U.S. OFFICE OF PERSONNEL MANAGEMENT OFFICE OF THE INSPECTOR GENERAL OFFICE OF AUDITS AUDIT OF THE 2011 AND 2012 LONG ISLAND COMBINED FEDERAL CAMPAIGNS Report Number 3A-CF-00-14-049 February 11,2015 -- CAUTION - This audit r epo11 h as been distributed to fede1·al officials who are responsible for t he administration of t he audited program . This audit •·eport may contain proprietary data which is protected by feder al law (18 U.S.C. 1905). T herefore, while t his audit r epo11 is available unde1· the Freedom of Information Act and made available to t he public on the OIG webpage (ltttp:/h vww. opm.gov/our-inspector-geu ernl), caution needs to be exer cised before releasing the r epo1·t to the general p ublic as it may contain proprietary inform ation t hat was redacted from the publicly distJ·ibuted copy. EXECUTIVE SUMMARY Auditofthe 2011 and 2012 Long Island Combined Federal C Why Did We Conduct the Audit? What Did We Find? The main objective of the audit was to We detennined that the PCFO an d LFCC need to strengthen their detennine if the Long Island CFC was procedm es and controls related to the Audit Guide, Budget and administered in compliance with Campaign Expenses, Campaign Receipts an d Disbmsements, and 5 CFR 950, including the Eligibility. Om audit identified 11 areas requiring improvement responsibilities ofboth the Principal and one program concern related to the LFCC's lack of oversight Combined Flmd Organization (PCFO) and participation in campaign matters. Specifically, we would and the Local Federal Coordinating like to highlight the following program concerns identified by om Committee (LFCC). audit. What Did We Audit? • LFCC members sent replacements to attend LFCC meetings instead of attending themselves. The Office of the Inspector General • The LFCC did not respond or provide a con ective action has completed a perfotmance audit of plan to the audit issues related to its non-compliance with the responsibilities of the PCFO and the CFC regulations. LFCC in regards to Budget and • The LFCC did not review or authorize the PCFO 's Campaign Expenses, Campaign reimbmsement of actual campaign expenses. Receipts and Disbmsements, • The LFCC included one member who was not a Federal Eligibility, the PCFO 's activities as a employee. Federation, and Fraud and Abuse for • We identified $10,791 in unallowable expenses charged to the 2012 campaign. Additionally, we the 2012 campaign. reviewed the Independent Public • The PCFO incon ectly applied CFC receipts to the wrong Accountant's Agreed-Upon campmgns. Procedm es audit of the 2011 • The PCFO did not make the initial, one-time disbmsement campaign. Om audit was conducted by the required deadline. from June 16 through 20, 2014, at the • The PCFO did not have the required policies and PCFO 's offices in Deer Park, New procedm es for lm-cashed checks. York. Michael R. Esser Assistant Inspector General for Audits ABBREVIATIONS 5 CFR 950 Title 5, Code of Federal Regulations, Part 950 AUP Agreed-Upon Procedures CFC Combined Federal Campaign CFR Code of Federal Regulations IPA Independent Public Accountant LE Loaned Executives LFCC Local Federal Coordinating Committee NALC National Association for Letter Carriers OCFC Office of the Combined Federal Campaign OIG Office of the Inspector General OPM U.S. Office of Personnel Management PCFO Principal Combined Fund Organization USPS United States Postal Service UWLI United Way of Long Island ii TABLE OF CONTENTS P age EXECUTIVE SUMMARY .......................................................................................... i ABBREVIATIONS ...................................................................................................... ii I. I NTRODUCTION AND BACK GROUND ................................................................. I II. OBJECT IVES, SCOPE, AND METHODOLOGY ...................................................3 III. AUDIT FINDINGS AND RECO MMENDATIONS..................................................8 A. AUDIT GUIDE REVIEW ........................................................................................8 1. Agreed-Upon Procedm es Not in Compliance with the Audit Guide .................8 B. BUDGET AND CAMPAIGN EXPENSES ............................................................. lO 1. Unallowable Expenses ....................................................................................... 10 2. Missing and Improper PCFO Application Statements ....................................... 13 3. Untimely PCFO Solicitation .............................................................................. 14 4. Review and Authorization of Expense Reimbmsement .................................... 15 C. CAMPAIGN RECEIPTS AND DISBURSEMENTS ............................................. 17 1. CFC Receipts Applied to the Wrong Campaigns .............................................. 17 2. Policies and Procedm es for Un-Cashed Checks ................................................ 18 3. LFCC Used an Incon ect Method to Establish Minimal Donations ................... 19 4. Application of Pledge Loss for One-Time Disbmsements ................................20 5. Untimely Distribution of One-Time Disbm sements..........................................21 D. ELIGIBILITY ..........................................................................................................22 1. LFCC Member Not a Federal Employee ...........................................................22 E. PCFO AS A FEDERATION ...................................................................................23 F. FRAUD AND ABUSE ............................................................................................23 G. PROGRAM CONCERN RELATED TO LFCC PARTICIPATION ......................24 IV. MAJOR C ONTRIBUTORS TO TillS REPORT ....................................................25 APPENDIX ...................................................................................................................26 REPORT FRAUD, WAST E, AND MISMANAGEMENT ......................................28 I. INTRODUCTION AND BACKGROUND Introduction This final rep01t details the findings and conclusions resulting from our audit of the 2011 and 2012 Long Island Combined Federal Campaigns (CFC). The audit was perf01med by the U.S . Office of Personnel Management's (OPM) Office of the Inspector General (OIG) , as authorized by the Inspector General Act of 1978, as amended. Background The CFC is the sole authorized fund-raising drive conducted in Federal installations throughout the world. In 2012, it consisted of 184 separate local campaign organizations located throughout the United States, including Pue1to Rico and the Virgin Islands, as well as overseas locations. OPM's Office of the Combined Federal Campaign (OCFC) has the responsibility for management of the CFC. This responsibility includes publishing regulations, memoranda, and oth er fonns of guidance to Federal offices and private organizations to ensure that all campaign objectives are achieved. Each CFC is conducted by a Local Federal Coordinating Committee (LFCC) and administered by a Principal Combined Fund Organization (PCFO). The LFCC is responsible for organizing the local CFC; dete1mining the eligibility of local volunta1y organizations; selecting and supervising the activities of the PCFO; encouraging Federal agencies