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THE COMBINED FEDERAL CAMPAIGN: MAKING 

EVERY DOLLAR COUNT 

HEARING 

BEFORE THE

SUBCOMMITTEE ON FEDERAL WORKFORCE, 

US POSTAL SERVICE AND THE CENSUS 

OF THE

COMMITTEE ON OVERSIGHT 

AND GOVERNMENT REFORM 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED THIRTEENTH CONGRESS 

FIRST SESSION 

JULY 10, 2013 

Serial No. 113–42 

Printed for the use of the Committee on Oversight and Government Reform 

( 

Available via the World Wide Web: http://www.fdsys.gov 

http://www.house.gov/reform 

(II) 

COMMITTEE ON OVERSIGHT AND GOVERNMENT REFORM 

DARRELL E. ISSA, California, Chairman 

JOHN L. MICA, Florida 

MICHAEL R. TURNER, Ohio 

JOHN J. DUNCAN, JR., Tennessee 

PATRICK T. MCHENRY, North Carolina 

JIM JORDAN, Ohio 

JASON CHAFFETZ, Utah 

TIM WALBERG, Michigan 

JAMES LANKFORD, Oklahoma 

JUSTIN AMASH, Michigan 

PAUL A. GOSAR, Arizona 

PATRICK MEEHAN, Pennsylvania 

SCOTT DESJARLAIS, Tennessee 

TREY GOWDY, South Carolina 

BLAKE FARENTHOLD, Texas 

DOC HASTINGS, Washington 

CYNTHIA M. LUMMIS, Wyoming 

ROB WOODALL, Georgia 

THOMAS MASSIE, Kentucky 

DOUG COLLINS, Georgia 

MARK MEADOWS, North Carolina 

KERRY L. BENTIVOLIO, Michigan 

RON DESANTIS, Florida 

ELIJAH E. CUMMINGS, Maryland, Ranking 

Minority Member 

CAROLYN B. MALONEY, New York 

ELEANOR HOLMES NORTON, District of 

Columbia 

JOHN F. TIERNEY, Massachusetts 

WM. LACY CLAY, Missouri 

STEPHEN F. LYNCH, Massachusetts 

JIM COOPER, Tennessee 

GERALD E. CONNOLLY, Virginia 

JACKIE SPEIER, California 

MATTHEW A. CARTWRIGHT, Pennsylvania 

MARK POCAN, Wisconsin 

TAMMY DUCKWORTH, Illinois 

ROBIN L. KELLY, Illinois 

DANNY K. DAVIS, Illinois 

TONY CARDENAS, California 

STEVEN A. HORSFORD, Nevada 

MICHELLE LUJAN GRISHAM, New Mexico 

LAWRENCE J. BRADY, Staff Director 

JOHN D. CUADERES, Deputy Staff Director 

STEPHEN CASTOR, General Counsel 

LINDA A. GOOD, Chief Clerk 

DAVID RAPALLO, Minority Staff Director 

SUBCOMMITTEE ON FEDERAL WORKFORCE, U.S. POSTAL SERVICE AND THE CENSUS

BLAKE FARENTHOLD, Texas, Chairman 

TIM WALBERG, Michigan 

TREY GOWDY, South Carolina 

DOUG COLLINS, Georgia 

RON DESANTIS, Florida 

STEPHEN F. LYNCH, Massachusetts, 

Ranking Minority Member 

ELEANOR HOLMES NORTON, District of 

Columbia 

WM. LACY CLAY, Missouri 

(III) 

C O N T E N T S 

Page 

Hearing held on July 10, 2013 ............................................................................... 1 

WITNESSES 

The Hon. Dave Reichert, A Representative in The United States Congress 

from the State of Washington 

Oral Statement ................................................................................................. 4 

Written Statement ............................................................................................ 6 

Mr. Mark Lambert, Associate Director for Merit System Accountability and 

Compliance, U.S. Office of Personnel Management 

Oral Statement ................................................................................................. 9 

Written Statement ............................................................................................ 12 

Ms. Ju ́Coby Pittman, President and CEO, Clara White Mission 

Oral Statement ................................................................................................. 17 

Written Statement ............................................................................................ 19 

Mr. Kalman Stein, President and CEO, Earthshare 

Oral Statement ................................................................................................. 23 

Written Statement ............................................................................................ 26 

Ms. Debby Hampton, President and CEO, United Way of Central Oklahoma 

Oral Statement ................................................................................................. 41 

Written Statement ............................................................................................ 43 

Mr. Ken Berger, President and CEO, Charity Navigator 

Oral Statement ................................................................................................. 48 

Written Statement ............................................................................................ 50 

(1) 

THE COMBINED FEDERAL CAMPAIGN: 

MAKING EVERY DOLLAR COUNT 

Wednesday, July 10, 2013, 

HOUSE OF REPRESENTATIVES, 

SUBCOMMITTEE ON FEDERAL WORKFORCE, POSTAL

SERVICE AND THE CENSUS, 

COMMITTEE ON OVERSIGHT AND GOVERNMENT REFORM, 

Washington, D.C. 

The subcommittee met, pursuant to call, at 1:03 p.m., in Room 

2154, Rayburn House Office Building, Hon. Blake Farenthold 

[chairman of the subcommittee], presiding. 

Present: Representatives Farenthold, Walberg, Gowdy, Lynch, 

Speier and Davis. 

Staff Present: Alexia Ardolina, Majority Assistant Clerk; Molly 

Boyl, Majority Parliamentarian; Daniel Bucheli, Majority Assistant 

Clerk; Caitlin Carroll, Majority Deputy Press Secretary; Adam P. 

Fromm, Majority Director of Member Services and Committee Operations; Linda Good, Majority Chief Clerk; Jennifer Hemingway, 

Majority Deputy Policy Director; Laura L. Rush, Majority Deputy 

Chief Clerk; Scott Schmidt, Majority Deputy Director of Digital 

Strategy; Lena Chang, Minority Counsel; Devon Hill, Minority Research Assistant; Safiya Simmons, Minority Press Secretary, Mark 

Stephenson, Minority Director of Legislation. 

Mr. FARENTHOLD. Good afternoon. We actually kind of have a 

tight schedule today. There are scheduled votes in the House of 

Representatives at 2:00 o’clock, and we would like to try to finish 

earlier rather than asking our witnesses and folks to stick around 

for what will probably be a very lengthy series of votes. I realize 

I am the only one here at this point, but in order to keep us moving 

ahead, I am going to go ahead and call the subcommittee to order, 

read my opening statement. Hopefully by that time minority members will be here. If not, we will address that issue when we come 

to it. 

So the subcommittee will come to order. As is normal, we will 

begin the hearing by reading the Oversight Committee’s mission 

statement. We exist to secure two fundamental principles. First, 

Americans have a right to know the money Washington takes from 

them is well spent. Second, Americans deserve an efficient, effective government that works for them. Our duty on the Oversight 

and Government Reform Committee is to protect these rights. 

Our solemn responsibility is to hold the government accountable 

to taxpayers, because taxpayers have a right to know what they get 

from their government. We will work tirelessly in partnership with 

citizen watchdogs to deliver the facts to the American people and 

2 

bring genuine reform to the Federal bureaucracy. This is the mission of the Oversight and Government Reform Committee. 

Thank you for being here. 

