrors in the same section (in the section dealing with Federal retirees);
  6. 6. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, TheCFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 6making small irritating changes that are harmful to the CFC donorsinformation gathering and make things harder for both the donor andthe CFC charities; the destruction of multiple business models that havebeen successful for decades without adequate discussion, and there area few good ideas thrown in as well. In many areas the proposedregulations are contradictory with significant differences about whatthe stated purpose is, and what the actual effect will be.As proposed, the regulations are: Harmful to CFC charities, both large and small, and willdefinitely 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 leadershipdevelopment of their workforce Harmful to the non-profit employees of the PCFOs,where all 184 private sector organizations areeliminated which means that at least 450 non-profitjobs now go to Federal positions. Harmful to the beneficiaries of the services provided bythe CFC charities. When just one of the items in theproposed regulations has been tried at the municipal orstate level (going all electronic) there has been 50%drops in revenue. If the regulations are implemented asproposed, a 75% drop in revenues is likely. Presume a massive transfer of functions from theprivate sector, non-profit PCFO workforce to theFederal workforce.Hidden Regulations – Federal Retirees SectionSome of the proposed regulations are poorly organized, with no logicbehind them, and they have the effect of hiding significant andimportant changes. For example, the section dealing with Federalretirees instead of being in a “Donors” section is hidden in the“establishing Regional Committees” section, ignores the CFC-50Commission recommendations, and makes a multi-million dollar error injudgment, all in less than a paragraph. Here’s the link to the sectionthat deals with retirees, hidden in the phrase “and also eliminatesrestriction on soliciting non-Federal personnel.” 950.103Establishing Regional Coordinating Committees.I have posted my analysis of the proposed CFC Regulations on theCFCTreasures.wordpress .com site and on the SAVETHECFC LinkedIn andFacebook Groups. To make it easier to follow the impact of theproposed regulations, the analysis contains the OPM proposedregulation, the OPM analysis, my analysis, and recommended actions ina table form.Federal Government Public Comment Period Closes June 7, 2013.This is the bad news, the good news is that these are proposedregulations, and we are in the Public Comment Period, which closesJune 7, 2013. By law Federal agencies must put out proposedregulations for public comment, and they must respond to all issuesraised before implementing the regulations. This is your opportunity toaffect public policy in a meaningful way, and to stop the regulationsfrom being implemented as proposed. The overall message is thatthe regulations as proposed are harmful, and OPM needs to goback to the drawing board.
  7. 7. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, TheCFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 7There are two ways to comment: Send a written letter to the OPM’sDirector of the Combined Federal Campaign, Keith Willingham or submityour comments via the electronic comment function of the FederalRegister.Subject: RIN 3206-AM68, Solicitation of Federal Civilian and UniformedService Personnel for Contributions to Private Voluntary OrganizationsReference Number: RIN 3206-AM68Dates: OPM must receive comments on or before June 7, 2013Here are the links to the proposed changes to the CFC regulations.URL: https://www.federalregister.gov/articles/2013/04/08/2013-08017/solicitation-of-federal-civilian-and-uniformed-service-personnel-for-contributions-to-privateShorter URL: https://federalregister.gov/a/2013-08017HERE IS THE SPECIFIC PAGE TO COMMENT ON THE PROPOSED CFCREGULATIONS:http://www.regulations.gov/#!docketDetail;rpp=100;so=DESC;sb=docId;po=0;D=OPM-2013-0006
  8. 8. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 8About the Author:Bill Huddleston shows non-profits how to get the most out of the Combined Federal Campaign (CFC), including howto use it to generate unrestricted funds, and how to use workplace giving as an integral part of the non-profit’sleadership development program. He is the author of many articles on workplace giving and leadership development.His blog is at www.cfctreasures.wordpress.com.Bill earned his MPA in Non-Profit Management from George Mason University, served in the Federal sector, and hasworked extensively in the non-profit world as well. In his Federal career he served in many CFC roles includingdeputy campaign manager, communications chairperson, special events chair, and Loaned Executive. He specializesin creating information resources about the CFC, and he also presents lectures to university audiences on non-profit management and fund-raising.Bill is on the faculties of the Foundation Center and the Center for Nonprofit Advancement in Washington, D.C.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 $258million dollars generated annually by the CFC, please don’t hesitate to contact me at BillHuddleston@verizon.net or by phone at 703-434-9780.
  9. 9. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 9FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONSolicitation of Federal Civilian andUniformed Service Personnel forContributions to Private VoluntaryOrganizationsDocket ID: OPM-2013-0006Agency: Office of Personnel Management (OPM)Parent Agency:Summary:The United States Office of Personnel Management(OPM) is issuing a proposed rule to amend the CombinedFederal Campaign (CFC) regulations in order tostrengthen the integrity, streamline the operation, andincrease the effectiveness of the program to ensure itscontinued success..RIN: 3206-AM68Impacts and Effects: NoneCFR Citation: 5 CFR 950Priority: Substantive, Nonsignificanthttp://www.regulations.gov/#!docketDetail;D=OPM-2013-0006SUPPLEMENTARYINFORMATIONPublication Date:Monday, April 08, 2013Agency:Office of PersonnelManagementDates:OPM must receivecomments on or beforeJune 7, 2013.Comments Close:06/07/2013Entry Type:Proposed RuleAction:Proposed rule.Document Citation:78 FR 20820Page:20820 -20832 (13 pages)CFR:5 CFR 950RIN:3206-AM68Document Number:2013-08017Shorter URL:https://federalregister.gov/a/2013-08017Analysis by Bill Huddleston,The CFC Coach, MPA in Non-profit Management.CFC Experience:DonorAnonymous DonorKeeper of CFC statistics forcommanding GeneralKeyworkerCharity Fair ChairCommunications ChairDeputy Campaign ManagerRecipient – CFC DirectorsAwardLoaned Executive during the9/11 CFC Campaign YearCFC Consultant to non-profitsAuthor/Speaker about CFC,workplace giving and leadershipdevelopment.Please note the OPM’s analysisof the “Impact and Effects” ofmassive changes to theCombined Federal Campaign as“None”.Recommendations/comments:(not mutually exclusive).Back to The DrawingBoard!Concur/keepGood ideaHarms CFC CharitiesNot addressedNo opinionNeeds to be addressed.Needs more publicdiscussionReject/ Bad Idea
  10. 10. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 10FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONThis proposed rule would replace the current regulationsfor the CFC. OPM proposes these new regulations togovern the solicitation of Federal civilian and uniformedservices personnel at the workplace. These proposedregulations are issued under the authority delegated toOPM by Executive Order 12353 (March 23, 1982), 47FR 12785 (Mar. 25, 1982), as amended by ExecutiveOrder 12404 (February 10, 1983), 48 FR 6685 (Feb. 15,1983).In 2011, the CFC celebrated its 50th anniversary. Inconnection with this landmark anniversary, OPMannounced the formation of the CFC-50 Commission.The Commission, formed under the Federal AdvisoryCommittee Act, was asked to study ways to streamlineand improve the program; improve accountability,increase transparency and accessibility and make it moreaffordable.The Commission delivered its report to the OPMDirector on July 20, 2012. The report contained 24recommendations for improvement in the followingareas: donor participation, CFC infrastructure, andstandards of accountability and transparency.OPM has reviewed these recommendations. Thisproposed rule reflects changes that OPM has concludedwill improve the CFC, based on its experienceadministering the program and its considered judgment.The proposed changes to theCFC regulations will have theeffect of destroying theequilibrium that exists in theCFC among all the partiesconcerned, including Federalagencies, CFC donors, CFCcharities, private sector workersfor the non-profit CFCcontractors who are the PCFOsin 184 regions, and mostimportantly, the people thatreceive the services provided bythe CFC charities. Ifimplemented they will cause aprecipitous drop in revenue andmany non-profits will be forcedout of the CFC.When just one factor has beenattempted (to go to allelectronic giving) in municipaland state workplace givingcampaigns, there has been a50% drop in revenues.The massive shift from privatesector non-profit functions togovernment functions andworkforce needs much morediscussion, and given the nature
