Current Structure of the CFC OPM Local Federal Coordinating Committees (LFCC) Local, National, International Charities PCFO Local Federal Agencies Sets Policy & Procedures Provides Campaign Oversight Manages Local Campaign

OPM Regional Coordinating Committee (Replaces LFCC) Must be a military base, FEB, FEA, or Federal Agency identified as the lead agency Staffed by federal volunteers to provides leadership, works w/ OPM to review applications, hire marketing firm, covers a larger territory Charities Pay fee to apply amount unknown Central Campaign Administrator (replace PCFO) Manages office functions such as application processing, pledge processing, pay marketing firm etc. These might also act as regional receipt and disbursement centers. Marketing Firm (Replace PCFO) Hired by RCC per OPM’s guidance to promote the campaign and train volunteers Regional Receipt and Disbursement Center Fed Pay Centers Proposed “Streamlined and Efficient” CFC Structure Sets Policy & Procedures Provides Campaign Oversight Manages Local Campaign

Procedures OPM Submit draft to OMB for ApprovalCompleted OMB publishes proposed rule in Federal RegisterCompleted Public Comment PeriodThru June 7 OPM drafts final rule based on public commentsImmediately OPM submits final rule to OMBImmediately OMB reviews and approves final rule Up to 60 days OMB publishes final rule in Federal RegisterTBA OPM implements new regulations2014 Based on 2006 regulation change timeline Office of CFC Operations Potential Timeline for Proposed Final Rule

OPM sets amount of money required to fund the campaign’s central administration and regional marketing Potential Charity Application FeeOct 31, 2014 No details provided on the proposed upfront and non- refundable charity application fee  Fee is non-refundable whether accepted to participate or not; charities will be forced to make expenditures without knowing the benefits  Fee amount unknown  No detail on assessed processing / administration  OPM lacks the capacity to review more than 25,000 charity applications each year Charity Impact

OPM proposed regulations lack specificity, which could lead to unforeseen impacts OPM proposed regulations lack organizational details and timelines No detail on when or who would begin serving as CCA  Government Contract Bidding Process Timeline? No detail for central online application process No local CFC guidance or training No details on how a central processing of disbursements  CCA?  Payroll Offices What is the implication for tax deductibility on donor contributions? Charity Impact

Loss of local “ownership” of the campaign Loss of fundraising events Loss of local promotion of the campaign Loss of charity visibility/exposure for Federal employees Loss of Local Federal Coordinating Committees (LFCCs) oversight Loss of local Federal employee engagement diminish the role of local federal employee volunteers Eliminate much of this personal interaction Charity Application FeeOct 31, 2014 OPM proposed regulations lack specificity, which could lead to unforeseen impacts Charity Impact