2016
Combined Federal Campaign (CFC)
Orientation
&
Application Training
Combined Federal Campaign Orientation
• Federal Government’s employee charitable giving
program
• One campaign, one time of year, one ask
• Designation campaign – donors selects the
charity(s) they wish to give to; The campaign
DOES NOT collect contributions to be distributed
to all participating charities; DOES NOT provide
grants
• Contributions through payroll deductions, cash,
check or credit card
Orientation
• The solicitation occurs in the Fall; Designations
are distributed quarterly starting the following
April.
• Charities must apply annually
• Charities must meet eligibility requirements
• Charity is verified by the IRS annually
• Final authorization to list a charity and code
assignment by the Office of Personnel
Management (OPM)
• The Combined Federal Campaign is the only
authorized solicitation of employees in the
Federal workplace on behalf of charitable
organizations.
CFC Structure
Office of Personnel Management
(Government Regulators & Oversight)
Local Federal Coordinating Committee
(Local Campaign Oversight)
Local Federal Agencies
Principal Combined
Fund Organization
(administration)
Federal Agency
Loaned Representatives
Federal Agency
Campaign Coordinators
Keyworkers
Donors
Charitable Agencies
CFC Updates
• The Pikes Peak region and the Rocky Mountain
region have merged effective Jan 28, 2015
• Potential merger pending to include Cheyenne
Area CFC
• The region will consist of more than 80,000
Federal employees and Military personnel.
•The region covers the Colorado Front Range.
CFC Updates
The new Rocky Mountain region map
CFC Updates
• OPM is moving forward with the new regulations
implementation effective Jan, 2017
•Charity application information will start being made
available for the 2017 solicitation from OPM in Oct 2016
• Charities can anticipate significant change
•Centralized communications
•Online application – web uploads
•Application fees
•Federations should be prepared to adhere to new
regulations regarding their involvement in the
application process
Rocky Mountain
Application Timeline
Feb 19 – Deadline to submit application to receive
prescreening feedback, recommendations, and
alerts of completeness issues.
Feb 29 – Deadline for 2015 Rocky Mountain region
application period. All applications and corrections
must be received by 6:00 PM.
April 29 – Deadline for LFCC to notify local organizations
of eligibility decisions in writing
June 3 – Deadline for decisions by LFCC on all local
organization appeals
July 31 – OPM target for completion of local appeal
determinations
CFC Structure
• All aspects of the CFC, including eligibility for
participation, are strictly governed by Federal
regulation.
• The US Office of Personnel Management (OPM)
has the overall responsibility for regulating the
management of the CFC.
• OPM reviews and provides guidance and
technical advice on regulations, and has the
authority to conduct compliance audits on any CFC
local campaign fiscal records. This applies to
participating federations and independent charities.
Campaign Overview
• International, National or Local charities may participate
• International & National charities apply directly to the Office
of Personnel Management Office of CFC Operations
• The CFC charities are divided into federations and
independent organizations.
• Federation - group of charitable human health and welfare
organizations established for the purpose of supplying
common fundraising, administrative, and management
services to its members.
• Independent Organization - organization that applies to the
CFC on its own behalf. Local independent organizations apply
to the Local Federal Coordinating Committee.
Campaign Overview
• Federal employees who voluntarily choose to donate
through the Combined Federal Campaign may give
their money to a federation, to an organization under a
federation, or to an independent organization.
• Private foundations and most units of government are
not eligible to participate in the CFC. OPM will verify
each applicant’s I.R.S. Code § 501(c)(3) tax-exempt
status with the IRS.
Campaign Accountability
• Charities that want to receive funds generated by the
campaign are required to submit to a substantial
review of their financial and governance practices
prior to acceptance. This eligibility review is in line
with community norms, but it has helped set
standards for participation in giving initiatives that
transcend the community.
Review Process
Sampling of Federation Members
• Federations MUST submit full applications of all
new members and members not approved for
participation in 2015, regardless of if they were
approved as an independent charity in 2015.
• 20% Sampling of federation membership
PCFO Completeness Review
• Available for all charities upon request prior to
pre-screen deadline & provision of
indemnification statement
• PCFO will contact applicant regarding completeness
issues and administrative oversights
• PCFO does not evaluate eligibility
Key Application Documents
Att. A
Att. C (if appl.)