  11. 11. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 11FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONof current Federal budgetissues, a reality check. Thereare some good ideas included aswell, but OPM should haveadopted a version of theHippocratic Oath, “First Do NoHarm,” and on that criterionalone, these proposedregulations fail.(1) Changing the Campaign Solicitation Period. Undercurrent regulations, the CFC campaign solicitationperiod runs from September 1 to December 15. OPMproposes to change its regulation at § 950.102 to shiftthe campaign solicitation period by one month, so that itwould begin on October 1 and end on January 15. Thiswill allow the many employees who take leave duringthe month of December to contribute through thecampaign when they return in the month of January. Italso enables employees to consider the impact of futurepay and other benefits (which often take effect the firstfull pay period in January) before making donations.“Shifting the Campaign” is NOTthe same as “Extending”In the CFC-50 Commissionmeetings there were manypeople and organizations thatspoke to the benefit ofextending the campaign toJanuary 15thfrom the currentDecember 15thend. There aremany reasons for this, includingboth year-end charitable givingand federal personnelschedules.In watching all eight hours ofvideo testimony, reading all therecommendations andappendices in the CFC-50report, not a single person said“Shift the Campaign” fromSeptember to December toOctober to January. “Shifting”is not the same as “extending”Back to The DrawingBoard!Harms CFC CharitiesReject/ Bad Idea
  12. 12. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 12FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONand there are many negativeconsequences to shifting, butsince there was no mention ofthis at all in 4 public meetingsover many months, the idea wasnot addressed. Additionalanalysis is contained in thesection by section analysis.(2) Immediate eligibility. Under current regulations, newemployees may not begin participating in the CFC untilthe next scheduled campaign solicitation period begins.OPM proposes to amend its regulation at § 950.102 toallow new employees to make CFC pledgesimmediately upon entering Federal service. UnderOPMs proposal, new employees would be providedinformation on the CFC at orientation and be able tomake pledges within 30 days of being hired if hiredoutside of the solicitation period. This will enable thoseemployees who wish to make an immediate contributionto do so.This was recommended bymany in the CFC 50 Commissionopen meetings.Concur/keep(3) Disaster Relief Program. Under current regulations,the OPM Director is authorized to allow specialsolicitations to respond to disasters. There is no standingmechanism in place, but rather each disaster requires anew authorization from the Director for a specialsolicitation period. OPM proposes to create a permanentstructure to streamline and facilitate solicitations tied todisaster relief. Accordingly, OPM proposes to amend itsregulations at § 950.102 to provide for the creation of aDisaster Relief Program that would be available toDisasters do not follow a settimetable, they can occuranywhere and at any time.Current regulations requirespecial permission from OPM toany government agency thatwants to conduct a specialsolicitation for a disaster, whichis granted routinely. Thischange allows for Federaldonors to give to CFC charitiesConcur/keepGood idea
  13. 13. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 13FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONdonors within hours after a disaster. that are involved in disasterrelief whenever the disasteroccurs.(4) Local Governance Structure. Currently, the CFC ismanaged locally through Local Federal CoordinatingCommittees (LFCC). The number of LFCCrepresentatives, the level of engagement, and knowledgeof CFC rules and regulations varies greatly among the184 campaign regions in the U.S. and overseas. In someareas, campaigns have difficulty identifying Federalemployees who can dedicate the time to fulfill theLFCCs oversight responsibilities, including theselection of a Principal Combined fund Organization(PCFO), review and approval of reimbursable campaignexpenses, review of local charity applications, andoversight of the PCFOs CFC functions. OPM isproposing to modify its regulations at § 950.103 tochange the LFCC to a Regional CoordinatingCommittee (RCC) structure. Under this proposedchange, the Director would maintain sole authority withregard to any revisions to the established geographicalregions, establish limits for the RCC Chair, setrequirement for a Vice Chair and establish newrequirements for Agency head to appoint employees toassist with the campaign. At a minimum, the RCCs willbe comprised of representatives of Federal inter-agencyorganizations, such as Federal Executive Boards andFederal Executive Associations, or personnel assignedto the military installation and/or Federal agencyidentified as the lead agency in that region. Theresponsibilities of the RCC will be similar to those ofCurrently there are 184 LFCCs inthe CFC and 28 FederalExecutive Boards in areasoutside the Washington DCNational Capital area. In thepublic meetings there was nodiscussion of how this transitionwould actually occur. Whetheror not OPM “believes thereduction in responsibilities, inaddition to larger campaignregions from which memberswill be selected, will attractmore individuals to serve in thisimportant leadership role” therehas been no informationpresented about what will bethe boundaries of the newregions, or how this wouldactually work.As CFC regions have beenconsolidated over the pastdecade, participation hasshrunk, and one could make thecase that one of the factors inincreasing participation ishaving a structure thatencourages more face to faceBack to the DrawingBoard!Needs more publicdiscussion
  14. 14. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 14FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONthe LFCC with the exception of the selection andoversight of a PCFO. OPM believes the reduction inresponsibilities, in addition to larger campaign regionsfrom which members will be selected, will attract moreindividuals to serve in this important leadership role.contact, instead of less.There needs to be much morediscussion of this will actuallywork in the Federal workforce,as opposed to restricting it to“OPM’s beliefs.” There was nodiscussion of this in the publicCFC 50 Commission meetings.Also, while OPM has authorityover FEBs, FEAs are voluntary,and OPM has no specificauthority over them, soassigning them duties could beproblematic.(5) Electronic Donations. OPM proposes to modify §950.103 to eliminate the use of cash, check and moneyorder contributions. Instead, all donations will berequired to be made through electronic means.Electronic transfers are now widely available and bymoving to an exclusively electronic donation system, wewill increase the efficiency of administration of the CFCprogram, eliminate burdensome paperwork, and saveresources.This ignores the fact thatsignificant amounts of CFCcontributions are made by cashand check.In particular, this has majornegative impacts for Federalpersonnel who wear uniforms,including members of the Army,Air Force, Navy, Marines andthe Postal Service, many ofwhom do not have computeraccess during their duty period.When other workplace givingcampaigns have tried to go “allReject/ Bad IdeaBack to the DrawingBoard!Needs more publicdiscussion
  15. 15. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 15FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONelectronic” there has been aprecipitous drop in donations.(6) Training and Oversight. OPM proposes to modify §950.104 to provide for additional training and oversightof the RCC. The training will be conducted by OPMstaff and will focus on oversight responsibilities, charityeligibility requirements, and how to select a marketingorganization and review/approve its reimbursablemarketing expenses.There are currently 184 PCFOs(Principal Combined FundOrganizations) that conduct thistraining in the 184 regions,performed by at least 450 non-profit private sector staff. TheOPM CFC Office has a staff ofless than 20, and while manytraining functions can now bedone via web based trainingthere was no discussion of howthis would actually beimplemented.Reject/ Bad IdeaBack to the DrawingBoard!Needs more publicdiscussion(7) Elimination of Paper Processes. OPM is alsoproposing to modify § 950.104 to eliminate paperprocesses within the CFC as much as possible.Specifically, OPM proposes changes in this section toeliminate printing and distributing the Charity List.Rather, this list will be made available exclusivelythrough electronic means. This change will reduceoverhead costs and increase efficiency in theadministration of the CFC program.This is a bad idea, and ignoresthe reality that thousands ofFederal employees do not haveaccess to a computer duringtheir work day. It also ignorestestimony made during thepublic meetings of the CFC -50Commission that the charity listand pledge cards are alsomarketing tools, not just an“obsolete” method offundraising.Other workplace givingcampaigns at the municipal andstate level have attempted to goReject/ Bad IdeaBack to the DrawingBoard!Needs more publicdiscussion
