**U.S. Office of Personnel Management**

**Offices of CFC Operations and the Inspector General**

**April** **2003**

**COMBINED FEDERAL CAMPAIGN AUDIT GUIDE**

**(\$1** **Million and Greater)**

**CONTENTS**

Page

**CHAPTER I \~ REPORTING REQUIREMENTS AND OTHER CONSIDERATIONS**

**Purpose of the Guide** I-1

Objectives I-1

**Use of the Guide** I-1

**Authorization** I-2

Accounting Requirements I-2

**CFC Reporting Requirements** I-3

PCFO, LFCC and IPA Reporting Responsibilities Defined I-3

**Corrective Action Plan** I-4

**LFCC Responsibilities** I-4

**PCFO Responsibilities and Assertions** I-5

**IPA Qualifications and Responsibilities** I-5

**Future Revisions** I-6

**CHAPTER II** **\~** **LFCC PROCEDURES FOR MONITORING PCFO COMPLIANCE**

**Procedures** II-1

PCFO General Compliance II-1

Campaign Brochure II-3

Pledge Card Processing Controls .II-5

**CHAPTER III** **\~** **IPA AGREED-UPON PROCEDURES** **(SSAE 10)**

**Procedures** III-1

Pledge Card Tracking System III-1

PCFO Budget and Administrative Expense III-2

Receipt and Disbursement of Funds III-4

> Status of Prior Year Findings III-6

## 

**CONTRIBUTORS TO THIS GUIDE** IV-1

**APPENDICES**

***Appendix A***

PCFO Financial Statement Format A-1

Illustrative Financial Statements and Disclosures A-2

***Appendix B***

Sample Reports B-1

*Illustrative Report on Agreed-Upon Procedures* B-1

*Illustrative Schedule of Findings and Questioned Amounts* B-2

*Illustrative Comments on Resolution of Prior Year\'s Examination
Findings* B-2

*Illustrative Corrective Action Plan for Findings* B-3

*Illustrative LFCC Report on Findings* B-4

***Appendix C***

Pledge Card Questionnaire C-1

Schedule of Campaign Receipts and Disbursements C-2

Distribution Schedule C-3

***Appendix D***

Definitions and Acronyms D-1

Authoritative References D-3

***Appendix E***

Laws, Regulations and OPM Guidance to be Tested for Compliance E-1

***Appendix F***

Freedom of Information Requests F-1

#### 

#### 

#### 

#### 

#### -1

**CHAPTER I**

**REPORTING REQUIREMENTS AND OTHER**

**CONSIDERATIONS**

**PURPOSE OF THE GUIDE**

**Objectives**

Overall objectives of the Office of Personnel Management (OPM) in
implementing these financial audit and agreed-upon procedure (AUP)
attestation requirements are to gain the following assurances:

A. Principal Combined Fund Organizations' (PCFO) fiscal year financial
statements are fairly stated in all material respects in accordance with
generally accepted accounting principles (GAAP) and OPM's prescribed
accounting practices.

B. PCFO's Combined Federal Campaign (CFC) operations are conducted in
accordance with the CFC regulations and OPM guidance and that controls
over compliance with CFC regulations and OPM guidance are effective.

## USE OF THIS GUIDE

This CFC Audit Guide (Guide) must be used by Local Federal Coordinating
Committees (LFCC) and PCFOs participating in local CFCs. In addition,
the Guide must be used by an independent public accountant (IPA) hired
by the LFCC and PCFO.

This Guide is divided into three sections.

***Chapter I*** provides general information about Guide requirements
and addresses the purpose of the Guide, the scope of required
engagements, management and IPA responsibilities, reporting, effective
dates, examination periods and due dates.

***Chapter II*** provides specific procedures for the LFCC to perform to
determine the PCFO's compliance with 5 CFR Part 950 and OPM guidance,
and evaluate the PCFO's internal controls over compliance.

***Chapter III*** provides compliance-related agreed-upon procedures,
related reporting requirements and other matters for IPAs to perform.

## AUTHORIZATION

OPM promulgated 5 CFR Part 950 pursuant to Executive Orders 12353 and
12404 and Public Law 100-202 to provide a system for administering the
annual charitable solicitation drive among federal civilian and military
employees. These regulations set forth ground rules under which
charitable organizations receive federal employee donations.

CFC regulation 5 CFR § 950.105(d)(9) requires the PCFO to submit to the
LFCC an audit for each campaign. The audit must be performed by an IPA
in accordance with generally accepted auditing standards (GAAS) and OPM
guidance.

In addition, CFC Memorandum 2003-05, in transmitting this Guide, makes
clear that certain agreed-upon procedures be performed by an IPA
regarding PCFO's compliance with CFC regulations. The Guide also
mandates procedures regarding the effectiveness of internal controls
concerning PCFO program compliance.

**Accounting Requirements** -- See Appendix A.

## CFC REPORTING REQUIREMENTS

The Guide requires the following documents from campaigns with receipts
\$1 million and greater:

## 

\- See Appendix A.

## 

## 

## 

##  

  -----------------------------------------------------------------------
                                  **Due annually each** **August 1** **to
                                  LFCC and September 15 to OPM**
  ------------------------------- ---------------------------------------
                                  

  **1. IPA** **audited            X
  organization-wide financial     
  statements (fiscal year)**      

  **2. IPA audited CFC only       X
  financial statements (campaign  
  period)**                       

  **3. LFCC Compliance Assessment X
  (Most recent on-going           
  campaign)**                     

  **4. Agreed-upon procedures     X
  (AUP) -- (Most recently         
  completed campaign)**           

  **5. AUP Corrective Action      X
  Plan**                          
  -----------------------------------------------------------------------

## PCFO, LFCC AND IPA REPORTING RESPONSIBILITIES

## Campaigns with Receipts \$1 Million and Greater

This Guide requires the PCFO to provide four items to the LFCC and OPM
annually each **August 1** **and September 15**, respectively. In
addition, the LFCC is required to provide one item to OPM annually no
later than **September 15**. The Guide requires:

A.  The PCFO prepares, as of and for the fiscal year ended,
    organizational-wide financial statements that are in accordance with
    GAAP and audited by an IPA in accordance with GAAS. The PCFO must
    provide the financial statements and all related audit reports to
    the LFCC no later than **August 1** and to OPM no later than
    **September 15**.

B.  The PCFO prepares, as of and for the campaign period ended, ***CFC
    activity only*** financial statements that are in accordance with
    GAAP and audited by an IPA in accordance with GAAS. See Appendix A
    for illustrative financial statements. The PCFO must provide the
    financial statements and all related audit reports to the LFCC no
    later than **August 1** and to OPM no later than **September 15**.

C.  The LFCC, with assistance from the PCFO, conducts a compliance
    assessment by performing certain procedures over the PCFO's
    compliance with CFC regulations and OPM guidance, and the
    effectiveness of the PCFO's internal controls over its compliance
    for the most recent ongoing campaign. The LFCC must provide a
    certification that all procedures were performed as described in
    Chapter II below and a report on any instances of non-compliance.
    See Appendix B for a sample report. The LFCC must provide the
    certification and report to OPM no later than **September 15.**

D.  The IPA performs specified agreed-upon procedures (AUP) over the
    PCFO's compliance with CFC regulations and OPM guidance, and the
    effectiveness of the PCFO's internal controls over its compliance as
    of the end of the most recently completed campaign period[^1] and
    prepares an AUP report on the results in accordance with Statements
    on Standards for Attestation Engagements (SSAE) Number 10 codified
    in the AICPA's Professional Standards -- Attestation Standards (AT)
    Sections 101, 201 and 601. See Appendix B for pro forma reports. The
    PCFO must submit the IPA's report to the LFCC by **August 1** and to
    OPM by **September 15**.

E.  If the AUP report identified areas of non-compliance or control
    weaknesses, then the PCFO must submit to OPM with a copy to the LFCC
    a corrective action plan for addressing the issues no later than
    **September 15**.

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A.  
B.  
C.  
D.  
E.  
F.  
G.  
H.  

Where applicable, we encourage the performance of any of the work
described in the requirements above to be performed throughout the year
or at interim periods.

## 

## CORRECTIVE ACTION PLAN

*Corrective Action Plan.* To assist OPM and the LFCC to resolve
deficiencies in financial statements, internal con­trols and regulation
and guidance compliance, a PCFO must develop and submit a corrective
action plan, reviewed and approved by the LFCC, directly to OPM within
45 days of report issuance. The corrective action plan, an essential
part of the report requirement for OPM, is prepared by PCFO management,
and is pre­sented on the entity\'s letterhead and includes the name,
title, and telephone number of the responsible PCFO official. In the
plan, management:

> A. Describes the corrective action taken or planned in response to
> findings identified in the IPA\'s report.
>
> B. Comments on the status of corrective action taken on any unresolved
> findings included in prior IPA reports.

## 

## 

See Appendix B, Example 4, for a suggested corrective action plan
format.

