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CFC MEMORANDUM 1998-02

SUBJECT:
  • Schedule of CFC Events During 1998
  • Model Applications for local federations and unaffiliated agencies with administrative guidance
  • CFC Audit Guides for large and small campaigns.
  • OPM Regional Workshop Information
  • OPM Form 1417 information

The above mentioned information is attached on the enclosed diskette in wordperfect 5.0 format. Additional copies of this information can ONLY be obtained through our web page at www.opm.gov/cfc.

This memorandum transmits specific guidance regarding applications and appeals. PLEASE PAY ATTENTION TO THE NEW FORMAT ON THE MODEL APPLICATIONS. Also included is the calendar of key CFC events during 1998. The calendar includes the key dates for the 1998 CFC, OPM regional workshop dates, and deadlines for 1998 campaign events.

Due to the new format development by the Office of Personnel Management (OPM) for the model applications, please find attached to this memorandum a diskette which contains the 1998 model applications and instructions. The model applications include all the requirements of the 1995 published CFC regulations. It is the applicant organization's responsibility to ensure reproduction of the application form and to retain and to update the information for future campaigns. Only new organizations or former CFC applicants requesting applications will get applications in future campaign years. Once this mailing is complete, OPM will no longer reissue the model application form each year.

LOCAL APPLICATIONS

The time for receipt of local applications and appeals is 5:00 p.m. (local time) on the dates established by the Local Federal Coordinating Committee (LFCC) in accordance with CFC regulations. It is suggested that LFCC's encourage, but not require, the use of the model application forms provided by OPM.

NATIONAL APPLICATIONS

OPM encourages organizations to apply early and, if possible, send the application via certified mail. Using the model application provided by OPM is not required but will expedite processing. The application deadline for organizations and federations seeking national eligibility is 5:00 p.m. Eastern Standard Time, February 5, 1998. A timely application must be received by the deadline at the following address:

Office of Personnel Management
Office of CFC Operations, Room 5450
1900 E Street, NW
Washington, DC 20415

BELOW IS A SHORT LIST OF PROBLEM AREAS IDENTIFIED DURING PREVIOUS APPLICATION PERIODS:

Complete Applications.

All required documents must be submitted before the application deadline. APPLICATIONS MUST BE COMPLETE. Missing and/or out-of-date materials will not be considered during the application or appeal process. An appeal must address ONLY the reason for denial.

Independent submission of required documents.

Local or regional affiliates of national organizations must submit their own required documents as part of their applications. Copies of the state, regional or national annual reports and IRS Form 990 are not acceptable. However, consolidated audits in accordance with GAAS are acceptable but must reflect the applicant organization's revenue and expenses in a separate schedule. Compiled audits are not acceptable.

Audit Reconciliation.

If the total revenue and expenses in the IRS Form 990 do not reconcile with the audit, the auditor or certifying officer of the organization must submit a written explanation or complete IRS Form 990, Parts IV-A & IV-B. The audit and the IRS Form 990 must cover the same period of time.

Properly documenting service areas covered.

CFC eligibility requirements mandate that statewide organizations demonstrate the area in which its services are provided. Simply providing a list of counties or areas where an organization conducts real services, benefits or program activities is not sufficient. Organizations must provide a full description of the services and activities they provided in each county or area over a three (3) year period and they should reflect more than a de minimus level.

The 25-word statement.

Marketing tactics to draw attention to an organization, such as capitalization, quotations, and underlining, will not be permitted. Any statement provided by the applicant that uses these tactics or exceeds 25 words will be edited by OPM or the LFCC. Organizations will be listed by their incorporated names only unless the appropriate legal documentation permitting otherwise, such as a Doing Business As (d.b.a.) letter from the IRS, is provided with the application. If the charity wishes to use its former name in addition to the new title, the former name will be counted as a part of the 25 words. A home page address may be included in addition to an agency address and phone number. E-mail addresses are not permissible.