  16. 16. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 16FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTION“all electronic” and when it hasbeen tried, donations were cutin half until some mix of face toface and electronic solicitationwas restored.(8) Streamlining Campaign Administration. Undercurrent regulations, many campaign administrationfunctions are performed by a number of PrincipalCombined Fund Organizations (PCFOs) supportinglocal campaigns throughout the country. We believe thata centralized approach will benefit from economies ofscale and ultimately reduce overhead costs.Accordingly, OPM proposes to modify its regulations at§ 950.105 to eliminate the PCFOs. In their place, wepropose to consolidate responsibilities for back officefunctions and establish one or more Central CampaignAdministrators (CCA). The CCA would either performthese functions itself or would set up regional receiptand disbursement centers. We further propose that theRCC may engage a marketing firm to continue outreachto Federal, Postal and military personnel, functionscurrently coordinated by the PCFOs.This proposed regulationeliminates more than 450private sector jobs in the non-profit arena, transfers theirfunctions to the Federalworkforce, with no estimate onthe reality of either creatingnew Federal positions or havingcurrent Federal personnelassume new duties.Currently PCFOs are required tobe 501(c)(3) non-profits – why?The requirement that a PCFO bea 501(c)(3) non-profit is a relicfrom the early CFC regulations.Since for-profit contractorsperform all types of variedservices in the moderngovernment, including air trafficcontrollers, military supply linesand thousands of otherfunctions, why are PCFOsrequired to be non-profit?This idea was not discussed inReject/ Bad IdeaBack to the DrawingBoard!Needs more publicdiscussionThis is a massive shiftfrom private sector non-profit jobs to Federalpersonnel.Open up PCFOopportunities to bothprivate and non-profitcontractors.
  17. 17. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 17FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONthe CFC- 50 public meetings.(9) Administrative Costs. Currently, the overheadadministrative costs of much of the CFC program arepaid for out of donor contributions to the campaign. Webelieve that more transparency with respect toadministrative overhead would be beneficial to theprogram, to the donors, and to the charitableorganization that receive donations through the program.Accordingly, OPM proposes that the cost of thecampaign previously outlined in § 950.106 instead berecovered through application fees paid by the charitableorganizations that apply for participation in the CFC.This section also establishes how the fees will becollected and the permissible uses of the fees.The effect of this will be todestroy the CFC for small non-profits, whether they are local,national or internationalcharities that will simply notenroll in the CFC program. Theproposed regulations contain notimetable, no explanation ofhow this would actually work,and no amounts attached toproposed fees.One of the oldest marketingprinciples in the world is that “aconfused customer does notbuy” and in this case “a smallconfused CFC charity will notenroll.”Back to the DrawingBoard!Harms CFC CharitiesKeep the currentCampaign Costmechanism in place, itworks, and it workswell.(10) Streamlined Application Process. OPM believesthere are efficiencies to be gained in its charityapplication process. We are proposing to modify theregulations at § 950.201 to reduce the burden oncharities that have previously been admitted toparticipate in the program. Thus, these charities wouldbe required to produce a more limited specified set ofdocuments, via a reduced application form, to beadmitted for the subsequent two years. We think thisapproach will afford us with sufficient information toevaluate the charitys continuing eligibility whilereducing unnecessary administrative burdens on theThe idea of making renewalapplications simpler for CFCcharities is a good one, but howexactly this would work and beimplemented needs furtherdiscussion. There is no mentionof timetables or costs in theproposed regulations, or whoexactly would be responsible forcreating the system forrenewals.Concur/keepNeeds more publicdiscussion
  18. 18. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 18FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONcharity.(11) Audit of Small Charities. OPM is proposing tomodify its regulations at § 950.203 to waive the auditrequirement for organizations reporting less than$100,000 in annual revenue to the IRS. In addition, wepropose that an organization with annual revenue of atleast $100,000 but less than $250,000 not be required toundergo an audit, but have their statements reviewed byan independent certified public accounting firm. Thiswould remove a disproportionate burden on smallcharities.There was not significantdiscussion in the CFC 50 publicmeetings about the problemscaused to non-profits by havingthe three financial levels, andthe $100,000 figure that hasbeen in place for years has notbeen indexed to inflation.This proposed regulation is animprovement, but what shouldalso be considered is eliminationof the middle level ($100,000 to$250,000), and creating twolevels for CFC non-profits: (1)Less than $250,000 and (2)Greater than $250,000 whichwould save millions in non-profit expenses.If correctly addressed,this regulation couldsave millions inexpenses for the CFCcharities, and stillensure a high level ofaccountability.Needs more publicdiscussionBack to the DrawingBoard!(12) Oversight of Federations. OPM proposes tostrengthen its regulations regarding federations toincrease accountability and transparency. OPM proposeschanges to § 950.301 to specify that federations providea copy of each member organizations application,require dates upon which disbursements must be madeto members, adds additional reporting requirements, andprohibit deductions of dues/fees from the disbursementof CFC contributions.This is a complete cancelationby government fiat of thefederation business model thathas been in existence fordecades, and has worked verywell. More than 70% of thefunds raised through the CFCare from charities infederations, and the federationsprovide valuable services totheir member non-profits.Reject/ Bad IdeaBack to the DrawingBoard!This is a massiveoverstepping of OPM’sauthority on dictatinghow federations shouldconduct their own
  19. 19. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 19FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONprivate sector businessoperations.(13) Payroll Deduction Disbursements. OPM hasdecided to standardize and improve how payroll officesprovide donor pledge reports to campaigns. OPMproposes changes to former § 950.901 (§ 950.801 inthese proposed regulations) to require payroll offices toeither distribute funds to the charities directly or, iffunds are transmitted to the CCA, provide more detailedreports. Currently, Federal payroll office disbursementreports vary in format and level of detail, which adds tothe administrative costs of the campaign administratorsresponsible for ensuring the accuracy of disbursementsto designated charities.These proposed changes will introduce efficiencies andcost savings into the CFC by leveraging technology thatwas not widely available just a few years ago. They willmake the CFC more efficient, more transparent, moreaccountable and more relevant to Federal, Postal andmilitary service personnel who want to make the biggestimpact with their donations.… continues… See note below:This function is currentlyperformed by the 184 PCFOS,which are non-profit contractorsto the government, and theirprimary fiduciary responsibilityis to see that the CFC donor’sgifts are sent to the correct CFCcharity. There has been nodiscussion about how theadditional workload of trackinggifts to 25,000 CFC charities willbe handled by the four Federalpayroll offices.One important way that thepayroll offices could be used,and this was not discussed inthe CFC-50 public meetings, is touse the payroll messagingcapability to say “Thank you” tothe CFC donors. This was notdiscussed at all in the CFC -50public meetings.Back to the DrawingBoard!Needs more publicdiscussionNote from Huddleston: The paragraph below iscontained at the end of the: (13) Payroll DeductionDisbursements section, but it is really a concludingparagraph referring to the entire set of proposed changesto the CFC regulations. It is in a separate row forpurposes of analysis and comment.While these proposals would make significant changesin the operation of the CFC, OPM remains committed toThe CFC 50 Commission did agood job, but too many of theirDon’t Kill the GoldenGoose of American
