Budget Change Proposal - Cover Sheet - CA.gov

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STATE OF CALIFORNIA
Budget Change Proposal - Cover Sheet
DF-46 (REV 09/19)

Budget Change Proposal - Cover Sheet
Fiscal Year: 2020-21
Business Unit: 0820
Department: Department of Justice
Priority Number: N/A
Budget Request Name: 0820-029-BCP-2020-GB
Program: Legal Services
Subprogram: Public Rights Division

Budget Request Description: Registry of Charitable Trusts Workload

Budget Request Summary: The Department of Justice requests 12 positions and $1.6
million Registry of Charitable Trusts Fund in 2020-21, and 13 positions and $1.5 million
in 2021-22 and ongoing, to enhance the Registry of Charitable Trusts Section’s efforts
to increase enforcement of registration and reporting requirements, and to detect fraud
and misuse of charitable assets.

Requires Legislation: ☐ Yes ☒ No
Code Section(s) to be Added/Amended/Repealed:

Does this BCP contain information technology (IT) components? ☐ Yes ☒ No
If yes, departmental Chief Information Officer must sign.
Department CIO Name:
Department CIO Signature:
Signed On Date:
For IT requests, specify the project number, the most recent project approval document
(FSR, SPR, S1BA, S2AA, S3SD, S4PRA), and the approval date.
Project Number:
Project Approval Document:
Approval Date:
If proposal affects another department, does other department concur with proposal?
☐ Yes ☒ No
Attach comments of affected department, signed and dated by the department director
or designee.
Prepared By: Catherine Taylor
Date: January 8, 2020
Reviewed By: Matt Rodriguez
Date: January 8, 2020
Department Director: Chris Ryan
Date: January 8, 2020
Agency Secretary:
Date:

Department of Finance Use Only

Additional Reviews: Capital Outlay:☐   ITCU:☐         FSCU:☐      OSAE:☐
       Department of Technology:☐
PPBA: Emma Jungwirth
Date submitted to the Legislature: January 10, 2020
A.     Budget Request Summary
The Department of Justice requests 12 positions and $1.6 million Registry of Charitable Trusts
Fund in 2020-21, and 13 positions and $1.5 million in 2021-22 and ongoing, to enhance the
Registry of Charitable Trusts Section’s efforts to increase enforcement of registration and
reporting requirements, and to detect fraud and misuse of charitable assets.

 2   Staff Services Managers I
10   Staff Services Analyst (SSA)
 1   Office Technician – Typing (OT-T)
13   Total Positions

B.     Background/History
The Supervision of Trustees and Fundraisers for Charitable Purposes Act (Act), Government
Code section 12580, sets forth the Attorney General’s authority over charities, trustees and
charitable fundraisers. Title 11, sections 300-316, 999.6-999.9.5, of the California Code of
Regulations were promulgated under the authority of the Act. The Act requires charitable
entities, charitable trustees, professional fundraisers, fundraising counsel, and commercial co-
venturers to register and file reports with the Registry of Charitable Trusts Section (Registry)
(Government Code sections 12584-12590.) For-profit fundraisers are required to file annual
financial reports with the Registry detailing expenses associated with their campaigns.

Government Code sections 12587 and 12587.1 specifically require that revenue generated
from registration and renewal fees are used by the Department of Justice to operate and
maintain the Registry, to provide public access via the Internet to reports filed with the Registry
and for the enforcement of registration and reporting requirements. The Legislature also
tasked the Attorney General with the responsibility to investigate and protect charitable assets
(Government Code sections 12584, 12588, 12589, 12591, and 12598). The registration and
reporting requirements are a critical element in the Attorney General’s efforts to protect
charitable assets. The publication of the registration forms and annual reports by the Registry
also promote transparency, allowing donors to see how a charity is using their donations.

The Registry manages and enforces the registration and annual financial reporting
requirements for charities, charitable trustees and fundraisers. The Registry publishes filings
on the Attorney General’s website and provides assistance to charities by offering educational
guides. The Registry is a self-funded program, raising revenue from registration filing fees, as
well as late fees paid by registrants, which fund the Registry’s operations.

The Registry has five program units that oversee the filing of registrations, renewal of financial
forms, and collection of filing fees. The primary responsibilities of these program units are to
process and enforce the registration and reporting requirements, and to ensure that
information provided complies with the registration and reporting laws and regulations. The
program units are:
• Initial Registration - process initial registration and filing fees.
• Renewals - process annual renewal registration reports and filing fees.
• Delinquency - enforce timely annual renewal registration reports and collect filing and late
fees.
• Commercial Fundraising - register, collect filing fees and annual reports.
• Raffles - register, collect filing reports and raffle registration fees.

