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The annual Combined Federal Campaign (CFC) and the innovative means employed by fundraisers present new questions and challenges to fundraisers and ethics counselors. Below is general guidance on fundraising for CFC as well as guidance on some specific fundraising techniques. Please note that the CFC is an official fundraising program for Federal personnel. Consequently, CFC events and techniques authorized below may not be appropriate for other organizations.
Use of Government Resources to Support CFC
Appropriated funds may be used when the proper authority reasonably determines that the proposed expenditure is logically connected to the appropriation's purpose, and that no statute prohibits it. The use of appropriated funds is usually limited to expenses related to kick-offs, victory events, awards, and other events to build support for the CFC. The use of appropriated funds for refreshments, personal gifts, or any other item or activity that is not essential to support the CFC is not authorized.
In making the determination, managers should be mindful of all the surrounding circumstances, including the amount of the proposed expenditure, the benefit expected to be gained, the importance to the mission served by the appropriation, prior Departmental practice, and possible public perceptions as to the appropriateness of the expenditure.
For the DoD CFC overseas program, this authority extends to the use of installation-level CFC administrative and logistical support, and the use of military aircraft to transport CFC materials on a "space available" basis.
Solicitation or Participation of Outside Sources (Including Contractor Personnel)
CFC is an authorized solicitation of Federal personnel only. DoD personnel may NOT solicit individuals or entities that are not Federal personnel (warning - this includes contractors and contractor employees working in the Federal workplace) for prizes, other incentives, or contributions. (5 C.F.R. 950.103(g))
Non-Federal personnel, such as credit union employees, contractor employees, other persons employed on Federal premises, as well as retired Federal employees, may make a voluntary contribution to the CFC through cash, check, or money order. While they may make voluntary contributions, they may not be solicited. In addition, they may voluntarily participate in various fundraising efforts, such as purchasing raffle tickets, buying food at food sales, or purchasing services offered as part of a fundraiser.
CFC offices that receive offers of gifts to be used for door prizes, raffles, or other fundraising events, should consult with the cognizant legal counsel to ensure that any donations from outside entities comply with agency gift acceptance regulations.
Solicitation of Prizes from Senior Officials
Fundraisers sometimes ask senior officials to volunteer their status, position, and time as prizes for auctions or other fundraising events. For example, prizes could include a round of golf with the agency head, donuts served to an office by the installation commander, etc. While senior officials may offer such personal contributions, the prerequisite that all contributions to CFC be truly voluntary applies to them as well as less senior personnel, so do not put inappropriate pressure on them to volunteer.
Be careful in our structured, hierarchical environment, as requests from a senior to a junior, particularly if they are in the same chain of command, inherently suggest coercion. Avoid placing senior officials in such a situation.
Fundraisers should ensure that such personal-service prizes are not inappropriate or potentially embarrassing.
Remember that some prizes, such as a commanding officer offering to provide a personal tour of a warship, also involve the use of Government resources, which invoke fiscal considerations.
CFC lotteries or raffles must comply with gambling regulations.
Section 2-302 of the JER and 5 C.F.R. 735.201, as well as several Federal building and grounds regulations, prohibit gambling on Government property or while on official duty. Clever fundraisers, however, have developed lottery-type games, door-prizes, and similar events that are not gambling. To be considered gambling, a game must have three elements: (1) the furnishing of consideration (betting something of value--usually money), (2) in a game of chance, (3) that offers a reward or prize. Events that do not include all three of these elements are not gambling. For example, a drawing using CFC pledge cards, when it is clear that the pledge cards may include no contribution, is not gambling because the participants in the drawing are not required to furnish consideration to enter the drawing. Beware, however, that overzealous fundraisers, in their solicitations, may fail to indicate that no contribution is required.
Fundraising events must be:
Bottom Line: Ethics officials should work with CFC coordinators from the start of the campaign to ensure fundraising events and strategies comply with the spirit and letter of applicable regulations. It is much easier to help design a successful event in the beginning, then tell the CFC coordinator on the day of the event (after the tickets have been sold, prizes obtained, and hall rented) that the fundraiser may not be held.
DISCLAIMER: The purpose of this advisory is to disseminate relevant information and sources of general guidance, policy and law on Government Ethics issues to the Department of Defense ethics community. Advisories are not intended to be and should not be cited as authoritative guidance, DoD policy, or law.