Question: My son's track team are selling running gear to help pay for their travel to the State Championship. May I sell and display the gear at work?
Answer: An employee may not use nor permit the use of his or her official Government title, position, or any authority associated with his or her office to further a fundraising effort other than those authorized by the agency, or in compliance with CFC regulations. In addition, an employee may not use Government, property, non-public information or time (including the time of a subordinate) in support of a private fundraising effort. However, an employee may give an official speech at a fundraising event if the employee's agency determines that the particular fundraiser is an appropriate forum for the speech, and may use Government resources to prepare the speech. The employee may not endorse the organization or solicit donations. The official speech should not be given in front or behind any material soliciting donations for the fundraiser.
Question: The new CFC coordinator came up with a great idea! We can solicit local businesses for donations for CFC events. Is this permissible?
Answer: 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 PCFOs of this prohibition.
Question: Is it permissible to hold bake sales, silent auctions, or similar events where items are purchased by employees and proceeds donated to the CFC; and is it also allowable for items donated by Federal employees to be given as door prizes?
Answer: 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.
Question: Can appropriated funds be used to purchase prizes for CFC events?
Answer: The Department of Justice provided a written opinion to an inquiry from its own Human Resources Director on this matter. The Director has 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.
Question: Rob has long been active in fundraising efforts for "Race for the Cure." This year, there will be a fundraising run that goes right past the Main Interior Building. Rob wants to form and enter a "Team DOI" to participate in the "Run." Can he do this?
Answer: No. Rob may not enter a "Team DOI" in the "Run." Rob is engaging in official fundraising by creating "Team DOI." Other than through the Combined Federal Campaign, official fundraising is not permitted except where specifically authorized by the Director, U.S. Office of Personnel Management.
Question: A local high school is asking for donations for a celebrity auction. May DOI contribute?
Answer: Sorry. DOI cannot make a donation no matter how good the cause, because it amounts to preferential treatment. It also may run afoul of Combined Federal Campaign regulations and fiscal and property law.