FEDERAL ELECTION COMMISSION

FISCAL YEAR 2024 

CONGRESSIONAL BUDGET JUSTIFICATION

March 13, 2023 

Concurrently submitted to Congress and the Office of Management and Budget
1 

Table of Contents

SUMMARY OF FY 2024 BUDGET JUSTIFICATION 2

Section 1: Purpose and Priorities in FY 2024 6

1A: Commission Overview and Future Outlook 6

1B: FY 2024 Priorities 9 

Section 2: Budget Overview 14

2A: Requested Budget Level 14

2A.1: Description of Budget Increases and Decreases at Request Level 16

2B: Appropriations Language 19

2C: Recommended Legislative Changes 20

Section 3: FY 2024 Annual Performance Plan and FY 2022 Annual Performance Report 25

3A: Introduction 25

3A:1 Mission Statement 25

3B: Organizational Structure 26

3C: Performance Framework 29

3C:1 Strategic Goal 29

3C:2 Plans and Progress by Strategic Objective 29

3D: Implementation Factors 47

3D:1 Major Management Priorities, Challenges and Risks 47

3D:2 Data Validation and Verification 49

3E: Conclusion 50

Office of Inspector General’s Fiscal Year 2024 Budget Request 51

OIG Summary of Outstanding FEC Audit Recommendations 52
2

SUMMARY OF FY 2024 BUDGET JUSTIFICATION

The Federal Election Commission (FEC) is an independent regulatory agency responsible for

administering, enforcing, defending and interpreting the Federal Election Campaign Act of 1971 (“FECA” 

or the “Act”), as amended.1 As the foundation of federal campaign finance regulation, FECA reflects 

Congress’s efforts to prevent corruption through two principal means. First, it ensures that the public has 

access to information about the sources of financial support for federal candidates, political party 

committees and other political committees. Second, FECA imposes amount limitations and source 

prohibitions on contributions received by certain types of political committees. The Commission’s 

responsibilities also include overseeing the federal public funding programs for presidential campaigns.2 

For the fiscal year (FY) 2024 Budget Submission, the FEC’s total requested funding level is $93.5 million. 

The request for FY 2024 represents a 14.5 percent increase from the FEC’s FY 2023 appropriation, which 

follows several years of essentially flat funding for FEC operations between FY 2016 and FY 2022. 

Funding at the requested level will allow the FEC to continue to rebuild staffing levels and modernize and 

secure crucial IT systems. The staffing levels proposed in the FY 2023 and FY 2024 Budgets are intended 

to fill some positions vacated over the past 10 years in order to better serve the public. Between FY 2016 

and FY 2022, the FEC reduced IT operational costs and refrained from funding the modernization of 

certain systems to stay within appropriated levels. This has placed strain on IT operations and the agency 

predicts that additional funding is needed during the FY 2024 presidential election year to continue 

services at current levels. At the same time, the agency plans to continue targeted investments towards its 

modernization efforts to account for significant growth in transactions reported to the FEC and real-time 

information requests from its website. 

Funding at the requested level for FY 2024 will support the agency’s disclosure mission during the current 

presidential election cycle and in future years. Currently, the FEC receives campaign finance reports, 

statements and other disclosure documents from more than 16,000 political committees and other filers. 

During the 2020 presidential election cycle, these filers reported more than 600 million financial 

transactions, which were reviewed by FEC staff and disclosed to the public on the FEC’s website. This is 

more than double the number of transactions reported in the previous election cycle, and a nearly 400

percent increase compared to the previous presidential election cycle. 

Changes in the way political committees raise and spend funds have contributed to this stark increase in 

the number of transactions disclosed to the FEC. Campaign finance disclosure data must be received, 

processed and made available to the public within tight deadlines for public disclosure, and it must be 

safeguarded to ensure the integrity and accessibility of the information. The chart below illustrates the 

growth of data transactions in presidential election cycles that the FEC needs to process, store, search and 

display to support the FEC’s disclosure mission. 

1

 Public Law 92-225, 86 Stat. 3 (1972) (codified at 52 U.S.C. §§ 30101-45).

2

 The Commission’s responsibilities for the federal public funding programs are contained in the Presidential

Election Campaign Fund Act, Public Law 92-178, 85 Stat. 562 (1971) (codified at 26 U.S.C. §§ 9001- 13) and the

Presidential Primary Matching Payment Account Act, Public Law 93-443, 88 Stat. 1297 (1974) (codified at 26 U.S.C.

§§ 9031-42).
3

0

50,000,000

100,000,000

150,000,000

200,000,000

250,000,000

300,000,000

350,000,000

400,000,000

450,000,000

500,000,000

550,000,000

600,000,000

650,000,000

2008 2010 2012 2014 2016 2018 2020 2022

Transactions Reported to the FEC

Two-year Periods: 2008-2022

Presidential Congressional

Aside from the substantial increase in the number of transactions reported to the FEC, the FEC website’s 

Application Programming Interface (API), which permits users to customize data searches making vast 

quantities of campaign finance data readily available, received over 407 million hits during the 2020 

presidential election cycle. With the steep rise in transactions reported every election cycle comes a 

heavier burden on the FEC’s API to quickly search across the FEC’s campaign finance database and 

display the data requested by the public. These trends in campaign finance activity illustrate how crucial 

it is for the agency to continue to implement new programs and systems to ensure the timely disclosure of 

this increasing volume of campaign finance data. 

Three Information Technology (IT) Modernization projects in particular are essential components of the 

FEC’s long-term strategy to meet the increase in both reported transactions and public demand for this 

data: (1) the migration of campaign finance data and applications to a cloud environment; (2) the 

modernization of the campaign finance data pipeline and applications migrated to the cloud during 

previous fiscal years; and (3) efforts to modernize the FEC’s eFiling system. The FEC anticipates 

completing the agency’s cloud migration during FY 2023. Adequate funding for FY 2024 will help to 

ensure that the FEC continues work to modernize the eFiling system and internal applications, including 
4

solutions for the Reports Analysis Division’s (RAD) review process as well as the voting and certification 

system used by the Commission. In addition, funding at the requested amount for FY 2024 would allow 

the FEC to make improvements during the 2024 election cycle to the FEC’s “data pipelines,” which are a 

set of automated methods and procedures that process raw data for use by internal applications and on 

FEC.gov. The successful completion of these projects will ensure the FEC can continue to efficiently, 

fairly and effectively achieve its mission, as well as help the agency comply with recent government 

mandates concerning customer service. 

Robust workload continues to strain staffing resources as well. During the period FY 2012 to FY 2022, 

the number of FEC employees has been reduced by approximately 17 percent while the levels of campaign 

finance activity, and the resulting workload, have increased. During this period the FEC has been able to 

meet its statutory mission primarily due to efficiencies gained by reassigning staff using details, 

maximizing operational efficiencies through reorganizations, and improving technology and processes, 

among other efficiencies. However, in recent years the FEC has begun to exhaust the benefits that can be 

gained through such efficiencies and has, in some situations, reduced performance targets in response to 

these reductions in staffing amid increasing campaign finance activity. The FEC has set as a priority 

filling vacant positions and rebuilding staffing levels during FY 2023 and FY 2024. Full funding at the 

FY 2024 requested level would allow the agency to continue to grow its staffing levels to meet its 

increased workload and ensure the agency can satisfy the public’s customer service expectations. 
5

MISSION STATEMENT

To protect the integrity of the federal campaign finance process by providing 

transparency and fairly enforcing and administering federal campaign finance laws

Congress created the FEC to administer, enforce and formulate policy with respect to FECA. The Act

reflects Congress’s efforts to ensure that voters are fully informed of the sources of financial support for 

federal candidates, political committees and others and to prevent corruption. Public confidence in the 

political process depends not only on laws and regulations to ensure transparency, but also on the 

knowledge that those who disregard the campaign finance laws will face consequences. 

The primary objectives of the FEC are: (1) to engage and inform the public about campaign finance data; 

(2) to promote compliance with FECA and related statutes; (3) to interpret FECA and related statutes; and 

(4) to foster a culture of high performance. 

Voluntary compliance with the requirements of FECA is a particular focus of the Commission’s efforts, 

and its educational outreach and enforcement programs are both designed to ensure compliance with the 

Act’s limits, prohibitions and disclosure provisions. Because of the large and rising number of political 

committees and the ever-growing number of financial disclosure reports filed with the FEC, voluntary 

compliance is essential to enforcing the requirements of the Act. Accordingly, the Commission devotes 

considerable resources to encouraging voluntary compliance through widespread dissemination of 

educational materials related to federal campaign finance laws to the public, the press, political committees 

and state election officials.

This Budget Justification is organized in three sections. Section 1 addresses the agency’s purpose and 

priorities in FY 2024. Section 2 provides an overview of the agency’s request. Section 3 provides an 

overview of the agency’s four strategic objectives and describes the agency’s performance goals, 

indicators and targets to ensure continued progress toward meeting these objectives during FY 2024. 
6

Section 1: Purpose and Priorities in FY 2024 

1A: Commission Overview and Future Outlook 

The FEC is an independent regulatory agency responsible for administering, enforcing, defending and 

interpreting FECA. The Commission is also responsible for administering the federal public funding 

programs for presidential campaigns. 

The FEC is directed by six Commissioners, who are appointed by the President with the advice and 

consent of the Senate. By law, no more than three Commissioners can be members of the same political 

party. The Commissioners meet regularly to formulate policy and to vote on significant legal and 

administrative matters. The Act requires the affirmative vote of four members of the Commission to 

approve official actions, thus requiring bipartisan decision making. 

As part of its responsibilities, the FEC makes available on its website the campaign finance disclosure 

reports all federal candidates and federal political committees must file, as required by the Act. These 

disclosure reports and the data contained in them are made available to the public through the 

Commission’s internet-based public disclosure system on the agency’s website at FEC.gov. The FEC 

also has exclusive responsibility for civil enforcement of FECA, including the handling of civil litigation 

arising from any legal actions brought by or against the Commission. Additionally, the Commission 

promulgates regulations implementing the Act. The Commission also has a statutory responsibility to 

issue advisory opinions responding to inquiries regarding interpretation and application of the Act and the 

Commission’s regulations to specific factual situations.

The FEC’s Strategic Plan for FY 2022 through FY 2026, developed pursuant to the Government 

Performance and Results Act of 1993 (GPRA)3 and the GPRA Modernization Act of 2010,

4 provides the 

agency’s strategic management framework. This framework is designed to ensure that every employee 

works in support of the FEC’s strategic goal and objectives, and that the effectiveness of these efforts can 

be regularly and meaningfully measured. 

The FEC is currently funded by a single annual appropriation for salaries and expenses. Over 70 percent 

of the agency’s budget is composed of expenses related to personnel, such as salaries and benefits. Of the 

agency’s remaining operational expenses, the largest categories are IT operations, including IT security 

requirements, and facilities rent. These three requirements constituted 93 percent of the agency’s FY 2022 

obligations. FY 2022 Budget obligations are shown in Figure one below. 

 

3 Public Law 103-62, 107 Stat. 285 (1993) (codified at 31 U.S.C. § 1115 et seq.). 

4 Public Law 111-352, 124 Stat. 3866 (2011) (codified at 31 U.S.C. §§ 1115-24). 
7

Figure 1 – FY 2022 Obligations by Major Category as of September 30, 2022

SALARIES and BENEFITS

71%

FACILITIES

7%

OCIO INITIATIVES

15%

OTHER SERVICES

7%

* OCIO Initiatives includes costs for (1) maintenance of all existing applications and systems that support the FEC’s statutory 

duties, including the legacy eFiling program; (2) IT modernization initiatives; (3) funding of cloud hosting costs, and (4) 

contracts for products and services associated with maintaining the FEC’s defenses against cybersecurity threats.
8

FEC Organizational Chart

The Offices of the Staff Director, General Counsel, Chief Information Officer and Chief Financial Officer 

support the agency in accomplishing its mission. The Office of the Inspector General, established within 

the FEC in 1989 under the Inspector General Act Amendments of 1988,5 is independent and reports both 

to the Commissioners and to Congress. The specific roles and responsibilities of each office are

described in greater detail at:

https://www.fec.gov/about/leadership-and-structure/fec-offices.

