2015 CFC Eligibility Requirements. - Annual fund-raising drive conducted by Federal employees -...

2015 CFC Eligibility Requirements

- Annual fund-raising drive conducted by Federal employees - Raises millions of dollars through the CFC - Benefits thousands of non-profit Human Health and Welfare charities. - Campaign conducted during a 6 week period Sept 1 – Dec 15 at every

Federal agency. LOCAL CAMPAIGN Oct. 1 – Dec 15.

- The Combined Federal Campaign is the only authorized solicitation of employees in the Federal workplace on behalf of charitable organizations.

Campaign ScopeCampaign Scope

$815,1312,525 donors

2014 Campaign Results2014 Campaign Results

Local Territory:Allegheny, Armstrong, Beaver, Bedford, Butler, *Blair, Cambria, *Centre, Clarion, *Clearfield, Fayette, Forest, Greene, *Huntingdon, Indiana, *Juniata, Lawrence, Mercer, *Mifflin, Somerset, Venango, Washington, and Westmoreland Counties (PA). Brooke, Hancock, Marshall, Ohio, and Wetzel Counties (WV). Belmont and Monroe Counties (OH).

*new counties

Contact: Amy ErvinPO Box 110047Pittsburgh, PA [email protected]

CFC LOCAL REGIONCFC LOCAL REGION

CFC Organizational ChartCFC Organizational Chart

Office of Personnel Management (OPM)

Local Federal Coordinating Committee

Principal Combined Fund Organization (Manager)

Local Federal AgenciesCharitable Agencies

- All aspects of the CFC, including eligibility for participation, are strictly governed by Federal regulation.

- The US Office of Personnel Management (OPM) has the overall responsibility for the management of the CFC.

- OPM reviews and provides guidance and technical advice on regulations, and has the authority to conduct compliance audits on any CFC local campaign fiscal records. This applies to participating federations and independent charities.

Campaign Overview

The CFC is divided into federations and independent organizations.

Federation - Group of charitable human health and welfare organizations established for the purpose of supplying common fundraising, administrative, and management services to its members.

Independent/Unaffiliated Organization - An organization that applies to the CFC on its own behalf. Local unaffiliated organizations apply to the Local Federal Coordinating Committee.

*International, National or Local

Campaign Overview

- Each organization that is deemed eligible to participate in the CFC is entitled to only one listing in the CFC brochure, regardless of the number of federations to which that organization belongs, with the exception that a national organization and its local affiliate may both be listed if the requirements of 5 CFR § 950.401(i) are met. (EXAMPLE Boy Scouts)

- If it comes to the attention of the Local Federal Coordinating Committee (LFCC) that an organization has applied more than once, the LFCC will contact the organization directly to request written confirmation of the one application to be considered.

- In the absence of a satisfactory response, all of the applications may be denied.

Campaign Overview

-Only independent organizations will be contacted directly by the LFCC. If you apply as a member of a federation, DO NOT send the LFCC an independent application. If dual applications are found, the independent application will not be considered.

- FAXES OR ELECTRONIC SUBMISSIONS OF APPLICATIONS ARE NOT ACCEPTED

Application Communications

- Application Period – January 15, 2015 – March 20, 2015

- Application Submission – 3 Rivers/PA West CFC PO Box 110047

Pittsburgh, PA 15232

- 2014 Totals/Donor Info to Charities March 13- Pre Screen Deadline Date March 6 - Application Deadline March 20 – 6:00PM- Application Review - LFCC April 1 - 29- Eligibility Notification – From CFC April 30- Local Appeals Deadline – From Charities May 14 - Tentative - Local Appeals Notification – From CFC June 4 - Tentative - OPM Appeals – From Charity June 21 - Tentative - Final Eligibility Decision – From OPM July 31

Eligibility Process

- Send application to charities (15 or more)- Charities complete application and sends back to Federation- Federation updates excel sheet with applying charity information - Listing of Eligible Member Organizations (Legal name, DBA, EIN, AFR, and Local Presence Category) Use excel sheet provided- Federation submits its own application, CFC excel sheet, Copies of 501c3 Letters for all member applicants and NEW charities application to CFC- 20% Sampling of membership requested by local CFC

- Federation Application must include:- Board terms and meeting dates and locations

- Annual Report - Describe Dues and/or Fees Arrangements

- Submission of Federation Audit regardless of size- Audit must include verification that organization is

honoring designations

MUST retain applications/records for three years.

Federation Application Process

Review Process (All Applicants)

Completeness Review• Application must be submitted by March 6, 2015 to

qualify for pre screen.

• Once Pre-Screened – CFC will contact applicant regarding administrative oversights.

• Application submitted after March 7, 2015 will not be pre screened.

