Gospel for Asia, the second largest mission organization in the U.S., has been sanctioned by the Office of Personnel Management for lack of compliance with charity guidelines and banned from participation in the 2016 federal charity campaign.
In October 2015, the Office of Personnel Management received complaints from former donors and other observers regarding Gospel for Asia’s compliance with OPM guidelines for participation in the Combined Federal Campaign. The CFC involving federal workers is one of the largest workplace fund raising campaigns on the planet. At that point, OPM began an investigation that led to a December 2015 warning of possible sanctions on GFA’s ability to participate in the campaign.
Late yesterday, I learned that the OPM decided to sanction GFA for lack of compliance with OPM guidelines. According to a spokesperson from the OPM’s Office of Communications, “the Gospel of Asia charity has been sanctioned and will no longer be affiliated with the Combined Federal Campaign for the 2014 and 2015 campaigns.”
Furthermore, according to the OPM spokesperson, “GFA is banned from the CFC for one year, then they will need to reapply.”
The sanctions appear to be the strongest allowed by law.
Not only will GFA not be allowed to participate in the 2016 campaign, they will not receive funds currently deducted from employee paychecks still outstanding from the 2015 and 2014 campaigns. Federal workers who pledged to GFA in 2015 will be contacted and allowed to redirect their pledges to other approved charities.
According to an OPM spokesperson, allotments to GFA were still coming out of employees pay checks in 2015 for pledges made at the end of 2014. Those funds have not yet been delivered to GFA. The OPM spokesperson said, “OPM directed campaigns and the federation to cease making further payments to them and discontinue processing pledges made to them at the end of 2015 that would have started being withheld from employees checks staring this pay period for the 2015 period that just closed.”
OPM told local and regional groups like Christian Charities USA to “cease making further payments” to GFA and to stop processing any employee pledges. Independent Charities of America and the related group Christian Charities USA had already denied membership to GFA for 2016 because GFA failed to provide an audited statement.
According to the most recent 990 form filed by Christian Charities USA, GFA received just over $150,000 from federal workers through CCUSA in 2013.
OPM guidelines require an independent board of directors, clean financial audit, and truthful communications about the use of donations. Upon scrutiny by the OPM, GFA did not comply.
In early October, GFA was terminated from membership in the Evangelical Council for Financial Accountability for similar violations of standards. The report issued by ECFA was made public by former board member Gayle Erwin in early December and contains numerous concerns and indications of financial mismanagement.
As recently as a week ago, Gospel for Asia touted participation in the Combined Federal Campaign (Google cache).
Not any more. Now if you go to that same page, one sees a “Page Not Found” message and a frown. Once, GFA boasted about their participation in the CFC (Google cache), but mention of the program is now missing at that page.
I have been aware for several weeks that the Office of Personnel Management was reviewing GFA’s status as an approved charity. Recently, I learned that GFA may be sanctioned by the OPM due to failure to meet requirements for participation in the CFC. Today, I learned from an OPM Spokesperson that OPM contacted Christian Charities USA about GFA. Christian Charities USA assists charities by submitting and certifying the accuracy of application for acceptance into the CFC and is managed by the same group that manages Independent Charities of America. CCUSA submitted GFA’s original application for the CFC to OPM.
In early December, OPM notified CCUSA that its member charity GFA may be in violation of CFC regulations. According to the spokesperson,
CCUSA contacted GFA, and gave them ample opportunity to provide evidence they were not in violation of CFC rules. However, CCUSA did not get an acceptable response from GFA. CCUSA then decertified GFA.
The decertification by CCUSA may be the reason GFA has pulled the CFC page. The next possible step for GFA would be a sanction from OPM. I have been informed by the OPM spokesperson that GFA has been notified that OPM intends to sanction GFA if GFA is unable to prove that they comply with OPM standards.
By statute, sanctions may involve expulsion from the CFC program. The removal of the CFC page and any mention of participation in the CFC may indicate that GFA has been removed although the OPM spokesperson has not commented on that point.
Prior to the termination of membership in the ECFA, GFA had touted ECFA membership, ICA membership and participation in the CFC as indicators of financial integrity. Now there is nothing to independently verify that GFA is abiding by financial promises.
In a mailing just received today, Gospel for Asia’s fund solicitation still carries the Evangelical Council for Financial Accountability seal. The letter is dated October 15, which is nearly two weeks after the ECFA board voted to terminate GFA’s membership.
Here is the pledge card with the seal and “Enhancing Trust” slogan (click to see letter and other materials):
Along with the ECFA charter member seal, the pledge card carries the meaningless ICA “Best in America” Seal.
According to the ECFA standards, this GFA mailing violates Standard 7.1 which relates to “Truthfulness in Communications.” According David Carroll, GFA’s COO, GFA will seek membership in the future. Continuing to violate a standard doesn’t seem like the best way to make a case for reinstatement.
By continuing to claim membership in the ECFA, GFA is in violation of ICA standards and the standards for qualification as a charity for inclusion in the Combined Federal Campaign.
The ICA requires truthful and non-deceptive fundraising materials (see the next to last bullet point in the image below):
The Office of Personnel Management’s standards also require truthful materials.
Gospel for Asia is participating in the Combined Federal Campaign going on now. This campaign allows federal employees to give via their paychecks to charity. For some charities, this is a windfall; for others it brings in enough to make it worth doing.
I give GFA credit for not including the ECFA seal on the recent promotional literature aimed at federal employees (see a part of it below). However, the rest of it is brazenly and tragically misleading.
If GFA operated with the highest standards of financial integrity, the organization would not have been kicked out of the ECFA. GFA’s leaders would answer donor and media questions. Financial matters wouldn’t be shielded behind excuses. GFA’s CEO K.P. Yohannan would be available for comment.
If GFA operated with the highest standards of integrity and accountability, celebrity pastors (yes, you Francis Chan) would state publicly what your position is regarding GFA. You have removed your endorsements from the GFA webpage, but you told Christianity Today you are still on the GFA board.
GFA now banks on the Independent Charities of America Seal of Excellence to claim the “highest standards.” However, GFA paid ICA and Maguire and Maguire a little extra to use it. Maguire and Maguire make money when donors give to GFA through the CFC. So it is to ICA’s and Maguire and Maguire’s advantage for GFA and other charities to look good with the Seal given by MM/ICA for pay.
Now that the Evangelical Council for Financial Accountability has terminated Gospel for Asia’s membership due to violations of multiple standards, GFA is using the Seal of the Independent Charities of America as a badge of financial integrity.
When I called the ICA, I was connected to Mike May with Maguire & Maguire, an association management firm. May told me that organizations approved by the Office of Personnel Management for inclusion in the Combined Federal Campaign are allowed by ICA to display the ICA Seal. GFA is approved as a charity for the 2015 campaign in progress now.
At the time, I asked why GFA was allowed to display the seal since GFA is a proselytizing organization. In contrast to the federal standards, the ICA adds a provision barring “proselytizing organizations.” See the image below:
Beyond explaining ICA’s use of CFC approval, May had no comment about any of the other questions put to him. At this time, I don’t know why ICA has the restriction on proselytizing organizations or why GFA, as a proselytizing organization, is allowed to display the Seal of Excellence.
In any case, my research, the recent actions of the ECFA and the recent statement of former board member Gayle Erwin call into question the compliance of GFA with most of the eligibility standards of ICA (and more basically with the federal standards for participation in the Combined Federal Campaign). Click the image below to go to a pdf chart with supporting links.
ICA is now aware of the discrepancies between their criteria and GFA’s performance and it remains to be seen if ICA will investigate or take any action.