5

 Public Law 100-504, 102 Stat. 2515 (1988).
9 

1B: FY 2024 Priorities 

The FEC priorities for FY 2024 are aligned with the agency’s FY 2022 to 2026 Strategic Plan and are 

limited to those needs that will allow the agency to fulfill its mission as required by law and support the 

President’s Management Agenda. As discussed below, funding at the requested amount of $93.5 million 

would allow the agency to grow FEC staffing levels from the FY 2023 appropriated level and would 

permit the FEC to take measures to enhance the delivery of campaign finance data and legal resources. 

The requested funding would also improve the agency’s systems and processes, allowing the Commission 

to make progress reducing its dependency on costly legacy systems and improve the efficiency of the 

agency’s IT infrastructure, including data pipeline modernization, modernization of cloud-hosted 

applications, improvements to the eFiling platform and continued enhancements to cybersecurity and 

tools. Also, the funding would permit the FEC to grow staffing levels that have been depleted over time 

and provide employees with the training and resources needed to foster a culture of high performance. 

The FEC’s priorities for FY 2024 will help to ensure that the agency can improve customer experience 

and service delivery as it meets increasing public demand for its services. These priorities are discussed 

in more detail below.

Prioritizing IT Modernization and Cybersecurity

The FEC protects the integrity of the federal campaign finance process by providing transparency and 

fairly enforcing and administering federal campaign finance laws. Fair enforcement and full disclosure 

of the sources and amounts of campaign funds allow the public to make informed decisions in the political 

process. Transparency requires that information is not only kept by the FEC but also that it is provided to 

the public in a way that is intuitive to users and provides the necessary context for understanding how 

federal elections are funded. The FEC must make election-related reports and information accessible to 

the public in a timely, reliable and useful fashion. The Commission is therefore committed to providing 

the public with robust access to campaign finance data, compliance information and legal resources. 

Funding at the requested amount of $93.5 million would allow the FEC to make progress improving the 

quality of services delivered to the public. 

Campaign finance reports disclose financial transactions that detail where political committees and other 

filers raised, spent, refunded, saved or transferred money. The transactions reported to the FEC might 

show a $5 contribution to a candidate or a $50,000 ad buy by a PAC. As a key means of preventing 

corruption, these transactions document campaign finance activity, which serves as the record commonly 

used for enforcement, historical and journalistic purposes. 

Once the FEC receives a report, that report is nearly immediately put on the FEC website for the public 

to view. The transactions contained in the report are also reviewed and coded by FEC staff, entered into

the FEC’s databases and made searchable on the FEC website, which provides decades of transactionlevel data for historical research and comparison. 

Transaction-level data reported to the FEC is also used by FEC staff to ensure compliance with the FECA. 

Transaction-level data is reviewed by staff in RAD through its eReview system, which is over 20 years 

old. Without electronic access to this data, RAD staff would not be able to review reports. This data is 

also used by other FEC staff via internal systems that support the agency’s enforcement and compliance 
10

functions. 

The FEC’s IT Modernization Projects

The FEC’s IT Modernization projects comprise a multi-year plan to migrate and modernize applications 

and data assets to a cloud environment in order to more effectively process transaction-level data, improve 

application performance and enhance security. The FEC is undertaking these projects primarily to ensure 

the agency can continue to receive, review and publicly disclose the increasing volume of campaign 

finance transactions that are reported. While much of the agency’s focus remains on data-related 

applications, the FEC also recognizes the need to start planning for replacing or modernizing other internal 

applications that support the agency’s ability to achieve its mission, including the eReview system used 

by RAD and the voting and certification system used by the Commission. 

The FEC provides free eFiling software to filers. Approximately $1.65 million in funds included in this 

request supports efforts to improve ease-of-use of this software and to make the software platformindependent. The new software will be released for PACs and parties first, with the expectation that the 

new software will go into production for PACs in early 2024. The new software will go into production 

for candidates in 2025-2026, with estimated additional costs of $3 million over the 2025-2026 FYs to 

complete development of the new software for additional types of filers and to cover support costs. Note 

that the FEC’s eFiling system cannot be taken offline without significant disruption of the FEC’s 

disclosure mission. Thus, during years when the new eFiling software and the FEC’s internal systems to 

support it are in development, overall costs to support eFiling capacity will be higher because the legacy 

eFiling system must continue to run in tandem with the new system. 

Once completed, the new eFiling software will be cloud hosted. The cloud-hosted software will allow the 

FEC to better control future costs of maintaining the system in an environment of steeply rising campaign 

finance activity and will make it easier for its users to file reports. The current software was developed in 

the 1990s when the FEC averaged 1.3 million transactions per election cycle, a small fraction of the 

number of transactions received during the 2020 and 2022 cycles. Over time, the cost-per-transaction of 

the FEC’s current server-hosted system has become increasingly high. In FY 2022 the FEC spent $1.4 

million annually maintaining and enhancing this 25-year-old system. The cloud-hosted cost-pertransaction of the new system is anticipated to be lower, in addition to other lower costs associated with 

eFiling support and security. 

While the new software is in development, the current legacy eFiling system must be maintained at the 

$1.4 million per year cost noted above. Costs to support the new eFiling system/platform are expected to 

be approximately half of what it would cost to continue under the old system/platform. The transactionlevel data received by the eFiling system must be rapidly processed and made available in an accessible 

format to FEC staff, such as RAD analysts who review campaign finance reports, as well as to the public 

on the FEC’s website. The FY 2024 request includes funding for the data pipeline modernization initiative, 

which aims to enhance the infrastructure and processes that facilitate the flow of information received 

through the eFiling system to internal review applications, like eReview, and other systems, then to 

agency’s public website. By modernizing the data pipeline, the FEC can avoid purchasing additional 

database licenses under the legacy database architecture and ensure that it can continue to effectively 

fulfill its disclosure mission. 
11

 

Absent funding to continue improvements to this data pipeline, the agency is not confident of its ability 

to meet the disclosure demands of the 2024 presidential election cycle. Although the total number of 

transactions received during the 2022 midterm cycle was slightly lower than that received during the 2020 

presidential election cycle, the agency still struggled to successfully process the number of transactions 

received on any particular day during the 2022 cycle. The maximum processing capacity of the FEC’s

current data pipeline is 15 million electronically filed transactions per day if the process is to be completed 

within the agency’s internal goals for timely disclosure. However, the number of transactions received per 

day can vary widely. For example, on a single day during the 2022 cycle the FEC received approximately 

49 million transactions reported by a single committee. While receiving this volume of transaction in a 

day is not a regular occurrence, it is also not uncommon. For the interim, the agency has adopted a partially 

manual process to ensure that the reported data can be made timely available to the public on the FEC’s 

website. However, without improvements to the data pipeline the FEC cannot ensure that it will continue 

to be able to meet the high-water mark of reported transactions and make this disclosure data timely 

available to the public. 

Another part of the IT modernization work is to make improvements to the eReview system itself so that 

the system can host as much data as it needs to and to facilitate RAD’s review of increasing and 

increasingly complicated data. In 2020, the FEC began migrating databases and applications, including 

RAD’s eReview, to the cloud. This was completed in 2022. The next step is to modernize these migrated 

applications and move to more efficient, cloud-native solutions, starting with eReview. Without 

significant improvements to eReview, RAD staff will not be able to keep up with the demands of 

reviewing the increasing load of transactions. 

The FEC is also prioritizing modernizing its mission-critical Document Voting System and Certification 

applications. These applications, utilized by Commissioners for voting and staff for management and 

workflow organization, are based on an outdated legacy platform that is over two decades old. While these 

applications have been migrated to the cloud, they are not cloud native and need to be replaced with 

applications that are designed for modern cloud technologies. Significantly, these outdated applications 

now present a cybersecurity risk. Funding at the requested amount will allow the FEC to fund the 

modernization or replacement of these applications, as necessary. 

Cybersecurity

The FEC continuously improves its security architecture. The Commission’s security operation, along 

with continuous diagnostics and mitigation, allows the agency to identify and remediate vulnerabilities. 

In partnership with the Department of Homeland Security (DHS) and other strategic partners, the FEC 

continuously identifies, protects, detects, responds to and recovers from the impact of known and potential 

threats. The FEC’s FY 2024 funding request includes funding for our information security efforts, 

including our security operation center and the tools for continuous diagnostics and mitigation, and 

implementing security controls to address identified cybersecurity gaps. The requested funding would 

help address identified risks and support the FEC’s cybersecurity program and security architecture’s 

ability to continue to safeguard the agency’s infrastructure, networks and applications against cyber threats 

and malicious activities. 
12

These new projects and continued improvements would also not be possible without an increase to our 

current staff. The additional positions would help support mission critical innovations, especially when 

related to prioritizing information technology modernization and cybersecurity.

Strengthening the Workforce to Achieve the FEC’s Mission

The FEC intends to continue its efforts to maintain the high performance of current staff and the excellent 

service that they provide to the public. A critical part of this effort is rebuilding staffing levels across the 

agency. Staffing levels dropped approximately 17 percent between FY 2012 and FY 2022. The FY 2024 

request builds on the FY 2023 appropriation to allow the agency to fill critical vacancies, including in 

some of the areas where the FEC has experienced increased demands in workload. Overall, the request 

would increase the FY 2024 funding level to support 340 employees and represents a concerted effort 

through FY 2024 and beyond to rebuild from reduced staffing levels. 

Over the past decade, the FEC has been able to meet its statutory mission primarily due to efficiencies 

gained by reassigning staff using details, maximizing operational efficiencies through reorganizations, 

and improving technology and processes, among other efficiencies. However, in recent years the FEC 

has begun to exhaust the benefits that can be gained through such efficiencies and has, in some situations, 

reduced services in response to these reductions in staffing amid increasing campaign finance activity. 

As one example, the number of inquiries handled by RAD’s campaign finance analysts has increased by 

more than 300 percent between the 2010 and 2022 election cycles, while the number of RAD campaign 

finance analysts has decreased by 18 percent over the same period. In order to continue to meet core 

performance measures, RAD stopped having a campaign finance analyst assigned to every authorized 

committee that reports to the FEC and now responds to inquiries from unassigned committees as 

availability permits, without the familiarity or established rapport that exists for committees that have an 

assigned analyst. The FY 2024 request would build off the FY 2023 appropriation to support priority 

hiring in RAD. 

Another example where concerted efforts are being undertaken to rebuild staffing levels to strive to meet

current workloads is in the Office of General Counsel (OGC), which is responsible for advising the 

Commission on enforcement and policy as well as representing the agency in litigation. In FY 2023 to 

date, OGC has increased its staffing levels overall by eight percent to 61 percent of FY 2012 levels, with 

additional hires across all divisions in process. Within OGC, the Policy division was able to begin 

rebuilding its staffing levels, resulting in an increase in its onboard staff of 12 percent to date with 

additional hires anticipated during FY 2023. This has enabled the Policy division to improve its 

performance metrics and its ability to meet its increased workload6

. The FY 2024 request will enable the 

agency to continue to build on these efforts across RAD, OGC and the agency as a whole. 

6 During FY 2023 to date, for example, the Commission published documents in multiple open rulemakings, including: final 

rules in the Internet Communication Disclaimers rulemaking, supplemental NPRM in Technology Modernization, conducted 

a public hearing on audit procedures for political committees that do not receive public funds in February 2023, published a 

Notice of Proposed Rulemaking (NPRM) proposing changes to regulations regarding the use of campaign funds by a 

candidate’s principal campaign committee to pay compensation to the candidate and scheduled a public hearing for March 

2023.
13

The request would also allow the FEC to invest in training and awards, so as to improve the skills-base of 

the workforce and reward high performance. Finally, the Commission has established a series of datadriven metrics to measure customer satisfaction with educational outreach efforts, and to ensure that 

matters are moved efficiently and fairly through the enforcement and compliance processes, with 

complainants and respondents afforded sufficient transparency regarding the processes. Funding at the 

requested level is necessary to provide staff the resources needed to meet these goals.
14

Section 2: Budget Overview

2A: Requested Budget Level 

In this section, increases and decreases are identified and the FY 2024 request is compared to the FY 2023 

appropriation. For FY 2024 the FEC seeks a 14.5 percent increase over the FY 2023 appropriation. 