  20. 20. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 20FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONensuring the broad participation of a multitude ofcharities in the CFC, and to preserving the localcharacter, sense of community, and employeeinvolvement that has been a hallmark of the CFC. Wewelcome comments on how to best maintain theseimportant attributes as we take steps to improve the CFCfor the future.24 recommendations areignored, or the changesproposed by OPM go far beyondwhat was discussed in the CFC-50 Open Meetings. There aresome good ideas in theproposed regulations, such asimmediate employee eligibilityand the disaster relief program.In terms of actual giving, if theCFC was a foundation, it wouldbe the 14thlargest foundation inthe USA, and the regulations asproposed will harm it. Some ofthe regulations are poorlyorganized, with no logic behindthem. For example, the sectiondealing with Federal retireesinstead of being in a “Donors”section is hidden in the“establishing RegionalCommittees” section, ignoresthe CFC-50 Commissionrecommendations, and makes amulti-million dollar error injudgment, all in less than aparagraph.OPM needs to not kill the“Golden Goose of AmericanPhilanthropy” and instead goback to the drawing board, andPhilanthropy, theCombined FederalCampaign (CFC), go backto the drawing boardand have a much widerbase involved in thediscussion of ways toimprove the CFC.Many obvious oneswere not evenmentioned in the CFC 50Public Meetings.The CFC-50 Commissionmeetings were attendedby a relatively smallnumber of observers,and it’s an extremelysmall number that havewatched the videorecordings.Here are the viewcounts as of May20,2013 from theYouTube- CFC- 50 OpenMeeting Videos:Inaugural Session: Sept13, 2011 - 1233 viewsDec. 6, 2011-1474 viewsMarch 2,2012 704 viewsMay 29, 2012 245 views
  21. 21. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 21FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONactually listen to the widevariety of people that careabout the CFC and want it tosucceed.Please continue belowfor my section bysection analysis of theimpact of the proposedchanges to the CFCregulations. 950.101 Definitions. Section 950.101 Definitions.Definitions were reviewed andupdated to conform to theproposed regulatory changes.Accordingly, we propose toeliminate terms no longerapplicable (Campaign Period,Designated Funds, DomesticArea, Local FederalCoordinating Committee(LFCC), Overseas Area,Principal Combined FundOrganization (PCFO),Undesignated Funds), add newterms (Campaign Expenses,Central CampaignAdministrator (CCA), CharityApplication Fees, RegionalCoordinating Committee(RCC)), and revise definitionsof some of the terms that remainin place (AdministrativeExpenses, Charity List,Many of the changes proposedare not advisable, and in factare extremely harmful to thecontinued success of the CFC;please see the analysis belowfor details.Since this is the definitionsection, no further comment isneeded.
  22. 22. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 22FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONOrganization or CharitableOrganization, Solicitation). 950.102 Scope of the Combined FederalCampaign.Note: There are so many regulatory changescontained in this one section that I have divided theanalysis by topic. Bill HuddlestonTopic areas are:(1) Adjustment of solicitation dates(2) Elimination of LFCC campaign dates(3) New Employee pledges(4) Disaster ReliefSection 950.102 Scope of theCombined Federal Campaign.Adjusts solicitation dates toOctober 1-January 15 fromSeptember 1-December 15. Thisshift addresses concerns abouthaving the campaign end inDecember, while maintainingthe current length of thesolicitation period, as well aseliminating the requirement forthe LFCC to establish campaigndates. It also provides theopportunity for new employeesto pledge within 30 days if hiredoutside the solicitation period,and establishes standardguidance for Disaster Reliefsupport. 950.102 Scope of the Combined FederalCampaign.Section 950.102 Scope of theCombined Federal Campaign.Adjusts solicitation dates toOctober 1-January 15 fromSeptember 1-December 15. This“Shifting the Campaign” is NOTthe same as “Extending”In the CFC-50 Commissionmeetings there were manypeople and organizations thatReject/ Bad Idea
  23. 23. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 23FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTION(1)Adjustment of solicitation dates shift addresses concerns abouthaving the campaign end inDecember, while maintainingthe current length of thesolicitation period, as well aseliminating the requirement forthe LFCC to establish campaigndates. It also provides theopportunity for new employeesto pledge within 30 days if hiredoutside the solicitation period,and establishes standardguidance for Disaster Reliefsupport.spoke to the benefit ofextending the campaign toJanuary 15thfrom the currentDecember 15thend. There aremany reasons for this, includingboth year-end charitable givingand federal personnelschedules.In watching all eight hours ofvideo testimony, reading all therecommendations andappendices in the CFC-50report, not a single person said“Shift the Campaign” fromSeptember to December toOctober to January. “Shifting”is not the same as “extending”and there are many negativeconsequences to shifting, butsince there was no mention ofthis at all in 4 public meetingsover many months, the idea wasnot addressed.The negative consequencesinclude, but are not limited to,that by shifting the start date itmakes it much more difficult foragencies to schedule outdoorcharity fairs, which by their verynature are mid-campaignevents. There are five distinctBack to the DrawingBoard!Needs more publicdiscussion
  24. 24. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 24FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONphases for a non-profit in theCFC, and in Phase IV, theCampaign Activities Period, thisis when CFC Kick-offs andCharity Fairs are held.Particularly for largeinstallations that have a numberof employees and/or membersof the uniformed services, theseevents are held outdoors,including on military bases,postal service centers, and theFBI HQ to name just a few.If the start date is shifted, itmoves the mid-campaign periodfrom October to earlyNovember to mid- November toDecember, and in many placesin the USA, it’s too cold foroutdoor events! 950.102 Scope of the Combined FederalCampaign.(2) Elimination of LFCC campaign datesSection 950.102 Scope of theCombined Federal Campaign.,as well as eliminating therequirement for the LFCC toestablish campaign dates.Currently 184 LFCCs set thedates for local CFC applicationsin their region. If LFCCs areeliminated there has not beenany discussion on how OPM willhandle the approval of theapproximately 25,000applications for local CFCcharities.Needs more publicdiscussion
  25. 25. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 25FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTION 950.102 Scope of the Combined FederalCampaign.(3) New Employee pledgesSection 950.102 Scope of theCombined Federal Campaign.It also provides the opportunityfor new employees to pledgewithin 30 days if hired outsidethe solicitation period….Concur/keepGood idea 950.102 Scope of the Combined FederalCampaign.(4) Disaster ReliefSection 950.102 Scope of theCombined Federal Campaign.…and establishes standardguidance for Disaster ReliefsupportDisasters do not follow a settimetable, they can occuranywhere and at any time.Current regulations requirespecial permission from OPM toany government agency thatwants to conduct a specialsolicitation for a disaster, whichis granted routinely. Thischange allows for Federaldonors to give to CFC charitiesthat are involved in disasterrelief whenever the disasteroccurs.Concur/keepGood idea 950.103 Establishing Regional CoordinatingCommittees.Note: There are so many regulatory changescontained in this one section that I have divided theanalysis by topic. Bill HuddlestonSection 950.103 EstablishingRegional CoordinatingCommittees.Changes Local FederalCoordinating Committee(LFCC) to RegionalCoordinating Committee (RCC)The section of the proposedregulations dealing with Federalretirees is hidden in this section.This is a stunning example ofextremely poorly writtenproposed change to the CFCregulations, and it is staggeringin its scope. Please see theReject/ Bad IdeaBack to the DrawingBoard!Needs more public