Registration, Renewals and Delinquency are highly integrated and interdependent, and the two
remaining program units, Raffles and Commercial Fundraising, are independent programs.

                           Resource History (Dollars in thousands)

 Program Budget               2014-15     2015-16     2016-17    2017-18     2018-19
 Authorized Expenditures       $3,137      $5,373      $5,311     $5,004      $5,740
 Actual Expenditures           $2,688      $3,302      $3,710     $4,322      $5,740
 Revenues                      $3,940      $4,174      $4,464     $4,560      $4,947
 Authorized Positions           28.0        40.0        40.0       36.0        42.0
 Filled Positions               25.0        27.0        34.0       33.0        39.0
 Vacancies                       3.0        13.0         6.0        3.0         3.0

                                        Workload History

Workload Measure (Hours)                   2014-15    2015-16     2016-17    2017-18     2018-19
Initial Registrations                        N/A       4,004        5,247      5,047       5,674
Renewals                                     N/A        N/A        46,096     44,617      52,344
Delinquency Notices                          N/A        N/A        11,587     11,195      10,522
Raffle Reports                               N/A        N/A         2,176      4,231       5,606
Raffle Registrations                         N/A        N/A         4,656      4,907       7,685
Professional Fundraising Reports             N/A        N/A         1,863      1,597       2,252
Professional Fundraising Registrations       N/A        N/A          777        803         842

C.     State Level Considerations
California nonprofit organizations, as well as foreign nonprofits doing business in California,
generate $243.2 billion in annual revenues and hold $909.3 billion in charitable assets. All
nonprofit organizations organized for the benefit of the public must register with the Attorney
General, with the exception of schools, religious organizations, hospitals, licensed health care
service plans, governmental entities, regulated cemetery corporations and committees defined
in Government Code section 82013.

The Registry works with the Secretary of State (SOS) and Franchise Tax Board to determine
which organizations need to register and which organizations are non-compliant with their
renewal filings. This communication helps ensure that charity organizations are fully compliant
with the Attorney General’s requirements, and that they are being held accountable.
D.     Justification
The Registry is requesting $1.6 million for 13 positions consisting of 2 Staff Services Managers
I, 10 SSAs, and 1 OT-T. The requested resources will expand the Registry’s efforts to increase
enforcement of registration and reporting requirements. Adding resources to the Registry’s
program units will ensure further improvement with registration and reporting compliance, the
critical review of data filed with the Registry, and the proper oversight and direction of the
Registry staff and processes.

Currently, the Registry manages over 115,782 active organizations. Of those organizations,
51,615 (45 percent) are listed as delinquent in their annual reporting requirements and 62,694
(54 percent) are current with their reporting requirements. The remaining 1,473 (1 percent) are
in other statuses, such as pending dissolution.

Every month, SOS authorizes the formation of approximately 800 new charities. With data
from SOS and Franchise Tax Board, the Registry database includes 123,004 unregistered
organizations that may need to register. The Registry seeks to augment its enforcement
efforts to suspend charities that chronically fail to file annual reports and to bring unregistered
charities in compliance with state law.

At current staff levels, the Registry can only process 468 applications a month. While the
resources provided in 2015-16 and 2018-19 allowed the Registry to reduce the processing
time for submitted forms from 120 to 160 days to approximately 45 days, additional staff is
needed to increase the number of applications processed monthly. Since the public relies on
the Registry’s website to provide relevant information on non-profits, reducing lag time
between the Registry’s receipt of information and its ability to act on and post information is
important.

Since Registration, Renewals, and Delinquency are highly integrated and interdependent, this
request largely addresses delinquent charities. In 2017, the Registry issued notices of intent to
suspend 2,263 charities and suspended 236 charities that were chronically delinquent in their
annual reporting requirements. In 2018, the Registry increased its efforts by issuing notices of
intent to suspend 3,748 charities and suspended 338 charities. While the Registry increased
its outreach efforts by sending reminder postcards to charities, producing educational
webinars, and collaborating with both the SOS and the Franchise Tax Board to give charities
notice alerts of their registration and annual reporting requirements, charities regrettably
continue to miss the mark when it comes to renewing their registration. While the delinquency
rate since 2016 has significantly decreased from 65,173 to 51,615 in 2018-19, the goal is to
reduce the delinquent population to less than 35,000. Adding staff to address unregistered
and delinquent charities will increase the Registry’s revenue resulting from anticipated initial
registration fees and annual renewal filing fees, and will accelerate its efforts to improve the
compliance of non-registered and delinquent organizations.