Approximately $7.7 million of the increased level would be used for personnel costs, both increased costs 

of current employees and costs of hiring new employees. The remaining requested increase of $4.1 million

in non-personnel increases would help the agency maintain current IT operations and continue targeted 

investments in modernization along with meeting other increased costs. 

Table 1 Changes from FY 2023 Appropriation to FY 2024 Request

Category Amount 

FY 2023 Appropriation $81,674,000 

Personnel Changes 

Personnel Compensation and Benefits $7,720,569

Personnel Changes Subtotal: $7,720,569

Non-Personnel Changes

Contracts & Other Services -254,379

Insurance Claims -4,000

Communications 19,844

Training 49,400

Printing & Reproduction 50,450

Travel 57,500

GSA Rent 82,810

Non-Capitalized & Capitalized Equipment 83,960 

Supplies & Materials 166,444 

Federal Goods & Services 347,440

IT Contracts 3,489,149 

 

Non-Personnel Changes Subtotal: $4,088,618

Total Change: $11,809,187

FY 2024 Request $93,483,187
15

Table 2 highlights the FY 2023 appropriation as compared to the FY 2024 Budget Request and FY 2022 

actual obligations. 

Table 2 

FY 2024 FEC Congressional Budget Justification

Object Class Data Federal 

Election Commission FY 2022 Actual FY 2023 Enacted 

FY 2024 

Request

Change from 

FY 2023 

Enacted to FY 

2024 Request 

% Change From 

FY 2023 Enacted to 

FY 2024 Request

11 Personnel 

Compensation 37,880,609 41,434,999 48,219,249 6,784,250 16.37%

11.52 Cash Awards 651,631 650,000 685,000 35,000 5.38%

12.1 Personnel benefits 13,908,013 14,968,081 15,831,437 863,356 5.77%

12.18 Transit Subsidy 82,472 237,037 275,000 37,963 16.02%

 Subtotal, Personnel $52,522,725 $57,290,117 $65,010,686 $7,720,569 13.48%

21

Travel & 

transportation of 

persons 23,229 222,500 280,000 57,500 25.84%

23.1 GSA Rent 5,215,071 5,300,000 5,382,810 82,810 1.56%

23.3 Communications, 

Utilities & Postage 424,059 658,700 678,544 19,844 3.01%

24 Printing & 

Reproduction 103,000 110,000 160,450 50,450 45.86%

25.11 Training, Commercial 

Fed. & Tuition

313,135 455,800 505,200 49,400 10.84%

25.14 IT Contracts 10,612,060 11,574,997 15,064,146 3,489,149 30.14%

25.2 Contracts & Other 

Services

1,289,786 2,094,080 1,839,701 -254,379 -12.15%

25.3 Federal Goods & 

Services 1,816,414 2,401,500 2,748,940 347,440 14.47%

26 Supplies and Materials 748,478 913,306 1,079,750 166,444 18.22%

31

Non-Capitalized and 

Capitalized 

Equipment 1,104,563 599,000 682,960 83,960 14.02%

42 Insurance Claims 800 54,000 50,000 -4,000 -7.41%

 Subtotal, Non-Personnel

$21,650,595 $24,383,883 $28,472,501 $4,088,618 16.77%

 TOTAL $74,173,320 $81,674,000 $93,483,187 $11,809,187 14.46%
16

2A.1: Description of Budget Increases and Decreases at Request Level 

Program Increases and Decreases ..........................................................................................$11,809,187 

Personnel Increase .....................................................................................................................$7,720,569 

The FEC’s $93.5 million funding request builds off the FY 2023 appropriation and would allow 

the agency to increase staffing levels above the FY 2023 appropriated levels. This funding level 

would support the Agency’s ability to reach 340 employees in fiscal year 2024. In addition to 

hiring, increased personnel funding is sought to support required personnel cost increases, such as 

the proposed and enacted pay raises (5.2 percent and 4.9 percent for calendar years 2023 and 2024) 

and awards funding at the same level as the FY 2023 President’s Budget. 

Non-Personnel Increases and Decreases ..................................................................................$4,088,618 

Contracts & Other Services ....................................................................................................... $-254,379 

This decrease is offset by a $3.5 million increase in IT contracts. FEC would prioritize funding to 

maintain existing IT support contracts, continue the current eFiling modernization project and 

begin new projects to increase FEC’s capacity to accept and transmit data as well as replace aging 

legacy systems. Information technology modernization is also essential to agency operations and 

with this increase of funds, staff processes will be eased for efficient services to the Commission 

and the public. 

Insurance Claims ............................................................................................................................ $-4,000 

The FEC experienced an increase of legal claims and indemnities in FY 2023 over FY 2022 levels. 

It is anticipated in FY 2024 that claims will decrease.

Communications, Utilities & Postage ............................................................................................$19,844 

This level would provide for expected increases in communication contracts, including contracts 

that implement GSA’s mandated Enterprise Infrastructure Solutions (EIS) telecommunications

program and mobile phones used by agency staff. 

Training ...........................................................................................................................................$49,400 

Training receives a modest increase to continue to invest in the agency’s personnel. 

 

Printing & Reproduction ...............................................................................................................$50,450 
17

The agency requests an increase to account for general cost increases and additional in-office 

activities. 

Travel ...............................................................................................................................................$57,500 

The agency expects travel costs to increase due to more in-person audits and educational 

conferences.

GSA Rent .........................................................................................................................................$82,810 

FEC’s rent costs in its lease agreement with GSA increased. 

Non-Capitalized and Capitalized Equipment ..............................................................................$83,960 

The FEC seeks efficiencies in equipment spending through its modernization and other efforts. 

Importantly, the implementation of modernization efforts, especially around cloud storage, would 

reduce the need for physical servers. Without investing in modernization efforts, the agency would 

not realize these savings. The FEC will need to replace and refresh hardware and other equipment 

used by agency staff, such as laptops and A/V equipment. These categories of equipment are aging 

and will need replacement in FY 2024. 

Supplies and Materials .................................................................................................................$166,444 

The increase is attributed to agency costs of necessary legal research. 

Federal Goods and Services .........................................................................................................$347,440 

This increase is for services purchased from other federal agencies, including the FEC’s contract 

with OPM’s HR Solutions, which provides a significant amount of the FEC’s HR functions, the 

Federal Protective Service and FEC’s Shared Service Providers, as well as web hosting costs for 

FEC.gov and eFiling modernization. 

IT Contracts ................................................................................................................................$3,489,149 

Much of this increase would allow the FEC to continue operations at current levels. Over the last 

two years, the FEC limited IT spending to stay within its appropriation. This has placed pressure 

on IT operations. The agency projects that additional funding is necessary to maintain those 

operations. At the same time, the agency recognizes the need to modernize its infrastructure to 

accommodate the rapid increase in reported transactions and data pulls from the public and to 

reduce costs to maintain increasingly outdated legacy applications. The modernization projects 

under consideration to utilize available funding include: (1) Modernization of legacy applications 
18

and the FEC’s data pipelines, which in turn will help the agency realize the future savings of these 

efforts and avoid the cost of maintaining outdated legacy systems; (2) The continued development 

and implementation of the new eFiling platform during FY 2024, which will allow the agency to 

retire its legacy eFiling system and realize those savings in future years; (3) Maintenance and 

support of the agency’s legacy eFiling system and data pipelines, which is necessary while the 

updated platforms and pipelines are being implemented; and (4) Funding of cloud hosting costs, 

which are increasing due to the significant growth in data. Importantly, this increase is partially 

offset by savings in the contracts object class.
19

2B: Appropriations Language

The FEC proposes the following Appropriations Language for FY 2024. 

FEDERAL ELECTION COMMISSION

Federal Funds Salaries and Expenses 

For necessary expenses to carry out the provisions of the Federal Election Campaign Act of 1971, 

$93,483,187, of which not to exceed $5,000 shall be available for reception and representation expenses.
20

2C: Recommended Legislative Changes 

On December 15, 2022, the Commission approved the 2022 Legislative Recommendations.7 Four of these 

recommendations represent bold proposals to streamline agency processes, including those for disclosing 

campaign finance data to the public, and ensure that the agency can operate more effectively and at a

lower cost to taxpayers.

These initiatives require statutory changes to be enacted through legislation and proposed statutory 

language for each was approved by the Commission and provided to the Congress and the Administration.

Make the Administrative Fine Program for Reporting Violations Permanent 

Section: FECA § 309(a)(4)(C)(v)

 (codified at 52 U.S.C. § 30109(a)(4)(C)(v)) 

Recommendation: Congress should make permanent the Commission’s authority to assess administrative 

fines for violations of the law requiring timely reporting of receipts and disbursements. The Commission’s 

current Administrative Fine Program only covers violations that relate to reporting periods through 

December 31, 2023. In the 118th Congress, legislation has been introduced in the Senate to make the 

Administrative Fine Program permanent with bipartisan original cosponsors of Sen. Amy J. Klobuchar 

(Minnesota) and Sen. Debra S. Fischer (Nebraska), who serve respectively as the Chairwoman and 

Ranking Member of the Rules and Administration Committee. 

Explanation: On December 21, 2018, President Trump signed legislation that extended the 

Administrative Fine Program, which authorized the Commission to include in the Program certain 

violations of FECA that relate to reporting periods through December 31, 2023.8 Congress has acted six 

times to extend the Administrative Fine Program, extending the initial covered period from two years to 

cover 24 years.9

 Instead of enacting a seventh temporary extension, Congress should act to make the 

7

 FECA § 304(c)(1) (codified at 52 U.S.C. § 30104(c)(1)). 

7

 FECA § 301(4)(A) (codified at 52 U.S.C. § 30101(4)(A)). 

7

 FECA § 301(4)(C) (codified at 52 U.S.C. § 30101(4)(C)). 

7

 FECA § 304(c)(1) (codified at 52 U.S.C. § 30104(c)(1)). 

8

 See Pub. L. No. 115-386, 132 Stat. 5161 (2018). 

9

 Pub. L. No. 107-67, §642, 115 Stat. 514, 555 (2001) (extending program through 2003 reports), Pub. L. 

No. 108-199, § 639, 118 Stat. 3, 359 (2004) (extending program through 2005 reports, leaving gap in coverage from January 

1 to February 10, 2004); Pub. L. No. 109-155, § 721, 119 Stat. 2396, 2493-94 (2005) (extending program through 2008 

reports); Pub. L. No. 110-433, 122 Stat. 4971 (2008) (extending program through 2013 reports); Pub. L. No. 113-72, 127 
21

program permanent. 

Through the Administrative Fine Program, the Commission has processed and made public 4,011 cases, 

with more than $8.8 million in fines assessed during the period from implementation of the program in 

2000 through the end of fiscal year 2022. The Administrative Fine Program has been remarkably 

successful: over the course of the program, the number of late and nonfiled reports has dramatically 

decreased. For election cycles 1992 through 2000, an average of 21% of campaign finance reports were 

filed late. Since the inception of the Administrative Fine Program, the percentage of late reports has 

dropped to below 10%. As a result, the Administrative Fine Program has become an integral part of the 

Commission’s mission to administer and enforce the Act. With fewer late reports and fewer challenges to 

administrative fines, the Commission has been able to reduce the number of employees who work on this 

program. By making the program permanent, Congress would ensure that the Commission would not lose 

one of the most cost-effective and successful programs in its history. 

Under the Administrative Fine Program, the Commission considers reports to be filed late if they are 

received after the due date, but within 30 days of that due date. Election-sensitive reports10 are considered 

late if they are filed after their due date, but at least five days before the election. Committees filing reports 

after these dates are considered nonfilers. Civil money penalties for late reports are determined by the 

amount of activity on the report, the number of days the report was late and any prior penalties for 

violations under the administrative fine regulations. Penalties for nonfiled reports are determined by the 

estimated amount of activity on the report and any prior violations. Committees have the option to 

challenge the Commission’s finding, proposed penalty or both, or they may pay the civil penalty assessed.

Increase the Rate of Pay for FEC Staff Director and General Counsel

Sections: FECA § 306(f)(1) 

(codified at 52 U.S.C. § 30106(f)(1)) 

Recommendation: Congress should revise section 306 of FECA to delink the salaries of the Staff Director 

and the General Counsel from Level IV and Level V of the Executive Schedule. 