2015 Service
Description
Att. B
2016 CFC
Application
Certifications
IRS
Determination
Letter
Audited
Financial
Statements
Att. D
IRS Form 990
(same period
as audit)
CFC Application Cover Page
• Organization address must be a physical mailing
address. No P.O. Boxes , Commercial Mail Receiving
Agency (CMRA)
• Address will be verified
• Organizations that submit False Certifications will be
subject to sanctions
• Contact info may include P.O. Boxes
• Use of Electronic Funds Transfer (EFT) by PCFO –
submit banking information
CFC Certification Statement #1
Substantial Local Presence
• Local –defined as a staffed facility, office or
portion of a residence dedicated exclusively to
that organization, available to members of the
public seeking its services or benefits
• Must have:
o Office in local campaign geographic area
o Open to the public 15 hours per week
o Exclusively dedicated phone line to the organization
CFC Certification Statement #1
Substantial Local Presence
• Substantial local presence cannot be
met on the basis of services provided
solely through an “800” telephone
number or by disseminating
information or publications via the U.S.
Postal Service, the Internet, or a
combination thereof.
CFC Certification Statement #1
Substantial Local Presence
• Service Address - The location within
the regional boundaries where services
are provided (if different from the
Organization Address).
• This address cannot be a PO BOX or a
Commercial Mail Receiving Agency
(CMRA) This address will be verified
prior to final eligibility determination.
CFC Certification Statement #1
Substantial Local Presence
Attachment A – Supporting Documentation
• WHO received the service, benefit, or
assistance
• WHAT the service, benefit, or assistance is
• WHEN it was delivered (must be in calendar
year 2015)
• WHERE it was delivered
CFC Certification Statement #1
Substantial Local Presence
Factors OPM/LFCC will consider:
• Nature and extent of the service, benefit,
assistance, or program activity
• Frequency, continuity, and duration of services
• Impact on, or benefit to, beneficiaries
• Number of beneficiaries
CFC Certification Statement #1
Substantial Local Presence
Applicants should avoid…
• Generalized statements
• Listing “offered” services
• Listing location of members, affiliates, or board
members
• Listing the residences of visitors to a facility
• Listing services provided by the service recipient
or other entity
• Fundraising activities as a service
CFC Certification Statement #1
Substantial Local Presence
Examples of Non-Qualifying Attachment A:
Denver, CO Charity Central holds an annual health fair
to promote healthier lifestyles in our community.
Colorado Springs, CO November 2015 ABC Charity’s
Colorado chapter held a workshop for local families
interested in learning more about ABC’s research
programs. Presentations were made by ABC Charity
Colorado’s Executive Director and Vice President of
Research.
CFC Certification Statement #1
Substantial Local Presence
Example of Qualifying Attachment A:
Colorado – Calendar Year 2015 (scholarships awarded
bimonthly)
• Charity XYZ awarded scholarships to the following
Colorado Front Range high school students pursuing
a degree in computer technology to attend the
college or university of their choice:
 A. Smith, El Paso County ($1,800)
 J. Doe, Jefferson County ($5,000)
 B. Callahan, Boulder County ($1,200)
 D. Johnson, Fremont County ($800)
 C. Jones, Douglas County ($900)
CFC Certification Statement #1
Substantial Local Presence
Example of Non-qualifying Attachment A:
Fort Collins The Philanthropy Museum, based in Fort
Collins, recorded 300 visitors from 27 Northern
Colorado counties since 2009.
Colorado Springs August 10, 2015 XYZ Institute
conducted a fundraiser at the Colorado Springs
Independence Day celebration that raised $22,000.
250 Coloradoians representing 20 counties
contributed.
CFC Certification Statement #2
Tax-Exempt Status
Not part of group
exemption
 Has own IRS letter
Part of Group
Exemption
 Name may not
be unique
 EIN listed in IRS
BMF
501(c)(3)
TaxExemption
Chapter/Affiliate
 Letter from CEO
 Name and EIN may be
same as the parent org.
CFC Certification Statement #2
Tax-Exempt Status
Family support and youth activities (also known as
Morale, Welfare and Recreation organizations or
“MWRs”) must meet criteria outlined at 5 CFR
950.204(d).
Commanding officer’s letter must specify that
organization is a “Non-Appropriated Fund
Instrumentality that supports the installation
MWR/FSYA program.”
• Cannot have an EIN of a charitable organization
• Cannot be recognized by the IRS as a 501(c) (3)
Day care centers located on Federal property may not
participate under these guidelines.
CFC Certification Statement #2
Tax-Exempt Status
Any charity that has not been verified by OPM
as having 501(c)(3) tax-exempt status cannot be
approved by the LFCC. The LFCC MAY NOT
approve a charity contingent on OPM’s
verification at a later date.