The requirements of this Guide should serve as the basis for
establishing certain perform­ance measures, which will be used to
evaluate future PCFO compliance by campaign activity.

**LFCC RESPONSIBILITIES**

The LFCC is responsible for providing oversight of the campaign's
operations and its staff. This includes verification of the existence of
accounting procedures sufficient to safeguard the finances of the CFC as
defined in 5 CFR Part 950; monitoring of campaign overall performance as
required by the CFC rules; review of evidence of disbursement controls
through LFCC approval and monitoring of the budget; review of the
fundraising practices; and, periodic review of financial reports.

The LFCC is also responsible for close review of the audit report.
Therefore, IPAs should present findings directly to the Chair of the
LFCC, as well as the PCFO.

The LFCC is responsible for ensuring that the expenses charged against
CFC funds are valid and appropriate expenditures and that any
discrepancies identified during the audit processes are rectified.

## PCFO RESPONSIBILITIES AND ASSERTIONS

Among other PCFO responsibilities discussed in this Guide, the PCFO is
responsible for:

A.  Preparing financial statements as of and for their fiscal period
    ending \[5 CFR § 950.105(d)(9)\].

B. Complying with 5 CFR Part 950 and OPM guidance.

C. Establishing and maintaining effective internal controls.

D. Evaluating and monitoring the effectiveness of internal controls.

E. Providing the audit IPA with written representations, in a separate
report, about all matters in paragraph 68 of SSAE Number 10, AT Section
601.

F. Maintaining accounting records for 3 years after the end of the
campaign period. The end of a campaign period is determined by when the
PCFO makes final disbursements to charitable organizations and when the
PCFO finalizes (closes) its accounting records.

The PCFO must comply with the above requirements. Failure to comply with
this Guide may result in the organization being barred from serving as
the PCFO for one year in accordance with 5 CFR § 950.105(e) or subject
to other sanctions cited in 5 CFR § 950.603.

## IPA QUALIFICATIONS AND RESPONSIBILITIES

This Guide requires a combination of an annual financial audit, review,
or compilation and reports on AUPs to be conducted by a licensed IPA in
accordance with GAAS. Therefore the requirements must be performed by a
licensed IPA who meets the general standards of qualification,
independence, due professional care and quality control. The IPA must
follow the standards and requirements contained in GAAS, SAS Number 1,
SAS Number 41, SAS Number 54, SAS Number 78, SAS Number 99, and SSAE
Number 10 as they pertain to the following:

-   *Qualifications and General Standards;*

-   *Field work and Reporting Standards;*

-   *Engagement Scope;*

-   *Engagement Letter.* The letter must include, at a minimum, the
    following:

    1.  A statement that the engagement is to be performed in accordance
        with GAAS and AICPA Attestation Standards as applicable.

    2.  A statement that both parties understand that the OPM intends to
        use the IPA's report to help carry out its responsibilities for
        oversight of the CFC.

    3.  A statement that the IPA is required to provide OPM's Director
        and Office of the Inspector General (OIG), as well as the U.S.
        General Accounting Office (GAO), or their representatives,
        access to working papers or related documents to review the
        engagement.

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-   *Obtaining PCFO Representations*;

-   *Fraud and/or Illegal Acts;*

-   *Due Care and Professional Skepticism;*

-   *Obtaining an Understanding of Internal Control Structure;*

-   *Obtaining Sufficient Evidence*; and

-   *Working Papers.*

*Engagement Quality.* OPM and the OIG have implemented procedures for
evaluating work performed by IPAs. As part of this evaluation, the IPA
shall make working papers available upon request to OPM, the OIG or
other representa­tives of OPM. To facilitate these requests,
management\'s reporting package should include an information sheet
identifying the name, address, and telephone number of the partner on
the engage­ment. Working paper reviews normally will take place at the
PCFO\'s office.

Whenever an OPM evaluation of a report or working papers discloses
inadequacies by the IPA, the IPA may be asked to take corrective action.
If OPM determines the report and working papers are substan­dard or
contain inadequacies, referral to the AICPA and the cognizant State
Board of Accountancy will be considered. When circumstances warrant, OPM
will consider further action including notification to appropriate
officials with authority to consider debarment from federal programs.

## FUTURE REVISIONS

It is the IPA\'s responsibility to ensure he/she is using the most
current version of this Guide. OPM periodically revises CFC regulations
and guidance and plans to issue revisions to this Guide to reflect these
changes. Until the Guide is revised, inconsistencies may exist between
the Guide and CFC regulations and OPM guidance. IPAs should follow the
CFC regulations in effect for the period being examined and modify their
procedures to test the CFC compliance requirements accordingly.

The IPA is also responsible for monitoring relevant changes in GAAS,
including AICPA SASs and SSAEs, and for considering the implications of
changes on the engagement.

Technical questions about applying the Guide and suggestions for
improving future Guides should be sent to:

U.S. Office of Personnel Management U.S. Office of Personnel Management

Director Assistant IG for Audits

Office of CFC Operations Office of the Inspector General

1900 E Street NW, Room 5450 1900 E Street NW, Room 6400

Washington, D.C. 20415-0001 Washington, D.C. 20415-1100

Fax: (202) 606-5056 Fax: (202) 606-4823

Email: <cfc@opm.gov> Email: [mresser@opm.gov](mailto:mwlamber@opm.gov)

**CHAPTER II**

**LFCC PROCEDURES FOR MONITORING PCFO COMPLIANCE**

**PROCEDURES**

Chapter II contains specific procedures for three requisite elements to
be followed by the LFCC. The primary objective of these procedures is to
determine PCFO compliance with 5 CFR Part 950 and OPM guidance. In
addition, the LFCC will evaluate the effectiveness of PCFO controls over
compliance with 5 CFR Part 950 and OPM guidance. If the PCFO's system of
accounts and records make the use of these specific procedures
inappropriate, the LFCC may request OPM to consider alternative
procedures designed to produce similar results. These procedures should
be performed on the most recent ongoing CFC. In the first year of this
Guide, the most recent ongoing campaign is the 2002 Campaign. The 2002
Campaign is defined as the Campaign that was solicited in the Fall 2002.
The LFCC must provide a certification that all procedures were performed
as described below and a report on any instances of non-compliance. The
three requisite elements include the following:

-   PCFO General Compliance

-   Campaign Brochure

-   Pledge Card Processing Controls

## PCFO General Compliance

*Timeliness of PCFO Activity.* The campaign cycle relies on a timeline
determined by CFC regulation. Adherence to the timeline and compliance
with critical activities such as selection of the PCFO, reporting of
campaign results and timely disbursements of contributions and
acknowledgement of donors is essential. Perform the following
procedures:

1.  Determine if the PCFO filed a timely application with the LFCC \[5
    CFR § 950.105(c)\].

    a.  Obtain the public notice (usually a legal notice in the
        newspaper) that contains the due date for PCFO applications from
        the PCFO or LFCC.

    b.  Obtain a copy of the PCFO application that includes the
        submission date from the PCFO or LFCC.

    c.  Compare the submission date on the PCFO application with the due
        date on the public notice.

> ***Evaluation:*** Report as a finding all instances where the PCFO's
> application was submitted after the LFCC's due date.

2.  Determine if the PCFO provided adequate opportunities for
    federations and organizations to offer suggestions relating to the
    operation of the campaign, campaign materials, and training \[5 CFR
    § 950.105(b)\].

    a.  Obtain evidence from the PCFO that it provided federations and
        organizations with opportunities to offer suggestions. Evidence
        can be letters to federations and organizations, minutes from
        meetings where federations and organizations were present, or
        some other form.

    b.  If the PCFO cannot provide physical evidence that federations
        and organizations were provided the opportunity to provide
        suggestions, then select a representative sample of 3 local
        federations and organizations. Contact the federations and
        organizations to determine if they were afforded the opportunity
        to offer suggestions. Whenever possible, the federations or
        organizations selected by the LFCC should not be affiliated or
        related to the PCFO. For example, if the PCFO is a United Way,
        then the representative sample should not include (if possible)
        other local United Ways participating as federations or United
        Way affiliated member organizations.

***Evaluation:*** Report as a finding all instances where the PCFO did
not afford local federations and organizations the opportunity to offer
suggestions relating to the operation of the campaign, campaign
materials, and training.

3.  Determine if the PCFO filed OPM Form 1417, Campaign Results Code
    Sheet, by

March 3rd with OPM \[CFC Memorandum 2003-2\].

a.  Obtain a printed OPM Form 1417 with a submission date from the PCFO.

b.  Compare the submission date on the OPM Form 1417 with the March 3
    due date.

> ***Evaluation:*** Report as a finding all instances where the PCFO did
> not file the OPM Form 1417 with OPM by March 3rd.

4.  Determine if the PCFO notified federations and organizations of the
    amount designated, if any, and of the amount allocated from
    undesignated contributions by March 15 \[5 CFR § 950.901(i)(1) and
    CFC Memorandum 1998-2\].