- CFC Application available on our website: www.3riverscfc.org

- Federation Charity application (Members can use Independent Application)

- Independent Charity Application

Downloading CFC Application

CFC Application Cover Page

• Include five-digit code, if participated in 2014 CFC

• Applicant MUST provide a physical mailing address.

• PO Boxes may be used for campaign contact person/disbursement point. PO Box cannot be used as place of business for the public.

• Use of Electronic Funds Transfer (EFT) by campaigns is optional, but highly encouraged.

CFC Certification Statement #1Local Presence

CHECK THE BOX

Local presence is defined as a staffed facility, office or portion of a residence dedicated exclusively to that organization, available to members of the public seeking its services or benefits within the CFC region. The facility must be open at least 15 hours a week and have a telephone dedicated exclusively to the organization. The office may be staffed by volunteers. Substantial local presence cannot be met on the basis of services provided solely through an “800” telephone number, the internet, the U.S. Postal Service or a combination thereof.

List service address (if different from front page) Hours of Operation Location – County/State where office resides 2014 Human Health and Welfare Services (attachment A)


“ATTACHMENT A” for 2014 describes your LOCAL PRESENCE.

DESCRIBE: WHO received the service, benefit, assistance, or

program activity in 2014 WHAT the service, benefit, assistance, or program

activity is WHEN it was delivered in 2014 WHERE it was delivered in 2014


Factors OPM/LFCC will consider from Attachment A

– Nature and extent of the service, benefit, assistance, or program activity

– Frequency, continuity, and duration– Impact on, or benefit to, beneficiaries– Number of beneficiaries


Applicants should avoid– Generalized statements– Listing “offered” services– Listing location of members, affiliates, or board

members– Listing the residencies of visitors to a facility– Listing services provided by the service recipient– Information disseminated by mail or internet– Repetitive text– Fundraising activities as a service

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Examples of Qualifying Attachment ALouisianaNew Orleans 1-3, 2014 ABC Charity conducted a national conference on cancer research and treatment in New Orleans. ABC Charity staff made presentations on new research, provided advocacy training to attendees, and facilitated a discussion between policymakers and medical researchers. 120 healthcare industry professionals attended the three-day conference

20


Example of Qualifying Attachment ALouisiana – Calendar Year 2014 (scholarships awarded bimonthly)Charity International awarded scholarships to the following Louisiana high school students pursuing a degree in computer technology to attend the college or university of their choice:

A. Smith, Jefferson Parish ($1,800) J. Doe, St. Charles Parish ($5,000)B. Callahan, Orleans Parish ($1,200)D. Johnson, Jefferson Parish ($800)C. Jones, Ascension Parish ($900)

Web-Based Service Requirements– Records indicating geographic distribution of users– Describe scope of services received– Document 2 of the following:

• Evidence that users registered for the service• Summary reports documenting customer feedback• Evidence that users paid a fee


CFC Certification Statement #2IRS Determination Letter

CHECK THE BOXInclude a copy of the most recent IRS determination letter as

ATTACHMENT B

• Must be 501(c)(3) tax-exempt organization• Units of government are not eligible• OPM will verify applicant’s current 501(c)(3) status with

the IRS

• If name on IRS letter, IRS Form 990, or audit is different from applicant, official documentation from IRS or state government must be included

• FEDERATIONS – Must submit all member charity 501c3 letters.

501(c)(3) Status Verification

CFC regulations at 5 CFR §950.202 require an applicant charity to

certify it is recognized by the Internal Revenue Service as tax‑exempt under 26 U.S.C. 501(c)(3) and to which

contributions are tax‑deductible pursuant to 26 U.S.C. 170(c)(2).

Most Common Errors found by

IRS • Typographical Errors in Employer Identification Number (EIN)

provided• Proper Legal Name not provided (insufficient “Doing Business

As” (DBA) documentation)• Governmental entity without 501(c)(3) recognition• Charity moved (or address changed) and IRS was not notified• Merger with another organization – EIN changed• IRS Form 990 was marked “Final Return”

NEED A NEW IRS FORM:

– Contact the IRS Tax-Exempt Division at: (877) 829-5500.

– Request an “Affirmation Letter” and submit the letter to the CFC with application.

CFC Certification Statement #2IRS Determination Letter (cont.)

Bona-Fide Chapters and Affiliates of a National Organization

• Include certification from CEO or equivalent (of parent) verifying that applicant is in good standing with the national organization and is covered by the national organization’s 501(c)(3) determination.