In addition to increased efficiencies in Registrations, Renewals, and Delinquencies, additional
resources will allow the Registry to increase its enforcement efforts. In July 2018, the Registry
initiated a project to target charities that purportedly provided veteran-related services. Of the
1,589 charities identified, Registry found 554 were delinquent on annual reporting
requirements and 1,035 never registered. The Registry issued 498 cease and desist notices
to the unregistered charities and revocation notices to the delinquent charities. Because of this
enforcement effort, 44 percent of the delinquent charities cured their delinquency status and 19
percent of the unregistered charities registered.

In 2018, the Registry started targeting professional fundraisers and assessing late fees for
their failure to timely file annual reports collecting over $80,000 in late fees. The Registry also
increased its enforcement of raffle filing requirements and began denying registration to
charities that failed to file past due annual reports. The Registry staff proactively monitored
online websites to investigate illegal online raffles conducted in California, and issued cease
and desist orders against three companies.

Additional staff will allow the Registry to invest more resources towards higher value
enforcement activities. The Registry coordinates its enforcement activities with the Charitable
Trust Section’s legal staff. Two outcomes of note include (1) Wounded Warriors Support
Group and (2) In re Maguire/Maguire.

(1) People v. Wounded Warriors Support Group, et al.
On November 5, 2018, a jury rendered a verdict in favor of the People and awarded
$8,755,268 in damages against this family run charity for breach of fiduciary duty, self-dealing
transactions, illegal raffles, unjust enrichment, and failure to run charitable programs for which
the nonprofits were formed. The Registry staff worked with the Charitable Trust legal team by
issuing the initial cease and desist order and by providing evidence and witness assistance at
trial.

(2) In re Maguire/Maguire, Inc.
Maguire/Maguire, Inc. was registered as Fundraising Counsel but it failed to comply with
reporting requirements and illegally charged charities percentage based fees. In November
2018, the Registry issued a cease and desist order, and was able recover $110,000 in
penalties and $1,800 in late fees.

Initial Registration: The Initial Registration Unit is currently staffed by one Associate
Government Program Analyst (AGPA), four SSAs, and three OT-Ts. The Registry is
requesting five additional SSAs for the Registration Program.

The Initial Registration team processes the application forms filed by charities formed or
operating in California. The Registry receives an average of 765 applications and responses to
Notice to Register per month. At current staffing levels, the Registration Analyst has been able
to review and approve an average of 468 new registrations per month from the rolling
inventory. The inventory is processed on a “first in-first out” basis and processing time has
averaged 30 to 60 days. An organization must clear any deficiency and register before it can
begin conducting business and actively solicit funds in California.

Since July 2016, the number of registered charities that are in Current Status increased from
51,677 to 62,694 as of June 2019, a total increase of 11,017 organizations. There are 238,786
known charities in California, with 123,004 that are not registered, and 115,782 that are active
registered charities. The goal of the Registry is to progressively reduce the number of charities
that are inactive or are doing business but have failed to register.

It is estimated that current SSAs in the unit average 1,123 registrations annually. By
increasing staffing by five SSAs, the unit is projected to increase its registrations by
approximately 5,615 organizations a year. The additional analysts will be dedicated to
targeting the 123,004 unregistered organizations and bringing them into compliance. The
additional resources would allow the Registry to continue its efforts in increasing the number of
current registered charities, as well as continue improving service level processing times and
nonprofit compliance enforcement efforts.

Charites that are sent Notices to Register (NTR) often respond with filings that also include
delinquent filings for previous years of operating without registering. Delinquent filing
responses to NTR require additional time for analysts to review and evaluate the submission
for missing requirements, completion, and approval. The current eight Registration staff
includes five analysts (one AGPA and four SSAs) and three OTs. The five analysts perform the
essential task of reviewing and researching the incoming applications while the three OTs
provide the support needed such as phone calls, payment processing, creating
correspondence, and file maintenance.

The 123,004 unregistered population is in need of stratification and analysis to devise handling
strategy, and therefore, the unit is currently not sending out mass-mailing NTR. With five
additional analysts, the unit will accelerate the current results and increase compliance by
mass-mailing NTRs. As a result, the responses from the NTRs will increase the workload for
both Registrations and Renewals.

