CFC MEMORANDUM 2003-04

February 11, 2003

MEMORANDUM FOR PRINCIPAL COMBINED FUND ORGANIZATIONS

Principal Combined Fund Organizations (PCFOs) have brought to our attention situations where they have collected contributions in excess of amounts pledged to their campaigns. In each of these situations, the PCFO has been able to determine that payroll office errors have caused the excess contributions to their campaigns. The payroll offices have either entered the wrong CFC code in their systems or entered a geographic locator code instead of the unique CFC code in their systems. OPM is working with the PCFOs, LFCCs, and payroll offices to remedy the situations that we know of.

However, we strongly recommend that PCFOs develop procedures for tracking receipts in order to detect these situations and ensure compliance with CFC regulations. Specifically, 5 CFR Part 950.901(i)(2) states, "The PCFO is responsible for the accuracy of disbursements it transmits to recipients." Without a method for tracking receipts, the PCFO cannot confirm that its disbursements were accurate.

First, prior to the solicitation of federal employees, PCFOs should adopt a system (e.g. numbering each envelope) to track all CFC campaign reports (envelopes) for key workers and campaign coordinators. The campaign coordinator and key workers training should include a reminder as to the importance of returning campaign reports, even zero dollar campaigns. This tracking system will assist in ensuring that all pledges are recorded properly. Please note that we are not recommending that PCFO's number and track pledge cards; only envelopes to ensure that all areas have reported their results.

Second, PCFOs should ensure that in accordance with 5 CFR Part 950.901(f)(1) all checks and electronic fund transfers (EFT) from payroll offices are accompanied by a statement identifying the agency, the dates of the pay period, and the total number of employee deductions. If the checks or EFTs you receive are not accompanied by these statements, then notify the payroll office and request that they provide the statements with each check or EFT.

In addition, prior to the first payroll deductions received from payroll offices, PCFOs should use the following procedures to track receipts and analyze receipts or develop procedures that accomplish the same results (see the attachment for an example). PCFOs should:

a) Sort the pledge card data according to federal agency;
b) Sort the individual federal agency pledge data by cash/check or payroll deduction;
c) Remove the cash/check pledge amounts;
d) Divide the remaining amount per agency by 26 for civilian agencies and 24 for military agencies. This should be the maximum amount of the bi-weekly/semi-monthly payment received from each agency;
e) Compare bi-weekly/semi-monthly amount received to amount calculated in step (d). If the amount is larger than the amount calculated in step (d), contact the agency payroll office to determine the reason. If you determine that there is an excess funds being transmitted to your campaign, then also notify your LFCC and the Office of CFC Operations (OCFCO) at OPM.

If you identify collections in excess of the amounts pledged to the campaign, place the excess funds in an interest-bearing account separate from current funds until a final decision has been made by OCFCO regarding their distribution.

Please contact us if you have further questions. Thank you.

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