to appoint Loaned Executives (LE), Federal employees who are temporarily assigned to work directly on the CFC, to assist in the campaign; ensuring that employees are not coerced to pruticipate in the campaign; and acting upon any problems relating to noncompliance with the policies and procedures of the CFC. The prima1y goal of the PCFO is to administer an effective and efficient campaign in a fair and even-handed manner aimed at collecting the greatest ammmt of charitable contributions possible. Its responsibilities include training LEs, coordinators, employee keyworkers and volunteers; maintaining a detailed schedule of its actual CFC administrative expenses; prepru·ing pledge f01ms and chru·ity lists; distributing campaign receipts; submitting to an audit of its CFC operations by an Independent Public Accountant (IPA) in accordance with generally accepted auditing standai·ds; cooperating fully with the OIG audit staff during audits and evaluations; responding in a timely and appropriate manner to all inquiries from pruticipating organizations, the LFCC, and the Director of OPM; consulting with federated groups on the operation of the local campaign; and for establishing and maintaining a system of intem al controls. Executive Orders No. 12353 and No. 12404 established a system for administering an annual chru·itable solicitation drive among Federal civilian and milita1y employees. Title 5, Code of 1 Rep01t No. 3A-CF-00-14-050 Federal Regulations, Part 950 (5 CFR 950), the regulations governing CFC operations, sets forth ground rules under which charitable organizations receive Federal employee donations. Compliance with these regulations is the responsibility of the PCFO and the LFCC. The previous audit of the Long Island CFC, which covered the 2004 campaign, was not considered when planning for this audit due to its age. The initial results of our current audit were discussed with the PCFO during our exit conference on June 20, 2014. A draft report was provided to both the PCFO and the LFCC for review and comment on September 24, 2014. Their response to the draft report was considered in preparation of this final report and is included as an Appendix. 2 Report No. 3A-CF-00-14-049 II. OBJECTIVES, SCOPE, AND METHODOLOGY Objective The primaty pmpose of this audit was to detennine compliance with 5 CFR 950. Our audit objective for the 2011 campaign was: Audit Guide Review • To detennine if the IPA completed the Agreed-Upon Procedures (AUPs) as outlined in the CFC Audit Guide. Additionally, our audit objectives for the 2012 campaign were as follows: Budget and Campaign Expenses • To detennine if the PCFO solicitation, application, campaign plan, and budget were in accordance with the regulations. • To determine if the PCFO charged the campaign for interest expenses and if the appropriate commercial loan was used. • To determine if expenses charged to the campaign were actual, reasonable, did not exceed 110 percent of the approved budget, and were properly allocated. Campaign Receipts and Disbursements • To determine if the pledge f01m fonnat was correct and if the pledge f01m rep01i agrees with the actual pledge f01m. • To detetmine if incoming pledge monies (receipts) were allocated to th e proper campaign and if the net fimds (less expenses) were properly distributed to member agencies and federations. • To detetmine if the member agencies and federations were properly notified of the ammmts pledged to them and that donor personal inf01matio n was only released for those who requested the release of infonnation. Eligibility • To detetmine if the charity list (CFC brochure) was properly f01matted and contained th e required inf01mation. • To detetmine if the charitable organization application process was open for the required 30-day period; if the applications were appropriately reviewed and approved; if the applicants were notified of the eligibility decisions in a timely manner; and if th e appeals process for denied applications was followed. • To detetmine if any non-Federal employees or retirees were members of the LFCC. 3 Rep01t No. 3A-CF-00-1 4-049 PCFO as a Federation • To detennine if the ammmts received by the United Way of Long Island (UWLI) as a federation reconciled to those disbmsed by the CFC; if the UWLI properly distributed funds to its federation members; if expenses charged by the UWLI (to its federation members) were documented properly; and if the disbmsements made to the federation members were accmate. Fraud and Abuse • To detennine what policies and procedmes the PCFO has in place related to detecting and preventing fraud and abuse and if they are adequate. Scope and Methodology We conducted this perfonnance audit in accordance with generally accepted government auditing stan dards. Those standar ds require that we plan and perf01m the audit to obtain sufficient and appropriate evidence to provide a reasonable basis for om findings and conclusions based on the audit objectives. We believe that the evidence obtained provides a reasonable basis for om fmdings and conclusions based on the audit objectives. The audit covered campaign years 2011 and 2012. The UWLI, located in Deer Park, New York, served as the PCFO dming both campaigns. The audit fieldwork was conducted at the PCFO's office from June 16 through 20, 2014. Additional audit work was completed at om Cranbeny Township, Pennsylvania, and Washington, D .C. offices. The Long Island CFC received campaign pledges, collected campaign receipts, and incuned campaign administrative expenses for the 2011 and 2012 campaigns as shown below. Campaign I Total Total Administrative Year Pledges I Receipts I Expenses 2011 $719,679 $705 ,417 $154,750 2012 $647,074 $620,535 $158,199 In conducting the audit, we relied to vmying degrees on computer-generated data. Om review of a sample of campaign expenses and supp01ting data, a sample of pledge fonn enu·ies, and the disu·ibutions of campaign conu·ibutions and related bank statements, verifi ed that the computer generated data. used in conducting the audit was reliable. Nothing came to om attention dming om review of the data to cause us to doubt its reliability. We considered the campaign's internal conu·ol stluctme in plaiiDing the audit procedmes. We gained an understanding of the management procedmes and conu·ols to the extent necessmy to 4 Rep01t No. 3A-CF-00-14-049 achieve our audit objectives. We relied primarily on substantive testing rather than tests of internal controls. The audit included tests of accounting records and such other auditing procedures as we considered necessary to determine compliance with 5 CFR 950 and CFC Memoranda issued by the OCFC. To accomplish our objective concerning the 2011 campaign (Audit Guide Review), we compared the IPA’s working papers to the requirements of the CFC Audit Guide to verify that the AUP steps were completed and properly documented. In regard to our objectives concerning the 2012 campaign’s budget and campaign expenses, we performed the following procedures: Reviewed the PCFO’s application to verify that it was complete. Reviewed a copy of the public notice to prospective PCFOs, and the LFCC meeting minutes, to verify that the PCFO was selected in a timely manner. Traced and reconciled amounts on the PCFO’s Schedule of Actual Expenses to the PCFO’s general ledger. Reviewed the