The primary challenge to sending out notices is performing the analysis before sending the
appropriate notice and managing the response volume. Unregistered organizations may have
been in operation for years prior, and must submit financials for all years in operation, in
addition to the initial registration materials. The unregistered population also includes mutual
benefit organizations that hold charitable assets. The Registry must review activity and
founding documents to make the proper determination. Delinquent organizations may also
require the submission of multiple years of filings which would also require a more extensive
analysis. With all charities, gaining good address information and getting in contact with a
responsive representative of the organization can be an added challenge. Many of the charity
cases require contact research, and multiple, repeated mailing and call attempts. For
Fundraisers and Raffle, Registry has been successful with the issuance of annual registration
reminders and delinquent reports. For charities, Registry is performing targeted mailings due
to the large portfolio volume based on time, benefit, cost and available resources. Currently,
Registry is sending out reminder notices for organizations that have a status of “reporting
incomplete” and will become delinquent unless annual submission requirements are satisfied.
Delinquency notices are also being sent to organizations that have recently turned delinquent
and have valid contact information. Finally, NTR reminders are sent to organizations known to
be actively conducting charitable solicitations and veterans organizations.
Historical data compiled for the previous 24 months indicates that the current 5 analysts can
review and approve an average of 468 organizations per month (5,616 organizations per year).
The analysts are responsible for registering an organization from beginning to end including
many back and forth communications, emails, phone calls, communication with legal staff,
request for missing documents and/or payments with the help of the OTs. Five new analysts
added to its workforce will allow the unit to increase output through expanded mass-mailing
and it is projected that the unit would double its output capacity. The additional analysts will
increase the rate of new registrations to 936 per month, 11,232 organizations per year, after
full implementation and training of new staff. Refer to the workload table in Appendix A.

Registration Renewal: The Registration Renewal Unit is currently staffed by one AGPA, four
SSAs and three OT-Ts. The Registry is requesting one additional SSA.

The Registration Renewal Unit processes annual registration renewal forms. On average, the
unit receives 3,826 renewal packages per month, and up to 11,000 per month during the peak
filing periods of May and November. The Registry is requesting one additional SSA to
accommodate the increased volume of annual renewals as a result of reducing the
delinquency rate, addressing the unregistered population, and the approximate three percent
annual increase, based on ongoing operations, in the total number of annual filings. The
increased workload in Initial Registrations and Delinquency is anticipated to increase the
volume of renewals one year later. The Registry is requesting one position to be allocated
beginning in fiscal year 2021-22. Refer to the workload table in Appendix A.

Delinquency: The Delinquency Program Unit is currently staffed by four SSAs and three OT-
Ts. The Registry is requesting an additional three SSAs and one OT-T for the Delinquency
Program.

The unit follows up on registered charities that have failed to complete their annual registration
renewal. When a charity fails to complete its renewal, the unit sends a letter advising the
charity of the missing reports. Delinquency also reviews and processes delinquent financial
reports, posts the renewal fees, and responds to public inquiries. The number of delinquent
organizations has reduced from 65,173 in July of 2016 to 51,615 as of June 2019. With the
requested additional staffing, the goal of the Registry is to reduce the delinquent population to
25,000 to 35,000 delinquent organizations, or about 15 percent to 30 percent of total registered
organizations.

Of the 115,782 currently registered organizations, 62,694 (54 percent) are current with their
annual filings. 51,615 (45 percent) organizations are delinquent, and the remaining 1,473 (1
percent) are in other forms of non-reporting status. To reduce the number of delinquent
organizations, Registry staff issue delinquency notices and perform outreach efforts. This is
labor-intensive and time-consuming, requiring additional staff to continue to achieve progress
in this area. Actively managing the number of current and delinquent organizations has
resulted in an increase in the amount of associated renewal and late fees. The Registry
continues to make steady progress toward the goal of reducing delinquent organizations to
about 35,000 or having current organizations represent about 75 percent of total registered
organizations.
The Delinquency Program works with previously registered organizations that have become
delinquent in filing their annual financial reports. Delinquency sends an average of 286 first
delinquent notices per month, which contributes in part to the receipt of about 976 pieces of
mail per month to process. Delinquent filing responses to notices requires additional time for
analysts to review and evaluate the submission for missing requirements, completion, and
approval.

Current Delinquency staffing includes 4 SSAs and 3 OTs. The 4 SSAs perform the essential
task of reviewing and researching the submissions, while the 3 OTs provide support, such as
answering phone calls, processing payments, creating correspondences, and maintaining files.
The 51,615 delinquent population is in need of stratification and analysis to devise handling
strategy, and as a result the program is currently not mass-mailing delinquent notices. With
three additional analysts and one additional OT, the program could accelerate the current
results and increase compliance by performing the necessary analysis to conduct mass-
mailing of delinquent notices. The responses from the notices will increase the workload for
both Delinquency and Renewals.

