Report Tile

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Report Tile
2009 Combined Federal Campaign (CFC) Eligibility
Requirements
UNITED STATES OFFICE OF PERSONNEL MANAGEMENT
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Combined Federal Campaign Overview

• Annual fund-raising drive conducted by Federal
  employees
• Raise millions of dollars through the CFC
• Benefits thousands of non-profit Human Health
  and Welfare charities.
• Campaign conducted during a 6 week period
• Sept 1 Dec 15, at every Federal agency.
• The Combined Federal Campaign is the only
  authorized solicitation of employees in the
  Federal workplace on behalf of charitable
  organizations.

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• Federal employees have an opportunity to give to
  charity through the CFC via cash, check or
  payroll deduction by designating a donation to
  the charities of their choice. Only charities
  that have been accepted into the CFC may receive
  designations.
• Each charity, upon meeting the eligibility
  requirements and being verified by the IRS to be
  in good standing, is assigned a charity code by
  OPM.
• Charities only receive funding if a designation
  has been made by a federal employee. The
  campaign DOES NOT collect contributions to be
  distributed to all participating charities.
• The solicitation for donor designations occurs
  in the Fall Designations are distributed
  quarterly starting the following April.

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• 2008 Campaign Results
• CFC of the Pikes Peak Region
• 2,113,252

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Pikes Peak RegionCFC Organizational Chart
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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 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.

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Campaign Overview

• The CFC is 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
  unaffiliated organizations apply to the Local
  Federal Coordinating Committee.
• International, National or Local

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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.
• All charities participating in the CFC must apply
  at either the national or local level. Only
  agencies approved by OPM or the LFCC may
  participate and must meet all requirements for
  eligibility.
• Private foundations and units of government are
  not eligible to participate in the CFC. OPM will
  verify each applicants I.R.S. Code 501(c)(3)
  tax-exempt status with the IRS.

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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.

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Eligibility Process

• Application Period March 9 April 9, 2009
• Application Submission 6660 Delmonico Drive,
  503D Colorado Springs, CO 80919 (UPS Store.)
• Application Review LFCC April 10 - 17
• Eligibility Determination Notification - LFCC
  May 1
• Local Appeals Deadline Charities May 15
• Local Appeals Notification LFCC June 8
• OPM Appeals June 22
• Final Eligibility Decision July 31

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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.

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Application

• Application available on our website
  www.peakcfc.com
• Federation member charity application
• Independent Charity Application
• Military Family Support Organization Application
• If submitting 2008 IRS 990 new application with
  new 990 form instructions

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Application Guidelines

• All required documents and attachments must be
  complete and submitted before the application
  deadline.
• Missing or out of date documents will not be
  accepted during the appeals process.
• The agency is to designate the Certifying
  Official for purposes of the application and use
  his or her signature consistently throughout the
  form no auto pens permitted.
• New - The CFC will not accept applications
  with modifications to any of the certification
  statements.

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Application Communications

• Only independent organizations will be contacted
  directly by the LFCC. If you apply as a member
  of a federation, DO NOT send the LFCC an
  independent application. If dual applications
  are found, the independent application will not
  be considered.
• FAXES OR ELECTRONIC SUBMISSIONS OF APPLICATIONS
  ARE NOT ACCEPTED

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Review Process

• Sampling of Federation Members
• Federations MUST submit full applications of all
  members not approved for participation in 2008
• LFCC will request 20 of member applications for
  audit sampling
• Completeness Review
• Contact applicant re administrative oversights

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Applicant Information

• Applicant MUST provide a physical mailing address
• PO Boxes may be used for campaign contact
  person/disbursement point
• Use of Electronic Funds Transfer (EFT) by
  campaigns is optional
• If campaign is not using EFT, it may be removed
  from the application cover page

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CFC Certification Statement 1Local, Adjacent,
or Statewide Presence

• DESCRIBE
• WHO received the service, benefit, assistance,
  or program activity
• WHAT the service, benefit, assistance, or
  program activity is
• WHEN it was delivered
• WHERE it was delivered

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CFC Certification Statement 1Local, Adjacent,
or Statewide Presence

• Hours of Operation
• Location County/State
• 2008 Human Health and Welfare Services

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CFC Certification Statement 1Local, Adjacent,
or Statewide Presence

• Factors OPM/LFCC will consider
• Nature and extent of the service, benefit,
  assistance, or program activity
• Frequency, continuity, and duration
• Impact on, or benefit to, beneficiaries
• Number of beneficiaries

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CFC Certification Statement 1Local, Adjacent,
or Statewide Presence

• Applicants should avoid
• Generalized statements
• Listing offered services
• Listing location of members, affiliates, or
  board members
• Listing the residencies of visitors to a facility

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CFC Certification Statement 1Local, Adjacent,
or Statewide Presence

• Applicants should avoid
• Listing services provided by another entity
• Listing services provided by the service
  recipient
• Information disseminated by United States Postal
  Service or Internet
• Repetitive text
• Fundraising activities as a service

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CFC Certification Statement 2IRS Determination
Letter

• Include a copy of the most recent IRS
  determination letter as ATTACHMENT B
• Must be 501(c)(3) tax-exempt organization
• Units of government are not eligible
• OPM will verify applicants current 501(c)(3)
  status with the IRS

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501(c)(3) Status Verification

• CFC regulations at 5 CFR 950.202 require an
  applicant charity to certify it is recognized by
  the Internal Revenue Service as tax-exempt under
  26 U.S.C. 501(c)(3) and to which contributions
  are tax-deductible pursuant to 26 U.S.C.
  170(c)(2).
• A 2006 Government Accountability Office review
  of the CFC found some participating organizations
  were not recognized as 501(c)(3) organizations by
  the IRS.

