Update: CFC Rule Change Set to Go Into Effect January 2017
By America's Charities on October 21, 2016
It’s that time of year again! The 2016 Combined Federal Campaign (CFC) and other workplace giving programs are in full swing, and we are busy making sure your nonprofit is well represented and visible to donors through marketing promotions and at campaign events nationwide. Your America’s Charities team is also busy proofing your member application materials in preparation for the 2017 CFC.
As you may already know, the CFC is set to undergo some changes in 2017. As a result, you may have or soon will be receiving an email sent on behalf of Keith Willingham, CFC Director at the U.S. Office of Personnel Management (OPM). This email references updates to the new rule implementation for 2017. While there are still some details outstanding regarding the rule change, we want to assure you that we will be communicating these to you in real time and as your workplace giving partner, we stand alongside you both as an advocate and a helping hand throughout this process.
The CFC rule change is set to go into effect starting on January 1st, 2017, for the fall 2017 campaign. Here is a summary of what we know, as well as a summary of what we are waiting for OPM to announce:
What We Know
In July 2012, a report from the CFC-50 Commission was delivered to the OPM Director containing 24 recommendations for improvement of the campaign to increase donor participation, streamline the CFC’s infrastructure, and build upon standards of accountability and transparency. In April 2014, OPM released their final rule, amending CFC regulations to account for recommended changes. This rule was set to take effect for the 2016 campaign but was delayed until the 2017 campaign. The changes that we can expect for 2017 are as follows:
- Campaign Solicitation Period – The solicitation period has changed from September 1st – December 15th to a time to be determined annually by the Director of OPM that will range anytime from September 1st – January 15th. The possible extension through January will allow employees who take leave during the month of December to contribute through the campaign when they return to work in January.
- Immediate Eligibility – New federal employees will be able to make pledges in the CFC within 30 days of being hired if they are hired outside of the solicitation period.
- Disaster Relief Program – The OPM Director has always been authorized to allow special solicitations outside of the normal solicitation period to respond to national or international disasters. This process has been refined to increase efficiency.
- Local Governance Structure and the Central Campaign Administrator – The campaign structure has changed. Instead of 150 campaigns, there will now be 38 campaign zones/regions. The role of the Local Federal Coordinating Committees (LFCC), while remaining in place, has changed. For example, the LFCC will no longer select and oversee the campaign manager. The Principal Combined Fund Organization (PCFO) has been eliminated in favor of one Centralized Campaign Administrator(s) (CCA), who will create the campaign website, receive application materials, distribute campaign funds and facilitate reporting for all campaign zones. The role of the PCFO has been restructured to that of an Outreach Coordinator, who may be hired to conduct campaign marketing, to include educational and promotional activities.
- Electronic Donations and Paper Processes – Federal employees will no longer be able to donate to the CFC through cash, but can still donate through check, money order, and online. Paper brochures will remain in place but will be eliminated over a 5 year period to move completely online.
- Application/Listing Fee – Beginning in 2017, a nonrefundable application/listing fee intended to cover OPM’s fixed costs of the campaign will be implemented. The amount of the fee will be determined by the Director of OPM and announced prior to the application period. This fee, which is set in the rule, must be determined no later than October 31, 2016.
- Application Process – There will be some changes to the CFC application in terms of what will be submitted to OPM versus what we as your workplace giving partner will need to retain for our records and have available for the CFC reviewer upon request. This will not affect the content of what you have submitted to us in your member application, but instead will affect which documents we are required to submit to the CFC versus those we are permitted to simply keep on file.
- Distribution of Funds – We, along with all other federations, will no longer be permitted to deduct fees from CFC contributions before distributing them to your nonprofit. Instead, we will be required to invoice your organization for member fees that pertain to CFC services.
- Retirees and Volunteerism – President Obama just signed an Executive Order that allows federal retirees to now participate in the CFC, and also will allow federal employees to pledge not only their money, but also their time as federal workers will now be able to devote volunteer hours to nonprofits participating in the CFC.
What We Are Waiting On:
- Clarification Surrounding Fees – We do not know yet how much the application fee will be for participating in the 2017 CFC. As noted above, we will know this by October 31st. For year two of the rule change 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. Please rest assured that we are monitoring this and will notify you if and when a final decision is made.
- The Exact Deadline for 2017 Applications – We believe it will be January 31st, 2017, but will confirm once the date is known.
Change can be a scary thing when there are unknowns – please know that the majority of these changes are meant to positively impact your nonprofit, grow the CFC program and grow your prospective donor base.
America’s Charities has been advocating for its members since the proposed rule was first issued in April 2013. Based upon our work and the work of our partners, some initial suggested changes did not make it into the final rule or now will be phased in gradually to ensure smooth implementation. For those changes that seem more daunting, such as the new CFC application fee, please know that we are ready at the helm, advocating in your best interest and focusing on ways that we can help you to not only understand the changes, but also on ways that we as your workplace giving partner can stay the course and uphold our end goal of garnering more unrestricted revenue for your cause.
As always, we remain available to answer any questions you may have relating to this or anything else. Please do not hesitate to reach out to our Client Engagement Services Team at (800) 458-9505, Extension 4953, or via email at ClientSolutions@charities.org.