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CFC Memorandum 2003-09

September 3, 2003

FOR: HEADS OF NATIONAL FEDERATIONS, LOCAL FEDERATIONS AND UNAFILIATED CHARITIES
FROM: MARA T. PATERMASTER
DIRECTOR, OFFICE OF CFC OPERATIONS
SUBJECT: CFC APPLICATIONS AND USE OF STANDARD FORMATS AND CHECKLISTS FOR DOCUMENTING SERVICE REQUIREMENTS

Our recent review of 2003 CFC applications found a problem with the use of checklists and standardized formats used to describe services, benefits, assistance and program activities provided by a number of organizations. The purpose of this guidance is to advise that the use of such formats and checklists may substantially affect an applicant's ability to provide the necessary clear showing of real services, benefits, assistance or other program activities in any state as required by Attachment A of the CFC application. As such, an application using such methods may not meet the requirements of 5 CFR §950.203 (a)(5) in future CFCs.

National organizations and federations must demonstrate that real services, benefits, assistance or other program activities are provided in at least 15 states or one foreign country. An increasing number of applicants rely on the use of standard listings of service categories which an organization may "check-off" to indicate the services, benefits, assistance or program activities provided in each state. Associated with such checklists has been a tendency to replicate the identical narrative description of services for each of the states in which the organization is claiming a presence. In some cases, the only unique information provided is a number indicating how many persons the organization claims to have served in each state.

The use of broad descriptions of services, benefits, assistance or program activities and/or descriptions that replicate the identical information for each state in which service is claimed does not adequately allow OPM to determine that the real services, benefits, assistance or program activities were provided or to accurately determine the number of individuals or entities to whom these were delivered.

Each year, in the fall, OPM sponsors an orientation session for participating charities and prospective applicants. See examples used for training purposes which illustrate the clear showing of services, benefits, assistance or program activities as required in Attachment A.

Each year, in the fall, OPM sponsors an orientation session for participating charities and prospective applicants. Enclosed is a copy of examples used for training purposes which illustrate the clear showing of services, benefits, assistance or program activities as required in Attachment A.

As you know, CFC Operations staff is always willing to respond to questions about the application process and discuss any issues identified.

Thank you for your attention to this matter.


Suggestions For Attachment "A"

All organizations seeking national list eligibility must certify that it provides or conducts real services, benefits, assistance, or program activities, in 15 or more different states or a foreign country over the 3 year period immediately preceding the start of the year involved. This requirement cannot be met on the sole basis of services provided through an "800" telephone number or by sending materials via the U.S. Postal Service or a combination thereof. A schedule listing those states (minimum 15) or the foreign countries (minimum 1) where the program activities have been provided and a detailed description of the activities in each state or foreign country must be included with the application. While it is not expected that an organization maintain an office in each state or foreign country, a clear showing must be made of the actual services, benefits, assistance, or activities in each state or foreign country. See >5 CFR § 950.202(a).

DO

  • Specify the recipient(s) of the service, benefit, assistance, or program activity (WHO)
  • Describe the type of activities provided or conducted (WHAT)
  • Describe how the services were provided or conducted (HOW)
  • Provide dates of services within the 3 year period immediately prior to the application year (WHEN)
  • Describe where the activities were provided by state or country (WHERE) - a total of 15 states or 1 foreign country must be represented

DON'T

  • Generalize the nature of the activity
  • State that an activity was provided in "numerous states"
  • List activities that were "offered"
  • List location of membership organizations, affiliates, individual members, or Board members

NATIONAL ELIGIBILITY GUIDANCE (CFC Memorandum 2002-7)

While CFC regulations note that an organization is not expected to maintain an office in each state or foreign country, a clear showing must be made of the actual services, benefits, assistance or program activities provided in each state or foreign country. That is, a listing of services, benefits, assistance or activities must be provided for each of the 15 or more states or 1 foreign country where coverage is claimed. Providing the location of where organization members reside, alone, is not a sufficient clear showing to support eligibility.

  • Dissemination of Information/Research. The dissemination of information and publications, alone, does not meet the eligibility criteria in CFC regulations at 5 CFR §§ 950.202 and 203 for providing real services, benefits, assistance or program activities.
  • Use of lists (i.e. member listings/affiliated or support group listings). Providing listings of affiliated support groups and a breakdown of attendees, by state or foreign country, at an annual conference without further documentation of national or international presence is not a sufficient demonstration of real services, benefits, assistance or program activities required for national or international eligibility.
  • Memorials, Museums and Public Recreation Facilities. Merely listing the names and addresses of an organization's members or visitors to a facility does not satisfy national eligibility criteria.

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EXAMPLE OF A QUALIFYING ATTACHMENT A

Note:

There are many ways to present the information necessary to meet this eligibility requirement. Following is a sample of one format with hypothetical information that provides the required details.

    1. STATE-BY-STATE DESCRIPTION OF SERVICES
      • California

        June 1, 2002 - Sacramento - staff presented volunteer training on healthcare advocacy issues; attended by 100 individuals from northern California

        July 9, 2001 -- Annual meeting, "Philanthropy in the New Millennium" conducted in San Francisco

      • Colorado

        October 20, 2001 - Presented at the University of Colorado Health and Wellness Fair. Staff were on-hand to distribute educational information and answer questions from students

    2. DESCRIPTION OF SERVICE WITH DETAILS ON RECIPIENTS

ABC Charity provides educational tools to inner-city schoolchildren whose families are below the poverty line. $5,000 educational scholarships for tuition at two or four year colleges are awarded to recipients who meet the eligibility criteria (3.0 grade point average, involvement in extra-curricular activities, 500-word essay, etc.). Following is a listing of the students who have received ABC scholarships in 2000-2002.

2001

    • A. Johnson - Miami, FL
    • C. Smith - Seattle, WA
    • J. Andrews - Los Angeles, CA
    • J. Callahan - Philadelphia, PA

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EXAMPLES OF NON-QUALIFYING ATTACHMENTS A

ABC Charity's publication, ABC Cares, is distributed monthly to 3,000 members residing in all 50 states, the District of Columbia, and Puerto Rico. Thousand of others receive ABC Charity's information from our website and other publications.

  • This information does not provide specific information to demonstrate that a real service was provided in at least 15 states.

ABC Charity offers educational packages to schools in every state. The package includes information on cancer prevention and detection.

  • This statement does not indicate that a real service has been provided. Applicants must demonstrate clearly that a service was rendered, describe the nature of the service, when it was provided, and who received it.

Attached is a listing of ABC Charity-affiliated support groups in 25 states.

  • A listing of affiliated groups, alone, is not sufficient to demonstrate real services, programs, or assistance. Applicants must provide additional details on the nature of the applicant's relationship with these groups and the services provided to them ( financial support, presentations, educational materials, etc.)

Over the past three years, ABC Charity's literature is used by high schools and universities in the following states: AL, CA, DE, FL, GA, IL, IN, ME, NY, NH, OH, OR, PA,

  • This example does not provide sufficient details to demonstrate who received the service, when it was delivered, or how it was delivered.

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