  26. 26. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 26FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONTopic areas are:(1) Elimination of 184 LFCCs(2) Elimination of all check, cash and money ordergifts, and requires only electronic giving.Elimination of restriction on soliciting non-Federalpersonnel, including Federal retirees, which I have splitinto two categories:(3) Federal Retirees(4) Contractors(5) Elimination of campaign boundaries withregards to giving, e.g. often called universal giving.to better reflect the proposedresponsibilities of thiscommittee of Federal personnel.Requires appointment of RCCChair and Vice Chair, limitsChair term to no more than 3consecutive years. Establishesnew requirement for Agencyheads to appoint employees insupport of the campaign.Eliminates use of cash, checkand money order, limitspledging to electronic meansusing only payroll deduction orcredit cards, and also eliminatesrestriction on soliciting non-Federal personnel. Removescampaign boundaries withregard to donors, as universalgiving is supported in acompletely electronic process.analysis below for the specifics. discussion 950.103 Establishing Regional CoordinatingCommittees.(1) Elimination of 184 LFCCsSection 950.103 EstablishingRegional CoordinatingCommittees.Changes Local FederalCoordinating Committee(LFCC) to RegionalCoordinating Committee (RCC)to better reflect the proposedEliminates 184 Local FederalCoordinating Committees andreplaces them with an unknownnumber of RegionalCoordinating Committees withunknown boundaries.There needs to specific planswith maps and timetables forBack to the DrawingBoard!Needs more publicdiscussion
  27. 27. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 27FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONresponsibilities of thiscommittee of Federal personnel.Requires appointment of RCCChair and Vice Chair, limitsChair term to no more than 3consecutive years. Establishesnew requirement for Agencyheads to appoint employees insupport of the campaign.this to work.As the number of LFCCs hasbeen reduced, participation hasalso declined, and a case can bemade that as the CFC campaignsbecome more removed,participation suffers. 950.103 Establishing Regional CoordinatingCommittees.(2) Elimination of all check, cash and money ordergifts, and requires only electronic giving..Section 950.103 EstablishingRegional CoordinatingCommittees.Eliminates use of cash, checkand money order, limitspledging to electronic meansusing only payroll deduction orcredit cards, and also eliminatesrestriction on soliciting non-Federal personnel. Removescampaign boundaries withregard to donors, as universalgiving is supported in acompletely electronic process.This is a bad idea, and ignoresthe reality that thousands ofFederal employees do not haveaccess to a computer duringtheir work day. It also ignorestestimony made during thepublic meetings of the CFC -50Commission that the charity listand pledge cards are alsomarketing tools, not just an“obsolete” method offundraising.Other workplace givingcampaigns at the municipal andstate level have attempted to go“all electronic” and when it hasbeen tried, donations were cutin half until some mix of face toface and electronic solicitationwas restored.Reject/ Bad IdeaBack to the DrawingBoard!Needs more publicdiscussion
  28. 28. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 28FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTION950.103 Establishing Regional CoordinatingCommittees.(3) Federal RetireesFEDERAL RETIREESElimination of restriction on soliciting non-Federalpersonnel, - Federal retirees.This is the language of the proposed regulation:(d) Current Federal civilian and active duty militaryemployees may be solicited for contributions usingpayroll deduction or by electronic means, includingcredit cards, as approved by the Director. Contractorpersonnel, credit union employees and otherpersons present on Federal premises, as well asretired Federal employees, may make singlecontributions to the CFC by electronic means,including credit cards, as approved by the Director.Section 950.103EstablishingRegional CoordinatingCommittees.Eliminates use of cash, checkand money order, limitspledging to electronic meansusing only payroll deduction orcredit cards, and also eliminatesrestriction on soliciting non-Federal personnel.This is a multi-million dollarerror in judgment that is buriedin a section named “EstablishingRegional CoordinatingCommittees,” as opposed tosomething obvious like “CFCDonors – Federal Retirees.”Federal retirees cannotcurrently donate through theCFC. Federal retirees should beable to designate a portion oftheir retirement pay to theirfavorite CFC charities, if theywish to do so. One of hugebenefits of the CFC to currentemployees is the payrolldeduction feature, and thisoption should be made availableto Federal retirees, and theyshould not be limited to a one-time credit card donationIn the CFC 50 Final Report, theNational Association of RetiredFederal Employees (NARFE)estimates that including Federalretirees could generate$132,000,000 to $165,000,000annually to the CFC. Theproposed regulation is in directopposition to the CFC-50 FinalReport, which presumed aReject/ Bad IdeaBack to the DrawingBoardAllow Federal Retireesto contribute to the CFCthrough retirement paydeductions.Additionally, recipientsof Federal Survivorbenefits should be ableto contribute to theirfavorite charitiesthrough the CFC if theywish to do so.Allow Federal Retireesto contribute to the CFCwith a portion of theirretirement pay, so thatthey can continue withthe most significantbenefit of the CFC toCFC donors, that ofpayroll (now retirementpay) deduction.Millions of dollars are atstake in this single
  29. 29. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 29FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONretirement pay deductionmethod to achieve this.Retirees can direct $50payments to go to their savingsaccount, why can’t they do thesame with their CFCdesignations?This is not that hard to do.Recipients of Federal Survivorbenefits should also be able tocontinue to contribute to theirfavorite charities through theCFC if they wish to do so.proposed regulation. 950.103 Establishing Regional CoordinatingCommittees.(4) ContractorsSection 950.103EstablishingRegional CoordinatingCommittees.…also eliminates restriction onsoliciting non-Federalpersonnel.Contractors, whether they areonsite or not, are paid throughtheir organization’s payrollsystem, and many have theirown workplace giving programs,and having contractorsparticipate in the CFC is simplynot a good idea and contradictsgood contract managementprinciples.A case can be made that theCredit Union employees on-siteat Federal installations are in adifferent category, and if theywish to make a credit carddonation it’s not going to affectReject/ Bad IdeaBack to the DrawingBoard!Needs more publicdiscussion
  30. 30. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 30FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONthe relationship between thegovernment and contractors inmeeting its mission. 950.103 Establishing Regional CoordinatingCommittees.(5)Elimination of campaign boundaries with regardsto giving, e.g. often called universal giving.Section 950.103EstablishingRegional CoordinatingCommittees.Removes campaign boundarieswith regard to donors, asuniversal giving is supported ina completely electronic process.Universal Giving: Promised toNon-profits when 5 digit codeswere implemented in 2006.How exactly this “completelyelectronic process” is going towork has not been thoroughlydiscussed, and while universalgiving is a good idea, it willprobably never be more than5% of the gifts, with theexception of deployed troops.Concur/keepNeeds more publicdiscussion 950.104 Regional Coordinating Committeeresponsibilities.Note: There are so many regulatory changescontained in this one section that I have divided theanalysis by topic. Bill HuddlestonTopic areas are:(1) Change from Local LFCC to Regional Structure(2) Federal Regional Training Requirements(3) Elimination of Local Application ReviewProcess(4) Elimination of PCFO (private sector) TrainingSection 950.104 RegionalCoordinating Committeeresponsibilities.Provides for a transition from alarge number of “local”campaigns to a smaller numberof “regions,” requiring areduced number of Federalpersonnel for oversightpurposes. Requires committeemembers to gain a completeunderstanding of regulationsand procedures by attendingspecific training and achievingcertification in RCC operations.