Today we are going to talk about the Combined Federal Campaign: Making Every Dollar Count. Through the Combined Federal 

Campaign, Federal workers have donated more than $7 billion to 

thousands of local and national charitable organizations. The CFC 

has marked its 50th anniversary with a commission designed to ensure the campaign’s long-term viability. In the midst of the anniversary, the Inspector General released a troubling report demonstrating how donations could have been put to a better use. 

With giving at an all-time low, it is clear that some changes need 

to be made to bring workers back into the fold and bring them back 

to donating. While I commend the OPM for moving quickly to address the concerns by the IG, banning food and entertainment paid 

for with charitable donations is one example, I am troubled by several aspects of the agency’s proposed regulations. Its regulations 

lack specificity, yet propose substantial untested changes to the administration of CFC, the financing of the campaign and the operation of the CFC federations. 

A number of the proposed changes move well beyond the recommendations of the commission. For example, the commission recommended OPM encourage the use of online giving, yet OPM proposes to eliminate paper donations. Past experience shows the absence of flexible giving options can result in a significant decline 

in donations. For example, the DC1 fund saw a 79 percent decrease 

in donations when it shifted to a web-only based campaign. Since 

it has returned back to a model that allows both paper and online 

contributions. 

The regulations also propose to reduce the local connection between the hallmark of the programs. OPM describes this change as 

part of its efforts to streamline the campaign. However, OPM’s history with managing large projects, from the failed redesign of the 

USAJOBS to millions wasted on the failed upgrade of the paperbased retirement claims system, does not inspire confidence. Moreover, I question why OPM would eliminate the opportunity for Federal employees to connect at the local level. This seems the logical 

way to increase giving. When it comes to donations, it always helps 

when the ‘‘ask’’ comes from a friend. 

The committee has heard concerns from many, from postal workers to charity watchdogs. I hope today’s hearing will help participants better understand the impact of OPM’s proposal and will 

lead to sensible changes that better support those who choose to 

donate. 

I thank the witnesses for their participation. We will now to go 

Ms. Speier who will deliver an opening statement. Is it yours or 

Mr. Lynch’s or both? 

Ms. SPEIER. I am just the oracle through which Mr. Lynch’s 

statement will be read. 

Thank you, Mr. Chairman, for holding this hearing to review the 

operations of the Combined Federal Campaign and evaluate OPM’s 

proposed changes to CFC regulations. 

The CFC is the largest workplace giving campaign in the world. 

Federal employees, military personnel and postal workers generVerDate Aug 31 2005 14:15 Jul 30, 2013 Jkt 000000 PO 00000 Frm 00006 Fmt 6633 Sfmt 6633 C:\DOCS\82140.TXT APRIL
3 

ously donate a portion of their hard-earned dollars to help people 

and local communities in need. Since the CFC’s establishment in 

1961, our Federal workforce and uniformed service members have 

contributed nearly $7 billion to charities that have helped men, 

women and children in need. Their generosity has continued even 

in the face of a challenging budget climate, a Federal pay freeze 

since 2011, sequestration, layoffs, buyouts, furloughs and legislation targeting their pay and benefits. 

As a result, it is understandable that contributions to the CFC 

have fallen from a high of $282.6 million in 2009 to $258.3 million 

in 2012. 

However, despite these difficulties, our Federal Government civilian and military personnel have donated more than $250 million 

each year since 2004 to help those who are less fortunate. As the 

Administrator of the CFC, OPM has an important responsibility to 

ensure that every dollar that is donated by our Federal workers is 

effectively used to help the individuals who need it. 

I want to thank OPM for creating the CFC 50 Commission to ensure the continued growth and success of this vital program. I fully 

support the commission’s goals of increasing the CFC’s accessibility, accountability, transparency and affordability. I believe in 

the need to increase accountability, strengthen program integrity 

and improve the quality and consistency of local campaigns. 

Last March, the OPM Inspector General found that the campaign 

administrator improperly charged over $300,000 in campaign expenses and should have used $764,000 in campaign funds more effectively. We must vigilantly prevent waste and abuse of donor contributions. 

I appreciate OPM’s commitment to make the CFC more efficient 

and effective, and I appreciate the agency’s efforts to follow 

through on some of the commission’s recommendations. Many charities, donors and watchdog organizations, including the witnesses 

here today, support proposed changes to the CFC program. 

But they also have concerns about a number of proposed 

changes. I understand that OPM is still in the process of reviewing 

the public comments received on the proposed rule. This hearing 

presents a good opportunity to hear from OPM, charities, donors 

and watchdog organizations about their views on the proposed rule. 

It is important that we have a conversation about whether, for 

example, CFC’s fund-raising structure should be centralized, 

whether the paper pledges, charity lists and donations should be 

eliminated, and whether charities should be charged non-refundable application fees. Making a good thing better is what should 

unite all of us here today. 

Thank you, Mr. Chairman, and I look forward to the hearing and 

the testimony from our witnesses. 

Mr. FARENTHOLD. Thank you very much, and again, we will get 

underway. Our first witness is Congressman Dave Reichert. He 

represents Washington’s Eighth Congressional District. Mr. 

Reichert, you are recognized. 

4 

STATEMENT OF THE HONORABLE DAVE REICHERT, A REPRESENTATIVE IN THE UNITED STATES CONGRESS FROM 

THE STATE OF WASHINGTON 

Mr. REICHERT. Thank you, Mr. Chairman, and also thank you to 

the members of the committee for inviting me here today. 

I am here because this is something I am very passionate about. 

I will share a couple of stories with you in a moment. 

But I first want to say that as a member of Congress, I can tell 

you that many of the programs, of course, that our government 

runs don’t work. I think we all recognize that. As a former chair 

of the King County Employee Charitable Campaign in Washington, 

which is King County’s version of CFC, I can tell you that the Combined and Federal Campaign is one of those programs that we got 

right. That is why I have continued to participate as a member of 

Congress. 

So first I would like to share some of my history with CFC, then 

I would like to share why I am concerned about OPM’s proposed 

changes. The CFC has given me the opportunity to donate to 

causes like the Special Olympics and the Pediatric Interim Care 

Center in Seattle, Washington. 

Now, the Pediatric Interim Care Center is a very special place. 

It is filled with little babies. Those babies are born in surrounding 

hospitals in the Seattle area. They are born drug-addicted. The 

hospitals don’t have the ability to take care of those little babies. 

So they are taken to the Pediatric Interim Care Center in Kent. 

I happen to have been involved as a detective in a case that took 

19 years to solve, the Green River Serial Murder case. One of the 

victims’ daughters in that case born as a drug baby, was one of the 

first babies taken into that organization. I wrote a book called 

Chasing the Devil. All the proceeds from that book, through CFC, 

went to the Pediatric Interim Care Center. I continue to support 

them today. What a wonderful cause, to make sure that our babies 

have a home. 

Two of my grandchildren are adopted from the Pediatric Interim 

Care Center, one a meth-addicted baby, the other a crack cocaine 

and heroin-addicted baby. 

As the former chair of the King County Washington Employees 

Campaign, I saw first-hand the benefits that the CFC and its current structure of local control and support had on our community. 

