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DC - U.S. Office of Personnel Management Associate General Counsel James S. Green testified before the House Subcommittee on Oversight of the Committee on Ways and Means on the Combined Federal Campaign (CFC) and the extent to which CFC participating charities comply with federal tax obligations to the Internal Revenue Service. OPM is responsible for the overall management and oversight of the CFC.
"OPM regulates and provides oversight and guidance to each of the local 299 participating campaigns to ensure each campaign is conducted in accordance with OPM regulations, congressional mandates, and established policy," said Green. "This is done primarily through the review of accountability and status reports from each local campaign throughout the year. OPM also establishes the basic eligibility and public accountability criteria for local and national/international participation."
Due to the decentralized structure of the CFC, most of the specific information related to the local campaigns and their participating charitable organizations is maintained locally.
In addition to the eligibility determination process for national/international applicants, OPM conducts a number of monitoring activities over local campaigns to minimize the risk of non-compliance with CFC regulations and prevent abuse within the CFC. In particular, OPM's Office of CFC Operations (OCFCO) receives copies of audit reports for each local campaign as required by CFC regulations. OPM also receives audit reports from OPM's Office of the Inspector General, which audits approximately 15 local CFCs each year. The OCFCO reviews all audit findings and works with the local CFC's to resolve issues.
The OCFCO also selects a sample of local CFC brochures each year to review for compliance with CFC regulations and OPM guidance. In addition, the OCFCO requires each local campaign to report campaign results, including amounts raised, costs of the campaign, and federal employee participation rates, after the solicitation period.
"The information gathered helps us identify campaign performance and potential at-risk campaigns that might need assistance, require merging with another more efficient campaign, or require dissolution," said Green. "Finally, OPM regularly communicates with the local campaigns to ensure each campaign is operational and has an active LFCC."
Green concluded his testimony by emphasizing the importance of ensuring CFC contributors have confidence in the integrity of the program, "The Director of OPM has requested staff examine options for improving the screening process, with particular emphasis on preventing charities that are not in compliance with IRS requirements from participating in the CFC."
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