Explanation: The current provision in FECA specifies that the Staff Director and General Counsel are to 

be paid at Level IV and Level V of the Executive Schedule, respectively. Both positions supervise 

personnel at the GS-15 and Senior Level pay scales, which often provide higher salaries than Levels IV 

and V of the Executive Schedule. The Staff Director and General Counsel have significant responsibilities 

Stat. 1210 (2013) (extending program through 2018 reports); and Pub. L. No. 115-386, 132 Stat. 5161 (2018) (extending 

program through 2023 reports).

10 Election sensitive reports are those filed immediately before an election and include pre-primary, pre-special, pregeneral, October quarterly and October monthly reports.
22

and oversight duties with respect to both administrative and legal areas, as well as management over 

almost all agency personnel. According to recruiting specialists who have worked with the Commission, 

the current limit makes attracting a strong pool of applicants to these positions more challenging. The 

appointment and retention of these key leaders have been identified as ongoing management and 

performance challenges to the Commission by the Inspector General in the nine most recent Agency 

Financial Reports covering 2014 through 2022 and in previous Performance and Accountability Reports. 

The General Counsel’s position is currently filled on an acting basis. 

The Commission proposes removing the statutory references to the Executive Schedule and 

amending FECA to specify that the Staff Director and General Counsel would be compensated under the 

same schedule as the Commission’s other senior managers. This revision will remedy the current situation 

where the Commission’s top managers are compensated at a lower rate than many of their direct reports 

and will ensure that the Commission can retain highly qualified individuals to serve in those positions as 

well as enable it to remain competitive in the marketplace for Federal executives when vacancies arise. 

Changing the salaries for these two positions would not require an increase in the Commission’s 

appropriation request. 

Electronic Filing of Electioneering Communication Reports

Section: FECA § 304(a)(11)(A)(i) 

(codified at 52 U.S.C. § 30104(a)(11)(A)(i))

Recommendation: Congress should require reports of electioneering communications to be filed 

electronically with the Commission, rather than on paper. 

Explanation: The Treasury and General Government Appropriations Act, 2000,11 required the 

Commission to make electronic filing mandatory for political committees and other persons required to 

file with the Commission who, in a calendar year, have, or have reason to expect to have, total 

contributions or total expenditures exceeding a threshold amount set by the Commission (which is 

currently $50,000). In addition, many independent expenditure reports are already subject to mandatory 

electronic filing under FECA section 304(a)(11)(A)(i). However, because electioneering communication 

reports are not filed by political committees, and because funds spent for electioneering communications 

are reported as “disbursements,” and not as “expenditures,” the mandatory electronic filing provisions do 

not apply to electioneering communication reports. 

Compared to data from paper reports, data from electronically filed reports is received, processed and 

disseminated more easily and efficiently, resulting in better use of resources. Reports that are filed 

electronically are normally available to the public, and may be downloaded, within minutes. In contrast, 

11 Pub. L. No. 106-58, § 639, 113 Stat. 430, 476 (1999).
23

the time between the receipt of a report filed through the paper filing system and its initial appearance on 

the Commission’s web site is 48 hours. 

Electronic filings are not subject to delay due to post office processing or disruptions in the delivery of 

mail, such as those arising from health and security measures related to the COVID-19 pandemic or the 

discovery of anthrax powder and ricin in mail. Because of these measures, the Commission’s receipt of 

mailed paper filings is delayed. In contrast, electronic filings are not subject to these delays. 

Only entities that report more than $50,000 of electioneering communications would be subject to 

mandatory electronic filing under the proposal. The current threshold selected by the Commission ensures 

that entities with limited financial resources can file reports on paper, which avoids the limited cost of 

internet access and a computer sufficient to file reports. 

Increase and Index for Inflation Thresholds and Exemptions

Sections: FECA §§ 301, 304 and 315 

(codified at 52 U.S.C. §§ 30101, 30104 & 30116) 

Recommendation: Congress should increase and index for inflation certain thresholds and exemptions in 

FECA that have not been changed since the 1970s. 

Explanation: Most of FECA’s contribution limits and registration and reporting thresholds were set in 

the 1970s. Because over twenty years of inflation had effectively reduced FECA’s contribution limits in 

real dollars, the Bipartisan Campaign Reform Act of 2002 increased most of FECA’s contribution limits 

to adjust for some of the effects of inflation. Furthermore, BCRA indexed these limits for inflation to 

address inflation in the future. The Commission proposes extending this approach to registration and 

reporting thresholds, which have been effectively reduced by inflation since those thresholds were 

established in 1971 or 1979. 

Since 1971, FECA has provided that any group of persons that receives contributions or makes 

expenditures in excess of $1,000 in a calendar year must register and report as a political committee.12 

FECA also requires political committees to abide by the contribution limits and source prohibitions 

specified in FECA. Since 1979, FECA has provided that local political party organizations are also subject 

to a $1,000 threshold for federal political committee status.13 The Commission recommends that Congress 

increase these thresholds to $2,000, and then index those amounts for inflation to prevent erosion in the 

12 FECA § 301(4)(A) (codified at 52 U.S.C. § 30101(4)(A)). 

13 FECA § 301(4)(C) (codified at 52 U.S.C. § 30101(4)(C)). 
24

future. Raising this threshold would be particularly beneficial for local and Congressional district 

committees of political parties. These organizations frequently breach the $1,000 threshold. An increased 

threshold would permit limited spending on federal elections without triggering federal political 

committee status for local and Congressional district committees of political parties.

Since 1979, FECA has required persons (other than political committees) who make independent 

expenditures in excess of $250 in a calendar year to report such expenditures to the Commission.14 The 

Commission recommends that Congress increase this threshold to $500 and index this amount for 

inflation. 

Under FECA, an individual may spend up to $1,000 per candidate, per election and up to $2,000 

per calendar year on behalf of all political committees of the same party for food, beverages, and 

invitations for an event held in the individual’s home without making a contribution.15 FECA also permits 

an individual to spend up to $1,000 per candidate, per election and up to $2,000 per calendar year on 

behalf of all political committees of the same party for unreimbursed travel expenses on behalf of the 

campaign or political party without making a contribution.16 

Congress added the current exemption limits in 1979, setting the amount for candidates as the 

same as the contribution limit then in effect ($1,000 per election) and setting the amount for political 

parties as 40% of the contribution limit then in effect for state, district, and local parties ($5,000 per 

calendar year) and 10% of the contribution limit then in effect for national parties ($20,000).17 

The Commission recommends that Congress update the in-home event exemption and 

unreimbursed travel expense exemption on behalf of candidates from $1,000 to $2,000 and index these 

amounts for inflation. The Commission further recommends that Congress update the in-home event 

exemption and unreimbursed travel exemption on behalf of political parties to $4,000. 

Increasing these thresholds and exemptions would take into account many years of inflation and 

the general increase in campaign cost and would ease the compliance burdens on individuals and smaller 

organizations. Additionally, by increasing the thresholds, Congress would exempt some individuals and 

small organizations that engage in only minimal spending from the Act’s registration and reporting 

requirements. Increasing the registration and reporting thresholds to compensate for inflation would leave 

significant financial activity subject to regulation as intended by Congress when it enacted FECA. 

14 FECA § 304(c)(1) (codified at 52 U.S.C. § 30104(c)(1)). 

15 FECA § 301(8)(B)(ii) (codified at 52 U.S.C. § 30101(8)(B)(ii)).

16 FECA § 301(8)(B)(iv) (codified at 52 U.S.C. § 30101(8)(B)(iv)).

17 See FECA Amendments of 1979, Pub. L. No. 96-187, § 101, 93 Stat. 1339 (1980). 
25

Section 3: FY 2024 Annual Performance Plan and FY 2022 Annual Performance 

Report

3A: Introduction

This Annual Performance Plan and Report (APP/APR) is considered the companion to the Federal 

Election Commission’s Strategic Plan for Fiscal Years (FY) 2022-2026, and designed to provide a solid 

framework for performance planning and reporting in accordance with the requirements of the GPRA 

Modernization Act of 2010.

18 The FY 2024 Annual Performance Plan and FY 2022 Annual Performance 

Report are combined in this document to present accomplishments through FY 2022 and performance 

targets associated with FYs 2022, 2023 and 2024. 

This plan positions the agency to promote compliance and to engage and inform the public about campaign 

finance data and rules. In order to meet these challenges, the FEC must maintain a workforce that is highly 

qualified to achieve the agency’s mission effectively and efficiently. 

3A:1 Mission Statement 

To protect the integrity of the federal campaign finance process by providing transparency and fairly 

enforcing and administering federal campaign finance laws. 

18 The President’s Budget identifies the lower-priority program activities, where applicable, as required under the 

GPRA Modernization Act of 2010, 31 U.S.C. 1115(b)(10). See http://www.whitehouse.gov/omb/budget.
26

3B: Organizational Structure

The FEC is an independent regulatory agency responsible for administering, enforcing, defending and 

interpreting the Federal Election Campaign Act (the Act). The Commission is also responsible for 

administering the federal public funding programs for presidential campaigns. This responsibility includes 

certifying and auditing all participating candidates and committees and enforcing the public funding laws.

Under the Act, all federal political committees, including the committees of presidential, Senate and 

House candidates, must file reports of receipts and disbursements. The FEC makes disclosure reports 

available to the public through the Commission’s Internet-based public disclosure system at www.fec.gov 

as well as through a public records office at the Commission's Washington, D.C. headquarters. The FEC 

also has exclusive responsibility for civil enforcement of the Act and has litigating authority independent 

of the Department of Justice in U.S. District Court and the Courts of Appeals. Additionally, the

Commission promulgates regulations implementing the Act and issues advisory opinions responding to 

inquiries. 

To accomplish its legislative mandate, the FEC is directed by six Commissioners, who are appointed by 

the President with the advice and consent of the Senate. By law, no more than three Commissioners may

be members of the same political party. Each member serves a six-year term, and two seats are subject to 

appointment every two years. Commissioners may serve beyond their six-year terms until new 

Commissioners are confirmed. The Chairmanship of the Commission rotates among the members, with 

no member serving as Chair more than once during a six-year term. The Commissioners are responsible 

for administering and enforcing the Act and meet regularly to formulate policy and to vote on significant 

legal and administrative matters. The Act requires at least four votes for the Commission to approve 

certain official actions, thus requiring bipartisan decision-making. The FEC has its headquarters in 

Washington, D.C. and does not have any regional offices. 
27

Figure 1: FEC Organizational Chart 

As noted in Figure 1 above, the offices of the Staff Director, General Counsel, Chief Information Officer 

and Chief Financial Officer support the agency in accomplishing its mission. The Office of the Inspector 

General, established within the FEC in 1989 under the 1988 amendments to the Inspector General Act, is 

independent and reports both to the Commissioners and to Congress. The specific roles and 

responsibilities of each office are described in greater detail immediately below.

 Office of the Staff Director (OSD)

The Office of the Staff Director consists of four offices: 1) Management and Administration; 2) 

Compliance; 3) Communications; and 4) Equal Employment Opportunity. The Office of Management 

and Administration is responsible for the FEC’s strategic planning and performance and works with the 

Commission to ensure the agency’s mission is met efficiently. In addition, this office houses the Office 

of the Commission Secretary, the Office of Human Resources (OHR) and the Administrative Services 

Division (ASD). The primary responsibilities of the Office of Compliance are making campaign finance 

reports and data available to the public, review of campaign finance reports, assistance with compliance, 

audits, administrative fines and alternative dispute resolution. The Office of Communications includes 

divisions charged with making enforcement, policy and other Commission documents, as well as 
28

presidential candidates’ personal financial disclosure reports, available to the public, encouraging 

voluntary compliance with the Act through educational outreach and training, and ensuring effective 

communication with Congress, executive branch agencies, states, the media and researchers, and the 

general public. The Equal Employment Opportunity Office administers and ensures compliance with 

applicable laws, regulations, policies and guidance that prohibit discrimination in the federal workplace 

based on race, color, national origin, religion, age, disability, sex, pregnancy, genetic information or 

retaliation. The EEO Director reports to the Staff Director on administrative issues but has direct reporting 

authority on all EEO matters. See 29 CFR 1614.102(b)(4). 