• If organization name on IRS letter or IRS Form 990 is different, official documentation from IRS or state government must be included

CFC Certification #3Affiliation Status

Choose one of three options:OPTION ONE

I certify that the organization named in this application is not part of a group exemption;

- Name and EIN on IRS Determination letter will be the same

OPTION TWOI certify that the organization named in this application is part of a

group exemption; - Name may or may not be the same- Organizations using this certification WILL have an EIN that is

different from the EIN on the national group exemption letter- Must have group number, usually a four digit number. This

number comes from the national organization and is mentioned in 501c3 letter.

- Must have certification letter from national organization verifying group exemption dated on or after 10/1/14.

CFC Certification #3Affiliation Status (cont.)

OPTION THREE

I certify that the organization named in this application is a bona-fide chapter or affiliate that operates under a national organization’s single corporate tax-exemption.

- Name and EIN will be the same as national- Must provide certification letter from national

dated on or after 10/1/14.

CFC Certification Statement #4Human Health & Welfare

Statement

- I certify that the organization named in the application is a human health and welfare organization providing services, benefits, or assistance to, or conducting activities affecting human health and welfare.

2014 human health/welfare service must be explained in Attachment A

CFC Certification Statement #5Audit

• Choose one of three options:1. Revenues over $250,000:

– accounts for its funds on the accrual basis in accordance with generally accepted accounting principles (GAAP); and,

– has an audit annually by an independent certified public accountant in accordance with generally accepted auditing standards (GAAS).

- Include as Attachment C- CHAPTERS - If using national organization

information, you must provide a certification letter from CEO of affiliated national organization for FYE June 30, 2013 or more recent.

OR

CFC Certification Statement #5 (cont.)Audit

2. Revenues between $100,000 and $250,000:- Accounts for its funds on an accrual basis in

accordance with generally accepted accounting principles (GAAP); and,

- Has an audit annually by an independent certified public accountant in accordance with generally accepted auditing standards (GAAS).

Do not need to provide audit, but must be available if requested by LFCC/OPM

OR

3. I certify the organization named in this application reports total revenue of less than $100,000 on its IRS Form 990 (or pro forma IRS Form 990) covering a period ending not more than 18 months prior to January 2015 and has controls in place to ensure funds are properly accounted for and it can provide accurate timely financial information to interested parties.



- Audit must cover the fiscal period ending not more than 18 months prior to the January of the campaign year to which the organization is applying (January 2015 – 18 months = June 30, 2013)

- Audit must state organization accounts for its funds in accordance with generally accepted accounting principles (GAAP) and it was audited in accordance with generally accepted auditing standards (GAAS)

- “except for” statements may cause denial

- Audit report must be signed, dated and be on the audit firm’s letterhead. Copies are accepted.

CFC Certification Statement #6990 Tax Form

TWO OPTIONS

OPTION ONE- I certify that the organization named in this

application prepares and submits to the IRS a complete copy of the organization’s IRS Form 990.

Include a copy of the complete IRS Form 990 for a period ending no later than 18 months prior to January 2015, including signatures in the box marked “Signature of Officer” as ATTACHMENT D .

Tax Form 990 – Signature needed on Page 1 (Copy is accepted)

Schedule B of 990 is not required, but all other supporting schedules are required.

CFC Certification Statement #6 (cont.)

990 Tax Form - If organization filed a 990EZ, must provide a

copy of 990EZ with Pro Forma 990:

- The organization must use either the 2012, 2013 or 2014 IRS Form 990 as its pro forma 990. It must complete and provide page 1 (Part I, Summary and Part II, Signature Block); pages 7 and 8 (Part VII, Compensation section A); page 9 (Part VIII, Statement of Revenues); page 10 (Part IX, Statement of Functional Expenses); and page 12 (Part XII, Financial Statements and Reporting.)

OR


990 Tax FormOPTION TWO- I certify that the organization named in this application

is not required to prepare and submit an IRS Form 990 to the IRS.

NEED PRO FORMA 990

If the organization’s fiscal period ended on or after June 30, 2013, it must include a pro forma IRS Form 990 provide page 1 (Part I, Summary and Part II, Signature Block); pages 7 and 8 (Part VII, Compensation section A); page 9 (Part VIII, Statement of Revenues); page 10 (Part IX, Statement of Functional Expenses); and page 12 (Part XII, Financial Statements and Reporting.)


Tax Form 990- Any organization’s IRS Form 990 (or Pro Forma 990) that

does not include a complete list of the officers, Board of Directors, trustees and key employees, and their compensation, if any, is incomplete and will result in a denial.

- Uncompensated members must have a -0- in the compensation column.

- The number of voting members on page 1 must be equal to or

less than the number of individuals identified as a director or trustee in Part VII (see CFC Memo 2010-5).

- If page 1 lists more voting members than are listed in Part VII, the

organization must either provide a letter of explanation of the difference

or submit an amended IRS Form 990.