  31. 31. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 31FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONResponsibilities, transfer to Federal workforce(5) Campaign Marketing Support(6) Elimination of Loaned ExecutivesEliminates the local applicationreview responsibility, and tasksthe RCC to assist OPM withapplication review as assigned.Reassigns the responsibility fortraining the campaign personnelfrom the PCFO to the RCC.Establishes the ability for RCCto hire campaign marketingsupport. Eliminates the need forLoaned Executives in a fullyelectronic pledgingenvironment. 950.104 Regional Coordinating Committeeresponsibilities.(1) Change from Local to Regional StructureSection 950.104 RegionalCoordinating Committeeresponsibilities.Provides for a transition from alarge number of “local”campaigns to a smaller numberof “regions,” requiring areduced number of Federalpersonnel for oversightpurposes.Eliminates 184 regional CFCcampaigns and replaces themwith an unknown number ofRegional CoordinatingCommittees with unknownboundaries and boundaries thathave had no discussion.There need to be specific planswith maps and timetables forthis to work.Back to the DrawingBoard!Needs more publicdiscussion 950.104 Regional Coordinating Committeeresponsibilities.Section 950.104 RegionalCoordinating Committeeresponsibilities.What is the timetable for this,and what exactly is meant by“achieving certification in RCCoperations.” What’s thetimetable for OPM to develop
  32. 32. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 32FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTION(2) Federal Regional Training Requirements Requires committee members togain a complete understandingof regulations and proceduresby attending specific trainingand achieving certification inRCC operations.this training? 950.104 Regional Coordinating Committeeresponsibilities.(3) Elimination of Local Application ReviewProcessSection 950.104 RegionalCoordinating Committeeresponsibilities.Eliminates the local applicationreview responsibility, and tasksthe RCC to assist OPM withapplication review as assigned.184 LFCCs currently review localcharity applications, and thenumber submitted varies greatlyby region (in general, a biggerregion will have moreapplications). Currently thereare a total of about 25,000applications processed by the184 LFCCs, and there has beenno discussion on how OPM willhandle this proposed increaseto its workload.Back to the DrawingBoard!Needs more publicdiscussion 950.104 Regional Coordinating Committeeresponsibilities.(4) Elimination of PCFO (private sector)Training Responsibilities, transfer to Federalworkforce.Section 950.104 RegionalCoordinating Committeeresponsibilities.Reassigns the responsibility fortraining the campaign personnelfrom the PCFO to the RCC.The effect of this is to eliminateat least 450 private sector non-profit jobs. Many trainingfunctions are certainly migratingto web-based instruction butthe loss of non-profit jobs wasnot discussed in the CFC 50Public Meetings. There arecurrently 184 PCFOs, there arean undetermined number ofRCCs to be established, withboundaries not yet discussed.Back to the DrawingBoard!Needs more publicdiscussion
  33. 33. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 33FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTION 950.104 Regional Coordinating Committeeresponsibilities.(5) Campaign Marketing SupportSection 950.104 RegionalCoordinating Committeeresponsibilities.Establishes the ability for RCCto hire campaign marketingsupport.Currently 184 LFCCs performthis function by selecting thePCFO for their region. There hasbeen no discussion of what theboundaries are for the RCCs andhow are they going to hirecampaign marketing supportwhen there has been nodecisions or discussions aboutany of the planned “super CFCregions” to coin a term.There need to be specific planswith maps and timetables forthis to work.How are RCCs to pay forcampaign marketing support,since in other parts of theproposed regulations, themethod of payment that hasbeen in place for decades hasbeen eliminated elsewhere inthe proposed regulations.Back to the DrawingBoard!Needs more publicdiscussion 950.104 Regional Coordinating Committeeresponsibilities.(6)Elimination of Loaned ExecutivesSection 950.104 RegionalCoordinating Committeeresponsibilities.Eliminates the need for LoanedExecutives in a fully electronicpledging environment.This is a fiction, with noevidence from OPM to back itup. Indeed, when certain cityand state workplace campaignshave tried a fully electronicgiving environment, the amountgiven to charities has droppedReject/ Bad IdeaBack to the DrawingBoard!Needs more publicdiscussion
  34. 34. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 34FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONby 50 percent.Loaned Executives act asconsultants to Federal agencieson how to conduct the mosteffective CFC campaignspossible.Federal Agency CFC Volunteersplay many roles, and they offera "practice field" for theleadership and communicationqualities from the ExecutiveCore Qualifications (or ECQs) ofthe Senior Executive Service. Formy non-profit colleagues,pardon the government jargon,but take a look at the leadershipqualities identified, many ofthem also apply to theleadership development of non-profit professionals andvolunteers as well.The CFC ECQ worksheet can befound on the FacebookSAVETHE CFC open Group.There was no discussionin the CFC 50 publicmeetings about this.950.105 Federal Agency Head responsibilities. Section 950.105 FederalAgency Head responsibilities.Outlines specificresponsibilities of AgencyHeads to include identificationof employees in support of theBy regulation, agency heads arein charge of their agency’sannual CFC campaign. As apractical manner, they oftendelegate a senior SES person tobe the Vice-Chair for theirReject/ Bad IdeaBack to the Drawing
  35. 35. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 35FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONcampaign. Previously definedduties are also indicated toinclude providing support to thecampaign, becoming familiarwith the regulations, andassuring the campaign isconducted in accordance withthose regulations.agency’s campaign.This particular regulationhowever strikes me as too muchmicromanagement by OPMregarding the details of how anagency head, including Cabinetsecretaries should set his or herpriorities in their agency, andcould easily be counter-productive.Board!950.106 Central Campaign Administrator (CCA).Section 950.106 CentralCampaign Administrator (CCA)Establishes CCA requirements,roles and functions andeliminates requirement forPCFO and all referencesthereto. Provides guidance forcircumstances where noqualified CCA can be retained.This eliminates 184 privatesector contractors to thegovernment that employ anunknown number of people, butit has to more than 450 privatesector positions. (largerregions, e.g. Chicago, San Diego,etc .) have more PCFOpersonnel than smaller ones.This is a massivetransfer of functionsfrom private sector non-profits to the Federalworkforce.Back to the DrawingBoard!Needs more publicdiscussion950.107 Campaign expense recovery. Section 950.107 CampaignExpense recovery. Shifts theexpense of the campaign fromthe donor to the charities via acharity application fee andchanges PCFO expenses tocampaign expenses (CCA andmarketing costs).The effect of this will be to forcemany small charities out of theCFC. If that is the intention, itneeds to be stated anddiscussed, but that will be theeffect of this regulation.The proposed regulation alsobelies a fundamentalReject/ Bad IdeaKeep the currentsystem.