Historical data compiled for the previous 24 months indicates that the existing 4 analysts can
review and approve an average of 617 organizations per month (7,404 organizations per year).
The analysts review and complete the curing process of an organization’s delinquent status
with many back and forth communications, emails, phone calls, communication with legal staff,
request for missing documents and/or payments, with the help from the OTs. Adding 3
analysts and 1 OT will allow the unit to expand its capacity on outreach to delinquent
organizations by 31 percent. The additional staff, after full implementation and training, will
increase the cure rate of delinquencies by 191 organizations per month (2,292 organizations
per year), and accelerate the progress made in decreasing the number of delinquent
organizations, as well as continued improvement of service level processing time and
organizational compliance. Refer to the workload table in Appendix A.

Raffle: The Raffle Program is currently staffed by one SSA and one OT. The Raffle Program
reviews and approves raffle registration applications and annual raffle financial reports filed by
charities. The program reviews forms and documents, posts registration fees, and responds to
public inquiries. The program receives an average of 586 applications, 196 incomplete notices,
and 407 reports per month. The volume for applications and reports fluctuates up to 1400 and
1100, respectively, per month during the peak filing periods of August and September. The unit
also responds to an average of 64 phone calls and 124 emails per month.

Registry requests increasing the Raffle Program’s workforce by half of a SSA to help improve
service level processing time especially during peak inflow periods for annual registration and
financial reporting, improve the continuity work, and allow for more detailed analysis of the
data submitted on the forms. Refer to the workload table in Appendix A.

Professional Fundraising: The Professional Fundraising Unit is currently staffed by one AGPA.
The Professional Fundraisers Program reviews and approves annual registration forms,
financial reports, and notices of intent filed by professional fundraisers. This program also
posts registration fees, prepares the Attorney General’s Report on Commercial Fundraisers
and responds to public inquiries.

The unit receives an average of 68 applications, 141 reports, and 188 Notices of Intent per
month. The volume fluctuates up to 370, 550, and 400, respectively, per month during the
peak filing periods of December to February. The unit also responds to an average of 26
phone calls and 214 emails, and 66 pieces of miscellaneous correspondences per month.

Registry requests increasing the Professional Fundraising Unit’s workforce by one-half SSA to
improve service level processing time especially during peak inflow periods for annual
registration and financial reporting, improve the continuity work and allow for more detailed
analysis of the data submitted on the forms. Refer to the workload table in Appendix A.

Statistics are tabulated monthly by the individual programs of the Registry. A new and more
comprehensive method of keeping statistics was created in July 2016. The statistics are
analyzed by Registry management to quantify inflows, quantify work in progress, and quantify
completed work. The collective information is used to determine where resources may be
needed and redirected, to balance workload and ensure that appropriate resources are made
available to the areas of highest importance. Currently, the Registry is staffed by 2 Staff
Services Managers I, responsible for managing 33 analysts and OT-Ts (3 AGPA, 1 ITS I, 16
SSA, 13 OT-T). Registry requests to add two more Staff Services Managers I to expand the
managerial and supervisory coverage. Additional managers will play a central role in efficient
workflow analysis which would help in effective prioritization and assignment of staff, ensuring
that both processes and supporting strategies are well defined and optimized.

Reports are also generated on a monthly basis within the Registry database which are used to
measure how many current/delinquent organizations are registered, as well as the number of
organizations that are not registered. This information is used to measure the effectiveness of
program activities and overall charity compliance. Finally, financial reports are reviewed on a
monthly basis to determine the effectiveness of charity compliance, measure/track available
resources, and ensure conformance to revenue and spending targets.