Tax Form 990


Tax Form 990

CFC Certification Statement #7

I certify the administrative and fundraising rate for the organization named in this application is __ __ .__%

Regulatory Formula• Use 990: Add the amount in Part IX (Statement of

Functional Expenses), Line 25, Column C (Management and General Expenses) to the amount in Line 25, Column D (Fundraising Expenses), & dividing the sum by Part VIII (Statement of Revenue), Line 12, Column A (Total Revenue).

• No other methods may be used to calculate this percentage. All percentages must be listed to the tenth of a percent (10.0% or 15.5%).

CFC Certification Statement #8Board of Directors

- I certify that an active and responsible governing body, whose members have no material conflict of interest and a majority of which serve without compensation, directs the organization named in this application.

• Listing of Board terms of office and meeting dates/locations required of Federations only.

CFC Certification Statement #9Sale/Lease of CFC Contributor

Information

- I certify that the organization named in this application prohibits the sale or lease of CFC contributor lists.

Donor names and addresses may be used to acknowledge the contribution. CFC regulations prohibit the sale or lease of this information


- I certify that the organization named in this application conducts publicity and promotional activities based upon its actual program and operations, that these activities are truthful and non-deceptive, include all material facts, and make no exaggerated or misleading claims.


- I certify that the organization named in this application effectively uses the funds contributed by Federal personnel for its announced purposes.

CFC Certification Statement #12Sanctions Compliance

- Sanctions compliance certification is required- Wording in CFC application provided by OPM must be

used- The list of countries, entities, or individuals

referenced in the certification can found at www.treasury.gov/ofac.

- Guidance in CFC Memorandum 2005-13

CFC Certification Statement #13Sanctions Compliance

Include as ATTACHMENT E a 25-word statement for listing in the campaign brochure. (See Instructions Item 13 for additional required information and the new optional taxonomy codes.)

- We encourage you to list what county you provide service to or where county office resides if not in Allegheny County.

Certifying Official’s Signature

- Certifying official does not have to be Executive Director, but must be individual in a position to verify the validity of the application and all attachments.

- Automatic pens and/or signature stamps MAY be used.

- Federations may provide photocopies for member charities

- Applicants must check the box next to each statement to demonstrate agreement to comply with the statement

- All organizations that apply for local eligibility and are found ineligible have only one opportunity to appeal to the LFCC. - If found ineligible on appeal by the LFCC, the organization will have only one opportunity to appeal to the Director of OPM.

- The OPM Director’s decision is final for administrative purposes.

- Appellants should insure that their appeals are complete and responsive to the actual reasons for the LFCC denial decision.

- Appeals may not be used to supplement applications that had missing or outdated documents

- No oral arguments. All appeals are in writing.

Eligibility Appeals

- All required documents and attachments must be complete and submitted before the application deadline.

- Missing or out of date documents will not be accepted during the appeals process.

- The CFC will not accept applications with modifications to any of the certification statements.

Automatically Denied From Campaign

2014 Common Application Mistakes

• IRS Form 990 not signed by an Officer on page 1 (June 30, 2013 or current)

• IRS Form 990 and Audit time periods do not match. (June 30, 2013 or current)

• IRS Form 990 and Audit are prepare using two different accounting methods; one is prepared using cash method of accounting; one is prepared using accrual method of accounting. (Must be accrual accounting method)

2014 Common Application Mistakes (cont)

• IRS From 990 is incomplete – does not include all supplemental statements and schedules

• Agency with income over $100,000 did not use accrual method of accounting.

• Board member count and list does not match or is less than stated.

• Agency does not provide adequate documentation of Human Health and Welfare 2014 as defined by the regulations. (Attachment A)

APPLICATION SELF AUDIT FORM

Self Audit Sheet - Provided for you to review application (optional)

APPLICATION RECEIPTCONFIRMATION

If sent with application email will confirm arrival of application.

COMPLETENESS STATEMENT

The PCFO is not required to offer an application pre-screening and that the PCFO is not responsible for ensuring the application is complete or correct by pre-screening it. The PCFO will pre-screen the application only as a courtesy and will pre-screen for completeness, not correctness. It is the responsibility of the applicant to verify the information submitted is correct. Should the PCFO note an application or application information that is not complete, it may notify the applicant of such discrepancy (ies) as a courtesy but is not required to do so and is not responsible should a notation of a discrepancy not be noted by the PCFO. It is the responsibility of the applicant to correct or not correct any application discrepancies noted by the PCFO as it deems appropriate. If an applicant resubmits an application or application information it is the responsibility of the applicant to confirm with the PCFO that it was received prior to the application deadline and included in their application file.

QUESTIONS & ANSWERS

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