  36. 36. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 36FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONmisunderstanding how the non-profit world works, and one ofthe huge benefits that thecurrent CFC regulations doprovide to CFC charities, the factthe CFC is “no money downfundraising.”Leaving aside medical charitiesthat may get government re-imbursements, the fundamentaltruth is that donors always paythe cost of fundraising. Forexample, it may not be thecurrent donor paying for thecost of direct mail campaignwith a 4% acceptance rate(which is good), but donors payfor the cost of fundraising. Theonly question is whosecheckbook does it come out offor a particular transaction orcampaign, but the sources ofnon-profit funds are donors.In the CFC, the fact that CFCdonors pay for the cost offundraising from theircontribution, before it gets tothe CFC non-profit’s checkbookis one of the benefits to CFCcharities.Back to the DrawingBoard!
  37. 37. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 37FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTION950.108 Preventing coercive activity. Section 950.108 PreventingCoercive activity.No changes.This is an area where theFederal government has been aleader in workplace giving,ensuring that the employees donot face coercive pressure todonate. Some of theregulations that help ensure thisinclude: Participation goalscannot be set higher than 75%,managers can’t solicit theiremployees, etc.Concur/keep950.109 Avoidance of conflict of interest. Section 950.109 Avoidance ofConflict of Interest.Removed references to LFCCand PCFO, added reference toRCC.The elimination of the PCFOsdestroys at least 450 privatesector jobs, which is a veryconservative estimate.Contingent upon LFCCand PCFO decisions.(4) 950.110 Prohibited discrimination. Section 950.110 Prohibiteddiscrimination.Updated to meet current legalstandards.Concur/keep(5) 950.201 Charity eligibility. Section 950.201 Charityeligibility.Combines all current charityeligibility guidance into onesubpart, eliminating separatesections for national/Concur/keep
  38. 38. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 38FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONinternational and local.Eliminates annual applicationrequirement and insteadestablishes a streamlinedverification process for two“renewal” years after the year inwhich the initial full applicationis approved950.202 Charity eligibility requirements. Section 950.202 Charityeligibility requirements.Establishes in one sectionrequirements fornational/international and localcharities. Codifies several OPMguidance memoranda into theregulation (2006-21 and 2008-08). Removes requirement tosubmit IRS verification letter ifthe organization can be verifiedin the IRS Business Master File(BMF). Outlines verificationrequirements for local affiliates,churches and Family Supportand Youth Activities/FamilySupport and Youth ProgramsFSYA/FSYPs.Concur/keep950.203 Public accountability standards. Section 950.203 Publicaccountability standards.Specifies `calendar year whereprevious reference was unclearDoes not clearly address theproblems created byBack to the DrawingBoard!Needs more public
  39. 39. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 39FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONand updated sample dates.Specifies requirement for US orInternational AccountingStandards, and modifiestransition levels for auditrequirements. Removesrequirement for Attachment Aof IRS Form 990, and removesdefinition of `pro forma 990 sorequirements can be modifiedeasily as the IRS updates theform.organizations whose fiscal yearis not the calendar year.discussion950.204 Eligibility decisions and appeals. Section 950.204 Eligibilitydecisions and appeals. All localeligibility requirements mergedfrom this section into section950.203. New section 950.204establishes process for decisionsand appeals in lieu of certifiedor registered mail. Codifiesappeal information in OPMguidance memorandum 2012-03.Section now in 950.203.See note above.950.301 Federation eligibility. Section 950.301 Federationeligibility.Establishes specificrequirements, combiningnational/international and localfederation eligibilityNeeds more publicdiscussion by federationexperts as to the effect
  40. 40. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 40FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONrequirements into one section.Requires federations to submit acopy of each memberorganizations application asoutlined in the CharityEligibility section. Specifies`calendar year where previousreference was unclear.of this proposal.950.302 Responsibilities of federations. Section 950.302 Responsibilitiesof federationsCombines national/internationaland local federationresponsibilities into one section.Establishes requirement forfederations to disburse funds tomembers on a quarterly basis,and prohibits federations fromdeducting fees or charges fromdisbursements made to memberorganizations. Requires thatCFC funds are identified assuch when payments thatinclude non-CFC funds aremade to member organizations.Federations provide valuableservices to their members. Theprohibition of deducting theirfees is a complete change ofhow they’ve operated sincetheir inclusion in the CFC. Itdoes not appear that there wasmuch, if any discussion aboutthis in the CFC-50 Commissionpublic meetings.Reject/ Bad IdeaBack to the DrawingBoard!Needs more publicdiscussion950.401CAMPAIGN and PUBLICITY INFORMATIONThis section (950.401) is fullof ideas that were notdiscussed in the CFC -50public meetings.
  41. 41. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 41FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTION950.401 Campaign and publicity information. Section 950.401 Campaign andpublicity information.Removes references to PCFO,changes references from LFCCto RCC. Eliminates use of paperCharity List and pledge form, asall donations must be enteredelectronically. Removes theundesignated gift option.Removes guidance forconfidential gifts as gifts will bemade electronically. Addsrequirement and references forcredit card usage. Adds theorganizations Web site addressas a standardized item in eachcharity list entry, and revises the25 word statement to a 256character statement.Eliminating the 25 worddescription that has been inplace for decades and replacingit with a 256 characterstatement is harmful to bothCFC donors and CFC charities,and tilts what has been a levelplaying field. Why should a CFCcharity whose mission useslonger words, for example, amedical research charity bepenalized?Back to the DrawingBoard!Harms CFC CharitiesHarms CFC DonorsReject/ Bad Idea(a) The specific campaign marketing and publicityinformation will be developed locally, except asspecified in the regulations in this subpart. Allinformation must be reviewed and approved by the RCCfor compliance with these regulations and will bedeveloped and supplied by the RCC or contracted agent.There has been no discussionabout how many RCCs there willbe, what the boundaries will be,or how this would work.Therefore there is no definitionof “local” since no one knowsany boundaries for the RCCs.There are currently 184 CFCregions, with 184 PCFOscontractors with staffBack to the DrawingBoard!Harms CFC CharitiesReject/ Bad IdeaNeeds more public
  42. 42. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 42FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONperforming these functions.This is a massive shift offunction from private sectornon-profit organizations toFederal organizations with noplans, boundaries, or budgetsrevealed on how this wouldactually work. Given the natureof current Federal budgetsituations, these proposals needmuch more detailed work.discussion(b) During the CFC solicitation period, participatingCFC organizations may distribute bona fide educationalinformation describing its services or programs. Theorganization must be granted permission by the Federalagency installation head, or designee to distribute thematerial. CFC Other employees or members of the RCC,are not authorized to grant permission for thedistribution of such information. If one organization isgranted permission to distribute educationalinformation, then the Federal agency installation headmust allow any other requesting CFC organization todistribute educational information.Concur/keepGood idea(c) Organizations and federations are encouraged topublicize their activities outside Federal facilities and tobroadcast messages aimed at Federal employees in anattempt to solicit their contributions through the mediaand other outlets.High performing CFC charitiesalready publicize. There areseveral simple steps that anyCFC charity should take, and theCFC marketing messages canalso be used by the CFC charityas a means of developingteamwork and leadership.There are two simple actionsConcur/keepGood idea