PCFO’s budgeted expenses and the LFCC’s approval of the budget, and matched all expenses to supporting documentation. Reviewed the LFCC meeting minutes and verified that the LFCC authorized the PCFO’s reimbursement of campaign expenses. Compared actual expenses to budgeted expenses to determine if they exceeded 110 percent of the approved budget. To determine if the 2012 campaign’s receipts and disbursements were handled in accordance with CFC regulations, we reviewed the following: A judgmental sample of the top 45 high dollar pledge forms, with pledges totaling $107,358, out of a universe of 3,538 pledge forms, with pledges totaling $647,074, from the PCFO’s 2012 campaign pledge form detail schedule and compared the pledge information from the schedule to the actual pledge forms. Distribution checks for a sample of 10 federations and organizations, totaling $274,197 in disbursed funds, out of a universe of 195 federations and organizations, totaling $462,336, to verify that the appropriate amount was distributed in a timely manner. We judgmentally 5 Report No. 3A-CF-00-14-049 selected the 10 agencies receiving the largest total disbursements which happened to include the PCFO as a federation. One-time disbursements to verify that the PCFO properly calculated pledge loss and disbursed funds in accordance with the ceiling amount established by the LFCC. The PCFO’s most recent listing of outstanding checks to verify that the PCFO was following the guidance issued by the OCFC. A sample of 5 pledge notification and donor letters (from a universe of 71) to verify that the PCFO accurately notified the organizations of the amounts due to them and properly released the donor information by the date required by the Federal regulations. We judgmentally selected this sample by picking the first five organizations from our high dollar pledge form sample in which a donor indicated they wanted their contact information released. CFC receipts and distributions from the PCFO’s campaign bank statements, campaign receipts and agency disbursements, and campaign expense support to verify whether the PCFO accurately recorded and disbursed all campaign receipts and disbursements. All bank statements used by the PCFO to verify that the PCFO was properly accounting for and distributing funds. The PCFO’s cutoff procedures and bank statements to verify that funds were allocated to the appropriate campaign. To determine if the LFCC and PCFO were in compliance with CFC regulations regarding eligibility for the 2012 campaign, we reviewed the following: The public notice to prospective charitable organizations to determine if the LFCC accepted applications from organizations for at least 30 days. Campaign charity lists to determine if they contained all required information. The PCFO’s responses to questions regarding the process and procedures for the application evaluation process. A sample of 8 local organization applications (from a universe of 49 local organization applications) to determine if the organizations met the requirements for participating in the CFC and if the LFCC sent the eligibility letters by the date required by the Federal 6 Report No. 3A-CF-00-14-049 regulations. We judgmentally selected the top three local federations (including the PCFO) and the top five local independent organizations, based on the amount of payments from the Agency Payment Schedule, as designated in the 2012 campaign. The LFCC’s processes and procedures for responding to appeals from organizations. The LFCC member listings to verify that all members were active Federal employees. To determine if the UWLI was in compliance with the CFC regulations as a federation for the 2012 campaign, we reviewed the following: Data reported on the CFC Receipts Schedule, with supporting documentation, to verify that receipts were properly recorded. The CFC Receipts Schedule and the Federation Distribution Schedule, to determine if the percentage of receipts assigned to each organization agreed to the percentage of pledges for that organization. Distribution checks for a sample of 6 federation member agencies, with disbursements totaling $42,304, out of a universe of 60, totaling $61,492, to verify that the appropriate amount was distributed in a timely manner. We judgmentally selected the six federation members with the highest disbursements, excluding the PCFO as a federation. The PCFO’s annual report and agreements with its member agencies to determine if member fees were reasonable and supported. Finally, to determine if the policies and procedures related to the detection and prevention of fraud and abuse were adequate, we reviewed the PCFO’s responses to our fraud and abuse questionnaire. The samples mentioned above, that were selected and reviewed in performing the audit, were not statistically based. Consequently, the results could not be projected to the universe since it is unlikely that the results are representative of the universe taken as a whole. 7 Report No. 3A-CF-00-14-049 III. AUDIT FINDINGS AND RECOMMENDATIONS A. AUDIT GUIDE REVIEW 1. Agreed-Upon Procedures Not in Compliance with the Audit Guide Procedural The IPA utilized by th e LFCC to complete th e AUP audit of the 2011 campaign did not perf01m its review in accordance with the requirements of the Audit Guide. The Audit Guide contains specific procedm es to be followed dming the examination by the IPA with the primmy objective of dete1mining LFCC and PCFO complian ce with 5 CFR 950 and OPM guidance. We reviewed the IP A's work papers an d rep01i in detail to detennine if th e IPA followed the AUPs as stated in th e Audit Guide an d if th e fmdings were properly rep01ied. Om review identified two m·eas where th e IPA did not comply with the requir ements of the Audit Guide. Specifically, we identified the following issues: The IPA did not complete all of the audit steps. • P CFO as a Federation, Steps 1-8 were to be completed by the IPA if th e PCFO served as a federation, eith er in its own local campaign or in other adjacent campaigns dming the 2011 CFC. The IPA did not complete these steps, stating that the PCFO did not pa1iicipate as a federation. However, based on om review, we found that the PCFO served as a federation in its own local campaign an d three other adjacent campaigns. • Receipts and Disbursements of Funds, Step 7(a-e) required the IPA to review one time disbmsements and recalculate the 2011 pledge loss. Specifically, th e AUP step instructed, "If the campaign made one-time disbmsements, then perfonn the following procedm es; othe1w ise, skip to #8 ." The IPA did not complete these steps, stating that they were not applicable. However, we found that the 2011 campaign did have one-time disbursements. The IPA failed to rep01i noncompliance in th e following m·eas: • LFCC Processes, Step l (a-c) required the IPA to review the PCFO 's application to administer the 2011 campaign for a signed statement by an appropriate official of the PCFO that it will administer the CFC fairly and equitably; conduct the applicant's non-CFC operations sepm·ately from the campaign operations; an d that it will be 8 Rep01i No. 3A-CF-00-14-049 subject to the decisions and supervision of the LFCC and/or Director. The IPA’s work papers documented that the PCFO’s application included a signed statement from the President and Chief Executive