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a.  Obtain from the PCFO copies of notification letters with dates sent
    to federations and organizations that informed them of designated
    and undesignated amounts received from donors.

b.  Compare the date of the notification letters to the March 15 due
    date.

> ***Evaluation:*** Report as a finding all instances where the PCFO did
> not notify federations and organizations of the amount designated, if
> any, and of the amount allocated from undesignated contributions by
> March 15.

5.  Determine if the PCFO forwarded a list of donors that requested
    their name and address to be released to recipient organizations by
    March 15 \[5 CFR § 950.601(c) and CFC Memorandum 1998-2\].

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a.  Obtain a copy of the letters with dates sent to organizations that
    contained the list of donors who requested their name and address be
    released.

b.  Review the list of contributors to determine that it omitted the
    amount designated and social security numbers.

c.  Review the list to determine that it clearly identified the
    federation member organization (not just the federation) to receive
    the donor\'s name and address.

> ***Evaluation:*** Report as a finding all instances where the PCFO did
> not forward a list of donors that requested their name and address be
> released to recipient organizations by
>
> March 15. Report all instances where the list did not omit the amounts
> designated and donor social security numbers. Report all instances
> where the list did not clearly identify the organization to receive
> the donor's name and address.

6.  If the PCFO received pledges totaling \$500,000 or more, determine
    if the PCFO made initial disbursements to federations and
    organizations by April 1 and monthly thereafter. If the PCFO
    received pledges totaling less than \$500,000, skip to step 7 \[5
    CFR § 950.901(i)(2)\].

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a.  Select 3 representative federations and 3 representative
    unaffiliated organizations from the local campaign.

b.  Obtain canceled checks made payable to each of the selected
    organizations for each disbursement during the campaign period from
    the PCFO.

c.  Compare the date of the first check to the April 1 due date.

d.  Compare the dates of the remaining checks to ensure that there is
    one check for each subsequent month after April.

> ***Evaluation:*** Report as a finding all instances where the PCFO did
> not make the initial disbursement by April 1 and monthly thereafter.

7.  If the PCFO received pledges totaling less than \$500,000, determine
    if the PCFO made initial disbursements to federations and
    organizations by June 1 and quarterly thereafter \[5 CFR §
    950.901(i)(2)\].

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a.  Select 3 representative federations and 3 representative
    unaffiliated organizations from the local campaign.

b.  Obtain canceled checks made payable to each of the selected
    organizations for each disbursement during the campaign period from
    the PCFO.

c.  Compare the date of the first check to the June 1 due date.

d.  Compare the dates of the remaining checks to ensure that there is
    one check for each subsequent quarter after June.

> ***Evaluation:*** Report as a finding all instances where the PCFO did
> not make the initial disbursement by June 1 and quarterly thereafter.

## Campaign Brochure

1\. Obtain the campaign brochure from the most recent ongoing campaign
from the PCFO. Review the campaign brochure and determine if the
campaign brochure contained:

a.  Required OPM information (OPM National List with instructions) \[5
    CFR § 950.401(g)(1) and CFC Memorandum 2002-8\].

b.  A list of eligible voluntary organizations (divided into national,
    international and local sections) and in the order prescribed by CFC
    Memorandum 2002-8 \[5 CFR § 950.401(g)(2)\];

c.  A statement informing employees of their right to make a choice to
    contribute or not to contribute \[5 CFR § 950.401(e)\];

d.  A statement informing employees of their right to designate or not
    to designate \[5 CFR § 950.401(e)\];

e.  A statement informing employees of their right to give a
    confidential gift in a sealed envelope \[5 CFR § 950.401(e)\];

f.  No organization symbols or other distractions were in use that could
    compete for the donor\'s attention \[5 CFR § 950.401(f)\].

g.  A description of the CFC program \[5 CFR § 950.401(g)(1)(I)\];

h.  An explanation of the payroll deduction privilege \[5 CFR §
    950.401(g)(1)(i)\];

i.  An explanation of the distribution procedures for undesignated funds
    \[5 CFR § 950.401(g)(1) and CFC Memorandum 2002-8\];

j.  A clear statement urging federal donors to direct their gifts to
    specific agencies, groups, or options of their choice by designating
    in the boxes provided up to five organizations

\[5 CFR § 950.401(g)(1) and CFC Memorandum 2002-8\];

k.  A statement that designations may only be made to listed
    organizations and that write-in designations are prohibited \[5 CFR
    § 950.401(g)(1)(ii)\];

l.  Instructions on how to obtain information about the programs and
    finances of the participating organizations \[5 CFR §
    950.401(g)(1)(iii)\]; and

m.  A statement informing employees of their rights to pursue complaints
    of undue pressure or coercion in federal fund-raising activities \[5
    CFR § 950.401(g)(1)(iv)\].

    2.  Determine whether the agency listing in the brochure included an
        \"Introduction\" with the following information:

        a.  A definition of a "Federation\" which reads: \"A federation
            is a group of voluntary charitable human health and welfare
            agencies established for the purpose of providing common
            fundraising, administrative, and management services to its
            members. Federations may be national or international
            agencies, or local, representing local or regional agencies.
            If you wish to designate all or some portion of your
            contribution to a federation, record that federation\'s code
            number in one of the boxes on your pledge card.
            Contributions designated to a federation will be shared in
            accordance with the federation\'s policy\" \[CFC Memorandum
            2002-8\].

        b.  A definition of \"Unaffiliated Organizations\" which informs
            the donor how to contribute to an organization not
            affiliated with a federation \[CFC Memorandum 2002-8\].

        c.  A definition of \"International General Designation Option\"
            which reads: \"I request that my gift be shared among all
            the international organizations listed in the
            \"International Section\" of the Agency Listing in the same
            proportion that they received designations\" \[CFC
            Memorandum 2002-8\].

        d.  \"Undesignated Funds\" section which reads: \"Even if you
            choose not to designate to a specific agency or federation,
            your contribution will still be accepted. Funds contributed
            to the CFC, but not designated to a specific organization or
            federation will be distributed to all organizations in the
            CFC brochure in the same proportion that was contributed in
            designations.\" Any organization that does not receive
            designated contributions will not receive undesignated funds
            \[CFC Memorandum 2002-8\].

    3.  Determine whether the agency listing in the brochure included a
        section titled, \"National Organizations\" which contained:

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a.  An accurate reproduction of the OPM Director\'s list (unless there
    were waivers) \[5 CFR § 950.401(g)(2) and CFC Memorandum 2002-8\];

b.  The title \"National Unaffiliated Organizations\" preceded the
    listing of unaffiliated agencies \[5 CFR § 950.401(g)(2) and CFC
    Memorandum 2002-8\]; and

c.  A list of National federations with their member organizations and
    identified them as federations \[5 CFR § 950.401(g)(3)\].

    4.  Determine whether the agency listing in the brochure included a
        section titled, \"Local Organizations\" division and contained:

        a.  A 25-word description, including the Employer Identification
            Number (EIN), and if applicable, the legal name of the
            organization; the percentage of their administrative and
            fundraising expenses for the preceding calendar year and, a
            telephone number for each organization listed \[ 5 CFR §
            950.401(g)(2)\];

        b.  A code number for each organization listed \[5 CFR §
            950.401(g)(3)\];

        c.  A title \"Local Unaffiliated Organizations\" preceding the
            listing of local unaffiliated agencies \[5 CFR §
            950.401(g)(2) and (3)\]; and

        d.  Local federations listed with their member organizations and
            identified as federations

> \[5 CFR § 950.401(g)(3)\].
>
> ***Evaluation***: Report as a finding all instances where the PCFO did
> not include the required information in the local campaign brochure or
> included items not allowed by the regulations (item 1.f).

## Pledge Card Processing Controls

The PCFO is required to follow certain regulations and OPM guidance in
preparing and processing pledge cards and should have effective internal
controls in place to ensure compliance. PCFOs are responsible for
honoring employee designations \[5 CFR § 950.105(d)(1)\], handling math
errors correctly \[5 CFR § 950.402(d)\], and honoring employee wishes
regarding the release of his/her name and address to organizations \[5
CFR § 950.601(a) and (b)\].

1.  Obtain a pledge card used in the most recent ongoing campaign from
    the PCFO. Compare this pledge card to the model pledge card provided
    by OPM (CFC Memorandum 2002-5). Determine if the pledge card used in
    the local campaign was:

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a.  Consistent with these regulations and instructions by the Director
    \[5 CFR § 950.105(d)(5)\];

b.  Reproduced based on the model pledge card provided by the Director
    each year at the local level \[5 CFR § 950.402(a)\];

c.  Not modified from the model pledge card unless approved by the
    Director in advance, except for incorporating additional giving
    levels and including their award recognition program \[5 CFR §
    950.402(b)\];

d.  Produced with the social security number block blacked out on Copy 2
    (Central Receipt Point Copy) and Copy 3 (Contributor Copy) \[Privacy
    Act requirement\].

> ***Evaluation***: Report as a finding all instances where the PCFO's
> prepared local pledge card is not in accordance with 1a-d.

