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Report Tile
2013 Combined Federal Campaign (CFC) Orientation
Eligibility Requirements
UNITED STATES OFFICE OF PERSONNEL MANAGEMENT
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Presenters

• Barbara Barfield, CFC Director, Rocky Mountain
  Region
• [phone], BarbaraBarfield_at_FESforCFC.org
• Cari Allen, CFC Coordinator, Rocky Mountain
  Region
• [phone], CariAllen_at_FesforCFC.org
• Anita Obando, Larimer County Manager, Rocky
  Mountain Region
• [phone], AnitaObando_at_FESforCFC.org
• Website www.rockymountaincfc.org

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Orientation

• Combined Federal Campaign
• Federal Governments employee charitable giving
  program
• Federal employees raise millions of dollars
  through CFC
• 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
• Contributions through payroll deductions, cash or
  check

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Orientation

• The solicitation occurs in the Fall Designations
  are distributed quarterly starting the following
  April.
• Charities must apply annually
• Charities must meet eligibility requirements
• Upon meeting the eligibility requirements,
  charity is verified by the IRS to be in their
  data base
• 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.

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Orientation
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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 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.

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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.
• 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 Feb 27 March 27, 2013
• Application Submission 6660 Delmonico Drive,
  503D Colorado Springs, CO 80919 (UPS Store.)
• Courtesy PCFO Application Completeness Review
• Contact applicant regarding administrative
  oversights
• Application Review LFCC Mar 28 Apr 18
• Eligibility Determination Notification - LFCC
  April 26
• Local Appeals Deadline - Charities May 3 -10
• (within seven (7) business days of the date of
  receipt of the initial LFCC decision or fourteen
  (14) )
• Local Appeals Notification LFCC June 4
• OPM Appeals June 8
• Final Eligibility Decision Target July 31

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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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Annual CFC 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. L3
  L5 Reports of verified charities as of 12/31
• Charities that do not pass OPMs automated
  validation process must submit documentation to
  OPM for manual verification.
• 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.

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Charity Registration Improvements

• Soliciting advance chapter/affiliate
  verificationsfrom national/parent organizations.
  
• Use the 2012 Exempt Status report from OPM to
  identify returning applicants that need to
  produce tax-exempt documentation and notify them.
• Provided with application
• PCFO granted direct access to OPM data system to
  enter charity verification information.
• Immediate EIN verification
• System will have already verified charities in
  system from pervious application years thru
  12/31/2012
• System will indicate to PCFO if a charity cannot
  be verified
• PCFO will be able to cross walk an EIN for
  accuracy with name it is associated with

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Verification Documentation

• Charities
• Be proactive
• Verify your organization is listed in the L5
  Report
• Check L3 report of address issues.
• 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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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 and submit the
  letter to the CFC with 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 spelling, punctuation
  and spacing.
• The legal name and EIN do not match.
• 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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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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Application

• Application available on our website
  www.rockymountancfc.org
• Federation member charity application
• Independent Charity Application
• Military Family Support Organization Application

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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 2012 Model Application.

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Application Guidelines

• All required documents and attachments must be
  complete and submitted before the application
  deadline.
• CFC will not accept late applications
• 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.
• The CFC will not accept applications with
  modifications to any of the certification
  statements.

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Review Process

• Completeness Review
• PCFO will pre-screen applications for
  completeness must include indemnification
  statement
• Contact applicant re administrative oversights
• Sampling of Federation Members
• All applications received will be reviewed for
  eligibility
• Federations MUST submit full applications of all
  members not approved for participation in 2012
  and all new members applications
• LFCC will request 20 of member applications for
  audit sampling

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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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2013 Application Changes

• Certifying official signature does not have to be
  original
• Revisions to Pro Forma 990 Requirements
• 0 AFR must be verified by audit
• Appeal documentation

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CFC Application Cover Page

• Include five-digit code, if participated in 2012
  CFC or previously
• Organization address must be a physical mailing
  address. No P.O. Boxes
• Contact info may include P.O. Boxes
• Use of Electronic Funds Transfer (EFT) in Pikes
  Peak Region

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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
• Example ABC charity provided (what) 50 tons of
  non perishable food to the (who) indigent in the
  (where) Denver County from (when) January 1, 2012
  thru December 31, 2012

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CFC Certification Statement 1Local, Adjacent,
or Statewide Presence

• Hours of Operation
• Location County/State
• 2012 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 1Local, Adjacent,
or Statewide Presence

• Example of Qualifying Attachment A
• Louisiana
• New Orleans 1-3, 2012 ABC Charity conducted a
  national conference on cancer research and
  treatment in New Orleans. ABC Charity staff made
  presentations on new research, provided advocacy
  training to attendees, and facilitated a
  discussion between policymakers and medical
  researchers. 120 healthcare industry
  professionals attended the three-day conference

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CFC Certification Statement 1Local and Adjacent
Presence

• Example of Qualifying Attachment A
• Louisiana Calendar Year 2012 (scholarships
  awarded bimonthly)
• Charity International awarded scholarships to the
  following Louisiana high school students pursuing
  a degree in computer technology to attend the
  college or university of their choice
• A. Smith, Jefferson Parish (1,800)
• J. Doe, St. Charles Parish (5,000)
• B. Callahan, Orleans Parish (1,200)
• D. Johnson, Jefferson Parish (800)
• C. Jones, Ascension Parish (900)

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CFC Certification Statement 1Local or Adjacent
Presence

• Examples of Non-Qualifying Attachment A
• Boulder, CO December 2012 Charity Central held a
  Family Day attended by local physicians.
• Denver, CO The Charity Museum, based in Fort
  Worth, recorded 300 visitors from 60 parishes
  since 2005.
• Golden, CO August 2012 XYZ Institute conducted a
  fundraiser at the Golden Independence Day
  celebration that raised 33,000. 250 Golden
  residents contributed.

