2013 Combined Federal Campaign (CFC) Orientation & Eligibility Requirements Report Tile UNITED STATES OFFICE OF PERSONNEL MANAGEMENT
Presenters • Barbara Barfield, CFC Director, Rocky Mountain Region (719) 531-5501, BarbaraBarfield@FESforCFC.org • Cari Allen, CFC Coordinator, Rocky Mountain Region (720) 352-5076, CariAllen@FesforCFC.org • Anita Obando, Larimer County Manager, Rocky Mountain Region (720) 999-1015, AnitaObando@FESforCFC.org Website: www.rockymountaincfc.org
Orientation • Combined Federal Campaign • Federal Government’s 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
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.
Rocky Mountain RegionCFC Organizational Chart Office of Personnel Management (Regulators & Oversight) Local Federal Coordinating Committee (Campaign Oversight) (Federal Agency Heads or their Representatives) Principal Combined Fund Organization (administration) Charitable Agencies Local Federal Agencies Orientation
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.
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, Nationalor Local
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 applicant’s I.R.S. Code § 501(c)(3) tax-exempt status with the IRS.
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.
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
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.
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 OPM’s 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.
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
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,,id=97186,00.html.
Verification Documentation • Separately organized charities – If not found in the Master file, these organizations need to: • Contact the IRS Tax-Exempt Division at: • (877) 829-5500. • Request an “Affirmation Letter” and submit the letter to the CFC with application.
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.
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”
Application • Application available on our website: www.rockymountancfc.org • Federation & member charity application • Independent Charity Application • Military Family Support Organization Application
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.
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.
ReviewProcess 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
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
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
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
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
CFC Certification Statement #1Local, Adjacent, or Statewide Presence • Hours of Operation • Location – County/State • 2012 Human Health and Welfare Services
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
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
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
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 CFC Certification Statement #1Local, Adjacent, or Statewide Presence
CFC Certification Statement #1Local and Adjacent Presence Example of Qualifying AttachmentA 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) 32
CFC Certification Statement #1Local or Adjacent Presence Examples of Non-Qualifying Attachment A Boulder, CODecember 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. 33
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 34
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). 35
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
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 applicant’s 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
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 parent’s 501(c)(3) determination, IRS Form 990 and audited financial statements
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 officer’s 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.
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.
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 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, 2012
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.
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
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
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.)
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 firm’s letterhead
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 organization’s 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 .
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).
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 • Officer’s Signature • All sections Pro Forma 990 • Download 990 from IRS website • FY ended on or after 6/30/11 • Officer’s Signature • Parts I, II, VIIA, VIII, IX and XII only