CFC Certification #3
Affiliation Status
• Choose one of three options:
I certify the organization named in this
application is not part of a group exemption;
Name and EIN on IRS Determination letter
will be unique
I certify the organization named in this
application is part of a group exemption;
Name may or may not be unique
Organizations using this certification should
have an EIN that is different from the EIN on
the national group exemption letter
Must have certification letter from national
organization dated on or after Oct 1, 2015.
CFC Certification #3
Affiliation Status (cont.)
• I certify the organization named in this application is
a bona-fide chapter or affiliate which operates
under a national organization’s single corporate taxexemption.
Name and EIN will be the same as national
Must provide certification letter from national
dated on or after Oct 1, 2015
CFC Certification Statement #4
I certify the organization named in the application is a
human health and welfare organization providing
services, benefits, or assistance to, or conducting
activities affecting human health and welfare.
2015 human health/welfare service must be in
Attachment A.
CFC Certification Statement #5
Audited Financial Statements
Total Revenue
Per 990
Accrual
Accounting
(GAAP)
Audited
Annually
Submit Audit
>$250k

$100250k




<$100k
CFC Certification Statement #5
•
Choose one of three options:
1.
Revenues over $250,000:
– accounts for its funds on the accrual basis in
accordance with generally accepted accounting
principles (GAAP); and,
– has an audit (NOT review) annually by an
independent certified public accountant in
accordance with generally accepted auditing
standards (GAAS).
 Include as Attachment C audit for FYE June 30,
2014 or more recent
 If using national organization information, provide
certification from CEO of affiliated national
organization for FYE June 30, 2014 or more recent
OR
CFC Certification Statement #5
Audited Financial Statements
• Audit must cover the fiscal period ending on or
after June 30, 2014 (18 months prior to January
2014)
• Typical Title: XYZ Organization
Financial Statements
June 30, 2014 and 2013
• Audit must state organization accounts for its
funds in accordance with generally accepted
accounting principles (GAAP) and it was audited
in accordance with generally accepted auditing
standards (GAAS)
“except for” statements may cause denial
• Audit report must be signed, dated and be on the
audit firm’s letterhead
CFC Certification Statement #6
Include as ATTACHMENT D a copy of the most
recently completed IRS Form 990, including
signature in the box marked “signature of Officer.
The preparer’s signature alone is not sufficient
•Must cover same time period as audited financial statements
•Copies of IRS Forms 990 filed electronically are acceptable if IRS Form
8879-EO or 8453-EO is also provided. (See CFC Memo 2007-11)
•If organization is not required to file the form 990, it must still provide a
pro forma Form 990 – see OPM requirements for submission
Any organization’s IRS Form 990 that does not include a complete list of
the officers, Board of Directors, trustees and key employees, and their
compensation, if any, is incomplete and will result in a denial. The number
of voting members on page 1 must be equal to or less than the number of
individuals identified as a director or trustee in Part VII (see CFC Memo 2010-5).
If page 1 lists more voting members than are listed in Part VII, the organization must
either provide an explanation of the difference or submit an amended IRS Form 990
CFC Certification Statement #6
990 vs. Pro Forma (Partial) 990
IRS Form 990
Pro Forma 990
• Filed with IRS
• Match FY of Audit
• FY ended on or
after 6/30/14
• Officer’s Signature
• All sections
•Download 990 from
IRS website/CFC
website
•FY ended on or
after 6/30/14
•Officer’s Signature
•Parts I, II, VIIA, VII,
VIII, IX and XII only
CFC Certification Statement #7
I certify the administrative and fundraising rate for the
organization named in this application is __ __ .__%
Regulatory Formula:
In Part IX (Statement of Functional Expenses, ADD
Line 25, Column C to the amount in Line 25,
Column D. Divide the sum by Part VIII (Statement
of Revenue, Line 12, Column A (Total Revenue).
The regulatory formula must be used. No other
calculations/methods are allowed
CFC Certification Statement #8
Governing Body
“I certify that an active and responsible
governing body, whose members have no
material conflict of interest and a majority of
whom serves without compensation, directs
the organization named in this application.”
• The number of voting members on page 1 must
be equal to or less than the number of individuals
identified as a director or trustee in Part VII (see
CFC Memo 2010-5).
• If page 1 lists more voting members than are
listed in Part VII, the organization must either
provide an explanation of the difference or
submit an amended IRS Form 990
CFC Certification Statement #8 (cont.)
• An organization’s IRS Form 990 that does not include
a complete list of the officers, Board of Directors,
trustees and key employees, and their
compensation, if any, is incomplete and will result
in a denial.
