The Dog That Didn’t Bark, and Should Touchdowns be worth 10 Points?

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    This posting by: Bill Huddleston

    Massive CFC Changes Proposed

    …Riveting Reading in the Federal Register
    I realize I’m mixing metaphors in the headline, but the intent is to get your attention about something that is very important to any nonprofit that is enrolled in the Combined Federal Campaign (CFC), or is considering applying in the future.

    During the 50th Anniversary of the Combined Federal Campaign in 2011, there was a special advisory council formed, named the CFC-50 Commission with the charter to hold several public hearings and make recommendations to the Director of the Office of Personnel Management (OPM) on ways to improve and streamline the CFC.

    As I write this (in late January), the draft CFC regulations have been proposed, but they have not yet been published in the Federal Register, which is the government site where all proposed government regulations are posted. The standard window for public comments is 60 days from the date of publication in the Federal register.

    By the time you’re reading this, the regulations will probably be published, and I will have information on my website about them and how to comment. As citizens, anyone can comment and suggest improvements or concerns about proposed government regulations, which by law, the sponsoring agency must consider.

    I realize that this is different than all of my other postings on how to use the CFC as one of the tools in your development toolbox for generating unrestricted funds, but this is a rare opportunity to make the case about ways to improve the CFC for both charities and donors. Regulations have been updated over the years, with the most recent being in 2007 when the CFC code numbers went from 4 digits to 5 digits and many of the application hurdles were eliminated.

    These proposed cfc-50 rule changes are a much bigger deal. They’re on a par with changing the rules of football so that touchdowns are worth 10 points, but it’s now to be played on a 120-yard field.

    The proposed regulations print out on 53 pages so I can’t cover it in detail in this post. The intended goal of the proposed regulations is to “streamline the operations and increase the effectiveness of the program to ensure its continued growth and success.”

    I certainly agree with that goal, but I do have two types of concerns with the draft regulations, one type is that I think some of the proposed regulations will not have that effect, and indeed will instead have a negative effect, such as the proposal to completely eliminate the printed catalog of CFC charities.

    The second type of concern I have, and this is even more fundamental is what is not included in the proposed regulations, and there is no mention about whether it was considered or not. As fans of Sherlock Holmes will recognize from the headline above, in the case of the Silver Blaze Mystery the major clue was the fact that the watchdog did not bark. In the case of the proposed CFC regulations, what’s missing is any consideration or approach for allowing retirees to continue to contribute to their favorite charities through the CFC, if they wish to do so. Given the amount of Federal retirements that have already taken place, and will continue to occur as the baby boomers retire, this has huge consequences for the CFC and the charities the Federal donor supports.

    Another proposed rule change is to have some type of application fee associated with the CFC, but the amount and how this would work is not specified.

    Another example of something not mentioned, is that when the 2007 regulations were proposed, one of the stated reasons for going to a 5 digit code was so that any Federal employee could donate to any nonprofit, regardless of where he or she lived. For example, if someone living in the Washington DC area wanted to donate to mom’s favorite CFC nonprofit back in Iowa, they could. This is not allowed under the current organization for local charities, and it is not mentioned in the proposed regulations.

    I will have a detailed analysis of the proposed regulations on my website by the time you are reading this. Please check it out for both the analysis, and instructions on how to comment on proposed regulations through the Federal Register.
    During his 25-year career in the Federal sector, Bill Huddleston, The CFC Coach, served in many CFC roles. If you want to participate in the Combined Federal Campaign, maximize your nonprofit’s CFC revenues, or just ask a few questions, contact … Bill Huddleston
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