
OPM has moved to boost participation by charities in the annual Combined Federal Campaign, which has seen a decline in both their participation and in contributions by federal and military personnel in recent years.
In a December 18 Federal Register notice OPM raised the thresholds above which charities must undergo certain types of audits, saying that “that the audit requirement serves as a barrier to participation” by charities, which has “dropped precipitously over the last decade.”
Under policy dating to 2014, full audit requirements apply to charities with overall revenue (as reported to the IRS) above $250,000 annually, while those with between $100,000 and $250,000 are subject to a less thorough review by an independent accountant. However, OPM said that three-fourths of CFC charities have revenues above the top threshold, and “at the same time, costs of audits have risen dramatically and now often exceed the value of donations collected through the CFC.”
Under the notice—applicable for 18 months pending issuance of formal rules—full audits will be required only of charities with annual revenue above $1 million, while the lesser requirement will apply to those with revenues between $750,000 and $1 million. “OPM will assess the effectiveness of this waiver in terms of encouraging charity participation in CFC and whether there is a resultant increase in employee participation,” it said.
OPM in prior recent years moved to boost the CFC by further automating the process, allowing pledges of time as well as pledges of money, and opening it to retirees. Still, giving has continued to erode, to $70 million in 2023—down by more than half just since 2016 and down by three-fourths since 2010.
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