Officer that the PCFO would administer the CFC appropriately. However, the application did not expressly include the above- mentioned required language in the statement. Furthermore, Step 1(d) required the IPA to review the PCFO’s application to verify it did not include a statement that the PCFO was subject to the provisions of 5 CFR 950.403, as this has been removed from the regulations. However, the PCFO’s application included a statement that it was subject to the provisions of 5 CFR 950.403. LFCC Processes, Step 8 required the IPA to obtain a list of LFCC members, their agency affiliations, their contact information, and the LFCC meeting minutes for calendar years 2011 through 2013 to determine if all LFCC members were current Federal employees and were active participants at LFCC meetings. The IPA stated that it confirmed that all members listed on the meetings’ minutes were Federal employees and, as of the last day of field work, all were deemed to be active employees. However, our audit work revealed that one LFCC member had not been a Federal employee since 2004. As a result of not completing the reviews required by the AUP and failing to report instances of noncompliance, the IPA did not provide OPM’s OCFC and the LFCC with the assurance that the PCFO was operating the CFC in accordance with the regulations. Additionally, based on the errors made in its review, the IPA may not have fully understood the CFC and its related regulations when completing the AUPs. Recommendation 1 We recommend that the OCFC and the LFCC ensure that the IPA fully understands the CFC and its related regulations so that it will complete the Audit Guide’s AUPs correctly and completely. LFCC and PCFO Response: The LFCC and PCFO agree that the IPA needs to fully understand the CFC and its related regulations to complete the Audit Guide’s AUP correctly and completely. OIG Comments: To help ensure that the IPA fully understands the CFC and its related regulations, we suggest that as part of their corrective action plan, the LFCC and PCFO provide the IPA with a copy 9 Report No. 3A-CF-00-14-049 of th e regulations (5 CFR 950) in effect dming the scope of the audit along with copies of any relevant memoranda issued by the OCFC. Recommendation 2 We recommend that the OCFC ensmes that the LFCC an d the PCFO meet with the IPA prior to an d dming the AUP engagement to discuss the Audit Guide steps, an d encom age the IPA to ask questions of the OCFC if it is lmsm e of how to complete any of th e required procedm es. LFCC and PCFO Response: The LFCC and PCFO agree and "will meet with the IPA prior to and dming the AUP engagement to make sm e they understand how to complete any of the required procedmes. " OIG Comments: We want to emphasize that if the PCFO, LFCC, or IPA needs any clarification for CFC matters, they should ask for guidan ce from the OCFC. B. BUDGET AND CAMPAIGN EXPENSES 1. Unallowable Expenses $10,791 Dm ing om review of campaign expenses, we fmmd that the PCFO inconectly charged $10,791 for unallowable expenses th at were eith er lmauth orized, lmreasonable, or did not relate to the 2012 CFC. The specific expenses included: • $7,056 in unauthorized food and beverage expenses related to meetings and training. 5 CFR 950.105(b) states that the PCFO is responsible for The PCFO conducting "an effective and efficient campaign in a fair and even inappropriately handed manner aimed at collecting the greatest amount of char~ed the CFC charitable conu·ibutions possible." food and beverage expenses that are considered Additionally, OPM's Directive Prohibiting th e Approval of Costs unallowable by IncmTed for Meals and Ente1iainment, dated March 28, 2012, OPM. states that past guidan ce did not authorize the expenditm e of funds 10 Rep01i No. 3A-CF-00-14-049 for meals served as a convenience to members of the LFCC, the PCFO, loaned executives, or CFC volunteers. Our review identified three food and beverage expenses related to the September 7, 2012, kickoff and training event that amounted to $6,705, three food and beverage expenses related to CFC meetings from July through September 2012, totaling $204, and one food and beverage expense for $147 related to a second kickoff event held on November 20, 2012. The PCFO explained that it did not fully understand OPM’s guidance related to meals and entertainment expenses. $3,125 in unreasonable raffle expenses. According to 5 CFR 950.602(b), “Raffle prizes should be modest in nature and value. Examples of appropriate raffle prizes may include opportunities for lunch with Agency Officials, agency parking spaces for a specific time period, and gifts of minimal financial value. Any special CFC fundraising event and prize or gift should be approved in advance by the Agency’s ethics official.” Notwithstanding the regulation’s explicit statement that raffle prizes should be modest in nature and value, raffle prizes were purchased that ranged in price from $515 to $99. The items included a flat panel television ($500), notebook computer ($500), gift cards (one $515 card, one $200 card, and nine $100 cards), two MP3 players ($165 and $116), musical theater tickets ($130), and an eBook reader ($99). The PCFO was unaware that these larger prizes would be considered unreasonable and emphasized that the LFCC considered the prize amounts to be reasonable. $438 in mileage expenses that were attributable to the 2013 campaign. 5 CFR 950.106(b) states that “The PCFO may only recover campaign expenses from receipts collected for that campaign ….” In other words, the PCFO may only be reimbursed for its 2012 campaign expenses from the funds received for the 2012 campaign. Our review identified 31 mileage expenses, totaling $438, related to the 2013 campaign that were accidently charged to the 2012 campaign. The PCFO explained that the error was due to including mileage incurred from April 1, 2013 through June 30, 2013 as part of the 2012 campaign expenses, when it should have been charged to the 2013 campaign. 11 Report No. 3A-CF-00-14-049 $172 for a Stuff-A-Bus program that was unrelated to the CFC. 5 CFR 950.106(a) states, that “The PCFO shall recover from the gross receipts of the campaign its expenses… reflecting the actual costs of administering the local campaign.” The UWLI purchased supplies from Target for its Stuff-A-Bus toy drive and accidently charged the amount to the CFC as a PCFO expense. This amount should have been charged to the UWLI’s Stuff-A-Bus program since it was unrelated to the CFC. As a result of charging the CFC these unallowable expenses, $10,791 was not disbursed to charities participating in the 2012 campaign. Recommendation 3 We recommend the OCFC and LFCC require the PCFO to distribute $10,791 in unallowable expenses as undesignated funds to the charities participating in the 2012 campaign and charge the 2013 campaign $438 for mileage expenses related to the 2013 CFC. LFCC and PCFO Response: The LFCC and PCFO agree that the PCFO will distribute $10,791 as undesignated funds to charities participating in the 2012 campaign and charge the 2013 campaign $438 for mileage expenses. Recommendation 4 We recommend that the OCFC and the LFCC instruct the PCFO to stop charging food and beverages to the CFC in accordance with OPM’s Directive Prohibiting the Approval of Costs Incurred for Meals and Entertainment. LFCC and PCFO Response: The LFCC and PCFO state that “The PCFO… will no longer charge cost of food and beverages to the CFC.” Recommendation 5 We recommend that the OCFC and the LFCC ensure that the PCFO develops and implements policies and procedures to ensure that prizes and gifts are modest in nature and value in accordance with 5 CFR 950.602(b). 