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2016 Norcal Combined Federal Campaign (CFC) Orientation & Application Training.

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Presentation on theme: "2016 Norcal Combined Federal Campaign (CFC) Orientation & Application Training."— Presentation transcript:

1 2016 Norcal Combined Federal Campaign (CFC) Orientation & Application Training

2 2 Federal Government: – Employee charitable giving program – 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, check or credit card The Combined Federal Campaign is the only authorized solicitation of employees in the Federal workplace on behalf of charitable organizations. Combined Federal Campaign Orientation

3 3 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 to be in their data base annually Final authorization to list a charity and code assignment by the Office of Personnel Management (OPM) Combined Federal Campaign Orientation

4 CFC Organizational Chart Local Federal Agencies Local Federal Coordinating Committee (LFCC) (Local Campaign Oversight) Office of Personnel Management (Government Regulators & Oversight) Principal Combined Fund Organization Administration (PCFO) Charitable Agencies Federal Agency Loaned Representatives Federal Agency Campaign Coordinators Keyworkers Donors 4

5 5 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

6 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. Note: This applies to participating Federations & independent charities CFC Structure 6

7 7 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.

8 8 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

9 Application Timeline March 1 – Deadline to submit application to receive PCFO prescreening feedback, recommendations and alerts of completeness issues. March 15– Deadline for 2016 NorCal region application period 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 9

10 Norcal Review Process Sampling of Federation Members 2016 - Federations MUST SUBMIT full applications of ALL members. PCFO Completeness Review Available to charities upon request prior to pre- screen deadline & provision of indemnification statement PCFO will contact applicant regarding administrative oversights PCFO does not evaluate eligibility 10

11 Key Application Documents 11 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

12 12 CFC Application Cover Page Organization address must be a physical mailing address. No P.O. Boxes or Commercial Mail Receiving Agency (UPS Store address, Mailboxes Etc. address or USPS General Mail Facilities.) 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

13 13 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

14 14 CFC Certification Statement #1 Substantial Local Presence Must be located in YELLOW counties only

15 15 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.

16 16 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.

17 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 17

18 18 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

19 19 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

20 20 CFC Certification Statement #1 Substantial Local Presence Examples of Non-Qualifying Attachment A: Sacramento, CA Charity Central holds an annual health fair to promote healthier lifestyles in our community. San Francisco, CA November 2015 ABC Charity’s California chapter held a workshop for local families interested in learning more about ABC’s research programs. Presentations were made by ABC Charity California’s Executive Director and Vice President of Research.

21 21 CFC Certification Statement #1 Substantial Local Presence Example of Qualifying Attachment A: California – Calendar Year 2015 (scholarships awarded bimonthly ) Charity XYZ awarded scholarships to the following Northern California high school students pursuing a degree in computer technology to attend the college or university of their choice:  A. Smith, Alameda County ($1,800)  J. Doe, Napa County ($5,000)  B. Callahan, San Francisco County ($1,200)  D. Johnson, Sierra County ($800)  C. Jones, Yuba County ($900)

22 22 CFC Certification Statement #1 Substantial Local Presence Example of Non-qualifying Attachment A: San Francisco The Philanthropy Museum, based in San Francisco, recorded 300 visitors from 27 Northern California counties since 2009. San Jose August 10, 2015 XYZ Institute conducted a fundraiser at the San Jose Independence Day celebration that raised $22,000. 250 Californian residents, representing 48 counties contributed.

23 23 CFC Certification Statement #2 Tax-Exempt Status Not part of group exemption Has own IRS letter 501(c)(3) Tax- Exemption 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.

24 CFC Certification Statement #2 Tax-Exempt Status 24 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 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.

25 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. MAY NOT approve a charity contingent on OPM’s verification at a later date. 25

26 26 CFC Certification #3 Affiliation Status (cont.) Choose one of three options: Option 1  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

27 27 CFC Certification #3 Affiliation Status (cont.) Choose one of three options: Option 2  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.

28 28 CFC Certification #3 Affiliation Status (cont.) Choose one of three options: Option 3  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

29 29 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. 2015 human health/welfare service must be in Attachment A.

30 CFC Certification Statement #5 Audited Financial Statements 30 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

31 CFC Certification Statement #5 Audited Financial Statements 31 Choose one of three options: I certify that the organization named in this application reports total revenue of at least $100,000 but less than $250,000 on its IRS Form 990 (or pro forma IRS Form 990) covering a period ending not more than 18 months prior to January 2016 and meets both of the following two conditions: accounts for its funds on an accrual basis in accordance with generally accepted accounting principles (GAAP); and, has an audit of its fiscal operations completed annually by an independent certified public accountant in accordance with generally accepted auditing standards (GAAS). OR

32 CFC Certification Statement #5 Audited Financial Statements 32 I certify that 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 2016 and has controls in place to ensure funds are properly accounted for and that it can provide accurate timely financial information to interested parties.

33 33 CFC Certification Statement #5 Audited Financial Statements Total Revenue Per 990 >$250k$100- 250k <$100k Accrual Accounting (GAAP) Audited Annually Submit Audit

34 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 2015) 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 34

35 35 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 2007-11) If organization is not required to file the form 990, it must still provide a pro forma Form 990 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 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

36 36 CFC Certification Statement #6 990 vs. Pro Forma 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 FY ended on or after 6/30/14 Officer’s Signature Parts I, II, VIIA, VII, VIII, IX and XII only

37 37 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). NOTE: The regulatory formula must be used. No other calculations/methods are allowed

38 38 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 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

39 39 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.

40 40 CFC Certification Statement #8 (cont.)

41 41 CFC Certification Statement #8 (cont.)

42 42 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.

43 43 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.

44 44 CFC Certification Statement #11 I certify the organization named in this application effectively uses the funds contributed by Federal personnel for its announced purposes.

45 45 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: www.treas.gov/ofac.www.treas.gov/ofac Guidance in CFC Memorandum 2005-13 at: http://www.opm.gov/combined-federal- campaign/reference-materials/memos/2005-cfc- memos/2006-cfc-application-sanctions-compliance- certification/ http://www.opm.gov/combined-federal- campaign/reference-materials/memos/2005-cfc- memos/2006-cfc-application-sanctions-compliance- certification/

46 46 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

47 47 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: 00000Name of Organization (legal name of organization, if applicable) (202)555- 1234 www.opm.gov/cfc EIN#123456789 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

48 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. 48

49 49 Attachment A – Federation membership listing See Item 1 Attachment B – Federation’s IRS determination letter See Item 2 Attachment C – Audited Financial Statements See Item 4 Attachment D – IRS Form 990 See Item 5 Attachment E – Board Members’ Current Terms of Office, Meeting Dates and Locations See Item 7 Attachment F – Annual Report  See Item 12 Federations Supporting Documentation

50 50 Federation Attachment A Use the provided OPM L3 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. OPM initiated an annual charity verification process following a Government Accounting Office investigation of charities

51 51 Federation Attachment A Cont. 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.

52 52 Federation Attachment A Cont. Rename the file to your Federation’s name Save the renamed file to your hard drive Attach it to an e-mail with the Federation Name and Attachment A in the Subject line to: norcalcfc@comcast.net Copy file to a CD or jump drive and submit it with your Federation Application

53 53 Common Application Mistakes Application not signed. 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.

54 54 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

55 55 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

56 56 ? Questions


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