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Combined Federal Campaign (CFC)
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Records of the Office of the Chief of Staff (Clinton Administration)
Jennifer O'Connor's Subject Files
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5-15-95
Jennifer o' 5/15
James King
Please respond
res Cambined Fed. Campaign
(acknowledge) to
action: Respond to Kins
king This was lost.
Thanks.
(John-Keep - copy.
Make file " Combined
Federal Campaisn -'9CR"
03/22/95
17:00
1
003/007
UNITED
STATES
UNITED STATES
OFFICE OF PERSONNEL MANAGEMENT
OF PERSONNEL HAMPSHIRE
file
WASHINGTON D.C. 20415
CFC
OFFICE OF THE DIRECTOR
MAR 22 1995
INFORMATION
MEMORANDUM FOR HAROLD M. ICKES
ASSISTANT TO THE PRESIDENT FOR POLICY AND POLITICAL
AFFAIRS AND DEPUTY CHIEF OF STAFF
FROM:
JAMES B. KING
can
DIRECTOR
SUBJECT:
Combined Federal Campaign
Cushing
-states
I.
SUMMARY
In a February 23, 1995 letter, House Civil Service Subcommittee Chair John Mica asked OPM
to implement the Combined Federal Campaign (CFC) eligibility standards proposed by the
Reagan Administration that would limit participation to organizations that provide direct human
health and welfare services. The regulations were blocked by Congress in 1986. (See letter
attached.)
П.
DISCUSSION
BACKGROUND
The Combined Federal Campaign (CFC) was established by President Kennedy to limit year-
round solicitation of federal employees, and instead provide charities an annual opportunity to
seek support from federal donors.
In the beginning the CFC was relatively non-controversial with participation limited to
"traditional" charities that provide direct human health and welfare services. In the late 1970s,
less "traditional" groups that affect human health and welfare services (e.g. political advocacy
groups and legal defense funds) succeeded, primarily through litigation, in becoming participants
in CFC.
In 1982-83, the Reagan Administration attempted to adjust the definition of human health and
welfare agencies by excluding advocacy, legal defense and other non-"traditional" groups. The
Supreme Court upheld Reagan's Executive Order, stipulating that exclusions be done even-
handedly, without discriminating for or against any particular political viewpoint. In 1986,
Congress blocked OPM regulations implementing the E.O.
03/22/95
17:00
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Harold M. Ickes
page 2
COST ISSUES
The costs Rep. Mica cites represent staff time dedicated to promoting the CFC, not
cash/appropriated funds.
The costs he cites are OPM 1988 figures and are significantly inflated, we believe.
There would be no significant savings in reducing the number of participating
organizations. Whether 100 or 1,000 the administrative costs are roughly the same.
Costs for items like printing and distribution of brochures are not paid by the Federal
government.
ORGANIZATION PARTICIPATION ISSUES
Whoever tries to change this program (by limiting participants) will run into tremendous
opposition from the many advocacy, legal defense and other non-"traditional" groups
participating in CFC.
Is it the place of government to limit the options of its citizen-employees in deciding to
make charitable contributions? (Opponents might counter, "We're not limiting their
options. They can make contributions on their own, without help from the government.")
There is anecdotal evidence to suggest that Reagan Administration officials were targeting
groups like Planned Parenthood.
We will complete an interim response to Rep. Mica in a few days. It may be of interest to you
and I'll show it to you. Our plan is to answer his specific questions, but take no immediate
action on implementing the 1986 restrictions without seeking additional information from the
affected groups. This would provide an opportunity for those groups to make their points
without casting OPM or "the government" in the role of advocate.
Among the options we will consider are:
Run the CFC without the accompanying promotional effort. Most of the costs involved
are tied up in efforts to urge employee participation in the CFC (these costs are in staff
hours, not cash). This option would likely result in decreased donations.