12 Report No. 3A-CF-00-14-049 LFCC and PCFO Response: The LFCC and PCFO state that “The PCFO has developed policies and procedures to ensure that any prize or gift is appropriate in accordance with CFC regulations.” OIG Comments: We recommend that the OCFC reviews a copy of the PCFO’s updated policies and procedures for prizes and gifts to ensure compliance with CFC regulations. Recommendation 6 We recommend that the OCFC and LFCC require the PCFO to develop and implement policies and procedures to ensure that only those expenses related to the CFC are charged to the campaign and that the PCFO properly matches expenses to receipts for each campaign period. LFCC and PCFO Response: “The LFCC will ensure that the PCFO implements policies and procedures so that only expenses related to CFC are charged to each campaign.” 2. Missing and Improper PCFO Application Statements Procedural The LFCC selected the UWLI as the PCFO for the 2012 campaign even though the PCFO’s signed application was missing several pledge statements and contained improper language. 5 CFR 950.105(c)(2) states that any organization wishing to be selected as the PCFO must submit an application that includes “A statement signed by the applicant’s local director or equivalent pledging to: (i) administer the CFC fairly and equitably, (ii) conduct campaign operations, such as training, kick-off and other events, and fiscal operations, such as banking, auditing, reporting and distribution separate from the applicant’s non-CFC operations, and (iii) abide by the directions, decisions, and supervision of the LFCC and/or Director.” Additionally, the PCFO is no longer required to include a statement that it’s subject to the provisions of 5 CFR 950.403. Federal Register Vol. 70, published November 20, 2006, removed 5 CFR 950.403 from the regulations. 13 Report No. 3A-CF-00-14-049 We reviewed the PCFO’s application to ensure that it was dated prior to the close of the announcement, signed by an appropriate official, contained all of the required language per 5 CFR 950.105(c), and did not include a statement that the PCFO was subject to the provisions of 5 CFR 950.403. Our review found that the PCFO’s application language did not include the required pledge statements. Additionally, the PCFO’s application included a statement that it was subject to the provisions of 5 CFR 950.403, which should have been removed. The PCFO stated that it was unaware that specific language had to be used. It was also unaware that 5 CFR 950.403 was removed from the regulations. The LFCC did not respond to our inquiry on this issue during fieldwork. As a result of the missing and improper application statements, the LFCC selected a PCFO that did not fully pledge its commitment to administer the campaign according to the Federal regulations. Additionally, the PCFO subjected itself to regulations that were no longer applicable. Recommendation 7 We recommend that the OCFC ensure that the LFCC understands its responsibilities in selecting a PCFO for future campaigns, to include reviewing PCFO applications for completeness and verifying that all of the required language is included and accurate. LFCC and PCFO Response: The LFCC and PCFO agree with our finding and recommendation. The LFCC stated that it understands its responsibility in reviewing PCFO agreements, and it will verify that all of the required language is included and accurate. 3. Untimely PCFO Solicitation Procedural The LFCC began soliciting PCFO applications after the deadline set by OPM. OPM’s 2011/2012 CFC Calendar of Events lists December 15, 2011, as the deadline for the LFCC to begin soliciting PCFO applications. We reviewed the LFCC’s public notice to solicit PCFO applications for the 2012 campaign to determine if the application period was timely and open for the required number of calendar days. We found that the LFCC’s solicitation for PCFOs was published on December 17, 2011, which was two calendar days after the deadline set by OPM. 14 Report No. 3A-CF-00-14-049 The PCFO stated that the employee who places the adve1iisement was out with an illness th at week, thereby causing th e delay. The LFCC did not respond to our inquny on this issue during fieldwork. As a result of not soliciting PCFOs by the deadline published in the CFC Calendar of Events, potential applicants may not have read the solicitation and applied to serve as the PCFO. Recommendation 8 We recommend that the OCFC dn·ect the LFCC to develop and implem ent policies and procedures for PCFO solicitations that adhere to th e dates set f01ih in the CFC Calendar of Events. LFCC and PCFO Response: The LFCC and PCFO state th at "The PCFO will adhere to th e dates set f01ih in the CFC Calendar of Events." OIG Comments : Because the LFCC and PCFO did not fully address our recommendation, the OCFC should verify that the LFCC implements policies and procedures for PCFO solicitations that adhere to the dates set f01ih in the CFC Calendar of Events. 4. Review and Authorization of Expense Reimbursement Procedural The LFCC did not review or authorize the PCFO 's reimbursement of actual campaign expenses. 5 CFR 950.104(b)(17) states that it's the responsibility of the LFCC to ThePCFO authorize th e PCFO's reimbursement of only those campaign expenses reimbursed itself for campaign that are legitimate CFC costs and are adequately documented. expenses without authorization from Additionally, 5 CFR 950.106(a) states that "The PCFO shall recover the LFCC. fr om the gross receipts of the campaign its expenses, approved by the LFCC, reflecting the actual costs of administering the local campaign." Finally, CFC Memorandum 2008-09 states that the approval of actual expenses by the LFCC is separate fr om the approval of the expense budget. "The LFCC must review actual 15 Rep01i No. 3A-CF-00-14-049 expenses, authorize full or partial reimbursement, and document this authorization in its meeting minutes.” We reviewed the LFCC’s meeting minutes to determine if the LFCC reviewed and authorized the PCFO’s reimbursement of legitimate CFC expenses. Our review found that there was no record of the LFCC reviewing or authorizing the reimbursement of the PCFO’s 2012 CFC expenses. The PCFO stated that it didn’t realize the reimbursement amounts and dates needed to be approved by the LFCC and documented in the minutes. The LFCC did not respond to our inquiry on this issue during fieldwork. As a result of not reviewing or authorizing the PCFO’s reimbursement of actual campaign expenses, the LFCC ran the risk of unrelated expenses being charged to the organizations and federations in the campaign, thereby reducing the contributions due to them. Recommendation 9 We recommend that the OCFC direct the LFCC to implement policies and procedures to document its review of the PCFO’s actual campaign expenses, which should be supported by itemized receipts and invoices, to ensure that the expenses are allowable and applicable to the campaign. LFCC and PCFO Response: “The LFCC will implement policies to document its review of the PCFO’s actual campaign expenses.” Recommendation 10 We recommend that the OCFC direct the LFCC to implement policies and procedures to document its authorization and approval of the PCFO’s reimbursement of actual campaign expenses. LFCC and PCFO Response: “The LFCC will document its authorization and approval of the PCFO’s reimbursement of actual campaign expenses.” 