General Rule on Fundraising

Unless permitted by law, regulation or special authority, Department employees may not engage in any form of fundraising activities. This includes but is not limited to conducting raffles, lotteries, bake sales, carnivals athletic events, etc. for charitable organizations.   Department employees may engage in charitable organizations sanctioned by the U.S. Office of Personnel Management (OPM).  This includes the Combined Federal Campaign, Federal agency day care centers and relief organizations assisting the victims of the September 11, 2001 terrorists attacks. 

During the Combined Federal Campaign,  it is acceptable for employees to conduct games and contests (e.g. door decorating contests, quizzes such as trivial pursuit, guessing games (how many jelly beans in a jar)), provided there is no requirement that a donation be made as a condition of participating and the contest prizes are legitimately obtained. A container for donations may be prominently displayed in proximity to where the contest is taking place, as long as it is clearly communicated that donations are voluntary. No suggested amount of an appropriate donation may be made.

Raffles, lotteries, and any other games of chance where employees pay money in exchange for the opportunity to win a prize may not be conducted in association with any OPM permitted fundraising activity.  Accordingly an employee may not be offered a chance to buy anything of value if the offer is based on a monetary contribution in the form of a donation. This applies whether or not there is a predetermined donation amount.

According to 5 CFR 950.102(d), solicitation of employees conducted by organizations composed of civilian employees for benefit of employees among their own members for organizational support or for the benefit of welfare funds for their members is permitted (with agency approval).  This would include the Interior Department Recreation Association, the Indian Arts and Crafts Store, and the Department Daycare centers.

As a result of the September 11, 2001 terrorists attacks, the U.S. Office of Personnel Management has authorized all Executive Department and Agency heads to allow a special solicitation of Federal employees at the workplace.  This special solicitation will allow Federal employees to assist the ongoing relief efforts in New York City and the National Capital Area with a one time cash or check donation, outside the normal Combined Federal Campaign procedures.  See Memorandum.

Additional guidance on acceptable activities for Department employees is provided below:

Ethics Rule: Federal employees may not solicit donations from entities outside the Federal government.

Department employees may not solicit merchandise from local businesses as an incentive to increase contributions to the CFC. Such gifts to Federal employees are prohibited.

This rule does not extend to representatives of Principal Combined Fund Organizations (PCFO), which are local organizations that run the local CFCs on behalf of the designated charities. These representatives are not federal employees and thus are not bound by statutory and regulatory restrictions. PCFO representatives may not offer gifts to CFC key workers to be used as prizes in kickoff ceremonies and other events. OPM is supposed to have advised the PCFOs of this prohibition.


Ethics Rule: It is permissible to hold bake sales, silent auctions, or similar events where items are purchased by employees and proceeds donated to the CFC.  It is also allowable for items donated by Federal employees to be given as door prizes.

The bake sale or silent auction items to be sold must be voluntarily donated by the employee. Management must take no action to pressure employees to donate goods, set official or unofficial levels of organizational participation or accountability, or use the incentive awards program as a quid pro quo to reward employees who are enthusiastic donors and/or purchasers.


Ethics Rule: Appropriated funds may not be used to purchase prizes for CFC events.

The Department of Justice provided a written opinion to an inquiry from its own Human Resources Director on this matter. The Director had asked if appropriated funds could be used to purchase "trinkets" (e.g. pens, mugs, caps, tee shirts, etc.). The general conclusion was that there is not a legal prohibition allowing the agency to use funds to purchase items of such negligible value, given that the items would be used as incentives or awards for CFC key workers and coordinators. However, DOJ went on to say it considered such expenditures imprudent and subject to scrutiny that could put the agency in an embarrassing position for using appropriated money for non-mission purposes.