2016 Combined Federal Campaign (CFC) Orientation & Application Training

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 Combined Federal Campaign 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. Orientation

CFC Structure Local Federal Agencies Local Federal Coordinating Committee (Local Campaign Oversight) Office of Personnel Management (Government Regulators & Oversight) Principal Combined Fund Organization (administration) Charitable Agencies Federal Agency Loaned Representatives Federal Agency Campaign Coordinators Keyworkers Donors

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 CFC Updates

Norcal Application Timeline March 1– Deadline to submit application to receive prescreening feedback, recommendations, and alerts of completeness issues. March 15 – 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

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. CFC Structure

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.

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 Overview

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. Campaign Accountability

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 % 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 2015 Service Description Att. B IRS Determination Letter Att. C (if appl.) Audited Financial Statements Att. D IRS Form 990 (same period as audit) 2016 CFC Application Certifications

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 Colorado Springs August 10, 2015 XYZ Institute conducted a fundraiser at the Colorado Springs Independence Day celebration that raised $22, Coloradoians representing 20 counties contributed.

CFC Certification Statement #2 Tax-Exempt Status 501(c)(3) Tax- Exemption Not part of group exemption Has own IRS letter Part of Group Exemption Name may not be unique EIN listed in IRS BMF 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 (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 tax- exemption. 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 human health/welfare service must be in Attachment A.

CFC Certification Statement #5 Audited Financial Statements Total Revenue Per 990 >$250k$ k <$100k Accrual Accounting (GAAP) Audited Annually Submit Audit

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 ) 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 ). 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 Filed with IRS Match FY of Audit FY ended on or after 6/30/14 Officer’s Signature All sections Pro Forma 990 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 ). 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 #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 Guidance in CFC Memorandum

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: 0000Name of Organization (legal name of organization, if applicable) (202) EIN# 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 L7 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 with the Federation Name and Attachment A in the Subject line to: 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

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. Eligibility Appeals

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