I also know what it takes to found a non-profit, and have approved 

to be a part of the CFC. So when I was a detective, my partner 

was shot and killed in the line of duty. We organized a non-profit 

organization around him and his family. That organization still exists today. I was the co-founder of that organization, put together 

the organization. Took a year or more to become a 501(c)(3), met 

individually at every precinct, 1,100 employees, to gain their support at the personal level with all those other folks that work with 

the CFC in King County. Finally, we became a part of their choices 

where people could say, I want to give to the Sheriff Fund, to help 

support those families that have lost a loved one in the line of duty, 

that have been killed in the line of duty. 

So those are two special stories to me. That is why I am so passionate about this. I have two grandkids that are drug-addicted baVerDate Aug 31 2005 14:15 Jul 30, 2013 Jkt 000000 PO 00000 Frm 00008 Fmt 6633 Sfmt 6633 C:\DOCS\82140.TXT APRIL
5 

bies, I lost my partner, who was shot and killed. And these charities helped those families. 

Why I am here today and what concerns me is that the Office 

of Personnel Management has proposed wholesale changes to the 

regulations governing the Combined Federal Campaign. While I 

say that these changes are based on a report produced by the CFC 

50 Commission, most of the proposed changes were never discussed 

in the hearings leading up to the report, or even mentioned in the 

report’s final text. 

The two proposed regulations that concern me the most are 

OPM’s plans to replace the local volunteer campaign structure with 

a centralized Washington, D.C. campaign. The new structure would 

be managed centrally by OPM and the volunteer local Federal coordinated committees that have successfully conducted the campaigns for decades will be eliminated. OPM would have exclusive 

control in establishing each region. 

I believe that removing local control over campaign administration will alienate donors in smaller communities by making them 

think that they are just giving their hard-earned dollars away to 

a bureaucracy in Washington, D.C. 

OPM further proposes to eliminate local operation of the campaigns through the establishment of central campaign administrators. This seems impractical and unwise and will only add to the 

Federal workforce and remove the campaign from the enthusiasm 

of local Federal agencies and staff. 

I am also concerned about the proposed non-refundable charity 

application fee. This could have the unintended consequence of 

causing smaller, more local charities to leave CFC. In my experience, these changes, taking away local control and operation, would 

take away the attributes that make the CFC so successful. The fact 

that local people know that they are giving to a locally-administered campaign benefitting local charities, helping local people, ultimately my concern is that these changes would result in fewer 

CFC participants and donations. 

In these times of need, these charities cannot afford fewer donations. I thank you again for the opportunity. 

[Prepared statement of Mr. Reichert follows:] 

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Mr. FARENTHOLD. Thank you very much. As is normal procedure 

of this committee, we typically do not have follow-up questions to 

members of Congress. In your case, Congressman, it is not necessary, I think you hit all the salient points I probably would have 

talked about anyway. 

So we will now take a very short recess again as we are trying 

to get as much of this done as possible before votes, to reset and 

make room for our next panel. We will reconvene as soon as the 

setup is completed and the next panel is seated, probably two minutes. 

Thank you very much, Congressman. 

In less than two minutes we have the next panel seated, in 

record time. I appreciate your promptness. 

We will now recognize our second panel, Mr. Mark Lambert, the 

Associate Director for Merit System Accountability and Compliance 

at the U.S. Office of Personnel Management. Ms. Ju ́Coby Pittman 

is President and CEO of the Clara White Mission in Jacksonville, 

Florida. Mr. Kal Stein is President and CEO of EarthShare. Ms. 

Debby Hampton is President and CEO of the United Way of Central Oklahoma. And Mr. Ken Berger is President and CEO of Charity Navigator. 

Pursuant to committee rules, all witnesses will be sworn in before they testify. Would you please rise and raise your right hand? 

Do you solemnly swear or affirm that the testimony you are 

about to give will be the truth, the whole truth and nothing but 

the truth? 

[Witnesses respond in the affirmative.] 

Mr. FARENTHOLD. Let the record reflect that all witnesses responded in the affirmative. You may be seated. 

In order to allow time for questions and in order for us to 

squeeze this in, I don’t mean to diminish the importance of this 

hearing. This is one I fought for, but we are pressed for time today. 

We ask that the witnesses limit their testimony to five minutes. 

We have your full prepared testimony in our book. It will be entered into the record. 

So if you will summarize and do the best you can to stay within 

five minutes, it would be very helpful. 

So we will start with Mr. Lambert. You are recognized for five 

minutes, sir. 

WITNESS STATEMENTS 

STATEMENT OF MARK LAMBERT 

Mr. LAMBERT. Chairman Farenthold and members of the subcommittee, thank you for allowing me the opportunity to appear 

before you today to discuss the Combined Federal Campaign. The 

Federal workplace giving program started in the 1950s under 

President Eisenhower. Back then, there were four distinct campaigns administered by different charities. Although a great program, it was considered expensive and disruptive to Federal employees because of multiple solicitations throughout the year. 

In 1961, President Kennedy, by Executive Order, directed the 

chairman of the Civil Service Commission to oversee the program, 

which resulted in one campaign season that continues today. 

10 

Pledges to the CFC are used to support charities that provide 

human health and welfare services throughout the world. The CFC 

is managed and overseen by the Office of Personnel Management 

to ensure the campaign is effectively and efficiently administered 

and that campaign components meet Federal requirements. 

Currently the CFC has over 160 local campaigns, and each campaign is managed by a local Federal coordinating committee and 

administered by a principal combined fund organization. The LFCC 

is a group of Federal employees that act as a de facto board of directors while the PCFO administers the local campaign under the 

direction and control of the LFCC and the director of OPM. 

Since 1961, Federal donors have pledged over $7 billion to char- ities through the CFC. In 2012, contributions totaled $258.3 million. In 2011, the CFC celebrated its 50th anniversary and former 

Director of OPM John Berry announced the formation of a Federal 

advisory committee known as the CFC 50 Commission. The commission was established to review the present structure and processes of the CFC and was tasked with developing recommendations 

to improve and modernize the CFC as well as enhance accountability and transparency. 

Convened in September 2011, the commission was comprised of 

28 members, including Federal employees from multiple agencies, 

members of LFCCs and PCFOs, the GAO, the OPM Office of Inspector General, charitable watchdog groups, leaders of charitable 

organizations and representatives from the National Active and Retired Federal Employees Association and Young Government Leaders. 

The commission focused on four main areas: donor participation, 

infrastructure, standards of transparency and accountability, and 

an inspector general task force. In July 2012, the commission 

issued 24 recommendations. The recommendations identified ways 

to enhance the donor experience, address the rising costs of the 

CFC, and institute better procedures for meeting the needs of donors and charities in order to increase transparency and accountability and improve the overall oversight of the CFC’s use of funds. 

OPM reviewed the commission report and concluded the recommendations reflected changes that would improve the CFC for 

both donors and the charitable organizations. To implement the 

donor participation recommendations, we propose regulatory 

changes, including moving the solicitation period to end on January 

15th, allowing new employees to make payroll deductions, creating 

a disaster relief program, and recovering administrative costs 

through an application fee from charities. 

To implement the CFC infrastructure recommendations, we propose regulatory changes, including reducing the responsibilities of 

the LFCCs and changing them to regional coordinating committees; 

eliminating redundant campaign administration functions by consolidating them into one or more central campaign administrators, 

requiring CFC charity lists be made available exclusively through 

electronic means, and requiring all donations to be made via electronic means. 