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Most Common Errors

• Typographical Errors in Employer Identification
  Number (EIN) provided
• Proper Legal Name not provided (insufficient
  Doing Business As (DBA) documentation)
• Governmental entity without 501(c)(3) recognition
• Charity moved (or address changed) and IRS was
  not notified
• Merger with another organization EIN changed
• IRS Form 990 was marked Final Return

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CFC Certification Statement 2IRS Determination
Letter

• Bona-Fide Chapters and Affiliates of a National
  Organization
• Include certification from CEO or equivalent (of
  parent) verifying applicant is in good standing
  with the national organization and is covered by
  the national organizations 501(c)(3)
  determination
• If organization name on IRS letter or IRS Form
  990 is different, official documentation from IRS
  or state government must be included

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CFC Certification 3Affiliation 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

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CFC Certification 3Affiliation Status (cont.)

• I certify the organization named in this
  application is a bona-fide chapter or affiliate
  which operates under a national organizations
  single corporate tax-exemption.
• Name and EIN will be the same as national
• Must provide certification letter from national

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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.
• 2007 human health/welfare service must be in
  Attachment A

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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 annually by an independent certified
  public accountant in accordance with generally
  accepted auditing standards (GAAS).
• Include as Attachment C
• If using national organization information,
  provide certification from CEO of affiliated
  national organization
• OR

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CFC Certification Statement 5 (cont.)

• 2. Revenues between 100,000 and 250,000
• accounts for its funds on an accrual basis in
  accordance with generally accepted accounting
  principles (GAAP) and,
• audited annually by an independent certified
  public accountant in accordance with generally
  accepted auditing standards (GAAS).
• Do not need to provide audit, but must be
  available if requested by LFCC/OPM
• OR

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CFC Certification Statement 5 (cont.)

• 3. I certify the organization named in this
  application reports total revenue of less than
  100,000 on its IRS Form 990 (or pro forma IRS
  Form 990) covering a period ending not more than
  18 months prior to January 2008 and has controls
  in place to ensure funds are properly accounted
  for and it can provide accurate timely financial
  information to interested parties.

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CFC Certification Statement 5 (cont.)

• The audit must cover the fiscal period ending on
  or after June 30, 2007 (18 months prior to
  January 2009)
• 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 firms letterhead

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CFC Certification Statement 6

• Two options
• I certify the organization named in this
  application prepares and submits to the IRS a
  complete copy of the organizations IRS Form 990.
  
• Include a copy of the complete IRS Form 990 for a
  period ending no later than 18 months prior to
  January 2009, including signatures in the box
  marked Signature of Officer as ATTACHMENT D
  
• 2008 990 Signature needed on Page 1 (Copy is
  accepted)
• 2007 990 Signature needed on Page 9 (Copy is
  accepted)

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CFC Certification Statement 6 (cont.)

• Schedule B is not required, but all other
  supporting schedules are required
• If organization filed a 990EZ, may provide a copy
  with pro-forma Page 1 and Part V of IRS Form 990
  (officers signature is not required)
• If the organization is using the revised 2008 IRS
  Form 990 as its pro forma 990, then it must
  complete and provide page 1 (Part I, Summary and
  Part II, Signature Block) pages 7 and 8 (Part
  VII, Compensation sections A and B) page 9 (Part
  VIII, Statement of Revenues) and page 10 (Part
  IX, Statement of Functional Expenses).
• OR

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CFC Certification Statement 6 (cont.)

• I certify the organization named in this
  application is not required to prepare and submit
  an IRS Form 990 to the IRS.
• Include a pro forma IRS Form 990 page 1 and Part
  V only for a period ending no later than 18
  months prior to January 2009 as ATTACHMENT D.
• If the organization is using the revised 2008 IRS
  Form 990 as its pro forma 990, then it must
  complete and provide page 1 (Part I, Summary and
  Part II, Signature Block) pages 7 and 8 (Part
  VII, Compensation sections A and B) page 9 (Part
  VIII, Statement of Revenues) and page 10 (Part
  IX, Statement of Functional Expenses).

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CFC Certification Statement 6 (cont.)

• Any organizations 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.

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CFC Certification Statement 7

• Regulatory Formula
• If using 2007 990 ADD Line 14 of IRS Form 990
  (management general expenses) and Line 15 of
  IRS Form 990 (fundraising expenses). Divide the
  sum by Line 12 of IRS Form 990 (total revenue).
• If using 2008 990 Add the amount in Part IX
  (Statement of Functional Expenses), Line 25,
  Column C (Management and General Expenses) to the
  amount in Line 25, Column D (Fundraising
  Expenses), dividing the sum by Part VIII
  (Statement of Revenue), Line 12, Column A (Total
  Revenue). 
• No other methods may be used to calculate this
  percentage. All percentages must be listed to the
  tenth of a percent (i10.0 or 15.5).

