Accounting for Funds Received via the Deployed Troops Pilot Program
CFC Memorandum 2006-23
February 27, 2006
| TO: | LOCAL FEDERAL COORDINATING COMMITTEES AND PRINCIPAL COMBINED FUND ORGANIZATIONS |
|---|---|
| FROM: | MARA T. PATERMASTER DIRECTOR, OFFICE OF CFC OPERATIONS |
| SUBJECT: | ACCOUNTING FOR FUNDS RECEIVED VIA THE DEPLOYED TROOPS PILOT PROGRAM |
Background
On February 27, 2006, the Department of Defense (DoD) announced a pilot program that included two additional options for deployed troops participating in the 2006 Combined Federal Campaign (CFC). The pilot program seeks to address the loss of CFC contributions to local charitable organizations due to the deployment of DoD personnel to certain war fighting areas of responsibility. Under the pilot program, the CFC Overseas Campaign (CFC-O) will offer affected deployed DoD personnel a modified CFC-O Campaign pledge card with two added donation options, as follows:
- Each deployed employee may designate all or a portion of their donation to their home installation's Morale, Welfare, and Recreation (MWR) activities which have been determined eligible to participate in the stateside local CFC; and/or,
- Each deployed employee may elect to apply all or a portion of their total contribution as a designated contribution for distribution among all local charities (ALC) located within the geographic area of their home base campaign.
The option of giving to the National and International charities listed in the CFC Overseas Campaign is unchanged.
All other campaign practices and policies affecting the solicitation of DoD personnel deployed to the affected war fighting areas of responsibility remain the same. Personnel deployed to the affected war fighting areas of responsibility during the campaign season can only be solicited by the CFC- Overseas. The only exception to this policy is when a Navy ship has been deployed but is still considered "homeported." In this instance, the stateside campaign should continue to solicit the donor stationed on the homeported ship.
Accounting/Tracking of Funds
The pledge card contains a place for each donor to identify his/her post, camp, base or station on the pledge card so that any donation under the pilot program can be correctly processed to the appropriate stateside campaign.
The CFC-O will collect and process all pledges from deployed troops. Payroll offices will transmit employee contributions to the CFC-O directly. The CFC-O will report these pledges on its 1417 report and for any media/marketing/advertising purposes as they will be considered pledged through their campaign. The stateside PCFO will need to track these receipts separately from its own Campaign receipts and then make payments to the MWRs and ALCs along with the usual monthly/quarterly disbursements. Although receipts from deployed troop contributions must be accounted for financial reporting purposes as "Other CFC receipts", these amounts cannot be combined with the totals reported by employees locally. Stateside PCFOs may however, recognize these additional contributions as long as they are not reported as campaign totals.
Reports and Payments from the CFC-O to Stateside CFCs
Stateside campaigns will receive a report from the CFC-O that provides details on how much should be paid to the MWRs and ALCs. For MWRs it will identify the post, camp, base or station associated with the amounts to be paid. The CFC-O will transmit these reports to the stateside local campaigns no later than March 15, 2007. Based upon the contributor's identification of stateside post, camp, base or station on the pledge card, the CFC-O will provide the participating stateside PCFO a one-time distribution for those receipts of $1,000 or less, less costs and shrinkage, and regular monthly distributions for receipts of over $1,000. Final payments in the distribution cycle will be sent early enough that the recipient campaign can include them in its final payment to charities. In order to distribute these designated funds to MWRs and ALCs, the stateside PCFO only needs to adjust its distribution schedules and include these CFC-O Campaign contributions in its regular monthly/quarterly distributions to the local charities and track as cash received. Consequently, no additional processing costs to distribute these donations are required or permitted.
Allocations and Payments to MWRs by Stateside Campaigns
Funds designated to stateside MWRs will be allocated by the stateside Local Federal Coordinating Committees (LFCC) in coordination with the appropriate installation commanders or designated installation staff. The LFCC will be able to identify which installations (posts, camps, bases, or stations) it needs to coordinate with and will need to document either through meeting minutes or written agreement how funds will be allocated to the eligible MWRs participating in the stateside 2006 CFC for that installation. For example, the LFCC and installation commander may decide that each of the MWRs participating in the CFC for the particular CFC will share any funding equally or based on some other percentages. This agreement needs to be documented and retained for auditing purposes.
Because of wide variations in the participation of MWRs by military branch the stateside PCFO may encounter the following scenarios:
No Eligible MWRs in Donor's Branch of the Military
If deployed troops designated funds to a particular post, camp, base or station that does not have any eligible MWRs participating in the stateside local CFC, then the stateside local campaign will allocate funds equally to any installations from the same branch of the military that have MWRs participating in stateside CFC. The LFCC must coordinate with the installation commanders on how the funds will be shared with the MWRs on the local installation that participate in the CFC. For example, if deployed troops from the Coronado Naval Base in the San Diego CFC select the MWR option on their pledge cards, but no MWRs from the Coronado Naval Base participate in the CFC, then the funds should be divided equally among any other Naval installations that have MWRs participating in the CFC and the LFCC will coordinate with those installation commanders on how to allocate those funds if there is more than one participating MWR at those installations. If no other MWRs from the same branch of the military participate in the local CFC, then the stateside local campaign will allocate funds equally among all installations that have participating MWRs. The LFCC will coordinate with those installation commanders on how to allocate those funds if there is more than one participating MWR at those installations.
No Participating MWRs in Stateside Campaign
If deployed troops designated funds to MWRs, but the campaign does not have any participating MWRs, then the assumption is that the donor wanted to keep his/her donation local and the campaign should allocate the funds to all local charities as described in the next paragraph.
Allocations and Payments to All Local Charities by Stateside Campaigns
| Charity Name | Amount Designated | Percentage Designated | Local Amount Designated | Local Percentage Designated | Total ALC Designation |
|---|---|---|---|---|---|
| national 1 | $ 100 | 12.90% | |||
| national 2 | $ 100 | 12.90% | |||
| national 3 | $200 | 25.81% | |||
| local 1 | $50 | 6.45% | $50 | 13.33% | $ 66.67 |
| local 2 | $ 25 | 3.23% | $ 25 | 6.67% | $ 33.33 |
| local 3 | $ 300 | 38.71% | $ 300 | 80.00% | $ 400.00 |
|
Campaign Total |
$775 | 100.00% | |||
| Local Totals | $375 | 100.00% | $500.00 |
Audit Procedures
For stateside campaigns, the Office of CFC Operations will provide specific AUPs to the 2008 CFC Audit Guide, which will cover the 2006 CFC and this deployed troop pilot program, to ensure that activity from the pilot program are specifically tested. The additional AUPs will include testing that the stateside PCFO distributed funds in accordance with the reports from the CFC-O, the documented allocation agreements between the LFCC and installation commanders for MWRs and the prescribed ALC allocations in this Guidance Memorandum.
As such, the CFC-O and affected stateside campaigns will need to maintain all records related to the reporting, receipt, allocation and distribution of funds related to the pilot program for at least three completed campaign periods, in accordance with CFC regulation 5 CFR § 950.604.
For question or further information regarding this memorandum, please contact Mark Lambert, Senior Compliance Officer on 202-606-2564 or at mark.lambert@opm.gov.