To implement the standards of transparency and accountability 

recommendations, we propose regulatory changes including streamlining the application process to permit charities to submit a full 

11 

application every three years, rather than annually; easing the financial reporting requirements for charities with less than 

$250,000 in revenue and requiring federations to disperse funds to 

member charities on a specified cycle and prohibiting them from 

deducting dues or fees from CFC funds. 

At present, OPM is reviewing comments from the proposed rule, 

which was issued on April 8th, 2013. Mr. Chairman, over 50 years 

ago, the Federal Workplace Giving Program was in need of reform. 

The resulting CFC has served us well until now. Through the CFC, 

we annually solicit millions of employees and uniformed service 

members. However, over 37 percent of donors in the past decade 

have walked away under the current practices. 

As such, it is evident that we are once again at a time of needed 

reform. I believe the changes recommended by the CFC 50 Commission and proposed in our rule will usher in the needed reforms 

to attract new donors and provide new contributions to the participating charities. OPM has historically demonstrated our commitment to working with our CFC stakeholders, and we plan to continue to partner with them going forward. 

I want to thank you for this opportunity to testify today and I 

am happy to address any questions you may have. 

[Prepared statement of Mr. Lambert follows:] 

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Mr. FARENTHOLD. Thank you very much, and you did that right 

on time. 

We will now go to Ms. Ju ́Coby Pittman. She is the President and 

CEO of the Clara White Mission in Jacksonville, Florida. Ms. Pittman? 

STATEMENT OF JU ́ COBY PITTMAN 

Ms. PITTMAN. Thank you. Good afternoon, Mr. Chairman and 

members of the subcommittee. It is indeed an honor to be here 

today. 

I am here as the CEO and President of the Clara White Mission, 

where I have served for 21 years. I would like to share my concerns 

on how several of the proposed changes to the Combined Federal 

Campaign will hinder and negatively impact our ability to deliver 

services in our community for the homeless and low income in 

Jacksonville. 

For over 109 years, the Clara White Mission has had a history 

of providing services. And through the dollars that are entrusted 

to our agency by Federal employees through the CFC campaign, we 

are able to support and uplift the neediest in our community. Our 

goal is simple. We help train and place individuals in jobs so they 

can become self-sufficient and independent in our society. Our programs are designed to train and educate homeless veterans and 

low income individuals in life and career skills that will allow them 

to give back while training, serving and preparing meals to over 

500 homeless individuals seven days a week at the Clara White 

Mission. 

To date, over 700 students have graduated from our program and 

been placed in jobs within 90 days of graduating. And 67 percent 

of those placed in employment remain in the workforce. Our track 

record is a direct result of continuous support from the Combined 

Federal Campaign, from which we have received over $190,000. 

I would like to tell you about a story of a gentleman that has 

been helped by our program. Hezekiah is a native of Havana, Florida, reared by both parents. Upon graduating from high school, he 

joined the Army on October 8th, 2005 and was discharged in October 8th, 2008. He was stationed in Fort Jackson and enjoyed the 

life of a family man and serving his Country. He mentioned that 

being married and being in the military made him grounded and 

stable. 

Unfortunately, soon after he was discharged, his perfect family 

life was shattered by the unexpected death of his wife, whom he 

loved dearly. He found that coping and living without her was very 

challenging, which led him to a spiraling life of drugs. He began 

using cocaine, he ran away to Tallahassee in hopes of starting a 

new life. But every day, he used drugs while working. 

Eventually, he lost his job and started stealing to support his 

habit. He was arrested and served one year in prison. After he 

completed his sentence and a rehab program, he moved to Jacksonville for a fresh start once again. He enrolled in the Clara White 

20-week culinary arts and housing program, certified by the State 

of Florida education program. After he was accepted and enrolled, 

18 

he took advantage of the total program. He attended AA classes, 

life management classes, developed a positive support system and 

joined a local church. He excelled and graduated with honors. He 

stated that our comprehensive programs helped him get his life 

back and overcome his negative choices and focus on making positive life changes. 

Three days after graduation, he was employed by Morning Star 

Foods. Three months later, he saved his money and moved into his 

own apartment. He remains clean and met his personal and career 

goals while enrolled in the Clara White Mission program. 

Our ability to reach out to Hezekiah and provide him with tools 

and training to help him is an amazing, amazing factor due to the 

generosity of the Federal workforce and the CFC campaign. However, today I am afraid that the proposed changes to the campaign 

will limit my access and the ability to provide similar services in 

the future. 

The proposed changes include a major reorganization, the elimination of all forms of giving outside of solicitation, and adding an 

undisclosed fee for agencies like myself participating in the campaign. The reorganization of the campaign will mean less opportunity to meet face to face with employees, share our agencies’ mission and also the opportunity to educate donors about how donating to the CFC campaign will build capacity and have a visible impact. 

During these difficult times for all Americans, I urge OPM to 

please, please be thorough about implementing changes that could 

have a significant effect on the size, scope and role of the combined 

campaign. I want to work with OPM to make sure the proposed 

changes do not cause hardship and harm to our communities up 

close and personal where we live, work, volunteer, and play, up 

close and personal. 

Thank you. 

[Prepared statement of Ms. Pittman follows:] 

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Mr. FARENTHOLD. Thank you very much, Ms. Pittman. And 

thank you for the hard work you do on behalf of the people of Florida with the Clara White Mission. 

We will now recognize Mr. Kal Stein, President and CEO of 

EarthShare. 

STATEMENT OF KALMAN STEIN 

Mr. STEIN. Good afternoon, Mr. Chairman, Ranking Member 

Lynch and members of the subcommittee. It is my honor to address 

the subcommittee, as it has been my honor to work with the Combined Federal Campaign for more than 25 years, in pursuit of the 

CFC’s mission to promote and support philanthropy through a program that is employee-focused, cost-efficient and effective, and to 

lessen the burden of government. 

I am speaking today on behalf of EarthShare, which represents 

80 national organizations and more than 600 local charities as well 

as on behalf of seven national federations that represent more than 

500 national charities and thousands of local charities across the 

Country. The CFC is the largest organized charity campaign in the 

world and the largest in history. It is a singular achievement of civilization, that regular working people, Federal employees, our 

friends and neighbors all across the Country and the world, have 

contributed more than $7 billion to charity during the 52-year history of the CFC. It is a unique American accomplishment that demonstrates the generosity of Federal employees and it is an extension of their public service. 

The CFC, in turn, provides critical annual renewable and unrestricted funds to more than 25,000 local, national and international 

eligible charities. There is no remotely comparable single source of 

funds for charity in the world. The CFC provides a bedrock of contributions of support that funds charitable services from disaster 

relief to assistance for veterans and military families, including onbase family support services, critical local human services, medical 

research and patient assistance, conservation and much, much 

more. 

I was pleased to serve on the CFC 50 Commission with the mission to ensure the continued growth and success of the CFC. And 

I commend Director Barry and OPM for creating the commission. 

With CFC participation at an all-time low, change is in order, and 

opportunities do exist to make the CFC more efficient and effective. 

While there are aspects of OPM’s proposed changes that are promising and that we support, we are deeply concerned that any positive impacts will be overshadowed by new regulations that will result in fewer donations, that will in turn impact charitable services 

to local communities, including Federal workers and their families. 

