What We’re Seeing in the New CFC Regs: Campaign Administration

As we reported in yesterday’s post, rx stuff the Federal Times has published OPM’s draft of the final regulations for the CFC, remedy cheap which will take effect for the 2015 campaign. We promised further analysis. Because there are so many changes – including some big ones – we’ll look at one area at a time, comparing existing regulations with the proposed new ones.

We begin with changes in campaign administration, which are less sweeping in the version of the regulations published yesterday than in the version the government released last April. That earlier draft proposed replacing the entire CFC administrative structure with new organizations to manage operations. The newly published version retains part of the existing structure – the Local Federal Coordinating Committees which are composed of federal volunteers who help run the campaign in their community.

Under the new version of the regs, LFCCs will have less authority than is the case now.  For instance, LFCCs currently determine eligibility of local applicants within their CFC zone. The newly published version of the regs say LFCCs will “assist in determining” eligibility; the final decision will rest with OPM. Also, LFCCs are now responsible for ensuring that other federal volunteers are adequately trained in CFC rules and procedures; under the new version of the regs, OPM will conduct the training.

In the newly published regs, the government still proposes to eliminate the PCFOs – the Principal Combined Fund Organizations. Currently, PCFOs administer the campaign in each CFC zone. Reporting to the LFCCs, PCFO responsibilities include the receipt of applications from local organizations seeking to enter the CFC, promotion of the campaign, creation of a local CFC website, printing and distribution of the Charity Directory and pledge cards, collection and tallying of pledges, and the distribution of donated funds to benefiting charities.

If the government proceeds with the version of the regs just published by Federal Times, PCFO responsibilities will be handled by one or more Central Campaign Administrators (CCAs) and community-based Outreach Coordinators. The CCA (or CCAs) will create and manage a national website that will accept national and local charity applications, publish the Charity Directory, solicit online pledges and credit card donations, and assist in the transfer of donations to benefiting charities. OPM will select and manage the CCA(s) which must be 501(c)(3) exempt and cannot receive CFC pledges.

Outreach Coordinators will take over the task of promoting the campaign in CFC zones. LFCCs will be authorized to hire Outreach Coordinators, which can be individuals or entities.

It may seem natural that today’s PCFOs would become tomorrow’s Outreach Coordinators, but we wonder how many will. The Outreach Coordinator’s role is narrower and the work would appear to be seasonal. With the strong push toward online pledging, the character and frequency of campaign events could change. The calculus of whether the contract is worthwhile may be different.

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