 Office of General Counsel (OGC)

The Office of General Counsel consists of five organizational units: (1) the Deputy General Counsel—

Administration; (2) the Deputy General Counsel—Law; (3) the Policy Division; (4) the Enforcement 

Division; and (5) the Litigation Division. The Deputy General Counsel—Administration directly 

supervises the Administrative Law Team, the Law Library and all OGC administrative functions. The 

Deputy General Counsel—Law has the primary responsibility for assisting the General Counsel in all of 

the substantive aspects of the General Counsel’s duties and shares in the management of all phases of 

OGC programs, as well as directly supervising the agency’s ethics program. The Policy Division drafts 

for Commission consideration advisory opinions and regulations interpreting the federal campaign finance 

law and provides legal advice to the FEC’s compliance programs. The Enforcement Division recommends 

to the Commission appropriate action to take with respect to administrative complaints and apparent 

violations of the Act. Where authorized, the Enforcement Division investigates alleged violations and 

negotiates conciliation agreements, which may include civil penalties and other remedies. If an 

enforcement matter is not resolved during the administrative process, the Commission may authorize suit 

in district court, at which point the matter is transferred to the Litigation Division. The Litigation Division 

represents the Commission before the Federal district and appellate courts in all civil litigation involving 

campaign finance statutes. This Division assists the Department of Justice’s Office of the Solicitor General 

when the Commission’s FECA cases are before the Supreme Court.

 Office of the Chief Information Officer (OCIO)

The Office of the Chief Information Officer (OCIO) consists of four units: (1) Enterprise Architecture; 

(2) Operational Support; (3) Data Administration; and (4) IT Security. The OCIO provides secure, stable 

and robust technology solutions for Commission staff and the public. OCIO both develops and maintains 

the systems that serve as the public's primary source of information about campaign finance data and law. 

OCIO ensures agency employees have access to the tools and technology platforms that allow them to 

perform their day-to-day responsibilities administering and enforcing campaign finance law. In addition, 

OCIO provides a vision and leads the implementation of projects to ensure the FEC continues to 

modernize strategic systems in order to support the significant growth in campaign finance transactions. 

 Office of the Chief Financial Officer (OCFO)

The Office of the Chief Financial Officer consists of three offices: (1) Budget; (2) Accounting; and (3) 

Procurement. The OCFO is responsible for complying with all financial management laws and standards, 

and all aspects of budget formulation, budget execution and procurement.
29

3C: Performance Framework

3C:1 Strategic Goal 

The strategic goal of the Federal Election Commission is to fairly, efficiently and effectively administer 

and enforce the Federal Election Campaign Act, promote compliance and engage and inform the public 

about campaign finance data and rules, while maintaining a workforce that delivers results.

3C:2 Plans and Progress by Strategic Objective 

The Act reflects a belief that democracy works best when voters can make informed decisions in the 

political process—decisions based in part on knowing the sources of financial support for federal 

candidates, political party committees and other political committees. As a result, the FEC’s first strategic 

objective is to inform the public about how federal campaigns and committees are financed. Public 

confidence in the political process also depends on the knowledge that participants in federal elections 

follow clear and well-defined rules and face consequences for non-compliance. Thus, the FEC’s second 

strategic objective focuses on the Commission’s efforts to promote voluntary compliance through 

educational outreach and to enforce campaign finance laws effectively and fairly. The third strategic 

objective is to interpret the FECA and related statutes, providing timely guidance to the public regarding 

the requirements of the law. The Commission also understands that organizational performance is driven 

by employee performance and that the agency cannot successfully achieve its mission without a highperforming workforce that understands expectations and delivers results. Consequently, the FEC’s fourth 

strategic objective is to foster a culture of high performance in order to ensure that the agency 

accomplishes its mission efficiently and effectively. The FEC’s strategies for reaching these objectives 

are outlined below. 

3C:2.1 Strategic Objective 1: Engage and Inform the Public about Campaign Finance Data 

Leaders: Assistant Staff Director for Reports Analysis Division; Assistant Staff Director for Public 

Disclosure and Media Relations Division and Deputy Chief Information Officer, Enterprise Architecture 

The FEC protects the integrity of federal campaigns by providing transparency and fairly enforcing and 

administering federal campaign finance laws. Full disclosure of the sources and amounts of campaign 

funds and fair enforcement of federal campaign finance laws allow the public to make informed decisions 

in the political process. Transparency requires that information is not only kept by the FEC, but also 

provided to the public in an easily accessible way. In order to make certain that campaign finance 

disclosure information is quickly available and easily accessible to the public, the agency has developed 

application programming interfaces (APIs) and other tools to improve access to campaign finance data. 

The agency is also committed to providing excellent customer service to help the public find and 

understand campaign finance information. The FEC gauges its effectiveness through a series of indicators 

designed to measure performance in areas that promote confidence in the campaign finance process, as 

detailed in the charts below. 
30

Strategies and Next Steps 

The FEC’s eFiling system acts as the point of entry for submission of electronically filed campaign finance 

reports, providing faster access to reports and streamlining operations. This system provides for public 

disclosure of electronically filed reports, via the FEC website, within minutes of being filed. When a 

committee files a financial disclosure report on paper, the Commission ensures that a copy is available for 

public inspection within 48 hours of receipt, both electronically on the website and at the FEC’s offices 

in Washington, D.C. The FEC is committed to providing timely and transparent campaign finance 

disclosure to the public and delivering data in accessible and easy-to-use formats. 

The number of financial transactions reported to the FEC has nearly doubled each election cycle for the 

past several election cycles through the 2020 cycle, resulting in a steep rise in the number of transactions 

that must be received, processed and made available to the public. This increase in reported activity places 

a strain on staff, systems and databases. For example, the number of financial transactions received during 

October 2020 alone was more than what was received during the entire 2016 election cycle. Each 

transaction must be received and processed by the FEC and made available to the public on the FEC 

website. This transaction-level data is also used by the FEC internally and supports much of the FEC’s 

mission-related work. 

The FEC understands it needs to modernize its disclosure data pipeline to receive, process, review and 

display the increasing volume of transaction-level data reported by political committees active in federal 

elections. Data pipelines are a set of automated methods and procedures that process raw data files 

received from filers into the primary campaign database for internal agency use and for public 

consumption on FEC.gov. They are essential to processing and reviewing campaign finance disclosure 

information in compliance with FECA’s mandates.

During FY 2023, the FEC will begin a multi-year project to improve and modernize its data pipeline. 

Much of the focus will be on improving the extract, transform and load (ETL) process. This is a threephase process where data is extracted from a source, transformed or standardized and loaded into a 

database table. The first milestone consists of four components: 1) refactoring ETL-2, 2) improving query 

performance, 3) changing database engines and 4) refactoring ETL-1. The FEC has two distinct ETL 

processes. ETL-1 processes reports and statements received from filers into our primary campaign finance 

database. ETL-1 adds data descriptions and ensures database tables used for reporting purposes have asamended data. ETL-2 moves data from our primary campaign finance database to our website and API 

database. ETL-2 produces aggregations used by the website and produces daily and weekly downloadable 

bulk data files for the public. 

The Commission is also improving and refining its website through iterative development, ensuring the 

FEC continues to provide an effective, user-centered online platform to deliver campaign finance 

information to its diverse base of users. This effort will ensure that the FEC provides full and meaningful 

campaign finance data and information in a manner that meets the public’s increasing expectations for 

data customization and ease of use. 

Performance measures and targets for assessing progress on this Strategic Objective include measures to 

ensure that data from campaign finance reports are quickly made available to the public and that the FEC 

pursues programs to make data more accessible to the public.
31

Progress Update for FY 2022 

The FEC continued its work to receive and make public campaign finance disclosure information. The 

FEC received 92,767campaign finance disclosure documents filed during FY 2022 disclosing over 206 

million transactions. Reports filed electronically are made available on the FEC website and may be 

downloaded by the public within minutes of submission. Reports filed on paper are scanned and made 

available on the FEC website within 48 hours of receipt. During FY 2022, the FEC ensured that 100 

percent of paper filed reports were made available to the public within two business days and that 100 

percent of independent expenditure filings were made available to the public within one business day. 

After reports are imaged for disclosure purposes, the information is coded and entered into the FEC’s 

database for review to assess accuracy and ensure complete disclosure of campaign finance information. 

The agency’s goal is to code and enter 95 percent of the reports within 30 days of receipt. In FY 2022 the 

agency processed 98 percent of reports within 30 days of receipt. 

Performance Goal 1-1: Improve the public’s access to information about how 

campaign funds are raised and spent.

Key Indicator: Percent of reports processed within 30 days of receipt.

FY 2017 

Actual

FY 2018 

Actual

FY 2019 

Actual

FY 2020 

Actual

FY 2021 

Actual

FY 2022 

Target

FY 2022 

Actual

FY 2023 

Target

FY 2024 

Target

96% 100% 94%19 98% 89%20 95% 98% 95% 95%

19 The agency’s ability to meet its target for this performance goal during FY 2019 was negatively impacted by the lapse 

in appropriations from December 22, 2018 to January 25, 2019.

20 The agency’s ability to meet its target for this performance goal during FY 2021 was negatively impacted by staff 

shortages and an unprecedented volume of filings received during the 2020 election cycle.
32

Supporting Indicators 1-1:

Measure Name FY 2017 

Actual

FY 2018 

Actual

FY 2019 

Actual

FY 2020 

Actual

FY 2021 

Actual

FY 2022 

Target

FY 2022 

Actual

FY 

2023 

Target

FY 2024 

Target

Percent of 

reports and 

statements filed 

on paper with 

the FEC made 

available on the 

FEC website 

within two 

business days of 

receipt

99% 99% 100% 100% 100% 100% 100% 100% 100%

Percent of 24-

and 48-hour 

reports on 

independent 

expenditure 

spending filed on 

paper made 

available on the 

FEC website 

within one 

business day of 

receipt

100% 100% 100% 100% 100% 100% 100% 100% 100%

Improve capacity 

to process 

campaign finance 

data

N/A N/A N/A N/A N/A Establish 

baseline 

Documente

d ETL-2; 

Average 

processing 

capacity for 

new reports, 

1 million 

transactions 

per hour; 

Average 

processing 

capacity for 

amendment

s, 600,000 

transactions 

per hour

Refactor 

ETL-2 

Improve 

query 

perform

ance to 

allow 

queries 

across 

more 

than two 

cycles

3C:2.2 Strategic Objective 2: Promote Compliance with the FECA and Related Statutes

Leaders: Deputy Staff Director/Chief Compliance Officer; General Counsel; Deputy General Counsel— 

Administration; Assistant Staff Director, Information Division 

Helping the public understand its obligations under the Act is an essential component of voluntary 

compliance. The FEC places a significant emphasis on encouraging compliance. The FEC measures its 

progress in meeting this Objective through two performance measures, discussed separately below. The 

first measures the agency’s efforts to encourage voluntary compliance through educational outreach and 
33

information and the second measures the FEC’s efforts to seek adherence to FECA requirements through 

fair, effective and timely enforcement and compliance programs. Progress against these measures and 

supporting indicators is detailed in the charts below. 

Strategies and Next Steps 

Encourage voluntary compliance with FECA requirements through educational outreach and 

information. 

The FEC’s education and outreach programs provide information necessary for compliance with 

campaign finance law and give the public the context necessary to interpret the campaign finance data 

filers disclose. The FEC maintains a toll-free line, public email accounts and a website portal to respond 

to inquiries regarding campaign finance data disclosed to the public and questions about how to comply 

with campaign finance law and its reporting requirements. 

One way the Commission encourages voluntary compliance is by hosting two-day conferences across the 

country, where Commissioners and staff explain how the Act applies to candidates, parties and political 

action committees (PACs). These conferences address recent changes in the law and focus on fundraising, 

methods of candidate support and reporting regulations. The agency supplements its conferences with a 

series of day-long webinars tailored specifically to candidates, parties and PACs, as well as periodic topicbased webinars and online discussions. These web-based events offer filers a convenient and costeffective way to receive training.

