CFC MEMORANDUM 2008-07

September 8, 2008

In response to the damages caused by Hurricane Gustav to the Gulf Coast area, which is still in the midst of recovering from Hurricane Katrina in 2005, the U.S. Office of Personnel Management (OPM) has authorized a special Combined Federal Campaign (CFC) solicitation and advanced disbursement of CFC cash/check contributions designated to charitable organizations supporting the Hurricane Gustav relief efforts. The effort is similar to the one conducted in response to Hurricane Katrina in 2005. Under normal circumstances, the CFC should be viewed as a means for long-term assistance with cash/checks and payroll deductions being used to fund organizations providing relief throughout the 2008 CFC. The Office of Combined Federal Campaign Operations (OCFCO) requests that Local Federal Coordinating Committees (LFCC) accommodate requests from Federal agencies to make cash/check advance disbursements available to designated charities involved in Hurricane Gustav relief efforts if there is significant local interest and if the LFCC determines it is feasible to conduct this special solicitation and advanced disbursement.

We ask that all local campaigns participating in this special CFC solicitation post a notice on their CFC websites regarding the relief efforts. Attached to this Memorandum is a model notice which can be adapted to your campaign for posting on your CFC website. If you do not have a CFC website, please make this message available to Loaned Executives, Coordinators and Key Workers for distribution to all Federal employees in your area. A notice will also be posted on the OPM-CFC website (www.opm.gov/cfc). This special Hurricane Gustav relief effort should not prevent or interfere with the implementation of the regular CFC solicitation process. As noted on the sample notice, Federal donors should be reminded that all CFC charities continue to need their support, in addition to those assisting Hurricane Gustav victims.

Many of the national organizations currently involved in the relief efforts are also CFC charities. For your convenience, a list of the CFC participating charities identified by Federal Emergency Management Agency (FEMA) as involved in Hurricane Gustav disaster relief efforts has been provided on OPM's website at [insert link]. Because the list of disaster relief organizations is still evolving there may be other charities not noted by OPM that Federal donors may wish to contribute to for relief efforts. Federal agencies must receive approval from OPM prior to the collection of funds for organizations that do not appear on the OPM Hurricane Gustav disaster relief list.

Contributions received through this process are considered CFC pledges. The contributions will be counted toward the total raised in the local campaign. Donors and Federal agencies should receive credit toward their campaign goals for any cash/check contributions received.

We recommend the following procedures for advancing cash/check contributions:

1. Principal Combined Fund Organizations (PCFO) must first discuss their plans and internal controls with their LFCC and obtain LFCC approval to move forward.
2. Because the bulk of cash/check contributions can be expected within the first two months of the campaign period, we recommend that the most cost efficient means of managing any advance disbursements is to distribute cash/check contributions in two lump-sum payments to be completed no later than October 17 and November 21, 2008.
3. Campaigns that make these advance disbursements should inform donors of these actions through keyworkers, emails, posters, or other communication methods.
4. Campaigns should check with their pledge processing or accounting vendors for assistance. Similar early distributions were made in 2005 as a result of Hurricane Katrina and the major vendors that provide CFC specific pledge/accounting software were able to accommodate this type of early distribution by providing campaigns with tools/resources to assist them.

Instructions for Handling Disbursements

PCFOs should model their plan in accordance with these instructions:

First Advance Cash/Check Disbursements

The first disbursement should include all cash and checks received through October 14, 2008, which have been processed by the PCFO. The PCFO should follow these procedures when processing funds for this first advance disbursement:

1. All cash/check contributions must be accompanied by a pledge card.
2. The only cash/check contributions that will be included in this advance disbursement are those to CFC participating organizations identified by FEMA as providing relief services. Note: The list of CFC participating organizations identified by FEMA is updated regularly and can be downloaded from OPM's website at Hurricane Gustav Disaster Relief Organizations. PCFOs are required to verify that the 5-digit CFC code matches to one of those on the list provided by OPM. PCFOs should check the OPM list periodically and, at the least, prior to the first advance disbursement. OPM is updating the list as new organizations are added to FEMA's list of organizations providing relief services.
3. If a cash/check contribution includes a pledge to an organization that is not on the list, then that portion of the contribution should be processed as normal through the CFC with disbursement occurring as required in April 2009.
4. The PCFO must record the pledge in its pledge processing system or a separate system used to track CFC contributions designated towards Hurricane Gustav relief. At a minimum, the PCFO must record the following:
   1. The Donor's name;
   2. If the Donor is Civilian or Military;
   3. Donor's Unit/Division name;
   4. Donor's work address & zip code;
   5. Donor's work phone number;
   6. Amount of the cash/check contribution;
   7. Five-digit CFC charity code;
   8. Date received;
   9. Date processed;
   10. Date disbursed; and
   11. Any other information deemed necessary by the PCFO for accounting and auditing purposes.
5. The PCFO must maintain any records processed through a separate system for a minimum of three campaign periods, and make such records available upon request to OPM, LFCC or to its auditor in accordance with CFC regulations.
6. The PCFO must not withhold any costs from this advance disbursement. Instead, the PCFO must count these cash/check contributions towards the recipient organization's designated CFC contributions and allocate actual incurred campaign expenses, including any incurred for this advance disbursement, proportionately to all CFC participating organizations based on their total designations in accordance with CFC regulations. PCFOs may withhold actual, substantiated costs incurred as approved by the LFCC from the organization's regular initial disbursement in April 2009.
7. The PCFO may establish a small reserve based on its history of canceled checks to protect against the possibility that any checks received may be canceled or that the donor's bank account may not have sufficient funds to honor the pledge. Any funds held in reserve should be specifically identified to one or more organizations and distributed as designated with the initial disbursement in April 2009.
8. The PCFO may designate a minimum threshold for aggregate receipts by an organization providing disaster relief. For example, the PCFO may determine that only organizations with cash/check contributions in excess of $100 will receive the advance disbursements.
9. The PCFO should make the first advance disbursement on October 17, 2008. If the organization(s) is a member of a National or International federation, the PCFO should make the disbursement, with the appropriate supporting documentation, to the federation. OPM has advised National/International federations to pass the CFC funds on immediately to their member organizations.

Second Advance Cash/Check Disbursement

The second disbursement should include all cash and checks received between October 15 and November 18, 2008, which have been processed by the PCFO. The PCFO should follow the same procedures identified in #1-9 above when processing funds for this second advance disbursement, except that the PCFO should make the second advance disbursement no later than November 21, 2008.

Any cash/check contributions received and processed after November 18, 2008, even if designated to an identified relief organization, must be processed as normal under the CFC and included in the initial disbursements in April 2009.

If campaigns have any questions, please contact the appropriate OPM Regional Representative at 202/606-2564 or cfc@opm.gov.

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