2.  Obtain from the PCFO a completed "Pledge Card Questionnaire" (See
    Appendix C, page C-1) and a walkthrough of the process. The
    walkthrough should include the PCFO physically demonstrating to the
    LFCC how pledge cards are received, validated, processed, and
    accurately entered into pledge systems. Determine if controls are in
    place to ensure:

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a.  Employee designations were honored \[5 CFR § 950.105(d)(1)\];

b.  Employees are not questioned in any way as to his or her designation
    or its amount except by keyworkers, loaned executives, or other
    non-supervisory Federal Personnel

> \[5 CFR § 950(d)(4)\];

c.  Employees do not make designations and contributions to an
    organization not listed in the brochure or to a campaign covering a
    geographic location different from the campaign where the employee
    works. If this occurs, the PCFO should treat the contribution as
    undesignated funds and distribute accordingly \[5 CFR §
    950.402(c)\];

d.  The total amount pledged is honored and that there are controls in
    place to treat the excess amount as undesignated funds for any
    pledge cards that have designations that add up to less than the
    total amount pledged \[5 CFR § 950.402(d)\];

e.  Designations are honored by assigning a proportionate share of the
    total gift to each organization designated for pledge cards that
    have a total amount pledged less than the sum of individual
    designations \[5 CFR § 950.402(d)\].

> ***Evaluation***: Report as a finding all instances where the PCFO's
> controls are not effective to ensure that items 2a-e are complied
> with.

**CHAPTER III**

**IPA AGREED-UPON PROCEDURES (SSAE 10)**

**PROCEDURES**

Chapter III contains specific procedures for four requisite elements to
be followed during the examination by the IPA. The primary objective of
these procedures is to determine PCFO compliance with 5 CFR Part 950 and
OPM guidance. In addition, the IPA will evaluate the effectiveness of
PCFO controls over compliance with 5 CFR Part 950 and OPM guidance.
Should the PCFO's system of accounts and records make the use of these
specific procedures inappropriate, the IPA may request OPM to consider
alternative procedures designed to produce similar results. These
procedures should be performed on the CFC activity from the most
recently completed campaign. In the first year of this Guide, this will
be the 2001 Campaign. The 2001 Campaign is defined as the Campaign that
was solicited in the Fall 2001 with receipts and distributions through
the early months of 2003. The IPA must prepare an AUP report on the
results in accordance with SSAE Number 10 and Attestation Standards (AT)
Sections 101, 201 and 601. The IPA should attach the "Schedule of
Campaign Receipts and Disbursements" and "Distribution Schedule" used
below to the AUP report. The four requisite elements include the
following:

-   Pledge Card Tracking System

-   PCFO Budget and Administrative Expenses

-   Receipt and Disbursement of Funds

-   Status of Prior Year's Findings

## Pledge Card Tracking System 

In order for the PCFO to properly follow the regulations cited in
Chapter II under the "Pledge Card Processing Controls" section, they
must enter the information accurately in their pledge card tracking
system and have sufficient quality controls to ensure accurate payments
to charitable organizations. Test the PCFO's pledge card tracking system
by performing the following steps.

1.  Select a representative sample of 25 pledge cards from the campaign.
    Pledge cards selected should represent all types of donations,
    including cash, designated and undesignated funds.

2.  Trace and determine that the following information from each pledge
    card agrees to the PCFO's automated system or pledge records:

    a.  Donor Name

    b.  Each Charity Code Number and Amount Donated

    c.  Total Amount Donated

    d.  Name Release Box Checked.

> ***Evaluation***: Report as a finding all instances where the PCFO's
> pledge tracking system does not agree with the pledge card.

## PCFO Budget and Administrative Expenses

During the annual PCFO application process, a federation, charitable
organization, or combination of charitable organizations or
federations(s) wishing to administer the local CFC, must submit a
written campaign plan to the LFCC on or before the deadline set by the
LFCC. The plan must be in sufficient detail to allow the LFCC to
determine if the applicant could administer an efficient and effective
CFC. The plan should also include a CFC budget that details all costs
estimated to be required to operate the CFC. The costs in the budget
should be based on estimated actual expenses, not on the percentage of
the funds raised in the local campaign \[5 CFR § 950.105(c)\].

The PCFO may recover from the gross receipts of the campaign its actual
costs of administering the local campaign. In no event should the amount
recovered for expenses exceed by more than 10 percent the estimated
budget submitted. The campaign expenses must be shared proportionately
by all the recipients according to their percentage share of gross
campaign contributions

\[5 CFR § 950.106\].

1.  Obtain the PCFO's 2001 application from the LFCC or PCFO. Review for
    a signed statement by an appropriate official of the PCFO that it
    will:

```{=html}
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```
a.  Administer the CFC fairly and equitably \[5 CFR §
    950.105(c)(2)(i)\];

b.  Conduct the applicant\'s non-CFC operations separately from the
    campaign operations

> \[5 CFR § 950.105(c)(2)(ii); and

c.  Be subject to the decisions and supervision of the LFCC \[5 CFR §
    950.105(c)(2)(iii)\] and to the provisions of 5 CFR § 950.403 and 5
    CFR § 950.603 \[5 CFR § 950.105(c)(3)\].

> ***Evaluation***: Report as a finding all instances where the PCFO did
> not include the signed statements in #1 above.

2.  Obtain a dated copy of the LFCC minutes documenting their selection
    of the PCFO and their approval of the PCFO's campaign plan and
    budget. Compare the date of the LFCC minutes to the March 15
    deadline set by 5 CFR § 950.801(a)(3).

> ***Evaluation***: Report as a finding all instances where the LFCC did
> not select the PCFO and approve the PCFO\'s campaign plan and budgeted
> expenses, on or before March 15.

3.  Review the PCFO's budgeted expenses from the most recently completed
    campaign to determine that they are based on actual expenses and not
    a percentage of funds raised \[5 CFR § 950.105(c)(1)\].

```{=html}
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```
a.  Obtain a copy of the PCFO campaign plan from the most recently
    completed campaign, including budgeted expenses, and a detailed list
    of the prior year's actual expenses from the PCFO.

b.  Compare the expense categories and amounts in the most recently
    completed campaign's budget to the prior year's actual expenses. The
    categories and amounts should be similar.

c.  Review the PCFO budget description in the most recently completed
    campaign's plan. Make sure the description does not state that the
    budget is based on a percentage of funds raised.

d.  Review LFCC minutes for discussions and justification of PCFO
    budgeted expenses. Make sure the discussion/justifications do not
    state that the budget is based on a percentage of funds raised.

> ***Evaluation***: Report as a finding all instances where the PCFO's
> budgeted expenses are not based on estimated actual expenses or where
> the budgeted expenses are based on a percentage of funds raised.

4.  Obtain a detailed list of actual expenses incurred by and reimbursed
    to the PCFO for administering the most recently completed campaign.
    Trace and determine that actual expenses incurred agree with the
    PCFO's general ledger.

5.  Compare the PCFO's actual expenses to their budgeted expenses and
    determine whether actual expenses exceeded budgeted expenses by more
    than 10 percent. If the actual expenses exceeded budgeted expenses
    by more than 10 percent, review accounting records to determine
    whether the PCFO absorbed (did not reimburse itself) the excess
    amount over 10 percent. Amounts recovered by the PCFO in excess of
    the 10 percent should be set out as not charged to the campaign,
    unless they were approved by OPM's Director \[5 CFR § 950.106(a)\].

> ***Evaluation***: Report as a finding all instances where the PCFO's
> actual expenses do not agree to the general ledger and where actual
> expenses reimbursed are more than 110 percent of the budgeted expenses
> and not approved by OPM's Director.

6.  Obtain a copy of or document the PCFO's policy for campaign expense
    reimbursement. Compare the PCFO's policy to 5 CFR § 950.106(b),
    which states that the PCFO should cover all campaign expenses at the
    start of the campaign and then recover their costs from the gross
    receipts of the same campaign. The PCFO may obtain a commercial loan
    or line of credit. It may not, however, use receipts from a prior
    campaign to cover current campaign expenses.

> ***Evaluation***: Report as a finding all instances where the PCFO is
> not properly matching campaign receipts and expenses.

7.  Either from the detailed list of actual expenses obtained in #4
    above or from the PCFO's accounting records (journal or general
    ledger) that support the list of actual expenses obtained in #4
    above, select a representative sample of 10 actual expenses incurred
    by and reimbursed to the PCFO for the most recently completed
    campaign. At least 2 of the actual expenses should be allocated
    expenses. For example, some employees do not work full time on CFC
    activities and their salaries may be allocated on a time equivalent
    ratio or rent/utilities may be allocated based on a percentage of
    square feet occupied by CFC staff \[5 CFR § 950.106(a)\].

    a.  For the 8 expenses that are not allocated, trace and determine
        that the expense agrees back to supporting documentation that
        contains a justification that the expense was CFC related.
        Supporting documentation should include a canceled check,
        invoice, billing, receipts, travel reports, or other supporting
        documentation.

    b.  For the 2 allocated expenses, review the allocation methodology
        to determine that the methodology is reasonable and that the CFC
        incurs a fair share of the costs. In addition, the allocations
        must be based on actual amounts that can be traced and agreed to
        the general ledger. For example, if the PCFO is allocating 10
        percent of rent out of a total of \$100,000, then the \$100,000
        total rent should be traced to the PCFO's non-CFC general ledger
        and the 10 percent should be based on the fact that the CFC
        occupies 10 percent of the square footage in the building.

    c.  For all 10 sample expenses, compare the title of the actual
        expense or its general ledger account to the budget categories
        from the PCFO's campaign plan. Determine that PCFO is not
        charging for expenses not listed in the budget.