There are also a number of proposed regulations that go beyond 

the recommendations of the commission, while other critical recommendations of the commission have not been addressed, including the need to do further research and testing and the formation 

of a working group of Federal leaders to assess that. 

In addition, there is a lack of detail on implementation that 

makes it difficult to respond to the changes in an informed manner 

and to suggest alternatives. Our primary concerns are in three 

areas: loss of local ownership of the campaign, the elimination of 

24 

giving options and the lack of testing and specificity regarding 

change in the cost recovery method of the campaign. 

One, loss of local ownership. In the current configuration, Federal employees are organized as local Federal coordinating committees, and engage all aspects of the campaign, including hiring local 

charities to manage the campaign, and reviewing and improving 

local charity applications. This gives Federal employees a strong 

sense of ownership and a stake in the success of the campaign. 

They can see the impact in their communities. 

The proposed regulations seek to eliminate the local Federal coordinating committees that provide oversight. Local charity management would be eliminated in favor of regional marketing organizations. This would dramatically diminish the role of local Federal 

employee volunteers to the detriment of the campaign and OPM 

would need to create the capacity to manage all fund-raising, web 

development, processing and operations internally and it has no experience in these areas. Such a radical reorganization in the campaign was not considered or discussed by the CFC commission. 

The most basic rule of fund-raising is that people give when they 

are asked and the campaign succeeds because it is a person to person endeavor, not because someone gets an email. When you ask 

people why they give, the reason most often cited is because someone asked, usually a person close to the donor. The CFC has been 

effective over the years because it includes hands-on, peer-peer 

communication and engagement at the local level should not be 

eliminated. 

While we recognize the current system may benefit from efficiencies, the proposed changes are an overreaction. OPM has been 

slowly merging campaigns and committees over the years, as well 

as increasing its guidance and oversight, and that evolution should 

continue. The recommendation of the commission was to improve 

the governance of the CFC at the local level by improving training 

and OPM support. It was not to abandon the current system. And 

we support that recommendation. 

Elimination of current giving options. While we strongly endorse 

the expansion of online giving options for Federal donors, we know 

from experience that it is a critical mistake to eliminate traditional 

means of giving altogether, and the commission did not recommend 

eliminating giving options. Many Federal employees who give to 

the CFC do not have access to or choose not to use online giving. 

This is a reality for many members of the military, postal service 

employees, park service personnel and others in similar circumstances and settings that are frequently without access to computers or cell phones. 

In 2012, $27 million was donated in cash, while $54 million was 

donated online, out of a total of $257 million. We need to increase 

participation in the campaign so we should expand online giving 

options, but not eliminate other forms of giving. 

Allowing donors to give in the method most convenient and secure for them is the key to donor satisfaction and increased participation. While some employees are content to give electronically, 

others prefer to give in other ways. Forcing people to give in a 

manner they are not comfortable with is not conducive to encouraging people to pursue the giving process. 

25 

Third, and my final point, lack of testing and specificity regarding change in the cost recovery method. No details have been provided on the proposed up-front and non-refundable fees for charities participating in the campaign, including the amount of the 

fees and how they will be assessed and adjusted each year. The 

proposal of an up-front fee against an unknown return, and that 

will be non-refundable under any circumstances, including withdrawal or denial, is patently unfair. 

Without more information, charities will be forced to make expenditures without knowing the benefits, which is bad governance. 

Due to the way that campaign cycles work, a charity will have to 

pay the fee twice before it knows if it will see any return on the 

investment. This is the equivalent of a college insisting on two 

years’ tuition fees up front, with the possibility of rejection, but no 

possible refund. 

The commission agreed that changing the fee structure is critical 

in increasing participation. The objective is to increase the value of 

the campaign to Federal employees. However, charity fees should 

first be tested at the local level before changing the entire campaign. Last year, OPM tested universal giving, which allows donations outside of current community stations in three local CFC’s. 

This was a relatively benign change in the campaign with no opposition or downside concerns. 

Changing the financial structure of the campaign is far more 

reaching and potentially disruptive, so it should be developed with 

an equally cautious approach that does not put donations at risk. 

The commission recommendation was to develop a series of focus 

groups to determine what donors want and that OPM should organize an ongoing working group with wide Federal department representation to recommend modifications to CFC. OPM should follow that recommendation before proceeding further. 

Despite the numerous challenges, $257 million was contributed 

last year by Federal employees at a cost of less than 11 percent, 

which is outstanding by any measure of effectiveness. I believe in 

the power of the CFC to be a positive force for the government and 

Federal employees and the communities where we live, work and 

play. We look forward to working cooperatively with OPM to continue a dialogue that ensures any changes in the current regulations will not only promote efficiency but also result in greater 

charitable giving and employee participation and will grow the 

campaign. 

Thank you for your time. 

[Prepared statement of Mr. Stein follows:] 

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Mr. FARENTHOLD. Thank you, Mr. Stein. 

We will now go to Ms. Debby Hampton, the President and CEO 

of the United Way of Central Oklahoma. 

STATEMENT OF DEBBY HAMPTON 

Ms. HAMPTON. Chairman Farenthold, Ranking Member Lynch 

and members of the subcommittee, thank you for allowing me to 

testify today in the hearing of the Combined Federal Campaign. 

I am here today to express United Way’s concerns about OPM’s 

proposed changes to the CFC. United Ways are the PCFO’s for 

more than 80 percent of the approximately 150 individual CFC, 

working with LFCCs to manage more than half of the approximately $265 million raised annually. 

In 2012, Central Oklahoma CFC raised $3.2 million. We solicited 

over 35,000 Federal employees; 9,100 chose to give to 1,500 charities. But more importantly, those charities helped tens of thousands of individuals and families throughout Central Oklahoma, 

including Federal employee families. 

The United Way network has a longstanding relationship with 

OPM, and while in partial disagreement with OPM’s proposals, we 

are confident that United Way and OPM will continue to have a 

strong, productive partnership for years to come. Some modest reforms may be needed to sustain the integrity and operational 

strength and effectiveness of the CFC. But our view is that this 

regulatory process needs to start from the beginning to ensure 

meaningful involvement by organizations with greater expertise in 

workplace charitable giving. 

There are several specific recommendations that we believe undercut the CFC’s operational effectiveness and integrity. Three 

main examples of that, first being elimination of local involvement 

in favor of a limited number of regional coordinated committees 

and central campaign administrators. Second, charging charities a 

non-refundable, up-front fee to participate. And third, shifting to an 

internet-only campaign. 

Among the changes that I just mentioned, the most damaging 

and destructive would be the disconnection of CFC from local engagement and the transfer of local campaigns to a regional administration. As a result of this, Federal employees would no longer be 

able to make well-informed decisions on how they support charities 

in their communities, not only monetarily, but as they volunteer. 

CFC decisions would then be outsourced to a regional authority 

without regard to unique needs of individual communities. 

There is a story I would like to share with you that happened 

and really relates to the importance of the local involvement. Early 

in the morning after May 20th, tornadoes devastated Moore, Oklahoma. I received an email from the executive director of the Federal Executive Board. The email was a request for United Way to 

compile a list of charities that were assisting or would be assisting 

in the aftermath of the tornadoes. We wanted that request, so a 

special solicitation of funds could be made by Federal employees. 

