PCC Management Insights

“Staying in the Know”

Guidelines for Postal Customer Council Charitable Endeavors
November 2008

Federal Regulations Governing Charitable Activities:

The Combined Federal Campaign (CFC) is the only authorized solicitation of funds from federal employees in the federal workplace on behalf of charitable organizations.  5 CFR Part 950.  

The Standards of Ethical Conduct for Employees of the Executive Branch (Standards of Ethical Conduct) prohibit an employee from soliciting a gift for himself or another.  The Standards also prohibit a federal employee from accepting a gift from a prohibited source or one given because of the employee’s official position -- unless the item is excluded from the definition of a gift or falls within one of the exceptions set forth in the regulations.  As a general rule of thumb, any item with a market value of more than $20 is considered a prohibited gift.  Cash and cash equivalents in any amount are always considered prohibited gifts.   5 C.F.R. Part 2635.204.

The Conduct on Postal Property Regulations prohibit the solicitation of “alms and contributions” on all real property under the charge and control of the Postal Service and apply to all persons entering in or on such property.   39 CFR § 232.1(h)(1).   ”Alms” are defined as money or goods given in charity.

The Community Service Activities Policy (CSAP) permits contributions of Postal Service resources to support a community service event, project or cause but may not be approved if the activity violates the Standards of Ethical Conduct or the Conduct on Postal Property Regulations.  Also, the CSAP does not authorize the donation of Postal Service funds.  Therefore, CSAP will not permit the solicitation of cash or goods from employees or customers in the workplace.  

Approval for any CSAP activity must be obtained from a USPS Area Vice-President.  Only charitable activities designed to meet the needs of specific causes may be approved.  Those causes are:

Assisting victims of a disaster
Relieving hunger
Promoting education/literacy
Enhancing the environment
Promoting wellness
Promoting child safety and well-being

See ASM § 333.  

PCC Guidelines to Charitable Activities: 

With certain limitations, PCCs may engage in charitable activities, as follows:
  
All charitable activities must be approved through the Postal Service’s Community Service Activities Policy (CSAP).   A CSAP application should be completed in accordance with Postal Service guidelines and submitted to the Area Vice President (AVP) through the Postal Co-Chair.  PCCs should note that the AVP cannot approve activities that are otherwise prohibited by federal regulations such as the Standards of Ethical Conduct for Employees of the Executive Branch, the CFC regulations or the Conduct on Postal Property regulations.  Information regarding these federal regulations can be provided to interested PCCs through the PCC Program office. 

If a charitable activity is approved by an AVP, industry members of the PCC may solicit and collect in-kind contributions only.  PCCs must organize and conduct all related activities on non-postal property and industry members must avoid making any representation that they are acting on behalf of the U.S. Postal Service.  

Postal Service employees may participate in related activities to the extent their participation is approved through the CSAP program.  Likewise, the use of postal resources (workhours, vehicles, etc.) for such activities is limited to those resource allocations approved by an AVP.   Postal members of the PCC may make personal contributions of goods to an approved CSAP program if they desire to do so. Any such contribution must be strictly voluntary.   

In addition to the prohibition from soliciting or collecting cash, the CSAP will not permit a PCC to redirect PCC funds to finance any charitable cause, scholarship, relief or assistance fund, insurance program, hardship loan, political activities, gifts or other causes or activities not directly related to the PCC Mission.  (Publication 286, Charitable Endeavors, page 15.)  

Specific Dear Santa Program Guidelines:
 
The Dear Santa program was designed as a letter writing program.  PCCs wishing to participate in a Dear Santa program should make application to the AVP through the CSAP program as set out above.