> ***Evaluation***: Report as a finding all instances where the PCFO's
> actual expenses were not supported by source documentation, justified
> as CFC related, allocated in a fair or reasonable method, allocated
> based on actual expenses, or included as part of the budget in the
> PCFO's campaign plan.

8.  From the detailed list of actual expenses obtained in #4 above,
    determine if the PCFO has charged the campaign for interest
    expenses.

    a.  If there is interest expenses listed in the actual expenses,
        then obtain supporting documentation from the PCFO to determine
        that the PCFO used a commercial loan to pay for campaign
        expenses. If the PCFO did not obtain a commercial loan but still
        charged the campaign for interest expense, then report this as a
        finding. 5 CFR § 950.106(b) only allows for interest expense if
        the PCFO obtained a commercial loan. The PCFO may not charge
        interest for using its own funds to pay for campaign expenses.

    b.  If there is no interest expense listed in the actual expenses,
        then no further work is required.

> ***Evaluation:*** Report as a finding all instances where the PCFO
> charged the campaign for interest expenses, but did not obtain a
> commercial loan.

## Receipt and Disbursement of Funds

Contributors may choose to direct their gifts to a specific voluntary
agency(ies) or federation(s) of his or her choice by designating up to
five organizations/options on their pledge cards.

Contributors may also select the international general designation
option. If they do not wish to designate their contributions to a
specific organization(s), federation(s), or use the international
general designation option, contributions are considered undesignated.

The PCFO receives contributions through cash donations or payroll
deductions. The PCFO is allowed to reimburse itself for actual campaign
expenses approved by the LFCC from the current year's receipts. The PCFO
is responsible for the accuracy of disbursements and must disburse
receipts, less their expenses, in accordance with contributor
designations. If the campaign has contributions in excess of \$500,000,
then the PCFO must make its initial disbursement by April 1 and monthly
thereafter. For campaigns with contributions \$500,000 or less, the PCFO
must make its initial disbursement by June 1 and quarterly thereafter.

0.  Obtain a completed "Schedule of Campaign Receipts and Disbursements"
    and "Distribution Schedule" (see Appendix C, pages C-2 and C-3.
    These Schedules will also be available in MS Excel format on the CFC
    website at [www.opm.gov/cfc](../www.opm.gov/cfc)) from the PCFO for
    the most recently completed campaign \[5 CFR § 950.105(d)(8)\].

1.  Trace and determine that the total campaign receipts, administrative
    expenses, and total campaign disbursements from the "Schedule of
    Campaign Receipts and Disbursements" agree with the PCFO's general
    ledger and the administrative expenses and total campaign
    disbursements to the totals on the "Distribution Schedule." If
    differences are noted between these totals on the schedules and the
    general ledger, request the PCFO to provide corrected schedules \[5
    CFR § 950.105(d)(8)\].

> ***Evaluation***: Report as a finding all instances where the PCFO's
> cannot produce schedules that agree with its general ledgers.

2.  Review the "Schedule of Campaign Receipts and Disbursements" for the
    following:

    a.  PCFO began the collection of cash receipts during the period
        September -- December, depending on the start of their
        solicitation period \[5 CFR § 950.102(a)\].

    b.  Disbursements began in either April (campaigns with
        contributions greater than \$500,000) and continued monthly
        thereafter or in June (\$500,000 or less) and continued
        quarterly thereafter \[5 CFR § 950.901(i)(2)\].

    c.  Total campaign receipts (cash/checks, payroll deductions, and
        interest), less service charges and administrative expenses,
        were distributed by the PCFO. The ending balance should equal
        \$0 \[5 CFR § 950.901(i)(2)\].

> ***Evaluation***: Report as a finding all instances where the PCFO did
> not begin collecting receipts between September and December based on
> their solicitation period, make initial disbursements by April 1 or
> June 1 (as applicable), and/or did not disburse all receipts, less
> administrative expenses by the end of the campaign.

3.  From the "Schedule of Campaign Receipts and Disbursements", select 6
    representative months of campaign receipts.

    a.  Trace amounts back to deposits and interest on bank statements
        for the selected months and determine that the amounts agree
        with the bank statements \[5 CFR § 950.105(d)(8)\];

    b.  Determine that all deposits on the bank statements are included
        on the "Schedule of Campaign Receipts and Disbursements" \[5 CFR
        § 950.105(d)(8)\].

    c.  Select 6 representative deposits from the bank statements.
        Request from the PCFO the statements provided by payroll offices
        for each deposit. Each payroll office is supposed to provide an
        accompanying statement with the payment check. The statement
        should identify the agency, the dates of the pay period, and
        total number of employee deductions \[5 CFR § 950.901(f)(1)\].

> ***Evaluation***: Report as a finding all instances where the PCFO's
> campaign receipts are not supported by deposits listed on the bank
> statements and where the bank statements include deposits not listed
> on the "Schedule of Campaign Receipts and Disbursements." Also, report
> when a PCFO does not maintain or has not received statements from
> payroll offices and if possible, identify which payroll offices did
> not submit statements. OPM will use this information to contact
> payroll offices which do not provide statements as required by the
> regulations.

4.  From the "Distribution Schedule", determine that organizations were
    distributed undesignated pledges and expenses in proportion to the
    funds designated to them by comparing the Undesignated % and Expense
    % to the Designated % on the schedule \[5 CFR § 950.106(c) and
    950.501(a)\].

> ***Evaluation***: Report as a finding all instances where the PCFO's
> Undesignated % or Expense % does not agree with the Designation % on
> the "Distribution Schedule."

5.  From the "Distribution Schedule", select 3 representative
    federations (one national, one international and one local) and 3
    representative unaffiliated (one national, one international and one
    local) organizations. Test the accuracy of disbursements by tracing
    the canceled checks to the "Distribution Schedule" and determining
    that the amounts on the canceled checks agree with the amounts on
    the "Distribution Schedule." \[5 CFR § 950.901(i)(2)\].

> ***Evaluation***: Report as a finding all instances where the PCFO's
> "Distribution Schedule" is not supported by canceled checks.

## STATUS OF PRIOR YEAR FINDINGS

Update the status of prior year findings. Obtain the PCFO's corrective
action plan from the prior year. Obtain an update on the status of each
finding from the prior year. Verify that the actions indicated were
completed by the PCFO by viewing evidence from the PCFO. See Appendix B,
numbers 3 and 4, for an illustration of comments on resolution of prior
year's examination findings and illustrative corrective action plan.

**CONTRIBUTORS TO THIS GUIDE**

OPM wishes to express our appreciation for the contributions of time,
effort and expertise so generously given by the members of the following
government and private entities.

OPM Office of CFC Operations

OPM Office of the Inspector General

OPM Office of the General Counsel

United Way of America's Financial Issues Committee

OPM and the Office of the Inspector General also gratefully acknowledge
the assistance provided by all local campaigns and their IPAs.

## 

B.  

## 

Th

## 

Whenever an

instances where the PCFO's controls are not effective to ensure that
items 2a-e are complied with.

## 

## 

0.  
1.  
2.  
3.  
4.  
5.  
6.  
7.  
8.  
9.  
10. 
11. 
12. 
13. 
14. 

## 

## 

## 

## 

**APPENDIX A**

**PCFO FINANCIAL ACCOUNTING STATEMENT FORMAT**

PCFO organizational financial statements should be presented in
conformity with Generally Accepted Accounting Principles (GAAP) for
Not-for-Profit Organizations (Financial Accounting Standards Number 116
& 117).

The following statements presented are for information purposes only and
provide a suggested format for those campaigns with CFC receipts of
\$1,000,000 or more that are required to provide ***CFC activity only***
financial statements. For the first year of this Guide, these financial
statements can be single year statements. For all future years, the
statements should be comparative statements. For the first year of this
Guide, the audit should be of the Fall 2001 campaign, which was
solicited in the Fall of 2001, collected receipts through the last pay
period of January 2003 and made disbursements from April 2002 until
around March 31, 2003. We acknowledge changes may be necessary for each
PCFO's individual situation and it is the PCFO's responsibility to
prepare full disclosure financial statements. All supplemental schedules
must be completed as detailed.

