The United States Office of Personnel Management (“OPM”) has issued proposed changes to the rules on the Combined Federal Campaign, a workplace giving program through which federal employees donate about $270 million annually to a wide array of charities—and as much as $4 million of that goes to charities here in Colorado. However, local nonprofits are worried that the changes would provide a barrier to entry for small organizations or otherwise reduce involvement or participation.

OPM is striving to make the campaign more efficient and transparent, and to increase standards of accountability and donor participation, but concerns have been raised about proposed changes in the following areas:

• Shift to Paperless: the proposed rules eliminate the ability of donors to give via cash, check or money order, and eliminate the hard-copy brochure that lists charities. Instead, donations would have to be electronic (e.g., credit card or PayPal), and the charity list would be available exclusively on the web.  While a shift to electronic is a worthy goal, it is possible that doing this so abruptly may negatively impact donor participation.
• Fee Structure: currently, the campaign is funded by withholding a percentage of donated funds. The OPM has proposed replacing this with a non-refundable application fee (amount still to be determined) in order to increase transparency to donors. However, for small organizations, it can be a larger gamble to pay a fee up-front for donations that may or may not materialize in the future. Additionally, federations that help coordinate charities participation in the campaign (such as Community Shares) would no longer be able to assess any fees from donations. Such organizations, however, do provide much support for member organizations that participate in the campaign, and argue that they are selected by organizations in order to provide this service and are transparent about their fees. This fee structure change would limit the ability of organizations like Community Shares to play this role, and could reduce participation in the campaign by smaller organizations without the resources to apply and manage involvement.
• Centralization of Campaign: the proposed rules provide for more centralization of the campaign’s governance structure, which has raised concern about local outreach and involvement.

Community Shares has a great deal of information on its website regarding the proposed changes. Any comments on the proposed rules are due to OPM by June 7.