E.     Outcomes and Accountability
The increased staffing at the Registry will allow it to effectively oversee charity registry filings
and process registration requests and other reporting documents in a timely nature. This will,
in turn, reduce the number of organizations that are incompliant with the registration and/or
reporting requirements of the Act. The Registry’s goal is to ensure that all qualified
organizations are compliant. The failure to register and report interferes with public access to
important organization data concerning the status and finances of the delinquent and
unregistered organizations. The failure to register and report hampers the Registry’s ability to
detect fraud, fiscal mismanagement, and loss of charitable assets, and impedes its referrals to
the Registry’s legal and/or audit staff for further investigation. Additional resources will
improve and substantially accelerate the desired compliance results pertaining to registration
of unregistered and delinquent organizations.
Projected Outcomes

Workload Measure (Hours)        2019-20    2020-21     2021-22    2022-23     2023-24    2024-25
Initial Registrations            5,616       8,424      11,232     11,232      11,232     11,232
Renewals                         56,105     58,105      60,105     63,950      69,365     69,365
Delinquency Notices              11,278     12,424      13,570     13,570      13,570     13,570
Raffle Reports                   4,883       6,104       6,409      6,537       6,668      6,668
Raffle Registrations             7,037       8,444       8,866      9,043       9,224      9,224
Professional Fundraising         1,691       2,029       2,029      2,029       2,029      2,029
Reports
Professional Fundraising           816       857         857         857        857        857
Registrations

F.    Analysis of All Feasible Alternatives
Alternative 1 – Approve as Requested

Approve 12 positions and $1.6 million Registry of Charitable Trusts Fund in 2020-21, and 13
positions and $1.5 million in 2021-22 and ongoing, to enhance the Registry’s efforts to
increase enforcement of registration and reporting requirements, and to detect fraud and
misuse of charitable assets.

Alternative 2 – Approve Partial Funding

Approve 6 positions and $800,000 Registry of Charitable Trusts Fund in 2020-21 and ongoing.
These resources would allow the Registry to increase enforcement of registration and
reporting requirements, but less delinquent charities would be addressed than if the full
request were to be granted.

Alternative 3 – Deny the Request

This alternative would prevent the Registry from increasing non-profit compliance with state
law and expose the public to organizations that are misappropriating charitable assets and
other acts harmful to the public interest.

G.    Implementation Plan
If approved, the Registry will recruit and hire the two Staff Services Manager I, nine SSAs, and
one OT-T in July 2020. The remaining one SSA will be added in fiscal year 2021-22. This
strategy will address both immediate needs and projected growth as illustrated in the workload
tables.
H.    Supplemental Information
Appendix A – Workload Tables

I.    Recommendation
Approve Alternative 1 to allow the Registry to further increase enforcement of registration and
reporting requirements, increase its effectiveness in detecting fraud and misuse of charitable
assets, and enable the Section to continue to provide and further enhance service level
processing time and continuity of coverage for the various Registry program units.
APPENDIX A

                              A - Initial Registration Workload Data

Initial Registration (SSA)                                  Volume    Minute/      Hours Per
(Effective 7/1/2020)                                                   Task          Year
New Registrations (Review/ Approval/ Confirmation              11,232     70          13,104
Letters)
Posting Fees/Returns                                           11,232          3          562
Reviewing/ Generating/ Creating NTR/                           16,488          1          275
Disallowance/Registering Delinquent/ Exemption Letters
Public Inquiries (Mail/Phone/Email)                            17,874          8        2,383
Check Deposit Bag Process/Review                                  261         15           65
Total Hours                                                                            16,389
Full-Time Equivalent                                                                       9.2
Available Positions                                                                        4.0
Required Positions                                                                         5.2
Requested Positions                                                                        5.0

   Five Registry positions were approved in the 2018-19 budget change proposal, which included
   one OT and four SSAs. One OT and two SSAs were conversions of limited-term appointments
   to permanent appointments. The remaining two SSAs were added to Initial Registration to
   assist with increased workload.

   The Registration Program has developed a successful long-term approach with helping
   organizations become compliant with their reporting requirements by creating an efficient
   process of notification and follow through with legal support. Analysts now enhance processes
   by performing the necessary analytics in a one-step beginning-to-end determination requiring
   increased research and analysis of incoming applications.

   Posting fees and return checks are now performed by the OT instead of an SSA. Time gained
   by the process enhancement of removing OT duties from SSA work increased the time
   available for analysis and research to make a final determination in one review of the
   application, which takes more time. Standard letters that do not require research is now
   processed by an OT instead of an SSA, streamlining the process to dedicate the SSA time
   only on letters requiring detailed analyses. Basic responses to public inquiries (mail, phone,
   and email) are now performed by the OT instead of an SSA, streamlining the process to
   dedicate the SSA time only on answering phone calls and emails that require analysis.
B - Renewal Workload Data

