Guidance on Application Review for the 2001 Campaign

CFC Memorandum 2000-07

During our review of CFC applications and appeals for the 2000 CFC, we became aware of the need to clarify certain aspects of the application review and approval process. This memorandum also provides guidance on how to address organizations providing web-based services not currently addressed in the regulations. If you have any questions about this guidance, please contact by e-mail, LGSUNDRO@opm.gov

1. Statement of Real Benefits and Services

OPM regulations require applicant organizations to demonstrate that they provide or conduct real services, benefits, assistance, or program activities. Applications should have a clear showing of what services are provided, who benefits and how they benefit. Detailed descriptions of the activities of an organization must be included as part of an application.

It has been OPM's interpretation of its CFC regulations that sending or mailing information or literature to recipients, such as home study material, books, and other publications does not meet the requirement of providing or conducting real services, benefits, assistance, or program activities. OPM interprets its regulations to require a more substantial and direct presence in the required number of states.

2. Administrative and Fundraising Expenses

Agencies are not automatically disqualified solely on the basis for having an administrative and fundraising rate above 25%. If a reasonable justification is provided to the satisfaction of the LFCC and a formal plan for the reduction of administrative and fundraising expenses is provided, organizations above 25% must be considered for participation in the CFC.

When reviewing CFC applications for organizations that participated in the past, we strongly recommend that LFCCs review the history of administrative and fundraising expenses for previous years in order to fully evaluate whether the organization has made progress in lowering its administrative and fundraising expenses. Typically it can take several years to lower the rate to the standards acceptable to the CFC, and we therefore advise that the record for at least the previous two years be taken into consideration.

3. Federation Status

If a federation is disqualified for not meeting the 15 member minimum, each member must be reviewed individually for eligibility in the CFC. Provided each organization qualifies on its own merits, they must be allowed to participate as unaffiliated organizations.

4. Statewide Presence

Criteria in the regulations require that organizations seeking statewide presence cover 30% of a state's geographic boundaries or affect 30% of a state's population. We recognize that statewide presence can be hard to measure. This is particularly true for organizations that provide environmental services, or for organizations providing services actually used by some but not available to all members of the general public.

Assessing the 30% Population Test

In the case of the 30% population test, it is OPM's interpretation that if an organization services special populations ( i.e. persons with HIV or AIDS, adults requiring literacy instruction, non-English speaking children, etc.) the organization should provide evidence that it affects 30% of the eligible or target population. This can be shown by providing an estimate (through population surveys, needs assessment studies, etc.) of the total target population eligible to receive the services. The organization would then be required to demonstrate that it provides or conducts real services, benefits, assistance, or program activities that affect 30% of the total target population.

Assessing the 30% Geographic Coverage Test

CFC regulations allow an organization to demonstrate that it provides or conducts real services, benefits, assistance or program activities covering 30% of a state's geographic boundaries. Applicant organizations must provide service records or other evidence (i.e. visitor statistics, client or membership statistics, habitat restoration, wildlife management project results or other projects, clearly outlined maps depicting the total geographic area of coverage) that clearly show what portion of the geographic area has been covered relative to the total state geographic area.

Whichever eligibility criteria the applicant organization chooses, LFCC's should keep in mind that the burden of proving the criteria is on the applicant organization. Organizations that apply for statewide presence are not required to provide services covering the geographic area or affecting the population within the applicable geographic boundaries of the CFC to which it is applying and therefore cannot be disqualified on this basis.

5. Web-based Services

The availability of electronic communication is opening new frontiers in all service sectors. Many organizations are adopting web-based information as a principal method of delivering information, education, and services. This trend suggests that future CFC applicants may increasingly use web-based services to justify eligibility to participate in the CFC.

As a general practice, organizations that wish to be considered for participation in the CFC that rely substantially on web-based services must comply with the requisite standards of public accountability defined in 5CFR 950. In addition, the Office of CFC Operations will require such organizations to also meet the following requirements:

• Proof of Service - service users, whether members of the general public, dues paying members or affiliate organizations, should be required to register for the site. The applicant organization must provide evidence that individuals connecting via the Internet actually received services related to the program. Reports that only reflect the number of hits to a website are not acceptable.

  Supporting documentation may consist of service logs or other records (i.e. service satisfaction surveys) indicating the geographic distribution of users and the scope of services received. If national eligibility or statewide eligibility is sought, evidence must be provided that the services, benefits, assistance or program activities met the requirements of 5 CFR 950.202 regarding national eligibility requirements or 950.204 regarding local eligibility requirements.

• Service Fees - consumer fees associated with the delivery of web-based services must be documented.
• Feedback Capability - evidence must be provided that the website has a mechanism for receiving feedback from its users. Summary reports documenting information reflecting customer feedback (i.e. through service satisfaction or utilization surveys or other mechanisms) should be available to OPM or the LFCC on request.

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