Federal Register Comments: Combined Federal Campaign (RIN:3206-AM68)1

Association of Community Services

June 7, 2013

Comments submitted to the Office of Personnel Management Regarding Proposed Changes to the: Solicitation of Federal Civilian and Uniformed Service Personnel for Contributions to Private Voluntary Organizations

Combined Federal Campaign (CFC) (RIN:3206-AM68)

The Association of Community Services (ACS) is celebrating its 50th year of service to the Howard County, Maryland health and human services community. A nonprofit itself, ACS works with and advocates on behalf of its 100 nonprofit, government and faith-based organizations to strengthen the capacity of its members to achieve their missions. ACS is submitting comments on this Office of Personnel Management proposal on behalf of our members who rely on the unrestricted-use funding afforded by CFC contributionsto cover program costs as well as administrative expenses that generally are not eligible for foundation and other funding support.

ACS supports revitalization of the Combined Federal Campaign regulations for the purpose of ensuring better oversight of the organizations collecting and distributing federal worker donations. It is our concern however that three elements of the proposed changeswould result in loss of participating organizations and a smaller percentage of donated dollars available for distribution to local community nonprofit agencies. These comments therefore are submitted in opposition to the proposed regulatory changes as follows:

(1) imposition of a nonrefundable nonprofit participation fee.

Requiring a nonprofit to pay to be considered a CFC designee would impose new costs on the nonprofit adding to a nonprofit’s administrative costs. The OPM goal may be able to say that 100% of contributions will flow to CFC participating agencies, but achieving that goal would come—without individual donor knowledge—at the cost of nonprofits who will have to pay with program or other donated dollars to participate in the program. Making the fee nonrefundable would further jeopardizenonprofit funds. The proposed regulations do not provide details regarding how fee charges would be assessed and therefore it is not possible to gauge how onerous the new participation fee might be. Clearly though, the fee could be a double hit for small nonprofit organizations that have limited budgets without cushion to pay to participate in the program.

(2) Elimination of current local campaign infrastructure.

If a desired outcome of this proposal is to eliminate inefficiencies and inappropriate relationships between Local Federal Coordination Committees (LFCCs) and Principal Combined Fund Organizations (PCFOs), ACS recommends instituting more effective audit and other oversight controls over the existing regional community based infrastructure.

The United Way of Central Maryland (UWCM) is our CFC administrating organization. UWCM has established a robust network of local employers, with passionate employee annual CFC campaign leaders who engage with UWCM representatives and community service organizations to promote giving. It seems unnecessarily costly (in terms of administrative costs and lost relationships) and counter to the federal government trend toward greater reliance upon public/private partnerships to dismantle or even disruptthis effective local partnership in favor of addinga new level of bureaucracy through a network of OPM regional offices.The proposed approach also is counter to the CFC stated missionto “lessen the burdens of government and of local communities in meeting needs of human health and welfare; [and] to provide a convenient channel through which Federal public servants may contribute to these efforts.”

(3) Elimination of all but electronic submission of donor contributions.

Consistent with national trends, ACS members report slowly increasing numbers of donors that choose to give electronically. The efficiency of electronic giving is well documented. ACS agrees that encouraging greater use of electronic giving is a reasonable expectation of CFC donors. The OPM proposal to limit giving options solely to electronic means, however, would take the CFC far beyond the current state of the full donor population’s willingness to engage in and sometimes even trust electronic cash exchanges. Allowing only electronic contributions would most certainly also disenfranchise a large percentage of current and future donorswho have limited computer and mobile access.

Thank you for the opportunity to comment on the proposed regulations. We sincerely hope that our voice and those of other nonprofit organizations from across our state and the country will be given full consideration and that we shall have opportunity to comment on a revised regulatory strategy that will ensure meeting our mutual goal of increased CFC contributions that are distributed efficiently and effectivelywith any nonprofit-of-choicethat meets CFC eligibility criteria accessible to a donor.

Respectfully,

Joan Driessen

Executive Director