Proposed Changes in CFC Rules and Regulations Released
Final Draft Lacks Details, Poses Threat to Participating Charities

From the desk of Steve Delfin, President & CEO, America's Charities

April 11, 2013

As you know, each year America’s Charities applies to the Combined Federal Campaign (CFC) on behalf of you, our member charities. The Office of Personnel Management (OPM), which provides oversight to CFC, has just released new proposed regulations to the CFC. While these proposed changes will not affect the fall 2013 CFC, they have implications moving forward that are of concern.
 
As stated in my March 18, 2013 email related to these proposed changes, we have been monitoring the situation on your behalf, and have urged OPM to offer greater detail so we can offer you meaningful guidance.  On Monday, April 8, OPM published the proposed new regulations in the Federal Register with a 60-day public comment period now in effect.
 
We had hoped that this official release would provide the details we have sought. Unfortunately, this is not the case.  While some changes may be positive, our view is that many of the proposed changes are at best not thought through, and at worst, significantly flawed.  Thus, they pose a threat to the financial support you receive annually from federal employees. 
 
We encourage you to review the OPM’s official document containing the proposed changes in its entirety.  While we have many concerns, the most significant are as follows. Charities will be charged an up front, non-refundable application fee.  The amount, how it will be structured and when it goes into effect are not defined. Pledges will be made through electronic means. Cash, check and money order contributions will be eliminated.  And the CFC charity list and pledge form will also be made available only through electronic means. In other words, if you do not have access to a computer as part of your regular job, you won’t be able to give.

In our view these proposed changes dramatically impact your ability to benefit from the CFC and will result in decreased giving as many federal employees do not now, and will not in the foreseeable future, have access to the technology platforms. 

In addition much of the local CFC infrastructure responsible for putting a human face on the campaign will be eliminated and replaced by a regional structure and technology based campaign.   In our view this will result in a significant drop in participation and giving.

Strategy

We have been and continue to work collaboratively with the other major charity federations to determine how to best communicate our collective concerns to OPM. One last outreach to OPM occurred earlier this week.  They refused to provide any more detail.  Therefore, our strategy is as follows:

• America’s Charities will be part of a coordinated response signed on to by the major federations that will be submitted to OPM long before the June 7 deadline.


• We anticipate we will be calling on you to voice concern directly to OPM and targeted members of Congress.  However, we ask that you wait for further instructions and details from us to ensure we speak in a coordinated fashion with a consistent voice.


• Some media have already reported on the final proposed changes.  The coverage has been neutral and brief.  We may initiate a more aggressive media strategy as part of our broader efforts to influence OPM.  


• As noted above, we are at the beginning of a 60-day period to provide official comments to OPM.  The comment period ends June 7.  

The CFC has been a significant source of contributions and volunteers for over 50 years benefitting thousands of charities nationwide.  It is the world’s largest employee workplace giving campaign raising over $260 million each year.  It is a source of pride and employee engagement for tens of thousands of federal employee volunteers and donors who are dedicated to and believe in the CFC.  But unfortunately there are significant aspects of these proposed changes that pose a threat at a time when charitable organizations are being asked to do more than ever. 
 
We believe this is bad public policy and will be engaging you for your support to make our collective voice heard.

Important Conference Call   To address any questions and to provide further guidance on the proposed changes and our response strategy, we are conducting conference calls for all America’s Charities and affiliated Federation members (Children First, Health First and Community First) on Thursday, April 18th at the following times: 9:00 a.m., 11:00 a.m. and 12:30 p.m. (EDT).  We encourage you to participate so you are fully informed and ready to take action. Please click here to RSVP.

Sincerely,

Steve Delfin
President & CEO
America's Charities