The FEC also devotes considerable resources to ensuring that staff can provide distance learning 

opportunities to the general public. The Commission’s website is one of the most important sources of 

instantly accessible information about the Act, Commission regulations and Commission proceedings. In 

addition to viewing campaign finance data, anyone with internet access can use the website to track 

Commission rulemakings, search advisory opinions, audits and closed enforcement matters, view 

campaign finance data, find reporting dates and access examples of how to report specific types of 

transactions. The Commission places a high emphasis on providing educational materials about campaign 

finance law and its requirements. Toward this end, the FEC has moved its focus away from the printing 

and manual distribution of its educational materials and instead looked for ways to leverage available 

technologies to create and disseminate dynamic and up-to-date educational materials through the website. 

While the Commission continues to offer printed copies of its educational publications, transitioning to 

primarily web-based media has allowed the agency to significantly reduce its printing, storage and mailing 

costs and use of resources while at the same time encouraging new and expanded ways of communicating 

with the public via the website.

As part of this broad effort to improve its internet communications and better serve the educational needs 

of the public, the Commission maintains its own YouTube channel, which can be found at 

https://www.youtube.com/FECTube. The YouTube channel offers a variety of instructional videos and 

tutorials that enable users to obtain guidance tailored to their specific activities. 

The agency’s educational outreach program has been significantly enhanced with the addition of an online 

training service that enables political committees, reporters, students and other groups to schedule live, 

interactive online training sessions with FEC staff. This on-demand service allows the FEC to provide 
34

tailored, distance learning presentations and training to the public in a manner that will significantly 

increase the availability of FEC staff to serve the public. The service also offers an efficient and effective 

way for alternative dispute resolution and other enforcement respondents to satisfy the terms of their 

agreements with the agency.

In addition, the Reports Analysis Division (RAD) Education Program (the Program) provides an informal, 

education-based means for resolving compliance issues. The goal of the program is to educate political 

committees on disclosure and compliance requirements to ensure future compliance with the Federal 

Election Campaign Act and Commission regulations. The Program provides eligible committees with an 

opportunity to participate in tailored training focused on the issues identified during the review of the 

committees’ reports and cited in Requests for Additional Information sent during the election cycle, in 

lieu of a referral for an audit. Further, committees that are not otherwise eligible for an audit referral, but 

that meet certain criteria, are invited to participate in the Program in order to prevent future compliance 

issues.

Seek adherence to FECA requirements through fair, effective and timely enforcement and compliance 

programs. 

The FEC has formed strategies for ensuring that its enforcement and compliance programs are fair, 

effective and timely. The Commission’s statutory obligation is to administer, interpret and enforce the 

Federal Election Campaign Act, which serves the compelling governmental interest in deterring 

corruption and the appearance of corruption in financing elections. In doing so, the Commission remains 

mindful of the First Amendment’s guarantees of freedom of speech and association, and the practical 

implication of its actions on the political process.

The FEC has exclusive jurisdiction over civil enforcement of Federal campaign finance laws. It consults 

with the U.S. Department of Justice, as appropriate, on matters involving both civil and criminal 

enforcement of the Act. Commission enforcement actions, which are handled primarily by the Office of 

General Counsel (OGC), originate from a number of sources, including external complaints, referrals from 

other government agencies and matters generated by information ascertained by the Commission in the 

normal course of carrying out its supervisory responsibilities. Enforcement matters are handled by OGC 

pursuant to the requirements of the FECA. If the Commission cannot settle or conciliate a matter involving 

an alleged violation of the Act, the Commission may initiate civil litigation by filing and prosecuting a 

civil action in Federal district court to address the alleged violation. Closed enforcement matters are 

available via the FEC website.

To augment OGC’s traditional enforcement role, the Office of Compliance manages several programs 

that seek to remedy alleged violations of the Act and encourage voluntary compliance. These programs 

include: 1) the Alternative Dispute Resolution Program, 2) the Administrative Fine Program and 3) the 

Audit Program. The Commission’s Alternative Dispute Resolution Program is designed to resolve matters 

more swiftly by encouraging the settlement of less-complex enforcement matters with a streamlined 

process that focuses on remedial measures for candidates and political committees, such as training, 

internal audits and hiring compliance staff. Violations involving the late submission of, or failure to file, 

disclosure reports are subject to the Administrative Fine Program. This Program is administered by the 

Reports Analysis Division (RAD) and the Office of Administrative Review (OAR), which assess 

monetary penalties and handle challenges to the penalty assessments. The Audit Program conducts “for 
35

cause” audits in those cases where political committees have failed to meet the threshold requirements for 

demonstrating substantial compliance with the Act, and conducts mandatory audits under the public 

funding statutes. Commission-approved threshold requirements used by RAD and the Audit Division are 

available via the FEC website, subject to limited redactions. 

The Office of Compliance’s Reports Analysis Division (RAD) reviews an ever-increasing volume of 

reports to track compliance with the law and to ensure that the public record provides a full and accurate 

representation of reported campaign finance activity. If the FEC’s review identifies an apparent violation 

or raises questions about the information disclosed on a report, RAD sends a request for additional 

information (RFAI letter) to the filer, affording an opportunity to take remedial action or correct the public 

record, if necessary. If the filer is able to resolve the FEC’s concerns, it may avoid an enforcement action. 

If not, the Commission has several tools available to it, such as the Administrative Fine Program, the 

Audit Program, the Alternative Dispute Resolution Program and the traditional enforcement program. 

The Alternative Dispute Resolution (ADR) Program was implemented in FY 2001 with the primary 

objective to enhance the agency’s overall effectiveness through more expeditious resolution of 

enforcement matters with fewer resources required to process complaints and internal referrals. A case is 

closed when the Commission votes on the recommendation made by the ADR Office as to what final 

action should be taken. 

In response to a legislative mandate, an Administrative Fine (AF) Program was implemented in July 2000 

to address late and non-filing of disclosure reports in a more efficient and effective manner. The AF 

Program is administered by RAD and Office of Administrative Review (OAR), which are within the 

Office of Compliance. 

The Commission generally conducts audits when a committee appears not to have met the threshold 

requirements for substantial compliance. The audit determines whether the committee complied with the 

limitations, prohibitions and disclosure requirements of the Act. In addition, the Commission is required 

by law to audit presidential campaigns that accept public funds. 

Progress Update for FY 2022 

Encourage voluntary compliance with FECA requirements through educational outreach and 

information. 

During FY 2022, the Commission continued to meet its mandate to assist the public by providing access 

to campaign finance compliance information. The Commission is deeply committed to providing 

candidates, committees and the public timely advice and support so they can fully understand and comply 

with the Act. The Commission also continues to strive to better understand and meet the needs of the 

public and other stakeholders. During FY 2022, the FEC produced a variety of instructional videos and 

web content and conducted online training workshops, including 21 fully remote webinars. Because of 

the pandemic, the Commission converted its planned regional conferences in Orlando and San Diego into 

all-virtual events, held exclusively online. Despite these challenges, the FEC again exceeded its customer 

service target for conferences and webinars, achieving an average attendee satisfaction rating of 4.55 on 

a five-point scale. 
36

Seek adherence to FECA requirements through fair, effective and timely enforcement and compliance 

programs. 

Reports Analysis Division

During FY 2022, RAD continued to ensure that campaigns and political committees file timely and 

accurate disclosure reports that fully disclose their financial activities. During the fiscal year, RAD 

reviewed 91,058 documents totaling 62.1 million pages. RAD continued to demonstrate its commitment 

to assisting filers with compliance, handling 11,919 phone calls and meetings, 1,334 electronic mail 

inquiries, developing reporting examples for the FEC website, and participating in several FEC 

conferences, seminars and webinars during FY 2022. In addition, the Reports Processing Branch 

demonstrated its commitment to providing the public with timely data, coding 59.2 million transactions 

during FY 2022.

Office of General Counsel

OGC continues to seek improvement in meeting its obligations to the Commission and the public to handle 

its caseload efficiently and effectively despite staffing challenges. In FY 2022, the Commission closed 

245 enforcement cases in an average of 811 days, which included $2,062,128 in negotiated civil penalties. 

The Commission closed 55 cases (22 percent) within 15 months. 

Alternative Dispute Resolution Office

The ADRO continued to promote compliance with Federal campaign finance law and Commission 

regulations and to reduce the cost of processing complaints by encouraging settlements outside the 

agency’s normal enforcement track. During FY 2022, the Commission completed 52 ADR cases, which 

included $252,650 in negotiated civil penalties. The Commission’s performance measure for ADR is to 

circulate 75 percent of cases to the Commission within 140 days of a case being referred. During fiscal 

year 2022, ADRO circulated 96 percent of recommendations within that timeframe. 
37

Administrative Fine Program

The Administrative Fine Program continues to successfully reduce the number of late and non-filed 

reports and encourage campaign finance transparency through the timely filing of campaign finance 

reports. During FY 2022, RAD processed 147 reason-to-believe recommendations for Commission 

consideration. RAD processed 100 percent of these recommendations within 60 days of the original due 

date of the untimely or not filed report. OAR reviewed 22 challenges submitted by committees in response 

to a reason-to-believe finding and/or civil money penalty. OAR reviewed 95 percent of these challenges 

within 60 days of receipt. Overall, OAR has reviewed 864 challenges submitted from the Program’s 

inception through FY 2022. 

Audit Division

The Audit Division continues to enforce the FECA through a Commission-approved audit process. The 

Commission’s performance goal is to complete 60 percent of audits within two years. During FY 2022, 

the Audit Division completed 10 audits, of which 40 percent were completed within the two-year 

performance goal period. During FY 2022 there were no requests received under the Request for Legal 

Consideration by the Commission program established in 2011 to allow for challenges to preliminary 

audit findings, and three requests for an Audit Hearing. 

Performance Goal 2-1: Encourage voluntary compliance with FECA requirements 

through educational outreach and information.

Key Indicator: Educational outreach programs and events achieve targeted satisfaction 

rating on user surveys.

FY 2017 

Actual

FY 2018 

Actual 

FY 2019 

Actual 

FY 

2020 

Actual 

FY 2021 

Actual 

FY 2022 

Target

FY 2022 

Actual

FY 2023 

Target

FY 2024 

Target

4.43 4.53 4.45 4.51 4.36 4.0 or higher 

on a 5.0 scale

4.55 4.0 or 

higher on a 

5.0 scale

4.0 or 

higher on a 

5.0 scale
38

Supporting Indicators 2-1:

Measure Name FY 2017 

Actual

FY 2018 

Actual

FY 2019 

Actual

FY 

2020 

Actual

FY 2021 

Actual

FY 2022 

Target

FY 2022 

Actual

FY 2023 

Target

FY 2024 

Target

Increase in the 

number of ELearning 

presentations 

available on the 

FEC website

6 new 

trainings

3 new 

trainings

9 new 

trainings

2 new 

trainings

4 new 

trainings

4 new 

trainings

2 new 

trainings

4 new 

trainings

4 new 

trainings

Performance Goal 2-2: Seek adherence to FECA requirements through fair, 

effective and timely enforcement and compliance programs.

Key Indicator: Of the enforcement matters resolved during the fiscal year, the 

percentage that was resolved within 15 months of the date of receipt.

FY 2017 

Actual

FY 2018 

Actual

FY 2019 

Actual

FY 2020 

Actual

FY 2021 

Actual

FY 2022 

Target

FY 2022 

Actual

FY 2023 

Target

FY 2024 

Target

68% 62% 56% 62% 34%21 50% 22%22 50% 50%

21 The agency’s performance under this measure was negatively impacted by the lack of a quorum for most of FY 

2020.

22 The agency’s performance under this measure was negatively impacted by the lack of a quorum for most of FY 

2020.
39

Supporting Indicators 2-2:

Measure Name FY 2017 

Actual

FY 2018 

Actual

FY 2019 

Actual

FY 

2020 

Actual

FY 2021 

Actual

FY 2022 

Target

FY 2022 

Actual

FY 

2023 

Target

FY 2024 

Target

Percent of 

notifications 

provided within 

five days of 

complaints filed 

with the FEC

100% 100% 100% 100% 100% 100% 100% 100% 100%

Percent of 

enforcement 

matters presented 

to the 

Commission for 

initial review 

within one year of 

the date of receipt

86% 84% 82% 81% 82% 80% 83% 80% 80%

Percent of RFAIs 

sent within 40 

days of report 

review

88% 88% 88% 86% 91% 75% 90% 75% 75%

Percent of reports 

reviewed by RAD 

within 90 days of 

receipt

77% 92% 76% 92% 85% 75% 93% 75% 75%

Percent of 

Proposed Final 

Audit Reports

(PFAR) approved 

by the 

Commission 

within two years 

from the start of 

fieldwork

25% 45% 100% N/A23 83% 60% 40%24 60% 60%

Percent of 

Reviewing Officer 

Recommendations

circulated within 

60 days

97% 100% 97% 100% 91% 75% 95% 75% 75%

Percent of 

ADRO 

Recommendations

circulated within 

140 days of 

referral

 78% 74% 70%25 100% 98% 75% 96% 75% 75%

23 The Audit Division was unable to obtain approval for any audit reports during FY 2020 because doing so requires the 

vote of the Commission, which lacked a quorum for approximately 11 months of the fiscal year.