By 10:45 a.m., our staff had compiled and sent that list to our CFC 

operations. By 3:48 p.m., the following day, only 29 hour later, we 

received our approval letter. 

42 

This coordination between our two organizations demonstrates 

an important benefit of the Combined Federal Campaign. The relationship and trust we have built through 30 years with the CFC 

allowed us to work quickly in Oklahoma’s most important hour of 

need. It makes no sense to replace a local-based CFC with an ineffective, generic campaign, run by an outsourced fund-raising, marketing person who really doesn’t even know what is important to 

our local donors. 

Another ill-informed change would require that charities be 

charged a fee in order to receive donations. Of the 1,500 charities 

that received funds from the CFC of Central Oklahoma in 2012, 

1,200 of them received $2,000 or less. So imagine the impact of a 

$500 to a $1,000 fee on our charities. I predict it would discourage 

about 40 percent of the local charities from participating in the 

CFC. 

Additionally, the proposed changes would eliminate any kind of 

paper form of donation and only electronic donations would be allowed. From our experience with the United Way’s annual campaign, we had a large corporation that chose to do that very same 

thing. The first year that they ran an online-only giving campaign, 

they lost 61.5 percent of their total campaign giving. Even three 

years later, we are still trying to make up, and have lost over half 

of that original giving when they offered both the paper donations 

as well as the online. 

You need to realize that there are people that do not trust doing 

anything financial online. They would rather have the paper donation form, and we need to keep that option. 

Mr. Chairman, in conclusion, United Way requests that Congress 

instruct OPM to go back to the drawing board on these proposed 

regulations and that they work with United Way and other charities who can provide expertise and guidance in crafting CFC reforms that will create efficiencies and more importantly, deeply engage Federal workers in the CFC. 

Thank you. 

[Prepared statement of Ms. Hampton follows:] 

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Mr. FARENTHOLD. Thank you very much. 

We will now go to Mr. Berger from Charity Navigator. 

STATEMENT OF KEN BERGER 

Mr. BERGER. Chairman Farenthold, Ranking Member Lynch and 

members of the Subcommittee, thank you for this opportunity to 

share my thoughts on the proposed regulation changes to the CFC 

program. 

Although I was a member of the CFC 50 Commission, I am most 

interested in commenting on these changes from my viewpoint as 

a donor advocate and leader of the charity watchdog organization, 

Charity Navigator. Charity Navigator has as its mission to be a 

guide to intelligent giving for donors to charities of every kind. We 

achieve this by operating a website where we rate the performance 

of charities, as well as provide a wide variety of resources. 

In 2012, we had 6.4 million visits to our website and influenced 

billions of dollar of U.S. charitable donations. Therefore, we believe 

we are the largest charity rating service in the world. 

However, today I am not expressing the official views of Charity 

Navigator on these matters, since the organization hasn’t taken 

any position. Rather, I am speaking based upon my own independent perspective and experience. Quite a few of us on the CFC 

50 Commission expressed the fundamental belief that OPM 

shouldn’t simply have a static list of recommendations and then 

consider the work done. 

Instead, we recommended that OPM develop a continuous improvement process that engages Federal employees ongoing. This 

involves creating a working group made up of a representative 

sample of Federal employees that would be consulted continuously 

by OPM regarding changes being considered over time, as well as 

a vehicle for employees to initiate new ideas to be considered. 

However, I have seen no record of this and I fear that if the CFC 

doesn’t have such a baked-in process to its design, the long-term 

viability of the program will be in jeopardy. 

I am also extremely concerned that many of the proposed 

changes don’t reflect any plan to pilot test or conduct further data 

analyses. The need for this is critical to the integrity of the program, to meet the growing concern for transparency and accountability, as well as best practices of securing ongoing donor feedback. 

Of the 13 OPM proposed actions that require regulatory changes, 

there are 6 with which I am not in full agreement. First, regarding 

the proposal to charge all charities an application fee to participate. 

Eighty-three percent of charities in the United States are $1 million or less in size. But the proposed change biases the program toward larger non-profits. If the application fee is substantial, it is 

likely that the bigger charities will end up covering much less of 

the overall cost of the CFC program. On the other hand, the added 

cost up front could be enough to discourage many smaller charities 

from participating at all. 

In addition, the premise that this change will shift the costs of 

the program from donors to charities is bogus. For most charities, 

unrestricted money from donors is what is going to pay for the upfront fee. So it is still donors’ money that is being used. 

49 

Second, I agree with the concern that any move to eliminate nonelectronic donations is likely to reduce the number of employees 

who participate, as well as the overall amount of money raised 

each year. Third, I believe the proposal to move to regional committees has valid arguments on both sides, but it needs to be pilottested to see where a good balance can be struck. 

Fourth, I agree with concerns about OPM’s plan to eliminate 

printing of various campaign materials and making them available 

only via electronic means. This change should only occur in locations where electronic data is easily accessible to all Federal employees. Further research and pilot testing, once again, is required. 

Fifth, it is being proposed that every few years, charities already 

in the program would be asked for a more limited set of documents. 

Charities that get large amounts of program funding each year 

shouldn’t have this annual requirement lifted. 

Sixth, OPM is proposing to waive the order requirement for organizations with annual revenues less than $250,000. If a charity 

gets a sizeable amount of money from the CFC each year, it should 

be required to conduct an audit, regardless of its size. 

I believe the other seven proposed changes are good ones that 

will help OPM to improve its oversight of the program. 

In conclusion, I know that the generosity of the Federal workforce is enormous, and OPM has a vitally important responsibility 

to help ensure that every charitable dollar raised is used effectively. My sense of the CFC leadership is that they sincerely want 

that to happen. I hope it does, so many more people receive the 

vital help they need. That is what matters most. 

Mr. Chairman, this concludes my statement. I would be pleased 

to answer any questions from you or the subcommittee. Thank you. 

[Prepared statement of Mr. Berger follows:] 

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Mr. FARENTHOLD. Thank you very much. 

I will recognize myself for five minutes of questioning. 

I think I speak for everybody on the dais here, that you don’t get 

into public service as an elected official if you don’t start in public 

service helping out non-profits and charities. My wife, a member of 

the Junior League, considers herself basically a professional fundraiser. I have served on the boards of the Texas State Aquarium, 

the art museum of South Texas, several schools, private schools 

that my children attended. My wife has been on the board of a 

small non-profit no-kill animal shelter, PeeWee’s in Corpus Christi. 

My company before I came to Congress did websites, we had a special program for non-profits. We were very involved in this. 

This is an issue I am very passionate about, and understand a 

little bit about fund-raising and the internet. I am deeply concerned about doing away with paper donations and the personal 

ask. I can guarantee you, I am much more effective raising money 

for whatever I am raising money for when I look somebody in the 

eye or talk to them on the telephone and say, can you help out, 

rather than firing off an email or a letter. I think we have heard 

testimony to the effect that we have had negative results there. 

Are there any thoughts, Mr. Lambert? Are there pilot programs 

where we determine what impact this will have? 

Mr. LAMBERT. Mr. Chairman, we are still evaluating the comments on the proposed rule. We will move forward once we have 

done so in a thorough way to finalize the reg. So a lot we don’t 

know yet. The regulations themselves are meant to be a general 

framework. The details, the processes and procedures of implementation will come after that. 

We have historically shown our commitment to our stakeholders 

to work with them on how best to implement those changes, and 

we will continue to do so. 

