Recommended Structure and Governance Functions of LFCCs

The role of the Local Federal Coordinating Committee as defined in CFR Part 950 (CFC regulations) is not unlike that of the "board of directors" of a non-profit organization.

Because time and again governance emerges as one of the leading critical factors in achieving organizational effectiveness, the following guidelines have been developed as one of several alternative models for governance and structure of an LFCC.

Governance Functions

The LFCC should be structured to provide adequate oversight of the CFC's operations and its staff. There should also be a common understanding of the oversight responsibilities of the LFCC and the various leadership roles required in the CFC.

These include, but are not limited to, selection and supervision of the PCFO, regularly scheduled appraisals of the staff and campaign performance as required by the CFC rules, review of evidence of disbursement controls through LFCC approval and monitoring of the budget and actual expenses, review of the fundraising practices, and annual review of financial information outlined in the CFC Audit Guide.

Accounting procedures sufficient to safeguard the finances of the CFC, must also be defined, at minimum, to meet the requirements in CFR Part 950, the regulations governing the CFC, and procedures prescribed by OPM CFC Memoranda.

The PCFO is the administrator and fiscal agent of the local campaign. It is subject to the direction and control of the LFCC in every aspect of its operation. One of the first official tasks of the LFCC is to work with the committee to selected a PCFO for the annual campaign by March 15 (OPM strongly recommends an earlier date to allow for additional planning time). It is important to make all eligible and interested nonprofit organizations aware of the opportunity to act as the PCFO (for more details see section titled, Selection and Supervision of PCFO in the LFCC Manual).

The LFCC should also advise OPM if it is advisable to consider combining contiguous local campaigns into a single, larger campaign. The geographic boundaries of local campaigns are determined by OPMs Director - individual campaigns may not voluntarily combine without OPM approval. CFC campaigns can sometimes reduce administrative overhead by combining with another local campaign. Since this results in larger donations to local charities, it is an objective to be considered as part of the LFCCs leadership role.

Composition, Officers, and Elections

As with a non-profit governing board, the LFCC should be composed of at least 5 members, each representing different Federal service sectors and agencies in the geographic area.

A blend of skills and experiences will be needed for the LFCC to function effectively, beyond basic familiarity with the CFC. These include accounting, experience as board members on nonprofit boards, accountability, public relations, marketing, event organizing, the legal profession and grant making.

Electing a Chair, Vice Chair, Secretary and Treasurer with defined responsibilities;

To ensure the rotation of members and leadership succession it is suggested that LFCC members be elected for up to three years on staggered terms.

Officers should be limited to three-year terms subject to re-election each year. If a member is elected as an officer this will automatically extend their term by the three years, subject to their re-election.

Avoidance of Conflict of Interest

No transactions shall be conducted in which any LFCC or staff member has material conflicting interests with the charity resulting from any relationship or business affiliation.

It is suggested that each LFCC member sign a "conflict of interest" statement each year.

CFC Memorandum 2002-15 reminded all LFCC members that they may not serve in any official capacity on the board of directors of any organization that serves the local CFC as its PCFO. Both the Justice Department and the Office of Government Ethics have issued opinions that 18 U.S.C. §208(a) prohibits an officer or employee of the executive branch from participating as a government official in any particular matter in which an organization he or she is serving as officer, director, trustee, general partner or employee has a financial interest. This includes service on a board of an outside, non-profit agency. In the past, PCFOs have offered board membership to LFCC members as an acknowledgment of the relationship between the two organizations. It is specifically because of this acknowledgment that an inherent conflict exists.

LFCC members may serve on boards to non-profits only if their membership is an acknowledgment of an individual's personal efforts, interests or community ties. But even then a Federal employee must recuse himself or herself on matters related to their Federal employment. If you have specific questions concerning this issue, please contact OPM's Office of CFC Operations or the Office of the General Counsel.

Meetings and Committees

The LFCC should meet no less than three times a year, at least quarterly. A majority of the LFCC should be in attendance at each of these meetings.

A number of committees may be required to conduct the business of the CFC (i.e. marketing, charity applications review committee, etc). At the LFCCs discretion, its governance structure could include a nominating committee, charged with the responsibility for identifying new members; and an audit committee, responsible for reviewing annual audited financial statements and independent public accountant's agreed-upon procedures report required by the CFC Audit Guide. An executive committee consisting of the officers and key committee chairs may also be formed which can meet more often as required and also be responsible for conducting an annual performance assessment of the campaign director.

Annual Meeting of Stakeholders

The LFCC ought to consider holding one meeting annually open to all stakeholders to review the campaign, receive feedback from the stakeholders and assess methods for improving the campaign.

Assessing LFCC Member Satisfaction and Performance

Once the structure is in place consideration should be given to conducting a periodic assessment of the LFCC leadership performance in the following areas:

• Is there a clear understanding of the CFCs fundraising strategies?
• Have the expectations between the role of the LFCC and the PCFO been clearly defined?;
• Have new members felt properly oriented to their role, LFCC practices and governance?
• Is the PCFO adequately supporting the decision-making needs of the LFCC?
• Does the LFCC effectively focus on the big issues?
• Is the LFCC structure supporting its strategic objectives?
• Does the LFCC have the necessary policies in place to ensure effective governance and assess the performance of the CFC and its staff.

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