CFC Update: OPM announces fee structure for 2017 CFC

Last month, we shared an update advising you to be on the lookout for some correspondence from the Office of Personnel Management (OPM) regarding upcoming rule changes to the federal code governing charitable giving in the federal workplace, to be enacted for the 2017 Combined Federal Campaign (CFC). 

One of the changes formalized in the Code of Federal Regulations and referenced in my prior email pertained to the implementation of a new fee structure for charities’ participation in the CFC.  Beginning with the 2017 campaign, OPM will assess nonprofits wishing to participate in the CFC a nonrefundable application fee as well as an additional listing fee once the charity is approved to participate. OPM plans to assess both fees with the intention to cover the government’s fixed costs to administer the campaign. These fees are to be determined by OPM annually and announced prior to the start of each campaign year application period.

The fee structure for the 2017 CFC was just announced. Attached is CFC memorandum 2016-06, issued on November 9, 2016, which sets forth OPM’s fees for the 2017 CFC.

To summarize what is stated in the attached, two separate fees are being assessed by OPM on participating charities.  It is possible, should these fees be insufficient to cover campaign costs, that a third fee will be assessed once the campaign is closed and prior to funds distribution.

Both the application and listing fees will be assessed by OPM using a tiered approach.  This fee is based upon total revenues listed in an organization’s IRS Form 990.  The tiers are as follows:

Tier I National/International Organizations and Local Organizations: Those organizations that report $1 million or more in total revenues on its IRS Form 990.

Tier II National/International Organizations and Local Organizations: Those organizations that report $250,000 or more in total revenue but less than $1 million on its IRS Form 990.

Tier III National/International Organizations and Local Organizations: Those organizations that report less than $250,000 in total revenue on its IRS Form 990.

Some things to note:

• Application fees are lower for federation members than those charities that do not participate in a federation. 
• The listing fee is the same for all regardless of federation participation.
• Overall assessed fees are lower for nonprofits that participate locally in the CFC.
• Timing of Fees: The application fee is due at the time that your CFC application is filed.  We believe that the application deadline (subject to change by OPM) is January 31, 2017.The listing fee is due once your application for the CFC has been approved.  This is usually between May and July each year.
• To ensure your organization meets all stated requirements for CFC participation and we are able to successfully submit your materials, America’s Charities will invoice your organization for its application fee once OPM releases 2017 CFC application.  In addition, we will invoice for the listing fee once we receive notification that your organization has been approved in the CFC.

The team at America’s Charities does not believe that the federal government is taking the fairest approach in the manner in which it is assessing fees for organizations participating in the 2017 CFC and had we been provided the opportunity to comment on the process as this was being finalized, we would have voiced this to OPM.  However, according to the new rule, this should only be the fee structure for the first year of the rule change, applicable for the 2017 CFC only.  For year two of the rule change – for the 2018 CFC and going forward–the rule states that it will not exceed an amount equivalent to the previous campaign period’s budgeted costs divided by the number of participating charities. For example, if the previous campaign period realized fixed costs of $6 million with 25,000 listed charities, the application/listing fee would not exceed $240.

We are here to advise you as we have done throughout this process and answer any questions that you may have regarding this change or your estimated fees for the upcoming 2017 CFC.  Please feel free to reach out to Robyn Neal, VP, Client Engagement Solutions, or contact our Client Engagement Solutions team at (800) 458-9505 extension 4953 with any questions that you have.