Mr. FARENTHOLD. Your agency’s budget justification for fiscal 

year 2014 states that ‘‘OPM received legislative permission to finance the CFC program via an administrative fee charged to each 

participating charity and will begin collecting the fee during fiscal 

year 2015.’’ I asked our staff to look into that and see where that 

legislative authorization was. They couldn’t find it. Could you help 

us out on that? 

Mr. LAMBERT. I am not surprised they couldn’t find it, because 

that was included in our justification in error, that language was. 

Mr. FARENTHOLD. I am obviously concerned about not running up 

the Federal deficit by funding this program. But I am also concerned that the administrative fee is going to cut out some small 

charities. 

Let me ask Mr. Berger, Charity Navigator, one of the criteria you 

use in evaluating charities is how much actually goes to the program and how much is eaten up in other expenses. Would this 

OPM fee actually downgrade, potentially, their rating as a charity 

that gives their money to the people and projects they say? 

Mr. BERGER. I want to emphasize that overhead is one of a number of things that need to be considered. So the overall picture of 

a charity, its performance, its results, are most important. Within 

that context, we certainly do think that the higher overhead in 

59 

some cases is a good indicator of inefficiency and can be a problem 

that would impact the rating of a charity if it became excessive. 

Mr. FARENTHOLD. All right. I am going to go to Ms. Pittman, because she is a small, local charity. Just on a personal level, and no 

offense to United Way, Ms. Hampton, but I tend to like the local 

charities where I know the people involved and can really see the 

impact that they are having. We heard some testimony about the 

disparate impact these new rule changes might have on smaller 

charities. 

Can you spend maybe 30 seconds telling us some of the negative 

impacts you see? 

Ms. PITTMAN. Well, I will tell you, as you mentioned earlier, the 

personal ‘‘ask’’ and the volunteer is important. Just yesterday, I 

had an opportunity to go speak at the DEP and because of a relationship that we had over five years ago, I go at least every other 

year to give them an update of what is going on locally with our 

organization. If I am not able to go inside and talk to the Federal 

employees, that will definitely impact what we do locally. That 

means that those dollars that we are used to, depending on helping 

the homeless and low income, those dollars will stop, they will 

cease. 

Mr. FARENTHOLD. Thank you very much. I see my time is about 

to expire. I want to give everybody on the panel a chance to go with 

their first round of questioning before we have to go for votes. So 

I will now recognize the ranking member, Mr. Lynch. 

Mr. LYNCH. Thank you, Mr. Chairman. First of all, I want to 

thank Mr. Davis for his kindness. I served as his assistant, he was 

my mentor before I took over ranking member here. I am sure he 

ably conducted my duties in my absence. I want to thank him and 

also Ms. Speier who delivered my opening statement. 

I want to thank all of the panelists for coming forward and helping the committee. This is a tremendous blessing we have in so 

many Federal employees who are willing to donate. So I think 

some of these recommended changes could be classified under the 

no good deed goes unpunished category. 

I just want to ask Mr. Lambert, have we looked at what impact, 

now, we are in the third year of a pay freeze for Federal employees. 

Third year, it started back in January of 2011. So we froze the pay 

of Federal employees. What impact has that had on donations? 

Have we looked at that? I know they have been dropping off in 

those years. Do we think any part of that is the fact that we have 

withheld raises for our Federal employees? 

Mr. LAMBERT. Sir, we do not do any in-depth research currently 

on why employees give or don’t give. It is one of the recommendations from the commission. And we are going to implement that. 

It didn’t require regulatory change, which is why it wasn’t seen by 

others in those regulatory changes we proposed. But certainly I 

would have to think the economy and the pay freeze has had an 

impact on donations. 

Mr. LYNCH. Furloughs, things like that that we are dealing with. 

Okay. If we could, I would like to get an answer to that question, 

if we can sort of quantify it. Not now, but in your work. 

A couple of the other issues jump out at me, one being, I understand the desire to go to paperless donations. I understand the reaVerDate Aug 31 2005 14:15 Jul 30, 2013 Jkt 000000 PO 00000 Frm 00063 Fmt 6633 Sfmt 6633 C:\DOCS\82140.TXT APRIL
60 

soning behind that, and it is good for the environment. However, 

sometimes ideology overtakes practicality. A couple of things here. 

If I am running a home like a Clara White Mission and I am trying 

to take care of homeless veterans, and only 22 percent of the folks 

are donating online, and 78 percent are donating with paper 

checks, that is a huge part of my donation base. 

Now, I wish everybody might be a little bit more up to speed, but 

the plain fact of the matter is, it is not good for the environment 

for my homeless veterans to not have a grant that helps them either get retraining or get through rehab. It is not good for my folks 

or families that are suffering from Alzheimer’s to not have a grant 

for their parents or grandparents. It is not good for the environment, I have an adolescent drug rehab facility in my district. It is 

not good for their environment for those kids who are trying to get 

off Oxycontin and heroin if there is no grant to make sure that 

those 20 beds are open for those kids, and I have a line around the 

block waiting to get in there. 

So when we think about environment, I just hope that we are not 

short-sighted. It is a wonderful ideal to pursue, but I would not cut 

loose 78 percent of my donors because they are sending me a check 

so I can do good work. 

On top of that, you are asking letter carriers, the National Association of Letter Carriers, to donate to your campaign. You are asking postal workers to donate to your campaign. It is antithetical for 

them to not use the mail. The reason that they are being laid off 

is because people are paying their bills online. Now you are asking 

those letter carriers, those postal workers, don’t use the mail, put 

yourself out of work, take your donations and send them to us online so that we can lay more of you off faster. That is just not going 

to work. They are too smart for that. So we have to back off a little 

bit, and do what we can to encourage e-donations. 

The last point I want to hit on is the disaster relief piece. I think 

that is a wonderful idea. I know how patriotic and loyal and good 

Federal employees are. I can see how they would step up in a situation like the Oklahoma tornadoes or even the terrorist attack in 

my district in Boston at the marathon, or these firefighters that 

just were killed in such a courageous line of work. I can see where 

folks would step up in a tragedy like that, especially Federal employees. 

Would this require a separate campaign? Is that how this is envisioned? Because it lacks some detail here. Like if it was outside the 

normal donation period, campaign period, would this be a separate 

type of campaign? Because in my district, we are getting 100-year 

storms every three weeks. So I can see where the need for this 

would be spot-on. It is a great idea. I am a little fuzzy on the details of how that might work. 

Mr. LAMBERT. Congressman, it could be. Again, we are seeking 

through the proposed regulations to get the authority to be able to 

do that. Once we have that authority, we will again work with all 

of our stakeholders to develop that program. But you are right, it 

could be a year-round program that is available immediately for 

Federal donors to be able to start contributing to, and to get that 

money as fast as possible to the local organizations that are responding to those disasters. 

61 

Mr. LYNCH. Okay. You have been very generous with my time, 

Mr. Chairman. And I appreciate your indulgence. I yield back. 

Mr. FARENTHOLD. It is my pleasure. 

We will now go to the gentleman from Michigan, Mr. Walberg. 

Mr. WALBERG. Thank you, Mr. Chairman, and thanks to the 

panel for being here. I wish I could have heard you, but I have had 

opportunity to review your statements. 