Renewal Program (SSA)                                              Volume Minutes/        Hours
(Effective 7/1/2021)                                                       Task          Per Year
Reviewing of annual financial reports                               56,105       7          6,546
Creating incomplete form notices and reviewing upon their           16,832       5          1,403
return
Renewal Compliance Review of reports                                   435           0            0
Preparation of Registry daily deposit                                  261          45         196
Responding to public inquiries (phone/email/misc.)                   9,201           7       1,074
Total Hours                                                                                  9,219
Full-Time Equivalent                                                                            5.2
Available Positions                                                                             4.0
Required Positions                                                                              1.2
Requested Positions                                                                             1.0

   The Renewals Program has developed a successful long-term approach with helping
   organizations renew their annual registration. The minutes per task reflect the current work
   processes of the SSA’s that include an expanded analytical review of the organization’s filings.
   The resources required will increase each fiscal year as more organizations come into
   compliance as Registered and Current. The request for one SSA in fiscal year 2021-22 will
   address the initial phase of organizations who have recently become registered and current,
   and are submitting their subsequent year annual registration renewal.

   In 2018-19, the additional SSAs approved in the budget change proposal for the Initial
   Registrations Program were based on projected volume of financial reports at that point in
   time. The projected workload did not materialize and based on the Section's workload
   analysis, one SSA originally approved for Initial Registrations was repurposed and redirected
   to the Renewals Program to assist with the Unit’s workload. The volume associated with
   creating notices and public inquiries has increased as the criteria of review, greater usage of
   email, and an increased usage of our electronic filing platform, has driven an increase in the
   total quantity of notices generated, as well as public inquiries.
C - Delinquency Workload Data

Delinquency Program (SSA)                                            Volume     Minutes/ Hours
(Effective Date 7/1/2020)                                                        Task    Per Year
Reviewing & processing of delinquent annual financial reports         4,853        20       1,618
Posting of delinquent renewal fees/late fees                          4,853        5          404
Creating of delinquency notices                                       6,303       5.5         578
Reviewing and handling organizations failing to respond               1,450       150       3,625
Responding to public inquiries (phone/email/ misc. mail)              25,212       15       6,303
Total Hours                                                                                12,528
Full-Time Equivalent                                                                           7.1
Available Positions                                                                            4.0
Required Positions                                                                             3.1
Requested Positions                                                                            3.0

Delinquency Program (OT-T)                                           Volume     Minutes/ Hours
(Effective Date 7/1/2020)                                                        Task    Per Year
Reviewing & processing of delinquent annual financial reports         4,853        40       3,235
Posting of delinquent renewal fees/late fees                          4,853       5.75        465
Creating of delinquency notices                                       6,303        24       2,521
Reviewing and handling organizations failing to respond               1,450        0             0
Responding to public inquiries (phone/email/ misc. mail)              25,212       2          840
Total Hours                                                                                 7,061
Full-Time Equivalent                                                                           4.0
Available Positions                                                                            3.0
Required Positions                                                                             1.0
Requested Positions                                                                            1.0

   The Delinquency Program has developed a successful long-term approach with helping
   organizations become current. The minutes per task reflect the current work processes of the
   OT-T’s and SSA’s, in relation to the minutes per task for each organization and include the
   additional time intensive handling of working with organizations who have become Suspended
   or Revoked. The Registry enhanced its methodology of counting volume due to the expanded
   number of delinquency notices the Registry will send to organizations and the expected cure
   rate from those additional notices. It is expected that with the additional resources, the number
   of organizations issued a delinquency notice will expand by 2,292 notices, to 6,303 per year
   versus the current average of 4,011 per year. The curing of an organization’s delinquent
   registration renewal often involves multiple notices. The volume in the 2020-21 table reflects
   the number of organizations issued a notice of delinquency. The table does not account for all
   mail received or all notices issued. The Registry often receives mail from organizations
   attempting to self-cure, referred through other state agencies, referred through other Registry
   programs, or as part of an incomplete emailed/voicemail public inquiry. The time associated
   with these additional organizations is reflected in the minutes/task section and not fully
   represented in the quantity of volume column. Total mail volume which represents an
organizations submittal of paper filings for the past 24 month period has averaged 11,712
   pieces of mail per year.

   The “Reviewing and handling of org failing to respond” is not a new task and was not
   previously demonstrated in the workload table in the 2018-19 budget change proposal. These
   organizations have not submitted financial reports. As more organizations have been issued
   notices of delinquency, approximately 23 percent of organizations do not initially respond and
   their charity registration is “Suspended” and subsequently “Revoked.” This work strategy has
   taken up a significant amount of time and increased the number of public inquiries and
   therefore, now factors into the ongoing workload.