16 Report No. 3A-CF-00-14-049 OIG Comments: Because the LFCC did not fully address our recommendation, the OCFC should verify that the LFCC implements policies and procedures to ensure that its approval of the PCFO's reimbursement of actual campaign expenses is documented in its meeting minutes. C. CAMPAIGN RECEIPTS AND DISBURSEMENTS 1. CFC Receipts Applied to the Wrong Campaigns Procedural The PCFO inconectly applied $23 ,144 in 2013 CFC receipts to the 2012 campaign and $346 in 2012 CFC receipts to the 2011 campaign. 5 CFR 950.901(d) states that the CFC payroll allotments will be authorized in one year tenns. The te1m authorizations will be in effect for one full year (26, 24, or 12 pay periods depending on the allotter 's pay schedule) stmiing with the first pay period beginning in Janumy and ending with the last pay period that begins in December. Additionally, CFC Memorandum 2006-5 requires PCFOs to track CFC receipts by payroll office to ensure that receipts are credited to the appropriate campaign. We reviewed the CFC bank statements to dete1mine if the PCFO properly tracked CFC receipts and applied them to the con ect campaign. Our review found that the PCFO inconectly applied $23,144 in CFC receipts from the 2013 campaign to the 2012 campaign. We also found that the PCFO inconectly applied $3 46 in CFC receipts from the 2012 campaign to the 2011 campaign. As a result of both actions, the PCFO over-disbursed $22,798 in CFC funds during the 2012 campaign . The PCFO over disbursed $22,798 Notwithstanding the requirements of 5 CFR 950.901(d) and CFC in CFC funds Memorandum2006-5 , the PCFO inconectly used the end of Janumy durin2 the 2012 as the basis to allocate CFC receipts to the 2012 campaign . The campaign, creating PCFO stated that it will be more diligent in recognizing th e shortages in submission timing differences used by the Federal entities, and disbursements received by appropriately record receipts by campaign year. participants in another campaign. As a result of not following the directives issued by the OCFC to properly accmmt for receipts by campaign year, the PCFO ended up over-disbursing funds to the 2012 campaign and creating a sh01iage in ftmds for other campaigns. We will not question the amounts from this fmding since the ftmds were ah·eady disbursed. 17 Rep01i No. 3A-CF-00-14-049 Recommendation 11 We recommend that the OCFC direct the LFCC to ensure th at th e PCFO develops and implements policies an d procedures to begin tracking CFC receipts by payroll office and to accurately accmmt for end of the year payroll receipts. LFCC and PCFO Response: The LFCC and PCFO agree. "The LFCC will ensure th at th e PCFO has policies in place to accurately track CFC receipts by payroll office and accurately account for end of year payroll receipts." 2. Policies and Procedures for Un-Cashed Checks Procedural The PCFO does not have written policies and procedures for un-cashed checks as required by CFC Memorandum 2006-5. Section C of CFC Memorandum 2006-5 states that the PCFO must develop an d follow policies an d procedures regarding un-cashed checks. The policy should be documented and implemented after a check has gone un-cashed for six months. The procedures should include at least three documented follow-up attempts to reach the payee by phone or e-mail. In spite of repeated IPA warnings in its During our review of prior audits, we found that the IPA has AUP audits of the continuously reported the PCFO 's failure to adopt policies and campaign, the procedures for un-cashed checks. Our review of the 2012 campaign PCFO has still not confnm ed that the PCFO still doesn 't have written policies and developed policies procedures for un-cashed checks. When we inquired why there was no and procedures for documented policy, the PCFO responded, "Since finance hasn ' t un-cashed checks experienced a material issue with outstanding checks they did not see a as required by the re2ulations. need to develop a fonnal policy." By not following th e guidance to develop an d implement procedures for lm-cashed checks, we cannot verify or assess how the PCFO handles outstan ding checks. Additionally, there is a significant risk th at charities whose checks ar e lost, misplaced, and not cashed will never receive ftmds due to inadequate follow-up attempts made by the PCFO, and there is the risk that ftmds may not be retmned to the CFC. 18 Rep01t No. 3A-CF-00-14-049 Recommendation 12 We recommend that the OCFC and the LFCC verify that the PCFO documents its policies and procedures for un-cashed checks in accordance with CFC memorandum 2006-5. LFCC and PCFO Response: “The PCFO will develop and document its procedures for un-cashed checks in accordance with CFC memorandum 2006-5.” OIG Comments: We would like to remind the OCFC and LFCC that this has been a finding identified by the IPA multiple times. The PCFO has failed to implement a corrective action plan over the last several years. If the PCFO continues to show disregard for the regulations governing the CFC, then the OCFC and LFCC should take appropriate steps, up to considering terminating the PCFO agreement and finding a replacement, or seeking to merge this campaign with another campaign. 3. LFCC Used an Incorrect Method to Establish Minimal Donations Procedural The LFCC incorrectly used net disbursement amounts instead of gross pledges to define minimal donations for charities receiving one-time disbursements. CFC Memorandum 2008-09 states the sum of the gross pledges determines whether a donation is minimal and subject to a one-time disbursement. If campaigns were using a different method for determining the minimal donation amount for one-time disbursements, then they should have corrected their determinations starting with the 2008 campaign. While reviewing the meeting minutes, we found that the LFCC approved one-time disbursements to organizations and federations that had a maximum disbursement amount of $1,200 during its December 14, 2012 meeting. One-time disbursements should have been approved based on gross pledges, not disbursement amounts. The PCFO acknowledged that net disbursements were used instead of gross pledges and stated that it will work with the LFCC to correct this error. The LFCC did not respond to our inquiry on this issue during fieldwork. Because the LFCC used an incorrect method to establish minimal donations for one-time disbursements, we determined that the PCFO made one-time disbursements to 11 charities 19 Report No. 3A-CF-00-14-049 that should have received funds via quarterly or monthly distributions. Additionally, these 11 organizations had a lower pledge loss withheld from their disbursements than if they received quarterly or monthly distributions. Recommendation 13 We recommend that the OCFC direct the LFCC to change its method of defining minimal donations for one-time disbursements by basing it on gross pledges instead of net disbursement amounts. LFCC and PCFO Response: “The LFCC will define minimal donations for one-time disbursements based on gross pledges.” 