• Uncompensated members must have a -0- in the
compensation column or the box above the table in
Part VII must be checked.
CFC Certification Statement #8 (cont.)
CFC Certification Statement #8 (cont.)
CFC Certification Statement #9
Sale/Lease of Contributor Information
I certify the organization named in this application
prohibits the sale or lease of CFC contributor lists.
– Donor names and addresses may be used to
acknowledge the contribution. CFC regulations
prohibit the sale or lease of this information.
CFC Certification Statement #10
I certify the organization named in this application
conducts publicity and promotional activities based
upon its actual program and operations, these
activities are truthful and non-deceptive, include all
material facts, and make no exaggerated or
misleading claims.
CFC Certification Statement #11
I certify the organization named in this application
effectively uses the funds contributed by Federal
personnel for its announced purposes.
CFC Certification Statement #12
Sanctions Compliance
Sanctions compliance certification is required
Wording in CFC application provided by OPM must
be used
The list of countries, entities, or individuals
referenced in the certification can be found at
www.treas.gov/ofac.
 Guidance in CFC Memorandum 2005-13
Certifying Official’s Signature
• Certifying official does not have to be Executive
Director, but must be individual in a position to
verify the validity of the application and all
attachments.
• Applicants must check the box next to each
statement to demonstrate agreement to comply
with the statement
Attachment E
25 Word Statement
• Include as ATTACHMENT E a 25-word statement for
listing in the campaign brochure. (See Instructions Item
13 for additional required information and the
taxonomy codes.)
EXAMPLE:
0000
Name of Organization
(legal name of organization, if applicable) (202)5551234 www.opm.gov/cfc EIN#123456789 The
description will contain no more than 25 words. It
should be worded so the donor understands the
program services provided. 4.2% B,V,O
Federation Requirements
• Listing of Eligible Member Organizations (Legal name, DBA, EIN,
AFR, and Local Presence Category)
• Submission of Audit Regardless of Size
 Audit must include verification organization is honoring
designations
• Board Terms and Meeting Dates/Locations
• Annual Report
 Must contain a full description of the federation’s activities
and supporting services during the year covered by the
report
 Identify its directors and chief administrative personnel
 Describe Dues and/or Fees Arrangements
 The annual report must cover the fiscal year ending not
more than 18 months prior to January of the campaign
year to which the federation is applying or the preceding
calendar year.
Federation Attachment A
•
•
•
•
Use the provided OPM L3 Report.
Sort the list for your Federation.
Do not make any changes to the charity name,
legal name or EIN number used to verify charities
in the IRS data base. EVEN IF IT IS MISSPELLED, is
in UPPER CASE or is listed differently than the
Federation lists it
It is in the report as it is recognized in the IRS
master file.
Federation Attachment A
•
•
Update contact information, website, AFR, 25 word
statement, and taxonomy information as needed in
bold BLUE font to stand out on the report for
returning member charities.
For new charities, insert the required information
for all fields at the bottom of the list in bold GREEN
font. Use the same formatting as listed charities for
EIN number and telephone number.
Federation Attachment A
•
•
•
•
Rename the file to your Federation’s name
Save the renamed file to your hard drive
Attached it to an e-mail with the Federation Name
and Attachment A in the Subject line to:
rockymountaincfc@comcast.net
Copy file to a diskette and submit it with your
Federation Application
Common Application Mistakes
• Application not signed.
• Incorrect certification for local presence, adjacent
campaign presence or statewide presence.
• Agency does not provide adequate documentation of
Human Health and Welfare as defined by the regulations.
(Attachment A)
• Missing or incomplete board information included on IRS
for 990.
• IRS Form 990 not signed by an Officer.
• There were more voting members listed on part 1 line 3 of
IRS Form 990 than were listed in Part VII, and the
organization did not provide an explanation of the
difference or submit an amended IRS form 990.
Appeals Process
• LFCC must provide information on how to
appeal at the local and national levels
• Appeals limited to the facts justifying the
reversal of the original decision
• No oral arguments. All appeals are in writing
only.
• Appeals may not be used to supplement
applications with missing or outdated
documents
Eligibility Appeals
• All organizations that apply for local eligibility and are
found ineligible have only one opportunity to appeal to
the LFCC.
• If found ineligible on appeal by the LFCC, the
organization will have only one opportunity to appeal
to the Director of OPM.
• The Director's decision is final for administrative
purposes.
• Appellants should insure that their appeals are
complete and responsive to the actual reasons for the
LFCC denial decision.
Questions
?