Improper deadlines

The deadline for reviews and appeals are expressly stated in the CFC regulations. Absent specific approval from OPM, LFCC's have no authority to deviate from or waive the deadlines stated in the regulations.

REVIEW OF APPLICATIONS OF FEDERATED AGENCIES

OPM will continue to select a sample of member applications for review from each national federation. For each member organization selected, OPM will require the federation to submit a copy of the application via next-day mail. LFCC's are strongly encouraged to begin or continue this same procedure regarding local federations. Particular attention should be given to federations whose members consist primarily of chapters of national organizations.

OPM has requested national federations submit a full application on any member organizations which are new to that federation. We recommend that each LFCC make the request for copies of new member organizations in local federations in accordance with '950.304(b). LFCC's must request this information. This will not only help assure the true certification of all agencies listed on a local level, but it will increase your chances for full compliance during OPM Office of the Inspector general (OIG) audits.

APPEALS

Local organizations must appeal adverse eligibility decisions to the LFCC within seven (7) calendar days from the date of receipt of the LFCC's original decision or 14 calendar days from the date the decision was mailed, whichever is earlier. If the LFCC denies the local organization's appeal, the organization may appeal to the Director of OPM. The Director of OPM must receive a local appeal within 14 calendar days of the date of the letter of the LFCC's denial of the appeal.

LFCC's must inform appellants of the materials, listed below, required for appeals to OPM.

- the LFCC's letter denying their eligibility and the reason(s)

- their appeal to the LFCC with all attachments, and

- the LFCC's letter denying the appeal.

LFCC's must cite each regulatory deficiency for denying an applicant's eligibility. LFCC's may not deny an organization's appeal for any reason(s) other than those stated in disapproving the application. Similarly, the Director will only consider the specific reasons for the LFCC's denial of the application.

CFC AUDIT GUIDES FOR LARGE AND SMALL CAMPAIGNS

We are pleased to forward guidance for Local Combined Federal Campaign (CFC) accountability. Please review the document carefully while completing. The Office of Personnel management (OPM) Office of the Inspector general (OIG) reviewed 32 CFC campaigns during 1997 and revisions to the audit guide have been added as a result.

The attached documents provide guidance to Principal Combined Fund Organizations (PCFO') for completing Office of Personnel Management (OPM) audit requirements for local Combined Federal Campaigns (CFC's). These reporting requirements are effective immediately.

For campaigns with gross receipts exceeding $250,000, an audit must be conducted consistent with the Combined Federal Campaign Audit Guide for Large Campaigns. For campaigns with gross receipts of $250,000 or less, a review by the PCFO must be conducted consistent with the Combined Federal Campaign Compliance Assessment Guide for Small Campaigns.

CFC WORKSHOPS

Although the agenda is still being developed, the dates and sites for the three 1998 CFC Workshops have been selected. The first workshop will be in Chicago, IL, March 22-24, 1998; the second will be in San Diego, CA, March 29-31, 1998; and the last will be in Tampa, FL, April 5-7, 1998. Registration materials will be sent in the near future. We encourage at least one member of the LFCC and PCFO attend one of the workshops. Charitable organizations are also encouraged to attend any or all of the workshops. The cost of attendance for the LFCC and PCFO should be included as a campaign expense for the 1998 CFC.

OPM FORM 1417

The OPM Form 1417 will be forward to all PCFO' in mid January of 1998 to report on the 1997 campaign figures. The Form 1417 has been completely revised to fit our current processing needs. In accordance with the new processing at OPM, it will be required that all PCFO' fax in their completed forms. Mailed copies will not be accepted as we are working toward complying with the Paper Reduction Act. OPM has waived the February 15 deadline and extended it to march 15, 1998, however, no additional extensions will be granted and any PCFO which has not reported their Form 1417 figures by the deadline of March 15, 1998 will be sanctioned by OPM.

My best wishes for a successful 1998 campaign.

This memorandum was sent with a diskette containing the model application, 1998 calendar of events, and audit guides.  The information has been updated and is still available on our web page.