**\[CAMPAIGN NAME\]**

**FINANCIAL STATEMENTS**

**FOR**

**THE FALL 2001 CAMPAIGN**

**PCFO Name:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
CFC Code\_\_\_\_\_**

**TABLE OF CONTENTS**

**Executive Summary**

A. Financial statements and required supplementary schedules of the
\[campaign name\] as of and for the campaign years ended March 31, 2003
and independent auditors' report.

> Required financial statements and supplementary schedules include:

-   Statement of Financial Position only

-   Statement of Activities

-   Statement of Cash Flows

-   Statement of Functional Expenses only

B. Other reports

-   Report of Agreed-Upon Procedures only

**Not-for-Profit Organization**

**Statements of Financial Position**

**March 31, 2003**

Assets:

Cash and Cash Equivalents

Pledges and Interest Receivable (Net of

Allowance for Uncollectibles of \$50,000)

Total assets

Liabilities and net assets:

PCFO Administrative Expense Payable

Total liabilities

Net Assets:

Restricted:

National and International Affiliated and

Unaffiliated Agencies

Local Affiliated and Unaffiliated Agencies

Total net assets

Total liabilities and net assets

**Fall 2001**

\$ 0

[0]{.underline}

\$ 0

[\$ 0]{.underline}

\$ 0

\$ 0

0

[\$ 0]{.underline}

[\$ 0]{.underline}

\$ 0

**Not-for-Profit Organization**

**Statement of Activities**

**Campaign Period Ended March 31, 2003**

Campaign Results and Revenues:

Campaign Results:

Contributions/Pledges

Less: Cancellations and Uncollected Pledges

Net Campaign Results

Revenues:

Interest on Bank Account

Net Campaign Results and Revenues

Operating and Distribution Expenses:

Salaries

Employee Benefits

Payroll Taxes

Printing

Rent/Occupancy

Telephone

Training

Postage

Travel

Awards and Special Events

Professional Fees

Office Supplies

Insurance

Freight and Shipping Campaign Material

Total Operating Expenses

Distribution Expenses:

Distributions to Participating Agencies

Total Operating and Distribution Expenses

Change in Net Assets

Net Assets at Beginning of Campaign

Net Assets at End of Campaign

**Fall 2001**

\$ 1,100,000

[(50,000)]{.underline}

\$ 1,050,000

[\$ 8,000]{.underline}

\$ 1,058,000

\$ 50,000

6,800

3,700

19,000

8,200

400

800

450

1,500

4,000

3,500

800

800

[50]{.underline}

[\$ 100,000]{.underline}

\$ 958,000

[\$ 1,058,000]{.underline}

\$ (0)

[0]{.underline}

\$ 0

**Not-for-Profit Organization**

**Statement of Cash Flows**

**Campaign Period Ended March 31, 2003**

[CASH FLOWS FROM OPERATING ACTIVITIES:]{.underline}

Cash Received from Contributors

Cash Payments to Participating Agencies

Cash Received from Investment Income

Cash Payments to Employees and Suppliers

Cash and Cash Equivalents Provided by Operating Activities,

and Net Change in Cash and Cash Equivalents

Cash and Cash Equivalents at Beginning of Campaign

Cash and Cash Equivalents at End of Campaign

Reconciliation of Change in Net Assets to Cash and Cash

Equivalents Provided by Operating Activities:

Change in Net Assets

Adjustments to Reconcile Change in Net Assets to Net Cash Used by

Operating Activities:

Pledges and Interest Receivable

Distributions to Participating Agencies Payable

Cash and Cash Equivalents Provided by Operating Activities

**Fall 2001**

\$ 1,050,000

(958,000)

8,000

[(100,000)]{.underline}

[\$ 0]{.underline}

0

\$ 0

\$ 0

0

[0]{.underline}

\$ 0

**Not-for-Profit Organization**

**Statement of Functional Expenses**

**For the Campaign Period Ended March 31, 2003**

**[Program Services]{.underline}** **[\_ Support Services
\_]{.underline}**

Distributions to Participating Agencies

Operating Expenses:

Salaries

Employee Benefits

Payroll Taxes

Printing

Rent/Occupancy

Telephone

Training

Postage

Travel

Awards and Special

Events

Professional Fees

Office Supplies

Insurance

Freight and Shipping

Campaign Material

Total Expenses

CFC

[Services]{.underline}

\$ 958,000

[\_]{.underline}

\$ 958,000

[Fundraising]{.underline}

\$45,000

6,120

3,330

19,000

4,000

[\_]{.underline}

\$ 77,450

Management

and

[General]{.underline}

\$5,000

680

370

8,200

400

800

450

1,500

3,500

800

800

[50]{.underline}

\$ 22,550

Total

Support

[Services]{.underline}

\$ 50,000

6,800

3,700

19,000

8,200

400

800

450

1,500

4,000

3,500

800

800

[50]{.underline}

\$ 100,000

[Totals]{.underline}

\$ 958,000

50,000

6,800

3,700

19,000

8,200

400

800

450

1,500

4,000

3,500

800

800

[50]{.underline}

\$1,058,00

**APPENDIX** **B**

**SAMPLE REPORTS**

**1. ILLUSTRATIVE REPORT ON AGREED-UPON** **PROCEDURES** **(Attestation
Standards** **Section 601.25 through 601.29)**

Independent Accountants' Report

We have performed the procedures included in the Combined Federal
Campaign Audit Guide *\[or enumerated below\]*, which were agreed to by
the Office of Personnel Management, Local Federal Coordinating
Committee, and *\[PCFO name\]*, solely to assist the specified parties
in evaluating the *\[PCFO name\]*'s compliance with 5 CFR Part 950 and
OPM guidance during the 2001 Combined Federal Campaign ended March 31,
2003 *\[or applicable date\]* and the effectiveness of the *\[PCFO
name\]*'s internal control over compliance with the aforementioned
compliance requirements as of *\[date\]*. Management is responsible for
the *\[PCFO name\]*'s compliance with those regulations and guidance.
This agreed-upon procedure engagement was conducted in accordance with
attestation standards established by the American Institute of Certified
Public Accountants. The sufficiency of these procedures is solely the
responsibility of those parties specified in this report. Consequently,
we make no representation regarding the sufficiency of the procedures
described below either for the purpose for which this report has been
requested or for any other purpose.

The procedures we performed are included in the Combined Federal
Campaign Audit Guide *\[or enumerated in the listing of engagement
procedures accompany­ing this report\]*. Findings obtained from
performing these procedures are presented in the accompanying schedule
of findings and questioned amounts.

We were not engaged to and did not conduct an examination, the objective
of which would be the expression of an opinion on compliance and on the
effectiveness of internal control over compliance. Accordingly, we do
not express such an opinion. Had we performed additional procedures,
other matters might have come to our attention that would have been
reported to you.

This report is intended solely for the information and use of the Office
of Personnel Management, Local Federal Coordination Committee and
*\[PCFO name\]* and is not intended to be and should not be used by
anyone other than these specified parties.

*\[Signature\]*

*\[Date\]*

**2. ILLUSTRATIVE SCHEDULE OF FINDINGS AND QUESTIONED AMOUNTS**

+----------------+--------------------+--------------+----------------+
| Schedule of    |                    |              |                |
| Findings for   |                    |              |                |
| Agreed-Upon    |                    |              |                |
| Procedures     |                    |              |                |
+----------------+--------------------+--------------+----------------+
| Area           | Description of     | \$           | Status of      |
|                | Findings           | Questioned   | Finding        |
+----------------+--------------------+--------------+----------------+
| 1\. Pledge     | The PCFO entered 1 | Procedural   | PCFO will      |
| Card Tracking  | pledge card out of |              | inform quality |
| System         | our sample of 25   | \$10,000     | reviewers to   |
|                | incorrectly into   |              | make sure all  |
| 2\. Receipt    | its tracking       |              | information    |
| and            | system.            |              | entered into   |
| Disbursement   | Specifically, the  |              | the pledge     |
| of Funds       | PCFO did not       |              | card tracking  |
|                | indicate that the  |              | system is      |
|                | donor wanted to    |              | accurate.      |
|                | release his name   |              |                |
|                | to charities.      |              | The PCFO       |
|                |                    |              | distributed    |
|                | The PCFO did not   |              | the \$10,000   |
|                | distribute         |              | in interest    |
|                | interest earned on |              | earned on May  |
|                | its CFC bank       |              | 15, 2003 (or   |
|                | account to         |              | has agreed to  |
|                | participating      |              | distribute the |
|                | organizations.     |              | \$10,000 or    |
|                |                    |              | disagrees with |
|                |                    |              | the finding    |
|                |                    |              | and is seeking |
|                |                    |              | resolution     |
|                |                    |              | from the LFCC  |
|                |                    |              | and OPM).      |
+----------------+--------------------+--------------+----------------+

**3. ILLUSTRATIVE COMMENTS ON RESOLUTION OF PRIOR YEAR'S EXAMINATION
FINDINGS**

Finding No 1: In an examination performed by the \[*name of audit
entity*\] dated \[*mm/dd/yy*\] and titled \[*name of report*\], in tests
of the PCFO General Compliance, the PCFO did not have controls in place
to ensure that it filed OPM Form 1417 by the required due date. This was
a procedural finding.