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CFC Certification Statement 8Board of Directors

• I certify an active and responsible governing
  body, whose members have no material conflict of
  interest and a majority of which serve without
  compensation, directs the organization named in
  this application.
• Listing of Board terms of office and meeting
  dates/locations required of Federations only.

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CFC Certification Statement 9Sale/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

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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.

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CFC Certification Statement 11

• I certify the organization named in this
  application effectively uses the funds
  contributed by Federal personnel for its
  announced purposes.

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CFC Certification Statement 12Sanctions
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

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CFC Certification Statement 13Sanctions
Compliance

• 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.)

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Certifying Officials Signature

• The Certifying officials signature MUST be
  original
• Automatic pens and/or signature stamps may not be
  used
• Federations may provide photocopies
• Applicants must check the box next to each
  statement to demonstrate agreement to comply with
  each certification statement

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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
• Describe Dues and/or Fees Arrangements

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2008 Common Application Mistakes

• Application not signed or application did not
  have original signatures. COPIES ARE NOT
  ACCEPTED.
• Incorrect certification for local presence,
  adjacent campaign presence or statewide presence.
• IRS Form 990 not signed by an Officer on page 9
  of 990.
• IRS Form 990 and Audit time periods do not match.
  (time period must not be longer than 18 months
  from January, 2009 of the application year, June
  31, 2007.)

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2008 Common Application Mistakes

• IRS Form 990 and Audit are prepare using two
  different accounting methods one is prepared
  using cash method of accounting one is prepared
  using accrual method of accounting. (Must be
  accrual accounting method)
• IRS From 990 is incomplete does not include all
  supplemental statements and schedules
• Agency with income over 100,000 did not use
  accrual method of accounting.
• Agency does not provide adequate documentation of
  Human Health and Welfare as defined by the
  regulations. (Attachment A)

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Application Self - Audit Form

• Prepare Self Audit of your application using
  provided form
• - Submit Self Audit with application
• LFCC will compare your self audit with theirs

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APPLICATION RECEIPTCONFIRMATION

• If sent with application, fax will confirm
  arrival of application.

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Annual Registration Facts

• Coded charities will use the same code every
  year.
• All applicants must be submitted to OPM for
  tax-exempt validation. If the applicant is new,
  the OPM will assign a 5-digit CFC code also.
• Only charities that are (a) determined eligible,
  (b) coded, and(c) are verified by OPM as
  tax-exempt may be listed in thecampaign charity
  list.
• OPM will review charity lists annually for
  compliance.
• Charities that do not pass OPMs automated
  validation process must submit documentation to
  OPM for manual verification.

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2009 Improvements

• Soliciting advance chapter/affiliate
  verificationsfrom national/parent organizations.

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Process for Registry (Steps 1-4)

• Use the 2009 Exempt Status report from OPM to
  identify returning applicants that need to
  produce tax-exempt documentation and notify them.
• Notify applicants that participation, if
  approved,is Contingent upon verification of
  their current 501(c)(3) tax-exempt status by
  OPM.
• Verification documents must be received by the
  campaign by July 31st (and to OPM by August 5th)
• Complete your local eligibility decisions.

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Contingent Eligibility and Verification
Documentation

• Notify applicants that participation, if
  approved,is Contingent upon verification of
  their current 501(c)(3) tax-exempt status by
  OPM.
• Verification documents must be received by the
  campaign by July 31st (and to OPM by August 5th)

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Contingent Eligibility and Verification
Documentation

• Charities
• Be proactive
• Check the IRS Exempt Organizations Master Listing
  now to determine if they are currently in good
  standing.
• The Master Listing is available at this URL
• www.irs.gov/taxstats/charitablestats/article/0,,i
  d97186,00.html.

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Contingent Eligibility and Verification
Documentation

• Separately organized charities If not found in
  the Master file, these organizations need to
• Contact the IRS Tax-Exempt Division at
• [phone].
• Request an Affirmation Letter dated on or after
  January 1 of the application year and submit the
  letter no later than the last business day in
  July tothe campaign and to OPM by August 5, 2009.

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Contingent Eligibility and Verification
Documentation

• Bona-Fide Chapters and Affiliates of a National
  Organizations If not found not found in the
  Master file, these organizations need to
• Follow the documentation requirements described
  in the 2009 Model Application.

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Common Automated-Validation Errors

• EIN is not correct or has dashes.
• Legal name is not identical to the legal name on
  file with IRS, including punctuation and spacing.
• The legal name and EIN do not match.

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Common Automated-Validation Errors
4. The address on the local application does not
match the address on file with IRS. 5. Parent
Organization has not notified OPM that the
applicant is tax-exempt OR OPM has not received
proper verification documents from the campaign.
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Q A
Questions?
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OPM 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
• Appeals may not be used to supplement
  applications with missing or outdated documents