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CFC advocates decry proposed fees, reforms

Jun. 4, 2013 - 06:00AM   |  
By SEAN REILLY   |   Comments

Key parts of the Office of Personnel Management’s proposed overhaul of the Combined Federal Campaign are raising alarms among some federal employees, charity organizations and local CFCs.

“I think overall OPM is trying to dismantle the CFC and make it go away,” Karl Howard, a Federal Aviation Administration employee in Fort Worth, Texas, said in an interview. Howard, who has been involved with the campaign for years as a volunteer, is particularly concerned about OPM’s plan to begin charging charities a nonrefundable application fee to participate in the charity drive each year.

He also questioned the agency’s refusal thus far to release any of more than 290 comments submitted since the proposal was published in the Federal Register almost two months ago. The public comment period ends June 7.

“There is something in there that doesn’t look on the level,” he said.

Similarly worried that the proposed application fee will drive away many smaller and local charities is Vincent Marzullo, chairman of the local federal coordinating committee at the CFC for Rhode Island and Southeastern Massachusetts. Marzullo is equally critical of OPM’s plan to abolish the current system of about 184 state and local campaigns in favor of an unspecified number of regional committees more closely controlled by the agency. The result, he said, will be to break long-established bonds between local CFCs and federal employees.

To think that a regional or national organization can maintain “those types of relationships that have taken on such a local flavor ... is delusional,” said Marzullo, who works at the Corporation for National and Community Service.

Both Howard and Marzullo stressed that they were speaking for themselves, not their agencies.

The planned changes would be the biggest in decades for the CFC, which has seen pledges sag for three straight years. The $257.2 million total for the 2012 campaign, down about 6 percent from the preceding year, was the lowest since at least 2004. At 21 percent, the participation rate among federal employees and military personnel was less than half of what it was 20 years ago.

In their published proposal — which ran almost 13 triple-columned pages in the Register and could still be revised — OPM officials said they believe it would improve the CFC based on the agency’s “experience administering the program and its considered judgment.” They have otherwise declined to discuss the plan before the comment period ends. Among other recommendations, they propose to:

■ Start the traditional 3 1/2-month fundraising campaign in October, instead of September, to allow employees on leave during the December holiday season to pledge when they get back.

■ Permit new federal employees to make pledges a month after they join the government. Currently, new hires must wait until the next campaign season to contribute.

■ Create a permanent program to allow federal employees to donate quickly to relief efforts for individual disasters.

Many of the proposed changes draw on a report last year by the CFC-50 Commission, an advisory panel assembled by then-OPM Director John Berry to come up with ideas to refresh the campaign a half-century after its creation.

The commission, for example, recommended charging charities a first-ever application fee to pay for campaign administration, paper pledge cards and other overhead expenses. Those costs are now covered by deductions from donors’ pledges; replacing that system with an application fee would “assure donors that 100 percent of their donations reach the benefiting organizations,” the commission said in the report.

But OPM has not said how much the fee would be or whether it would be tied to the amount a charity raises in pledges. “Without more information, charities will be forced to make expenditures without knowing the benefits, which is bad governance,” 10 organizations, including the United Way, YMCA and National Black United Fund, wrote in a joint comment to OPM last month. The groups were among respondents who released their comments regarding the proposal to Federal Times.

While acknowledging that the campaign has flaws, they said it still raises more than $250 million annually with only 10 percent overhead. They added that OPM should proceed with “fine-tuning” rather than “overturn multiple aspects of the campaign all at once.”

Also sparking unease is OPM’s intent to abandon paper pledges in favor of online giving as a way of lowering overhead. At the Coastal Carolina campaign, based in Charleston, S.C., more than 94 percent of pledges last year came via paper, Director Jamie McKanna wrote in a comment to OPM, adding that her campaign risks losing more than $1 million in annual pledges if the proposed shift takes effect.

Because those donors have been using paper for so long, McKanna said, they “will not be comfortable with the change or they don’t trust it.”

Because OPM has not otherwise made comments public, it is impossible to know at this point whether McKanna’s concerns — as well as those of the 10 organizations — represent all feedback received.

But Paul Billings, senior vice president for advocacy and education at the American Lung Association, said he was “flabbergasted” by OPM’s policy of not quickly making the comments public. Under instructions from the Office of Management and Budget, agencies are supposed to post comments on the main federal rule-making website,, “in a timely manner.” That typically means within a few days of receipt, Billings said.

By not following suit, he added, OPM officials are “stifling thoughtful participation and reaction from the stakeholders.”

In a statement, Keith Willingham, who heads the CFC office at OPM, said the agency policy is to post comments online after the public comment period ends. “We understand this information is important to our stakeholders and will strive to post them as quickly as possible,” he said.

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