24 The agency’s ability to meet its target for this performance goal during FY 2022 was negatively impacted by staffing 

shortages.

25 The agency’s ability to meet its target for this performance goal during FY 2019 was negatively impacted by the lapse 

in appropriations from December 22, 2018 to January 25, 2019.
40

3C:2.3 Strategic Objective 3: Interpret the FECA and Related Statutes

Leader: General Counsel; Deputy General Counsel— Administration 

Commission initiatives, Congressional action, judicial decisions, petitions for rulemaking or other 

changes in campaign finance law may necessitate that the Commission update or adopt new regulations. 

Consequently, the FEC undertakes rulemakings either to write new Commission regulations or revise 

existing regulations. The Commission also provides guidance on how the Act applies to specific situations 

through the advisory opinion process and represents itself in most litigation before the federal district and 

appellate courts. The Commission’s three primary means for providing interpretive guidance for the Act

and related statutes are discussed below.

Regulations 

The Policy Division of OGC drafts various rulemaking documents, including Notices of Proposed 

Rulemaking (NPRMs), for Commission consideration. NPRMs provide an opportunity for the public to 

review proposed regulations, submit written comments to the Commission and, when appropriate, testify 

at public hearings at the FEC. The Commission considers the comments and testimony and deliberates 

publicly regarding the adoption of the final regulations and the corresponding Explanations and 

Justifications, which provide the rationale and basis for the new or revised regulations. 

Advisory Opinions 

Advisory opinions (AO) are official Commission responses to questions regarding the application of 

Federal campaign finance law to specific factual situations. The Act generally requires the Commission 

to respond to AO requests within 60 days. For AO requests from candidates in the two months leading up 

to an election, the Act requires the Commission to respond within 20 days. On its own initiative, the 

Commission also makes available an expedited process for handling certain time-sensitive requests that 

are not otherwise entitled to expedited processing under the Act. The Commission strives to issue these 

advisory opinions in 30 days. 

Defending Challenges to the Act

The Commission represents itself in most litigation before the federal district and appellate courts and 

before the Supreme Court with respect to cases involving publicly financed presidential candidates. It also 

has primary responsibility for defending the Act and Commission regulations against court challenges. In 

addition, the Act authorizes the Commission to institute civil actions to enforce the Act. 

Strategies and Next Steps

The Office of General Counsel continues to focus on its processes to ensure that staff provides timely and 

well-written advice to the Commission so that it can meet its obligations to administer and enforce 

campaign finance law. The Commission considers it a high priority to ensure that guidance is provided 

through the advisory opinion process within the timeframes established by the Act. OGC continues to 

ensure that court filings meet all deadlines and rules imposed by the courts and has set as a performance 

target meeting 100 percent of these deadlines and rules. 
41

Progress Update for FY 2022 

During FY 2022, the Commission met its goal to issue 100 percent of advisory opinions within the 

applicable 60- or 20-day statutory deadlines. During FY 2022, the Commission completed work on 24 

AO requests and issued 23 opinions in response to those requests.

26 Twenty-two AO requests that the 

Commission completed in FY 2022 were 60-day AORs (ten of which received extended deadlines) and 

two were 20-day AORs (one of which received an extended deadline). The average number of days from 

receipt of a complete AO request to Commission action on it was 43 days for 60-day AORs that did not 

receive an extended deadline and 88 days for 60-day AORs that did receive an extended deadline.

27 The 

Commission also provided legal guidance within statutory and court-ordered deadlines 100 percent of the 

time.

. 

Performance Goal 3-1: Provide timely legal guidance to the public.

Key Indicator: Percent of legal guidance provided within statutory and courtordered deadlines.

FY 2017 

Actual

FY 2018 

Actual

FY 2019 

Actual

FY 2020 

Actual

FY 2021 

Actual

FY 2022 

Target

FY 2022 

Actual

FY 

2023 

Target

FY 2024 

Target

100%28 100%29 100%30 88%31 100%32 100% 100%33 100% 100%

26 In one advisory opinion request the Commission issued a closeout letter rather than an advisory opinion because a majority of 

Commissioners did not vote to approve a draft advisory opinion. 27 For the two 20-day AORs, one was completed within 16 days of receipt of a complete AO request and one received a brief extension 

and was completed within 22 days of receipt of a complete AO request. 28 The Commission obtained extensions to consider seven advisory opinion requests in FY 2017. 29 The Commission obtained an extension to consider one advisory opinion request in FY 2018. 30 The Commission obtained extensions to consider six advisory opinion requests in FY 2019; two of those extensions 

were lengthened by the partial Federal government shutdown during the first and second quarters of FY 2019.

31 This corrects the figure in the 2020 Agency Financial Report, which indicated that 100% of legal guidance was 

provided within statutory and court-ordered deadlines. The Agency Financial Report did not take into account one rulemaking 

that the Commission approved after the statutory deadline, due to the lack of a Commission quorum for most of FY 2020. The 

Commission approved the rulemaking—which adjusted for inflation civil monetary penalties—in July 2020, when a quorum 

was briefly restored. 

32 The Commission obtained extensions to consider five advisory opinion requests in FY 2021; one of those extensions 

was lengthened by the lack of a Commission quorum during the first quarter of FY 2021.

33 The Commission obtained extensions to consider eleven advisory opinion requests in FY 2022. 
42

Supporting Indicators 3-1: 

Measure 

Name 

FY 2017 

Actual

FY 2018 

Actual

FY 2019 

Actual

FY 2020 

Actual

FY 2021 

Actual

FY 2022 

Target

FY 2022 

Actual

FY 2023 

Target

FY 2024 

Target

Percent of 

advisory 

opinions 

issued within 

60-day and 

20-day 

statutory 

deadlines

100%34 100%35 100%36 100%37 100%38 100% 100%39 100% 100%

Percent of 

court filings 

that meet all 

deadlines and 

rules 

imposed by 

the courts

98% 99% 97% 98% 100% 100% 100% 100% 100%

34 The Commission obtained extensions to consider seven advisory opinion requests in FY 2017. 35 The Commission obtained an extension to consider one advisory opinion request in FY 2018. 36 The Commission obtained extensions to consider six advisory opinion requests in FY 2019; two of those extensions 

were lengthened by the partial Federal government shutdown during the first and second quarters of FY 2019.

37 Due to the lack of a quorum for most of FY 2020, the Commission sought extensions from all advisory opinion 

requestors. Two advisory opinion requestors declined to grant an extension and, once the deadline for responding to those 

requests expired, the Commission notified those requestors that it was unable to approve an advisory opinion by the required 

affirmative vote of four commissioners. 

38 The Commission obtained extensions to consider five advisory opinion requests in FY 2021; one of those extensions 

was lengthened by the lack of a Commission quorum during the first quarter of FY 2021.

39 The Commission obtained extensions to consider eleven advisory opinion requests in FY 2022.
43

3C:2.4 Strategic Objective 4: Foster a Culture of High Performance

Leaders: Deputy Staff Director for Management and Administration/Chief Human Capital Officer and 

Deputy Chief Information Officer, Enterprise Architecture

One of the objectives from the FEC’s Strategic Plan, FY 2022-2026, Foster a Culture of High 

Performance, cuts across the organization and reflects the agency’s strategic priorities for improving the 

efficiency and effectiveness of its workforce and management processes. The FEC’s primary measure of 

success in developing and maintaining a result-driven workforce is at the program level: a workforce that 

delivers results will meet the internal performance targets set by the Commission. Supporting targets and 

results are detailed in the charts below.

Strategies and Next Steps

The Commission understands that the success of its programs depends upon the skills and commitment of

its staff. To ensure the agency can recruit and retain the best talent in support of its mission, the agency 

will work to increase strategic outreach and recruitment efforts and to provide a fair, impartial, inclusive 

and accessible work environment. The FEC is also committed to continuously improving the performance 

of staff in support of the agency’s mission objectives. To ensure staff development opportunities and 

trainings are provided fairly, effectively and strategically in support of mission objectives, the FEC will 

work to develop and implement an agency-wide training program. 

In recent years, the FEC has been challenged to recruit and retain talent necessary to meet the agency’s 

workload and hiring goals. During FY 2022, the FEC identified additional strategic outreach platforms 

and partnerships to better ensure the agency’s hiring efforts reach out to diverse and highly talented 

potential employees. In addition, the FEC has continued work to ensure staff retention by providing a fair, 

impartial, inclusive and accessible work environment. 

Due to the COVID-19 pandemic and budget constraints, FEC spending on employee training was reduced 

during FY 2021. In FY 2022, the FEC began adjusting its spending to devote more resources to improve 

the skills base of the workforce, and the FEC intends to continue doing so in future fiscal years. However, 

with budget constraints continuing to affect the amount of funds that can be allocated to training, the FEC 

will focus on ensuring that mandatory training requirements are met first, along with training required to 

support activities that are deemed to be mission critical. The agency additionally maintains a robust online 

training library and encourages employees to use these resources to improve their skills. 

The FEC is undertaking a multi-year IT modernization project to reduce overall costs to maintain the 

FEC’s systems and data, improve services provided to the public and better ensure the security of the 

FEC’s networks, systems and data. Modernization and refactoring of the agency’s legacy applications, 

systems and data pipeline will help the FEC streamline the processing of information provided to the 

public while at the same time improve the systems and tools used by agency staff to provide services to 

the public and ensure compliance with the campaign finance law.

In FY 2018, the FEC completed the migration of its website and one of its campaign finance databases 

from a physical datacenter to a cloud environment, allowing the agency to shut down one of its physical 

datacenters. This migration effort allowed the agency to reduce its physical datacenter footprint by 25 
44

percent. 

During FY 2020, the FEC conducted a study of its remaining legacy systems to develop a cloud migration 

plan for these legacy applications and systems. The cloud migration plan developed during FY 2020 also 

included recommendations for migrating the FEC’s disaster recovery environment and the FEC’s primary 

campaign finance database to a cloud environment. 

During FY 2022, the FEC completed migrating legacy mission critical applications, systems and databases 

identified in the cloud migration plan. In FY 2023, the FEC will continue to migrate network and storage 

devices and shut down our physical, datacenter-based disaster recovery site. The agency is also focused 

on reducing the footprint of our on-premise data center and will continue these efforts.

In FY 2023, the agency will begin to modernize and refactor the legacy systems that now reside in the 

cloud to adopt a cloud-native architecture. This project will include modernizing the data pipeline to help 

improve the processing of data, as well as automating parts of the review process, that lend themselves to 

machine learning, based on review standards used by our Reports Analysis Division to check compliance 

with FECA. 

In addition, the Commission’s records management program continues to make advancements. FY 2023 

will bring continued focus on updating the agency’s Records Management Program and training staff on 

the agency and governmentwide records schedules, policies and responsibilities. 

Progress Update for FY 2022 

In accordance with the Transition to Electronic Records Memorandum, which superseded the Managing 

Government Records Presidential Directive as of June 28, 2019, the Commission has made progress 

toward the Memorandum’s goal of managing all permanent records in an electronic format with 

appropriate metadata by 2022. The Commission previously received approval from the Archivist of the 

United States for its National Archives and Records Administration (NARA) Form 1005 (NA-1005) 

Verification for Implementing GRS 6.1. This established the Commission’s agency-wide Email 

Management Policy via the Capstone approach. In support of that goal, the Commission has continued to 

develop the implementation of that policy. The Commission is still seeking approval of its January 2018 

request, pending with NARA, to electronically maintain all records associated with the Office of 

Alternative Dispute Resolution’s case files, as NARA seeks to finalize and formally add to its regulations 

digitization standards applicable to paper records that are ultimately digitized. Further, to conform with 

Executive Order 13556, the Commission is also developing a Directive on Controlled Unclassified 

Information, which will develop a program to manage information that is not classified for national 

security purposes but nevertheless requires safeguarding or dissemination controls. 