4. Application of Pledge Loss for One-Time Disbursements Procedural The PCFO incorrectly applied pledge loss to the organizations and federations receiving one-time disbursements during the 2012 campaign. According to 5 CFR 950.901(i)(3), the “PCFO may deduct the proportionate amount of each organization’s share of the campaign’s administrative costs and the average of the previous 3 years pledge loss from the one-time disbursement.” Additionally, CFC Memorandum 2008-9 provides guidance and detailed instructions to PCFOs regarding the calculation and application of pledge loss to gross pledges, prior to any estimated expenses being withheld. Using the pledge and receipt totals reported by the PCFO to OPM, we calculated the average of the previous three campaigns’ pledge loss and compared our calculation to that of the PCFO to determine if its calculation was correct. Overall, we found that the PCFO miscalculated the pledge loss that was applied to the organizations and federations receiving one-time disbursements by $1,247. The difference was due to the PCFO’s CFC software calculating pledge loss net of expenses. The effects of applying pledge loss after expenses resulted in higher one-time disbursements and lower monthly disbursements. We are not recommending an adjustment for $1,247 since pledge loss is an estimated amount and the disbursements already took place. 20 Report No. 3A-CF-00-14-049 Recommendation 14 We recommend that the OCFC and LFCC direct th e PCFO to develop and implement policies an d procedm es that incmporate the directives of CFC Memorandum 2008-9 regar ding the calculation an d application of pledge loss to one-time disbmsements . LFCC and PCFO Response: The LFCC and PCFO agree. "The PCFO will develop procedm es regar ding the calculation and application of pledge loss to one-time disbm sements according to the requirements of CFC Memorandum 2008-9." 5. Untimely Distribution of One-Time Disbursements Procedural The PCFO did not m ake the initial disbmsement for one-time disbmsements by the deadline set in the CFC Calendar of Events. The CFC Calendar of Events established a deadline of April 1, 2013 , for all campaigns to begin disbmsement of the 2012 campaign funds. Additionally, CFC Memorandum 2008-9 states that one-time disbmsements must be made with the first distribution for the campaign. If the campaign opts not to mak e one-time disbmsements, then all organizations with pledges must receive disbmsements with each quruierly or monthly distribution . Campaigns ru·e not permitted to hold disbmsements until th e amount reaches a pre-determined "minimum check" ammmt. We reviewed the PCFO 's Receipt and Disbmsement Schedule and the disbmsement check supp01i to determine if the PCFO m ade the initial distribution by SomeCFC April 1, 2013. Although the PCFO issued its monthly disbmsements charities were paid beginning in March 2013, the one-time disbmsements were not six months late due distributed until September 2013, five months after the CFC to the PCFO's non- Calendru· of Events deadline and six months after the initial compliance with distribution . The PCFO stated th at this en or occmTed as a result of the Calendar of Events deadlines mislmderstanding OPM 's directive. for initial disbursements. As a result of the PCFO not distributing the one-time disbmsements with the first distribution in Mru·ch 2013, those organizations an d federations receiving minimal donations were paid six months late. 21 Rep01i No. 3A-CF-00-14-049 Recommendation 15 We recommend that the OCFC and LFCC require the PCFO to develop and implement policies and procedures to ensure adherence to the CFC Calendar of Events deadlines and CFC Memorandum 2008-9 for the timely distribution of one-time disbursements. LFCC and PCFO Response: The LFCC and PCFO state that “The PCFO will adhere to the CFC Calendar of Events deadlines as well as CFC Memorandum 2008-9 for one time disbursements.” OIG Comments: Because the LFCC did not fully address our recommendation, the OCFC should verify that the PCFO implements policies and procedures to ensure adherence to the CFC Calendar of Events deadlines and CFC Memorandum 2008-9 for the timely distribution of one-time disbursements. D. ELIGIBILITY 1. LFCC Member Not a Federal Employee Procedural We identified one LFCC member listed in both the 2012 CFC Charity List and the LFCC roster who was not an active Federal employee. 5 CFR 950.101 defines the LFCC as the group of Federal officials designated by the Director to conduct the CFC in a particular community. During our pre-audit review, we obtained a roster from the LFCC to determine if all LFCC members were active Federal employees. We then matched this LFCC roster with the list of LFCC members included in the 2012 CFC Charity List and found that both lists included one LFCC member who was a retired Federal employee since 2004. The list of LFCC members that included the non-Federal official was published and distributed across the campaign in the 2012 CFC Charity List. Without active Federal employees serving as LFCC members, the CFC loses its Federal oversight and becomes susceptible to misguided, poor, and uninformed decisions. 22 Report No. 3A-CF-00-14-049 Recommendation 16 We recommend that the OCFC develops and implements regulations and/or memoranda which stipulate that LFCC members be comprised of active Federal employees. LFCC and PCFO Response: Although a response from the LFCC and PCFO was not required for this recommendation, they stated that “The NALC is the largest union of federal employees on Long Island and their President has always been invited to be part of the CFC in a supportive ad hoc role. Retirees will not be a part of the LFCC. NALC will continue to support and work with our USPS Division Chair.” Recommendation 17 We recommend that the OCFC direct the LFCC to implement policies and procedures to ensure that its members are only active Federal employees. LFCC and PCFO Response: “The LFCC will ensure its members are active federal employees.” OIG Comments: Because the LFCC did not fully address our recommendation, the OCFC should verify that the LFCC implements policies and procedures to ensure that its members are only active Federal employees. E. PCFO AS A FEDERATION Our review of the PCFO’s activities as a federation showed that it complied with the applicable provisions of 5 CFR 950. F. FRAUD AND ABUSE Our review of the PCFO’s policies and procedures for fraud and abuse indicated that they were sufficient to detect and deter potential fraud and abuse activities. 23 Report No. 3A-CF-00-14-049 G. PROGRAM CONCERN RELATED TO LFCC PARTICIPATION In addition to the findings identified in this report, we ar e concemed with the LFCC pa1iicipation in CFC matters. Specifi cally, we identified the following problems with the LFCC : 1. Several LFCC members, who are Federal agency heads and directors , sent replacements to attend LFCC meetings instead of attending themselves. As a result, imp01iant decisions and votes were not properly recorded during LFCC meetings. 