  43. 43. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 43FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONthat a CFC charity can take thatwill answer 90% of thequestions a potential donormight have and that’s to havethe CFC logo and their 5 digitcode on their homepage.(d) Agency Heads are further authorized to permit thedistribution by organizations of promotionalinformation to Federal personnel in public areas ofFederal workplaces in connection with the CFC,provided that the manner of distribution accords equaltreatment to all charitable organizations furnishingsuch information for local use, and further providedthat no such distribution shall utilize Federal personnelon official duty or interfere with Federal governmentactivities. RCC members and other campaign personnelare to be particularly aware of the prohibition ofassisting any charitable organization or federated group.Concur/keepGood idea(e) The Campaign Charity List and pledge form are theofficial sources of CFC information and shall be madeavailable in electronic format to all potentialcontributors. The Charity List and pledging systemmust inform employees of their right to make a choiceto contribute or not to contribute.It is fine to make the CharityCampaign List available in anelectronic format, however thatdoes not mean that all papercopies should be completelyeliminated. The Charity Listitself in its printed for marketingpurposes, which are not servedby a 100% electronic list.Needs more publicdiscussion(f) Campaign marketing materials must be comprised ofa simple and attractive design that is donor focused andhas fundraising appeal and essential workinginformation. The design must focus on the CFC withoutundue use of charitable organization symbols and logosor other distractions that compete for the donorsDesign choices should be left upto the CFC charities.If a charity wants to use their“charity good housekeeping sealReject/ Bad IdeaHarms CFC CharitiesHarms CFC donors
  44. 44. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 44FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONattention. of approval” type logo, let them.(g) The following applies specifically to the campaignCharity List:(1) OPM will provide the approved Charity List as wellas general campaign information. This will include:(i) An explanation of the payroll deduction privilege.(ii) A description and explanation of other electronicpledging, to include credit cards.(iii) A statement that the donor may only designatecharitable organizations or federations that are listed inthe Charity List and that write-ins are prohibited.(iv) Instructions as to how an employee may obtainmore specific information about the programs and thefinances of the organizations participating in thecampaign.(v) A description of employees rights to pursuecomplaints of undue pressure or coercion in Federalfundraising activities.Concur/keep(2) The Charity List will consist ofNational/International, International, and Localorganizations. The order of these organizations will berotated annually in accordance with OPM instructions.The order of listing of the federated and independentorganizations will be determined by a random selectionprocess. The order of organizations within eachfederation will be determined by the federation. Theorder within the National/International, Internationaland Local independent groups will be alphabetical.Absent specific instructions from OPM to the contrary,each participating organization and federated grouplisting must include a description, not to exceed 256This regulation replaces the 25word description that has beenin place for decades, which isthe one piece of the CFCinformation that the CFC charitygets to write to tell its story witha 256 character limit.Why?Why should a charity that has amission where longer words areReject/ Bad IdeaKeep the 25 worddescription!Harms CFC Charities
  45. 45. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 45FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONcharacters, of its services and programs, plus a Web siteaddress and telephone number for the Federal donor toobtain further information about the groups services,benefits, and administrative expenses. Each listing willinclude the organizations administration andfundraising percentage as calculated pursuant to §950.203(a)(4). Neither the percentage of administrativeand fundraising expenses, nor the Web site address ortelephone number count toward the 256 characterdescription.needed, e.g. some of themedical research charities, thanone that can say use shorterwords, like “rescues dogs” bepenalized?This “solution” creates moreproblems than it solves, peoplethink in words, not characters.This is extremely harmful to theCFC non-profits, and it impairsthe ability of the CFC donor tolearn about a given non-profit.This is a truly dumb bureaucraticresponse, someone has gone“twitter crazy.”If the paper catalog is to beeliminated, it also makes nosense because the web-basedcatalog could easily handle a 25,50 or even a 100 worddescription.Harms CFC DonorsThere was no discussionof this in the CFC - 50public meetings.(3) Each federation and charitable organization will beassigned a code in a manner determined by theDirector. At the beginning of each federated groupslisting will be the federations name, code number, 256character description, percentage of administrative andfundraising expenses, Web site address and telephonenumber. Each organization will be identified asNational/International, International and Local,respectively.It needs to be made clear that ifa charity already has a 5 digitcode, it does not change.The 256 character description isan extremely bad idea andshould be rejected, and it harmsthe CFC charities, as well as itharms the ability of CFC donors
  46. 46. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 46FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONto get information aboutcharities.(h) Listing of national and local affiliate. Listing of anational organization, as well as its local affiliateorganization, is permitted. Each national or localorganization must individually meet all of the eligibilitycriteria and submit independent documentation asrequired in § 950.202 and § 950.203 to be included inthe Charity List. However, a local affiliate of a nationalorganization that is not separately incorporated, in lieuof its own 26 U.S.C. 501(c)(3) tax exemption letter and,to the extent required by § 950.203(a)(2), auditedfinancial statements, may submit the nationalorganizations 26 U.S.C. 501(c)(3) tax exemption letterand audited financial statements, but must provide itsown pro forma IRS Form 990, as defined in§950.203(a)(3), for CFC purposes. The local affiliatemust submit a certification from the Chief ExecutiveOfficer (CEO) or CEO equivalent of the nationalorganization stating that it operates as a bonafidechapter or affiliate in good standing of the nationalorganization and is covered by the nationalorganizations 26 U.S.C. 501(c)(3) tax exemption, IRSForm 990 and audited financial statements.No opinion(i) Listing local offices. Listing of a local organization,as well as its satellite offices, is permitted, as long asthere is no more than one location within a county orparish. Each office must individually meet all of theeligibility criteria and submit independentdocumentation as required in § 950.202 and § 950.203to be included in the Charity List. However, a satelliteoffice that is not separately incorporated, in lieu of itsown 26 U.S.C. 501(c)(3) tax exemption letter and, to theNo opinion
  47. 47. Back to the Drawing Board! - An Analysis of the Proposed Changes to the Combined Federal Campaign (CFC) Regulations – by Bill Huddleston, The CFC Coachwww.cfctreasures.wordpress.com LinkedIn & Facebook Groups - SaveTheCFC Bill Huddleston@verizon.net, 703-434-9780 Page 47FEDERAL REGISTER PROPOSEDREGULATIONS - CFCFEDERAL REGISTER –OPM COMMENTSBILL HUDDLESTONANALYSISRECOMMENDEDACTIONextent required by § 950.203(a)(2), audited financialstatements, may submit the local organizations 26U.S.C. 501(c)(3) tax exemption letter and auditedfinancial statements, but must provide its own proforma IRS Form 990, as defined in § 950.203(a)(3), forCFC purposes. The satellite office must submit acertification from the Chief Executive Officer (CEO) orCEO equivalent of the local organization stating that itoperates as a bonafide office in good standing and iscovered by the local organizations 26 U.S.C. 501(c)(3)tax exemption, IRS Form 990 and audited financialstatements.(j) Multiple listing prohibited. Except as provided inparagraphs (h) and (i) of this section, once anorganization is deemed eligible, it is entitled to only onelisting in the Charity List, regardless of the number offederations to which that organization belongsConcur/keep950.402 Pledge form. Section 950.402 Pledge formRemoves use of paper pledgeforms, and all referencesthereto. Also removesundesignated option, as well asall references with regard toundesignated pledging.More than 80% of Federalemployees use paper pledgeforms, which is also animportant marketing tool forthe Federal CFC campaign teamand keyworkers running theiragency’s campaignThis change is particularlyharmful for Federal personnelwho wear uniforms, includingmembers of the Army, Air Force,Navy, Marines and the PostalService and are not sitting in anair conditioned cubicle duringtheir work day.Reject/ Bad IdeaHarms CFC Charities

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