Replace CFC with a Charity Allotment Program. In this case, employees could
contribute to any 501(c)(3). An allotment mechanism is already in place. There would
be no need to create a new bureaucracy, but employees would have to do all of the work
of obtaining and providing an organization's information to their payroll offices. This
would likely result in a dramatic drop in contributions, at least in the short run.
Privatize the CFC. "Does the Federal government need to be in this business?," might
be a fair question. After shutdown costs, this option takes the program off the budget
and gets the government out of the business of supporting all of the organizations.
Make no change to CFC.
03/22/95
17:01
005/007
WILLIAM F. CLINGER, JR.. PENNSYLVANIA
CHAIRMAN
CARDISS COLLINS, ILLINOIS
RANKING MINORITY MEMBER
BENJAMIN A. GILMAN, NEW YORK
DAN BURTON. INDIANA
ONE HUNDRED FOURTH CONGRESS
HENRY A. WAXMAN, CALIFORNIA
TOM LANTOS. CAUFORNIA
CONSTANCE A MORELLA, MARYLAND
ROBERT E. WISE, JR,, WEST VIRGINIA
CHRISTOPHER SHAYS, CONNECTICUT
MAJOR H. DWENS, NEW YORK
STEVEN SCHIFF, NEW MEXICO
ILEANA ROS-LEHTINEN. FLORIDA
Congress of the United States
EDOLPMUS TOWNS, NEW YORK
JOHN M. SPRATT, JR.. SOUTH CAROLINA
WILLIAM H. ZELIFE, JR. NEW MAMPSHIRE
LOUISE MONTOSM SLAUGHTER, NEW YORK
JOHN M. McKUGH. NEW YORK
PAUL E. KANJORSKI. PENNSYLVANIA
STEPMEN NORN, CALIFORNIA
house of Representatives
GARY A CONDIT. CALIFORNIA
JOHN L MICA, FLORIDA
COLLIN C PETERSON. MINNESOTA
PETER BLUTE, MASSACHUSETTS
KAREN L THURMAN. FLORIDA
THOMAS M. DAVIS. VIRGINIA
DAVID M. MEINTOSH. INDIANA
COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT
CAROLYN B. MALONEY, NEW YORK
THOMAS M, BARRETT, WISCONSIN
JON D. FOX, PENNSYLVANIA
GENE TAYLOR. MISSISSIPPI
RANDY TATE. WASHINGTON
DICK CHRYSLER. MICHIGAN
2157 RAYBURN HOUSE OFFICE BUILDING
BARBARA-ROSE COLLINS, MICHIGAN
ELEANOR MOLMES NORTON, DC
GIL GUTENECMT. MINNESOTA
MARK E. SOUDER. INOIANA
95-82
JAMES P. MORAN, VIRGINIA
WASHINGTON, DC 20515-6143
GENE GREEN. TEXAS
WILLIAM J, MARTINI, NEW JERSEY
CARRIE P. MEEK, FLORIDA
JOE SCARBOROUGH FLORIDA
FRANK MASCARA PENNSYLVANIA
JOHN SHADEGG, ARIZONA
CHAKA FATTAH. PENNSYLVANIA
MICHAEL PATRICK FLANAGAN. ILLINOIS
VEB 27
CHARLES F. BASS. NEW HAMPSHIRE
STEVE C. LATOURETTE, CHIO
BERNARD SANDERS. VERMONT
MARSHALL "MARK" SANFORD. SOUTH CAROLINA
INDEPENDENT
ROBERT L. EMRLICH, JR., MARYLAND
February 23, 1995
MAJORITY-1202) 223-5074
MINORITY-(202) 225-6061
The Honorable James B. King
Director
SBU
U.S. Office of Personnel Management
1900 E St., N.W.
Washington, D.C. 20415-0001
Dear Mr. King:
Recently, I have received a number of complaints about the
presence of numerous advocacy groups and other organizations that
do not directly benefit human health and welfare (e.g., those who
do not provide or support such activities as care, education, or
research on human heath; disaster relief; or feeding, sheltering,
or housing the poor) in the Combined Federal Campaign. I, too,
am deeply troubled by their presence and am considering holding
hearings and introducing legislation to remedy this problem.