Status: As of \[*mm/dd/yy*\] the PCFO developed and implemented a
schedule of key due dates. As a result, the PCFO indicated that it met
all key due dates for the 2002 campaign.

**ILLUSTRATIVE CORRECTIVE ACTION PLAN FOR FINDINGS**

Corrective Action Plan

(Prepared by PCFO or service organization)

Name of PCFO or service organization and plan code:

Official responsible for plan:

Phone number:

Audit Period:

IPA/Audit firm:

> A. Comments on findings and recommendations
>
> The PCFO should provide a statement of concurrence or nonconcurrence
> with each finding and recommendation. For instances of nonconcurrence,
> the PCFO should provide documentation to support their position.
>
> B. Actions taken or planned
>
> The PCFO should develop a detail action plan to correct or resolve all
> IPA findings. The plan should include expected correction date(s) and
> name of official responsible for corrective actions.
>
> C. Status of corrective actions for prior year findings
>
> The PCFO, should document status of all prior year findings and the
> related corrective actions including changes in corrective action, and
> expected dates of completion.

5.  **ILLUSTRATIVE LFCC REPORT ON FINDINGS**

> Office of Personnel Management
>
> Director of CFC Operations
>
> Office of CFC Operations
>
> 1900 E Street, NW., Room 5450
>
> Washington, DC 20415-1000
>
> The LFCC certifies that it has developed an understanding of the
> campaign regulations, is carrying out its responsibilities under the
> campaign regulations and has a current active membership, including a
> LFCC Chairperson. The LFCC has conducted a compliance assessment by
> performing the procedures included in Chapter II of the Combined
> Federal Campaign Audit Guide. The objective of these procedures was to
> assess the *\[PCFO name\]*'s compliance with CFC regulations and OPM
> guidance and the effectiveness of the PCFO's internal controls over
> its compliance for the 2002 campaign.
>
> Based on our compliance assessment, we found the *\[PCFO name\]* was
> in compliance for each of the procedures we performed with 5 CFR Part
> 950 and OPM guidance.
>
> or
>
> Based on our compliance assessment, we found the *\[PCFO name\]* was
> in compliance for each of the procedures we performed with 5 CFR Part
> 950 and OPM guidance, except for the following:

1.  The PCFO did not have controls in place to ensure that it filed OPM
    Form 1417 by March 3, 2003 as required by CFC Memorandum 2003-02.

2.  The PCFO did not include a statement in the 2002 brochure informing
    employees of their right to make a choice to contribute or not to
    contribute as required by 5 CFR § 950.401(e).

> We have discussed these issues with the PCFO. The PCFO agrees with all
> the issues above and is working to correct them.
>
> or
>
> We have discussed these issues with the PCFO. The PCFO agrees with all
> the issues above except for number 1. The PCFO believes the date was
> extended to March 15, 2003. We would appreciate your input on the
> correct date for submitting OPM Form 1417.
>
> *\[Signature\]*
>
> *\[Date\]*

*\[Date\]*

  ----------------- --------------------- --------------- ----------------
                                                          

                                                          

                                                          
  ----------------- --------------------- --------------- ----------------

6.  

**APPENDIX** **C**

**PLEDGE CARD QUESTIONNAIRE**

*(A narrative description of this process may be substituted. Please
address each of these questions.)*

1\. How are pledge cards collected, organized, and processed \[5 CFR
950.105(d)(1)\]?

> a\. What procedures are in place to ensure that pledge cards are
> processed properly (e.g., not misplaced or lost, etc.)?
>
> b\. What procedures are in place to ensure that designated and
> undesignated contributions are recorded properly?
>
> c\. What procedures are in place to verify the totals?

2\. What procedures are used when an employee makes a desig­nation to an
agency not listed in the brochure \[5 CFR 950.402(c)\]?

3.  What procedures are used when a pledge card has mathematical errors
    or is illegible \[5 CFR 950(d)(4) and 5 CFR 950.402(d)\]?

  -- --- -- ----------------- -- --- ------------ -- -- -- -- --------- -- -- -- ---------- -- -- ------- ----------------- -- -- -- -- -- ---------------- -- -- -- ---- --------------- -- -- -- -- ----- ------- -- -- -- -- -- --------- ------ -- -- -- -- -- ---
                                                                                                                                                                                                                                                                   

            **SCHEDULE OF                                                                                                                                                                                                                                          
            CAMPAIGN RECEIPTS                                                                                                                                                                                                                                      
            AND                                                                                                                                                                                                                                                    
            DISBURSEMENTS**                                                                                                                                                                                                                                        

                                                                                                                                                                                                                                             Page 1                

            **Month**                **Campaign                                                           **Campaign                                                                                                               Ending                          
                                     Receipts**                                                           Disbursements**                                                                                                          Balance                         

                                     Cash &                   Payroll            Interest         Total   Service charges                  Administrative                 Disbursements                     Total                                                  
                                     Checks                                                                                                Expenses                       to agencies                                                                              

            Sep-01                                                                                0                                                                                                         0                      0                               

            Oct-01                                                                                0                                                                                                         0                      0                               

            Nov-01                                                                                0                                                                                                         0                      0                               

            Dec-01                                                                                0                                                                                                         0                      0                               

            Jan-02                                                                                0                                                                                                         0                      0                               

            Feb-02                                                                                0                                                                                                         0                      0                               

            Mar-02                                                                                0                                                                                                         0                      0                               

            Apr-02                                                                                0                                                                                                         0                      0                               

            May-02                                                                                0                                                                                                         0                      0                               

            Jun-02                                                                                0                                                                                                         0                      0                               

            Jul-02                                                                                0                                                                                                         0                      0                               

            Aug-02                                                                                0                                                                                                         0                      0                               

            Sep-02                                                                                0                                                                                                         0                      0                               

            Oct-02                                                                                0                                                                                                         0                      0                               

            Nov-02                                                                                0                                                                                                         0                      0                               

            Dec-02                                                                                0                                                                                                         0                      0                               

            Jan-03                                                                                0                                                                                                         0                      0                               

            Feb-03                                                                                0                                                                                                         0                      0                               

            Mar-03                                                                                0                                                                                                         0                      0                               

            TOTAL                    0                        0                  0                0       0                                0                              0                                 0                      0                               

            If there was                                                                                                                                                                                                                                           
            activity after                                                                                                                                                                                                                                         
            March Year 03,                                                                                                                                                                                                                                         
            please add a row                                                                                                                                                                                                                                       
            and include that                                                                                                                                                                                                                                       
            information.                                                                                                                                                                                                                                           

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   

                                                                                                                                                                                                                                                                   
  -- --- -- ----------------- -- --- ------------ -- -- -- -- --------- -- -- -- ---------- -- -- ------- ----------------- -- -- -- -- -- ---------------- -- -- -- ---- --------------- -- -- -- -- ----- ------- -- -- -- -- -- --------- ------ -- -- -- -- -- ---

  -- -- -- ---------------- -- -- ----------- -- -- ----------------- -- -- -- ------- -- -- -- ------------------ -- -- -- -- ------- -- -- ----------------- -- -- -- -------------- -- -- -- -- -- ------- -- -- ------------------ -- ------------ -- ------------ -- ------------ -- ------------ -- -- -- -- ------------ -- -- ------------ -- -- ------------ -- -- ------------ -- -- ----------- -- -- --------------- -- -- -- -- ------- -- -- -- -- -- -- -- -- --
           ***Name Of CFC                                                                                                                                                                                                                                                                                                                                                                                                                                                    
           Audit***                                                                                                                                                                                                                                                                                                                                                                                                                                                          

           **Distribution                                                                                                                                                                                                                                                                                                                                                                                                                                                    
           Schedule**                                                                                                                                                                                                                                                                                                                                                                                                                                                        

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

           ** **                  ** **             **Desig-nated**                             **Undesignated**                             **Gross**                  **Expenses**                                **Total**             ** **           ** **           ** **           ** **                    ** **              ** **              ** **              ** **              **Total**         **Shrinkage**                                               

           **Agency#**            **Agency          **Designated**             **%**            **Undesignated**               **%**         **Designation**            **Charged**                   **%**         **Desig-nation**      **Mar-00**      **Apr-00**      **May-00**      **Continue               **Dec-00**         **Jan-01**         **Feb-01**         **Mar-01**         **Paid**          **\$**                      **%**                           
                                  Name**                                                                                                                                                                                                                                                  with each                                                                                                                                                                          
                                                                                                                                                                                                                                                                                          month**                                                                                                                                                                            

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                                                                                                                             0.00                                                                   0.00                                                                                                                                                                       0.00              0.00                                                        

                                  **TOTAL**         0.00                                        0.00                                         0.00                       0.00                                        0.00                  0.00            0.00            0.00            0.00                     0.00               0.00                0.00              0.00               0.00              0.00                                                        

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

                                                                                                                                                                                                                                                                                                                                                                                                                                                                             
  -- -- -- ---------------- -- -- ----------- -- -- ----------------- -- -- -- ------- -- -- -- ------------------ -- -- -- -- ------- -- -- ----------------- -- -- -- -------------- -- -- -- -- -- ------- -- -- ------------------ -- ------------ -- ------------ -- ------------ -- ------------ -- -- -- -- ------------ -- -- ------------ -- -- ------------ -- -- ------------ -- -- ----------- -- -- --------------- -- -- -- -- ------- -- -- -- -- -- -- -- -- --

**APPENDIX** **D**

**DEFINITIONS AND ACRONYMS**

\"Agency\" or \"Voluntary Agency\" - a private, non-profit,
philanthropic, human health and welfare organization.