Mr. Lambert, let me just ask, before I go back to some of the 

train of thought that Mr. Lynch was going down, why did OPM 

wait until after the public comment period to post comments on the 

proposed regulation? Was it OPM’s decision, consistent with 

OMB’s? 

Mr. LAMBERT. Yes. We believe it was consistent with OMB guidance. Our policy is to not post the comments until after the comment period is over. So the comment period ended on June 7th, and 

after reviewing those comments and redacting PII, we posted those 

comments, I believe it was by June 24th. So very soon after. 

Mr. WALBERG. What is the rationale for the policy? 

Mr. LAMBERT. I think it is that we don’t want to bias the comments that are being made. So we just try and hold off until the 

end, and then post those. We don’t get them all through electronic 

means. A lot of them come in through the mail, so they have to be 

kind of uploaded into the system and it takes a little time. 

Mr. WALBERG. Interesting. Through the mail. 

[Laughter.] 

Mr. WALBERG. Let me ask you, how much will be saved by the 

shift to electronic-only donations? 

Mr. LAMBERT. I don’t have a specific number, but I can tell you 

shifting to an automated environment would be significant savings. 

When you consider that we solicit over 4 million donors, and that 

charity lists are produced, I guess pretty close to 4 million, that is 

a lot of printing that happens. Not too many contributions come in 

by cash or check. It is a small percentage of what does come in. 

Probably around $20 million of the $250 million that we raised. 

So not having to print the brochure, not having to process the 

cash or checks and not having to input pledge forms that we get 

in the manual format, because all that information has to be entered manually into systems then to determine who it should go to 

and how it should be distributed. 

So it would be a significant amount, but I don’t have an actual 

dollar amount. 

Mr. WALBERG. In light of that, do you have any idea of how the 

dollar amount that decreased donations, overall amount received 

from donations would result from this change? 

Mr. LAMBERT. I don’t know that it would decrease. Again, cash 

and check donations are a very small percentage of what we get. 

And we think a lot of those people, now again, automated systems 

aren’t available in all 160 of our campaigns. So right now it might 

be a small percentage that are coming in that way. We are seeing 

that this is growing every year. 

But we also think that by implementing and going to an automated fashion, we would attract a lot of new donors, new younger 

donors, who are used to operating online. So they are not going to 

contribute by filling out a pledge form. They want to go online and 

62 

be able to contribute, or they want to go to their smart phone and 

use an app to contribute. 

So we think we can attract a lot of new donors by going to an 

automated giving environment. 

Mr. WALBERG. Okay, thank you. I yield back my time. 

Mr. FARENTHOLD. Thank you very much. 

They have called folks in the House, fortunately we are about 

four minutes away from the Floor here. We have a nice, quick way 

to get there. So I do believe we have time for Mr. Davis’ round of 

questions. We will now yield to the gentleman from Illinois. 

Mr. DAVIS. Thank you very much, Mr. Chairman. 

One of the reasons I think I like serving on this subcommittee 

is the practical questions and answers that the members give. As 

you were describing your wife and her engagement and involvement in charitable activities, it sounded like we had married two 

sisters. 

[Laughter.] 

Mr. DAVIS. Charitable, charitable, charitable. I really like the 

ranking member’s economic outlook, that you don’t participate in 

a way to hurt yourself, that you try and help yourself. I can certainly agree with his description of how letter carriers might feel 

in terms of what they do. 

Let me ask each one of you, there has been some expression of 

concern about the proposed changes. And if you, Ms. Pittman and 

Mr. Stein and Ms. Hampton and Mr. Berger could each just indicate what is your greatest concern about the proposed changes? 

Ms. PITTMAN. I would say getting input from those organizations 

that are on the front line, who need those dollars and those dollars 

mean a whole lot. And not only that, it allows us to leverage those 

dollars that we get from CFC to get other dollars in the community. So it is very important, and I would hate to see those dollars 

disappear because we would have to cut back on services. 

Mr. DAVIS. Mr. Stein? 

Mr. STEIN. It would be retaining the local component of the campaign and retaining the giving options and testing the change of 

the fee structure at the local level before proceeding. And it would 

also be the establishment of an advisory group, as Mr. Berger said, 

that could advise OPM going forward with stakeholders, particularly fund-raising experts, people that understand workplace giving, so we could proceed with a cautious approach. These are charitable donations. Any money lost is services that are denied. 

Mr. DAVIS. Ms. Hampton? 

Ms. HAMPTON. I would have to echo what Ms. Pittman and Mr. 

Stein have said. But I also, it goes back to the local presence. I also 

have concerns for the Federal employees, because when they have 

that local presence, they also, they themselves know where to go 

for help, and their families and their co-workers. They seem to be 

a resource to others to tell them where to go. 

Oklahoma is a very disaster-prone State. I can tell you, there 

were over 100 families off our military base that were affected by 

these tornadoes, and they knew how to get help. And it was thanks 

to the CFC campaign. 

Mr. STEIN. When I was on the CFC 50 Commission, one of the 

things we kept saying, some of us, was, it shouldn’t just be about 

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the 28 of us telling you what we think. It shouldn’t be me here telling you what I think. It really should be the Federal employees 

that donate that have an ongoing voice, the donors need to have 

a voice in this on an ongoing basis. That is by far, far more than 

anything else. 

And then also test, test, test. As you heard from a number of the 

remarks, that there are a number of things where we don’t have 

the data, we don’t know the answer. And that is critical, to get 

those answers and to make informed decisions as we move forward 

with any of these changes. 

Mr. DAVIS. Let me ask, Mr. Berger, is it your hope that the data 

you have received across the board, as people have responded, 

would also indicate or would also have enough expert opinion coming from people who are users of the service, or people who are 

most involved, that that becomes very helpful to OPM as it finalizes any new rules? 

Mr. BERGER. Absolutely. We value the comments that we have 

gotten through this comment period with the proposed regs. Certainly we will thoroughly consider those comments in drafting the 

final version of the regs. 

There seems to be a misunderstanding that we are doing away 

with the local presence of the campaign. And that is not what we 

are looking to do at all. We are not eliminating local Federal coordinating committees. We are just changing the names to regional 

coordinating committee to represent the larger geographic district 

that they are going to represent. But they still will have that local 

touch into the Federal agencies and each of these local communities will still be able to do that solicitation and that personal ask. 

The automated means that we are trying to implement are just 

a means to get those donations in. It is not to eliminate that local 

touch, that local feel, the local interaction that currently is there. 

We want that to continue. We realize the importance of that, too. 

Mr. DAVIS. Thank you very much, Mr. Chairman. 

Mr. FARENTHOLD. Thank you very much, and as we conclude, I 

do think we can sum up a lot of what we have heard here, we don’t 

want to take the local aspect out of it, we don’t want to place the 

Federal programs out of the reach of the smaller, local charities. 

I think those are two of our big takeaways. We have covered a very 

broad and important topic in a very small amount of time. 

But I do think we have gotten the information that we need. We 

have a relatively thorough record here, with your written testimony 

and questions. I would like to thank all the witnesses for their involvement in their communities and their States and our Country 

and in the world. Together we are all making a difference, and we 

thank you for taking time to be with us and educating us today. 

The subcommittee now stands adjourned. 

[Whereupon, at 2:09 p.m., the subcommittee was adjourned.] 

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