The FEC began implementation of the FY 2020 cloud migration study’s recommendations in FY 2021 

and has completed the migration of its primary campaign finance database. It has also set a performance 

target to complete the migration of the legacy applications identified in the cloud migration plan during 

FY 2023 and start refactoring (or modernizing) the legacy system and processes to take advantage of 

cloud-native architecture. Migrating these legacy applications from physical datacenters to a cloud 

environment will reduce future costs for hosting these applications and lower costs for maintaining legacy 

systems in the FEC’s physical datacenters over time.
45

Performance Goal 4-1: Foster a workforce that delivers results.

Key Indicator: Commission-required quarterly updates meet targeted performance 

goals.

FY 2017 

Actual

FY 2018 

Actual

FY 2019 

Actual

FY 2020 

Actual

FY 2021 

Actual

FY 2022 

Target

FY 2022 

Actual

FY 2023 

Target

FY 2024 

Target

85% 73% 53%40 73%41 87%42 65% 87%43 65% 65%

40 The agency’s ability to meet its target for this performance goal during FY 2019 was negatively impacted by the lapse 

in appropriations from December 22, 2018 to January 25, 2019.

41 The agency’s performance under this measure was negatively impacted by the lack of a quorum for most of FY 2020. 42 The agency’s ability to meet its target for this performance goal during FY 2021 was negatively impacted by staff 

shortages and an unprecedented volume of filings received during the 2020 election cycle.

43 The agency’s ability to meet its target for this performance goal during FY 2022 was negatively impacted by the lack 

of a quorum for most of 2020 and staffing shortages during FY 2022.
46

Supporting Indicators 4-1:

Measure 

Name 

FY 2017 

Actual

FY 

2018 

Actual

FY 

2019 

Actual

FY 

2020 

Actual

FY 2021 

Actual

FY 2022 

Target

FY 2022 

Actual

FY 

2023 

Target

FY 2024 

Target

Develop and 

implement 

an agencywide training 

program

N/A N/A N/A N/A N/A Evaluate 

current 

program 

and 

develop 

initial 

recomme

ndations

Began 

reviewing 

current 

program and 

developing 

evaluation 

plan

N/A N/A

Increase 

strategic 

outreach and 

recruitment 

efforts to 

ensure the 

FEC 

continues to 

attract and 

retain a 

diverse and 

highperforming 

workforce

N/A N/A N/A N/A N/A Evaluate 

current 

program 

and 

develop 

initial 

recomme

ndations

Evaluated 

current 

recruitment 

program and 

conducted 

in-depth 

assessment 

of piloted 

expanded 

workplace 

flexibilities. 

Developing 

limited initial 

recommenda

tions based 

on budget 

constraints.

N/A N/A

Meet 

Records 

Management 

Presidential 

Directive 

milestones 

70% 73% 76% 80% 81% As 

specified 

in Presidential 

Directive

82% of 

milestones 

met 

As 

specifie

d in 

Presidential 

Directiv

e

As 

specified 

in Presidential 

Directive

Reduce 

reliance on 

physical data 

centers

N/A 100% N/A N/A N/A N/A N/A 100% of 

targeted 

applicati

ons 

migrate

d to 

cloud

Reduce 

reliance 

on 

physical 

data 

centers 

60% 
47

3D: Implementation Factors

3D:1 Major Management Priorities, Challenges and Risks 

The FEC identified in the agency’s FY 2022-2026 Strategic Plan a management objective, Foster a Culture 

of High Performance, that sets out strategies and measures designed to help the agency deliver greater 

impact through innovation, increase effectiveness and efficiency, and improve service. Detailed 

information about this Strategic Objective is available in section 3C:2.4, above. In addition, the 

Commission has identified management initiatives as strategic activities in the strategic plan to support 

its mission objectives where those activities are deemed crucial to the success of the objective. 

The FEC continues to confront a heavy workload and is working to rebuild its staffing levels. Over the 

past decade, the FEC has been able to meet its statutory mission primarily due to efficiencies gained by 

reassigning staff using details, maximizing operational efficiencies through reorganizations, and 

improving technology and processes, among other efficiencies. However, in recent years the FEC has 

begun to exhaust the benefits that can be gained through such efficiencies and has, in some situations, 

reduced performance targets in response to these reductions in staffing amid increasing campaign finance 

activity. 

The FEC had 293 employees as of September 30, 2022. As shown on the chart below, the FEC’s 

employment level has contracted substantially during the recent past. During the period FY 2012 to FY 

2022, the number of FEC employees has been reduced by approximately 17 percent. 
48

FEC Total Staffing Levels FY 2012 – FY 2022 

295

300

305

310

315

320

325

330

335

340

345

350

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022

FEC Actual FTE FY 2010 to FY 2022

*Figures are from Actual Column of the President’s Budget Appendix. 

At the same time, the FEC’s workload has continued to increase with the increase in campaign finance 

activity. The table below shows Total Reported Receipts and Disbursements for the period 2012 through 

2020, the most recent complete election cycle. (Note that presidential election cycles show increased 

spending compared to nonpresidential election cycles.) 

Total Reported Receipts and Disbursements by Election Cycle44

Election Cycle Total Receipts Total Disbursements

2012 $8,884,594,132 $8,795,764,278

2014 $5,976,582,396 $5,815,419,284

2016 $10,926,836,244 $10,729,954,205

2018 $10,333,084,467 $10,010,442,497

2020 $27,920,326,860 $27,179,563,157

2022 $16,749,759,126 $16,613,818,671

During FY 2022 the FEC partnered with the Office of Personnel Management’s HR Solutions to improve 

44 The data in the chart are the reported total receipts and disbursements. Reported contributions and expenditures would 

be a subset of receipts and disbursements. 
49

the FEC’s staffing, classification and performance management processes. Goals for the FEC’s human 

capital management processes are detailed in section 3C:2.4. 

Each year the FEC’s Inspector General (IG) is required to provide a summary and assessment of the most 

serious management and performance challenges facing the FEC. In a memorandum dated October 26, 

2022, the IG identified five challenge facing management: 

• Growth of campaign spending 

• Identifying and regulating unlawful foreign contributions 

• Continuity of Operations 

• Human Capital Management 

• Cybersecurity

The IG’s assessment and the FEC’s response are included in the FEC’s FY 2022 Agency Financial Report, 

available on the FEC website at https://www.fec.gov/resources/cmscontent/documents/FEC_FY_2022_Agency_Financial_Report_Final_11_15_22.pdf. 

3D:2 Data Validation and Verification

OMB Circular A-136, as revised, and the GPRA Modernization Act of 2010 (GPRAMA) require each 

agency to describe the accuracy and reliability of the data used to measure progress toward its performance 

goals, including an identification of the means used to verify and validate the measured values and the 

source for the data. Agencies are encouraged to determine the appropriate frequency of data validation 

and verification (V&V) needed for the intended use and should allocate appropriate resources to carry out 

validation and verification on an appropriately periodic basis. 

Many of the FEC’s performance measures set goals for the timely completion of tasks that are either 

internally generated or triggered through requests, reports or complaints filed with the Commission. As a 

result, the universe of data the FEC must collect and verify to support its performance information is 

generally small, centrally located and easily verified. The FEC tracks data to support its performance 

measures through its internal databases and with spreadsheets maintained by program managers. In cases 

where performance is measured based on the timeframe for completing a decision, matter or inquiry, the 

universe of data to be measured and the dates on which performance milestones are reached are tracked 

electronically. Data provided by the agency’s litigation, policy, enforcement and compliance offices are 

reported at least quarterly to the Commission, which provides regular opportunities for the accuracy of 

the data to be verified. 

The FEC also tracks its performance in making campaign finance information available to the public. 

Reports filed with the FEC represent the largest universe of data the agency must consider in determining 

its performance. Campaign finance reports and statements filed electronically are made available on the 

FEC website nearly instantaneously, and reports and statements filed on paper with the FEC are placed 

on the FEC website within 48-hours of receipt. In addition, FEC staff process the data contained in 

campaign finance reports so that the information can be accurately organized, categorized and searched 

in the agency’s databases. The FEC sets as a performance goal processing 95 percent of reports through 

its data and coding system within 30 days. The entry and completion dates for each report are retrievable 

through the FEC’s electronic systems. 
50

The FEC has completed a broad review of its methods for verifying and validating performance as part of 

its overall assessment of its strategic and performance plans. The FEC has identified senior-level staff and 

key managers to serve as goal leaders for each area of the strategic and performance plans. In addition, 

each strategic activity in the Strategic Plan has been assigned one or more program managers, who are 

responsible for the delivery and performance reporting of that activity. These managers will be serving as 

measure managers and data quality leads to ensure the completeness, consistency and accuracy of the 

reported data of their respective strategic activity. 

3E: Conclusion 

As described in this section, the FEC’s plans and strategies for FYs 2023 and 2024 are designed to ensure 

that the agency is well-prepared to provide full campaign finance transparency to the public despite the 

expected increase in campaign finance activity.

 
51

Office of Inspector General’s Fiscal Year 2024 Budget Request

The Inspector General Reform Act (Pub. L. 110-409) was signed by the President on 

October 14, 2008. Section 6(f)(1) of the Inspector General Act of 1978, 5 U.S.C. app., was amended to 

require certain specifications concerning Office of Inspector General (OIG) budget submissions each fiscal 

year.

Each Inspector General (IG) is required to transmit a budget request to the head of the establishment or 

designated Federal entity to which the IG reports specifying: 

• the aggregate amount of funds requested for the operations of the OIG; 

• the portion of this amount requested for OIG training, including a certification from the IG 

that the amount requested satisfies all OIG training requirements for that fiscal year; and

• the portion of this amount necessary to support the Council of the Inspectors General on 

Integrity and Efficiency (CIGIE).

The head of each establishment or designated Federal entity, in transmitting a proposed budget to the 

President for approval, shall include:

• an aggregate request for the OIG;

• the portion of this aggregate request for OIG training; 

• the portion of this aggregate request for support of the CIGIE; and 

• any comments of the affected IG with respect to the proposal. 

The President shall include in each budget of the U.S. Government submitted to Congress: 

• a separate statement of the budget estimate submitted by each IG;

• the amount requested by the President for each OIG;

• the amount requested by the President for training of OIGs; 

• the amount requested by the President for support of the CIGIE; and 

• any comments of the affected IG with respect to the proposal if the IG concludes that the budget

submitted by the President would substantially inhibit the IG from performing the duties of the OIG. 

Accordingly, the FEC OIG requests an earmark within the FEC’s budget appropriation of not less 

than $2,139,053 for fiscal year 2024, to include: 

• $2,139,053 in the aggregate for the operations of the OIG; 

• $40,000 of that amount for OIG training; and 

• $7,961 of that amount to support the CIGIE. 

I, Christopher L. Skinner, certify as the IG of the Federal Election Commission that the amount I have 

requested for training satisfies all OIG training requirements for fiscal year 2024.
52 

OIG Summary of Outstanding FEC Audit Recommendations 

45 The OIG notes six additional recommendations from one audit, one special review, and one evaluation that are less 

than one year old from the date of this submission, resulting in a total of 12 open recommendations to date.

OIG Audits/Inspections 

Reviews/Investigations 

Total 

Recommendations 

Total Closed Total Open as of 

Feb 2023

Inspection of the FEC’s Disaster 

Recovery Plan and Continuity of 

Operations Plans 

10 years outstanding

3 1 2 

I21INV00037: Investigation into 

Allegations of Bias Against FEC Personnel 

Reviewing 58th Presidential Inaugural 

Committee Reports 

1.5 years outstanding

5 1 4 

Total Outstanding Recommendations 645

The Good Accounting Obligation in Government Act requires each agency to include, in its annual 

budget justification, a report that identifies each public recommendation issued by the agency's 

inspectors general (IGs) which has remained unimplemented for one year or more from the annual 

budget justification submission date. Accordingly, the OIG reports a total of 4 open recommendations 

with the FY24 budget justification.