\"Agreed-Upon Procedures (AUP)\" - An agreed-upon procedures engagement
is one in which a independent public accountant (IPA) is engaged to
issue a report of findings based on specific procedures performed on a
subject matter. OPM and the IPA agree upon the procedures to be
performed as outlined in this Guide. The IPA may request alternative
procedures be performed to achieve the desired result if the current
procedures do not match the operating environment.

\"Business Days\" - calendar days exclusive of Saturdays, Sundays, and
Federal holidays.

\"Campaign Cycle\" - a two year period which marks the beginning of a
campaign and the end of a campaign. March 15 marks the beginning of the
first year of the campaign and March 14 two years later ends the
campaign. For example, March 15, 2000 begins the fall 2000 campaign and

March 14, 2002 mark the end of the fall 2000 campaign.

\"Combined Federal Campaign\" or \"Campaign\" or \"CFC\" - the
charitable fund-raising program established under Executive Order Number
10728, as amended by Executive Order Number 10927, 12353, and 12404.

\"Director\" -- The Director of the Office of Personnel Management.
Currently, OPM's Director is Kay Coles James.

\"Designated Funds\" - those contributions which the contributor has
designated to a specific voluntary agency (ies), federation(s), or
general option(s).

\"Employee\" - any person employed by the Government of the United
States or any branch, unit, or instrumentality thereof, including
persons in the civil service, uniformed service, foreign service, and
the postal service.

\"Federation\" or \"Federated Group\" - a group of voluntary charitable
human health and welfare agencies organized for purposes of supplying
common fund-raising, administrative, and management services to its
constituent members.

\"International General Designation Option\" -- a donor option
indicating that the gift be distributed to all of the international
agencies listed in the international section of the campaign brochure in
the same proportion as all of the international agencies received
designation in the local CFC. This option will have the code \"IIII.\"

\"Local Federal Coordinating Committee\" or \"LFCC\" - the group of
Federal officials designated by the Director to conduct the CFC in a
particular community.

\"Most recent ongoing campaign\" -- The campaign solicited this past
Fall for which receipts and disbursements continue to occur. In the
first year of this Guide, this will be the 2002 Fall campaign (solicited
in Fall 2002).

\"Most recently completed campaign\" -- The most recent campaign for
which all receipts and disbursements have been completed. In the first
year of this Guide, this will be the 2001 Fall campaign (solicited in
Fall 2001).

\"Organization-wide Financial Statements\" -- Financial statements of
the PCFO as an organization. These statements may or may not include CFC
activity. These are the financial statements that are made available to
the public and that should reconcile to the organization's IRS Form 990.

\"Principal Combined Fund Organization\" or \"PCFO\" - the federated
group or combination of groups, or a voluntary agency selected by the
LFCC to administer the local campaign under the direction and control of
the LFCC and the Director.

\"Undesignated Funds\" - those contributions which the contributor has
not designated to a specific voluntary agency(s), federation(s), or
general option(s).

*AICPA* American Institute of Certified Public Accountants

*AIGA* Assistant Inspector General for Audits

*AR* AICPA's Professional Standards - Accounting and Review

*AT* AICPA's Professional Standards -- Attestation Standards

*AUP* Agreed-Upon Procedures

*CFC* Combined Federal Campaign

*CFR* Code of Federal Regulations

*CPA* Certified Public Accountant

*FOIA* Freedom of Information Act

*GAAP* Generally Accepted Accounting Principles

*GAAS* Generally Accepted Auditing Standards

*GAO* U.S. General Accounting Office

*Guide* Combined Federal Campaign Audit Guide

*IPA* Independent Public Accountant

*LFCC* Local Federal Coordinating Committee

*OIG* Office of the Inspector General

*OPM* Office of Personnel Management

*PCFO* Principal Combined Fund Organization

*SAS* AICPA's Statement on Auditing Standards

*SSAE* AICPA's Statements on Standards for Attestation Engagements

*SSARS* Statements on Standards for Accounting and Review Services

##### AUTHORITATIVE REFERENCES

5 CFR Part 950, Solicitation of Federal Civilian and Uniformed Service
Personnel for Contributions to Private Voluntary Organizations

Generally Accepted Accounting Principles (GAAP)

Generally Accepted Auditing Standards (GAAS)

SAS Number 1, Codification of Auditing Standards and Procedures

SAS Number 41, Working Papers

Interpretation Number 2 of SAS Number 41, Providing Access to or

> Photocopies of Working Papers to a Regulator

SAS Number 54, Illegal Acts by Clients

SAS Number 78, Consideration of Internal Control in a Financial

> Statement Audit: An Amendment to SAS Number 55

SAS Number 99, Consideration of Fraud in a Financial Statement Audit

SSAE Number 10 Attestation Standards: Revision and Recodification

**APPENDIX** **E**

**LAWS, REGULATIONS AND OPM GUIDANCE TO BE TESTED FOR COMPLIANCE**

1\. 5 CFR Part 950 -- Solicitation of Federal Civilian and Uniformed
Service Personnel for Contributions to Private Voluntary Organizations.

2\. Applicable CFC Memoranda, which can be found at
[www.opm.gov/cfc](../www.opm.gov/cfc).

**APPENDIX** **F**

**FREEDOM OF INFORMATION REQUESTS**

**NOTIFICATION TO SUBMITTERS OF CONFIDENTIAL COMMERCIAL INFORMATION**

You have been or may be asked to submit to the U.S. Office of Personnel
Management and/or its Office of Inspector General information in
connection with these procedures, audit, inspection or other inquiry
pursuant to the Inspector General Act of 1978, as amended, 5 U.S.C. app.
3, sec. 1 et seq. This is to notify you that if you deem any of this
information to be "confidential commercial information," you may take
steps to so designate that information to protect its confidentiality if
at a future point in time a request is made for disclosure of this
information under the Freedom of Information Act (FOIA).

"Confidential commercial information" means records that may contain
material exempt from release under Exemption 4 of FOIA (pertaining to
trade secrets and commercial or financial information that is privileged
or confidential), because disclosure could reasonably be expected to
cause substantial competitive harm.

You may use any reasonable method you believe appropriate and which is
acceptable to OPM or the OIG to indicate which documents and information
you deem to fall into the category of "confidential commercial
information." Please be as specific as possible in segregating the
information that you consider to be "confidential commercial
information" from any other information you are providing to OPM or the
OIG. This may be done before such information is provided to OPM or the
OIG if feasi­ble, but only if it will not delay or interfere with
production of the information or delay or interfere with OPM's or the
OIG's investigation, audit, inspection or other inquiry. Otherwise, you
may so desig­nate this information within a reasonable period of time
after the information is provided to OPM or the OIG.

If a FOIA request is received by OPM or the OIG for information you have
designated as "confidential commercial information," OPM or the OIG is
nevertheless required by law to make its own independent determination
of whether the FOIA requires disclosure of the information or whether it
should be withheld pursuant to Exemption (b)(4) or any other exemption
of FOIA. If OPM or the OIG determines that it may be required to
disclose pursuant to FOIA that information you have designated or other
information that OPM or the OIG has reason to believe could be expected
to cause substantial competitive harm, to the extent permitted by law,
we will make a good faith effort to notify you and provide you with a
reasonable opportunity to object to such disclosure and to state all
grounds upon which you oppose disclosure. We will give careful
consideration to all specified grounds for nondisclosure prior to making
our final decision.

If we nonetheless believe that disclosure is required, we will provide
you with a statement explaining why your objections were not sustained
and specifying a disclosure date. To the extent permitted by law, this
statement will be provided to you in a reasonable number of days prior
to the specified disclosure date. Furthermore, if disclosure of the
designated information is denied pursuant to an exemption under FOIA and
an administrative or judicial appeal is taken by the FOIA requester, we
will make a good faith effort to notify you promptly.

The procedures outlined in this notice are intended only to improve the
internal management of OPM and the OIG and are not intended to create
any right or benefit, substantive or procedural, enforce­able at law by a
party against the United States, its agencies, officers, or any person.

[^1]: Campaign period is defined as generally a 24 month period
    beginning with the selection of the PCFO and ending with final
    disbursements to organizations. For example, the 2001 campaign began
    in March 2001 with the selection of the PCFO and continues until
    approximately February/March 2003, when the last disbursement of
    funds is made.