2. The LFCC was invited to both the entrance and the exit conference, but did not respond to these invitations or attend either meeting. The LFCC's lack of LFCC members pmiicipation and communication during our audit led to us relying fully sent replacements, on the PCFO for supp01i . which may not have been aware of 3. The LFCC was sent multiple audit inquiries to help us identify the the LFCC's cause of the findings related to its non-compliance with program responsibilities, to regulations. However, responses were not provided by the LFCC and attend meetings where important the responsibility was passed on to the PCFO to provide a response and decisions about con ective action plan. CFC matters were made. Recommendation 18 As a result of these issues, the OIG (with supp01i from the PCFO) recommends that the OCFC replace the LFCC with members who can be actively involved in the CFC. LFCC members do not need to be agency heads. Instead, those replacements (Federal employees) that the LFCC members sent to attend the LFCC meetings could replace the cmTent LFCC. This will allow accurate record keeping and voting related to CFC issues and LFCC meetings. LFCC and PCFO Response: "The USPS has always been the Chair for the LFCC for the Long Island Combined Federal Campaign. They have the most federal employees on Long Island 67% with the next closest federal agency having 17%. We traditionally have a Co-Chair from one of the other federal agencies. The cmTent Co-Chair is from Veterans Affairs. Due to scheduling difficulties our cmTent LFCC Chair was unable to attend the entrance or exit interviews for this audit. This should not be taken as a sign of any disrespect for the OPM CFC Audit process or the LFCC's role to ensure implementation of the CFC by the PCFO in accordance with all CFC regulations." 24 Rep01i No. 3A-CF-00-14-049 IV. MAJOR CONTRIBUTORS TO THIS REPORT Special Audits Group Auditor , Group Chief, Senior Team Leader 25 Rep01t No. 3A-CF-00-14-049 APPENDIX November 4, 2014 Deleted by OIG – Not Relevant to Final Report Special Audits Group Office of the Inspector General Washington, DC 20415 Deleted by OIG – Not Relevant to Final Report The following is a joint response from the Long Island Combined Federal Campaign and PCFO to the draft report we received detailing the results of your 2011 and 2012 audit. Recommendation 1: We agree that the IPA needs to fully understand the CFC and its related regulations to complete the Audit Guide's AUP correctly and completely. Recommendation 2: We agree that the LFCC and PCFO will meet with the IPA prior to and during the AUP engagement to make sure they understand how to complete any of the required procedures. . Recommendation 3: We agree that the PCFO will distribute $10,791 as undesignated funds to charities participating in the 2012 campaign and charge the current campaign for $438 for mileage expenses. Recommendation 4: Already implemented. The PCFO based on CFC regulations will no longer charge cost of food and beverages to the CFC. Recommendation 5: Already implemented. The PCFO has developed policies and procedures to ensure that any prize or gift is appropriate in accordance with CFC regulations. Recommendation 6: We agree that the LFCC will ensure that the PCFO implements policies and procedures that only expenses related to CFC are charged to each campaign. Recommendation 7: We agree the LFCC does understand its responsibility in reviewing PCFO agreements and will confirm completeness and verify that all the required language is included and accurate. Recommendations 8: Already implemented. The PCFO will adhere to the dates set forth in the CFC Calendar of Events. Recommendation 9: We agree the LFCC will implement policies to document its review of the PCFO's actual campaign expenses. Recommendation 10: We agree that the LFCC will document its authorization and approval of the PCFO's reimbursement of actual campaign expenses. 26 Report No. 3A-CF-00-14-049 Recommendation 11: We agree the LFCC will ensure the PCFO has policies in place to accurately track CFC receipts by payroll office and accurately account for end of year payroll receipts. Recommendation 12: We agree that the PCFO will develop and document its procedures for un- cashed checks in accordance with CFC memorandum 2006-5. Recommendation 13: Already implemented. The LFCC will define minimal donations for one- time disbursements to be based on gross pledges. Recommendation 14: We agree the PCFO will develop procedures regarding the calculation and application of pledge loss to one-time disbursements according to the directive of CFC Memorandum 2008-9. Recommendation 15: Already implemented. The PCFO will adhere to the CFC Calendar of Events deadlines as well as CFC Memorandum 2008-9 for one time disbursements. Recommendation 16: Already implemented. The NALC is the largest union of federal employees on Long Island and their President has always been invited to be part of the CFC in a supportive ad hoc role. Retirees will not be a part of the LFCC. NALC will continue to support and work with our USPS Division Chair. Recommendation 17: Already implemented. The LFCC will ensure its members are active federal employees. The USPS has always been the Chair for the LFCC for the Long Island Combined Federal Campaign. They have the most federal employees on Long Island 67% with the next closest federal agency having 17%. We traditionally have a Co-Chair from one of the other federal agencies. The current Co-Chair is from Veterans Affairs. Due to scheduling difficulties our current LFCC Chair was unable to attend the entrance or exit interviews for this audit. This should not be taken as a sign of any disrespect for the OPM CFC Audit process or the LFCC's role to ensure implementation of the CFC by the PCFO in accordance with all CFC regulations. Submitted By: LFCC Chair District Manager/Executive in Charge United States Postal Service Theresa A. Regnante, President & CEO United Way of Long Island 27 Report No. 3A-CF-00-14-049 Report Fraud, Waste, and Mismanagement Fraud, waste, and mismanagement in Government concerns everyone: Office of the Inspector General staff, agency employees, and the general public. We actively solicit allegations of any inefficient and wasteful practices, fraud, and mismanagement related to OPM programs and operations. You can report allegations to us in several ways: By Internet: http://www.opm.gov/our-inspector-general/hotline-to- report-fraud-waste-or-abuse By Phone: Toll Free Number: (877) 499-7295 Washington Metro Area: (202) 606-2423 By Mail: Office of the Inspector General U.S. Office of Personnel Management 1900 E Street, NW Room 6400 Washington, DC 20415-1100 -- CAUTION -- This audit report has been distributed to Federal officials who are responsible for the administration of the audited program. This audit report may contain proprietary data which is protected by Federal law (18 U.S.C. 1905). Therefore, while this audit report is available under the Freedom of Information Act and made available to the public on the OIG webpage (http://www.opm.gov/our-inspector-general), caution needs to be exercised before releasing the report to the general public as it may contain proprietary information that was redacted from the publicly distributed copy. 28 Report No. 3A-CF-00-14-049
Audit of the 2011 and 2012 Long Island Combined Federal Campaigns
Published by the Office of Personnel Management, Office of Inspector General on 2015-02-11.
Below is a raw (and likely hideous) rendition of the original report. (PDF)