Accordingly, I am writing to ask for your support and cooperation
in restoring the CFC to its rightful role of aiding traditional
charities that do directly benefit human health and welfare.
The CFC resulted from the Federal government's efforts to
reduce the burden numerous separate charitable solicitations at
the Federal workplace imposed on it. This was done by providing
a single, coordinated fund-raising drive. Until the 1980s, only
a limited number of traditional charities participated in the
CFC. Then, as a result of litigation, certain advocacy groups
were allowed to participate. Subsequently, participation has
exploded to the point that the list of organizations
participating in the 1994 CFC for the National Capital Area
consumed nearly 21 single-spaced, double-columned pages.
Many of the groups on the 1994 list are plainly advocates
that try to advance a particular point of view through lobbying,
litigation, or other activities. For example, on the list are
the following: the Center on Budget and Policy Priorities, the
Sierra Club Legal Defense Fund, the Firearms Civil Rights Legal
Defense Fund, the NAACP Legal Defense and Educational Fund, the
Heritage Foundation, the National Right to Work Legal Defense
Foundation, Inc., and the Teamster Rank and File Education and
Legal Defense Foundation. Other participating organizations,
03/22/95
17:01
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Page 2
Hon. James B. King
February 23, 1995
Unlimited, however worthy their goals, do not provide direct
Turkey Federation, Inc., the Source Theater Company, and Trout
such as the Center for Investigative Reporting, the National Wild
benefits to human health and welfare.
As Thomas Jefferson said, "to compel a man to furnish
contributions of money for the propagation of opinions which he
what disbelieves, is sinful and tyrannical. Yet that is precisely
of advocacy groups to participate in the CFC. In 1988, the Report
the Federal government is doing to taxpayers by allowing
acknowledged that the CFC is a subsidy for participating
the Director's Task Force on the Combined Federal Campaign
organizations "in and estimated the amount of that subsidy to be then
the neighborhood of $55-60 million" per year. American
advocacy groups.
taxpayers simply should not be compelled to subsidize these
It is time now to restore the CFC's pre-1980s status a
direct in benefits to human health and welfare. The Supreme Court,
vehicle for solicitations by traditional charities providing as
a ruling on President Reagan's Executive Order No. 12404, has
made it clear that advocacy groups and others may be excluded
from the CFC through "viewpoint neutral" restrictions. OPM
restrict eligibility for the CFC to traditional charities
attempted to do this in 1986 by promulgating final regulations to
has concerned with human health and welfare. Unfortunately, Congress
prevented OPM from implementing those regulations.
If this Congressional bar is lifted, Mr. Director, will OPM
of take the necessary steps to implement the eligibility standards
to do those so? 1986 regulations and, if so, how long will it take you
Please also provide me with the following information:
each year for the last five years.
1. The total amounts collected and distributed by the CFC
2. A complete list of all organizations that have
participated in the CFC over the last five years and the amount
contributed to each through the CFC in each of those years.
3. The total cost to taxpayers of conducting the CFC in
the 1988 Report of the Director's Task Force on the Combined
each of the last five years, following the methodology used in
provide a more accurate picture of the taxpayers' burden in
Federal Campaign. (If you believe some other methodology would
the supporting the CFC, please also provide those figures for each of
last five years and a description of your methodology.)
03/22/95 17:02
007/007
Page 3
Hon. James B. King
February 23, 1995
I look forward to working with you as we address this important
issue, and I hope to have the Administration's support in
restoring the CFC to the purpose originally intended for it: the
support of "traditional charities" that directly benefit human
health and welfare.
Sincerely,
John L. Mica
Chairman
Sub committee on Civil Service