June 2, 2013; Federal Times

The Office of Personnel Management doesn’t plan on posting any of the 320 comments it has received so far about its proposed overhaul of the Combined Federal Campaign before the window for comments closes on June 7th, but Sean Reilly at the Federal Times is posting the comments of anyone who wants to send their feedback to OPM to him as well. He posted several, all but one from some of the typical players in this issue, like the federations that typically coordinate the access of a number of charities to the CFC or those that actually manage various CFC campaigns, such as America’s Charities, Global Impact, and Combined Health Charities.

The NPQ Newswire will also try to keep abreast of the feedback OPM is receiving. Jamie McKenna, the director of the Coastal Carolina CFC, notes for example that in 2012, Coastal Carolina received 94.3 percent of its donations as paper pledges, which would be harmed by OPM’s intent to go all online. Even the best CFCs, McKenna indicates, are only about 40 percent online. The predictable losses will compel some charities to conclude that it’s not worth it to stay in the CFC, even without the additional disincentive of the proposed up-front application fee. On the fee, McKenna writes, “In my 12 years working with non-profits, I do not know of any Board of Directors who would vote to spend 3-5K up front to participate in the CFC. This is a massive gamble for the local non-profit and will further squash local charity participation.” A member of the committee that recommended some these changes to OPM, Ken Berger of Charity Navigator, sort of agreed. “If you’re a new charity and you have to pay an application fee, and you don’t get that much money out of the campaign, yeah, that could cost you,” Berger told the Dallas Morning News. “Now there’s a risk. They may actually lose money.”

Although like Berger, Aaron Dorfman of the National Committee for Responsive Philanthropy was also on the OPM committee last year that was the precursor for the proposed CFC rules, he takes issue with aspects of the changes. NCRP’s letter to OPM raises a concern that goes unseen and unsaid in most of the other comments we have seen about the CFC changes: OPM’s emphasis on eligible charities delivering “services” or “benefits” seems to undermine the impact that organizations can have in policy research and advocacy. “Applicants ‘must describe the manner in which beneficiaries requested or used the document or information in order to establish the provision of a real services, benefit, assistance, or program activity,’” Dorfman explains, regarding the proposed rule. “For a research and advocacy organization, the difficulties of complying with such a requirement are abundantly clear.”

We admire the Federal Times’ commitment to collect and publish comments about the CFC regs to OPM. Anyone who also wants to share their opinions in our comments box below is most welcome.—Rick Cohen