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CFC Certification Statement 1Statewide Presence

• Example of Non-qualifying Statewide Attachment A
• Colorado Springs 2012 ABC Charity provides
  newsletters, mentoring program, recreational
  activities, and counseling to at-risk youth. We
  have two youth camps in the Pikes Peak area
  serving 100 young adults
• Canon City 2012 ABC Charity provides
  newsletters, mentoring program, recreational
  activities, and counseling to at-risk youth. We
  have a youth camp in the Canon City area serving
  130 young adults

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CFC Certification Statement 1Local, Adjacent,
or Statewide Presence

• 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).

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Web-Based Service Requirements

• Records indicating geographic distribution of
  users
• Describe scope of services received
• Document 2 of the following
• -Evidence that users registered for the
  service
• -Summary reports documenting customer
  feedback
• -Evidence that users paid a fee

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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
• If name on IRS letter, IRS Form 990, or audit is
  different from applicant, official documentation
  from IRS or state government must be included

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CFC Certification Statement 2IRS Determination
Letter

• Bona-Fide Chapters and Affiliates of a Parent
  Organization
• Include a certification letter date no older than
  Oct 1, 2012, from CEO or equivalent verifying
  applicant is in good standing with parent and is
  covered by parents 501(c)(3) determination, IRS
  Form 990 and audited financial statements

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CFC Certification Statement 2Tax-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 officers letter must specify that
  organization is a Non-Appropriated Fund
  Instrumentality that supports the installation
  MWR/FSYA program.  
• Day care centers located on Federal property
  may not participate under these guidelines.

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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 dated on
• or after Oct 1, 2012.

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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
  dated on or after Oct 1, 2012

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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.
• 2012 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 audit for FYE June 30,
  2011 or more recent
• If using national organization information,
  provide certification from CEO of affiliated
  national organization for FYE June 30, 2011 or
  more recent
• 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 2013 and has controls
  in place to ensure funds are properly accounted
  for and it can provide accurate timely financial
  information to interested parties. (not required
  to use GAAP accounting can use Cash Accounting.)

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CFC Certification Statement 5Audited Financial
Statements
Total Revenue Per 990 gt250k 100-250k lt100k
Accrual Accounting (GAAP)
Audited Annually
Submit Audit
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CFC Certification Statement 5 (cont.)

• The audit must cover the fiscal period ending on
  or after June 30, 2011 (18 months prior to
  January 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 will 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
• Option 1
• 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 2013, including signatures in the box
  marked Signature of Officer as ATTACHMENT D .

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CFC Certification Statement 6 (cont.)

• Option 2
• I certify the organization named in this
  application is not required to prepare and submit
  an IRS Form 990 to the IRS.
• Download IRS From 990 (www.irs.gov)
• Include a pro forma IRS Form 990 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), Page
  10 (Part IX, Statement of Functional Expenses),
  and Page 11 (Part XI, Financial Statements and
  Reporting).

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CFC Certification Statement 6990 vs. Pro Forma
990Summary

• IRS Form 990
• Filed with IRS
• Match FY of Audit
• FY ended on or after 6/30/11
• Officers Signature
• All sections

• Pro Forma 990
• Download 990 from IRS website
• FY ended on or after 6/30/11
• Officers Signature
• Parts I, II, VIIA, VIII, IX and XII only

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CFC Certification Statement 6 (cont.)

• Include as ATTACHMENT D a copy of the most
  recently completed IRS Form 990, including
  signature in the box marked signature of
  Officer. The preparers 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
• 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.  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

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CFC Certification Statement 7
I certify the administrative and fundraising rate
for the organization named in this application is
__ __ .__

• Regulatory Formula
• 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

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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.
• Verified on IRS form 990 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 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

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CFC Certification Statement 8 (cont.)
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CFC Certification Statement 8(cont.)
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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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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 00000 Name of Organization
  (legal name of organization, if applicable)
  [phone] www.opm.gov/cfc EIN123456789 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

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Key Application Documents
Att. A 2012 Service Description
Att. C (if appl.) Audited Financial Statements
2013 CFC Application Certifications
Att. B IRS Determination Letter
Att. D IRS Form 990 (same period as audit)
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Certifying Officials 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
• Federations may provide photocopies
• Applicants must check the box next to each
  statement to demonstrate compliance with each
  certification statement Failure to check box is
  interpreted as refusal to comply with the
  certification statement and charity will be
  denied eligibility

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2012 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.

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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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Eligibility Appeals Process

• 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
• No oral arguments. All appeals are in writing
  only.

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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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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, e-mail from PCFO will
  confirm arrival of application.

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PCFO APPLICATION COMPLETENESS PRE SCREEN

• If the indemnification statement is signed and
  returned with application
• Charity will be notified via e-mail or telephone
  of screening findings.
• Organization may choose to provide items noted or
  not.
• The PCFO does NOT make any eligibility decisions

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Q A
Questions?