                                     D - Raffle Workload Data

                                                                   Volume Minutes/        Hours
Raffle Program                                                             Task          Per Year
Reviewing & processing of application forms                         7,037    22              2,580
Reviewing & processing of annual report forms                       4,883    20              1,628
Creating incomplete form notices                                    2,351    12                470
Responding to public inquiries & follow up correspondence           2,263     5                189
Total Hours                                                                                  4,867
Full-Time Equivalent                                                                            2.7
Available Positions                                                                             2.0
Required Additional Positions                                                                   0.7
Requested Positions                                                                             0.5

                          E - Professional Fundraising Workload Data

                                                                   Volume Minutes/        Hours
Professional Fundraising Program
                                                                           Task          Per Year
Reviewing & processing of annual registration forms                    817      30             409
Reviewing & processing of annual financial reports                   1,691      30             846
Reviewing & processing of annual Notices of Intent                   2,254      15             564
Responding to public inquiries & follow up correspondence            3,667      15             917
Total Hours                                                                                  2,736
Full-Time Equivalent                                                                            1.5
Available Positions                                                                             1.0
Required Additional Positions                                                                   0.5
Requested Positions                                                                             0.5

   The Raffle Program and the Professional Fundraising Program have developed a successful
   long-term approach with helping organizations become compliant. The minutes per task
   reflect the current work processes of the SSAs, in relation to the minutes per task for each
   organization.
BCP Fiscal Detail Sheet
BCP Title: Registry of Charitable Trusts Workload
BR Name: 0820-029-BCP-2020-GB
Budget Request Summary

Personal Services
 Personal Services                                  FY20          FY20      FY20     FY20     FY20     FY20
                                                    Current       Budget    BY+1     BY+2     BY+3     BY+4
                                                     Year          Year

 Positions - Permanent                                   0.0         12.0     13.0     13.0     13.0     13.0
 Total Positions                                         0.0         12.0     13.0     13.0     13.0     13.0

 Earnings - Permanent                                         0       641      690      690      690      690
 Total Salaries and Wages                                $0          $641     $690     $690     $690     $690

 Total Staff Benefits                                         0       372      401      401      401      401
 Total Personal Services                                 $0        $1,013   $1,091   $1,091   $1,091   $1,091
Operating Expenses and Equipment
Operating Expenses and Equipment          FY20         FY20         FY20        FY20        FY20       FY20
                                         Current       Budget       BY+1        BY+2        BY+3       BY+4
                                          Year          Year
5301 - General Expense                             0       308         218         210         210        210
5302 - Printing                                    0            4          4           4           4          4
5304 - Communications                              0          25           27          27       27         27
5306 - Postage                                     0            3          3           3           3          3
5320 - Travel: In-State                            0          26           29          29       29         29
5322 - Training                                    0          11           12          12       12         12
5324 - Facilities Operation                        0       141             45          45       45         45
5346 - Information Technology                      0          24           26          26       26         26
Total Operating Expenses and Equipment           $0       $542        $364        $356        $356       $356

Total Budget Request
Total Budget Request                      FY20         FY20         FY20        FY20        FY20       FY20
                                         Current       Budget       BY+1        BY+2        BY+3       BY+4
                                          Year          Year
Total Budget Request                          $0        $1,555      $1,455      $1,447      $1,447     $1,447
Fund Summary
Fund Source

Fund Source                                         FY20         FY20      FY20     FY20     FY20     FY20
                                                   Current       Budget    BY+1     BY+2     BY+3     BY+4
                                                    Year          Year
State Operations - 3088 - Registry of Charitable
                                                             0     1,555    1,455    1,447    1,447    1,447
Trusts Fund
Total State Operations Expenditures                        $0     $1,555   $1,455   $1,447   $1,447   $1,447
Total All Funds                                            $0     $1,555   $1,455   $1,447   $1,447   $1,447

Program Summary
Program Funding
Program Funding                                     FY20         FY20      FY20     FY20     FY20     FY20
                                                   Current       Budget    BY+1     BY+2     BY+3     BY+4
                                                    Year          Year
0435028 - Public Rights                                      0     1,555    1,455    1,447    1,447    1,447
9900100 - Administration                                     0       194      182      181      181      181
9900200 - Administration - Distributed                       0      -194     -182     -181     -181     -181
Total All Programs                                      $0        $1,555   $1,455   $1,447   $1,447   $1,447
Personal Services Details
Positions
Positions                                         FY20         FY20        FY20        FY20        FY20        FY20
                                                 Current       Budget      BY+1        BY+2        BY+3        BY+4
                                                  Year          Year
1139 - Office Techn (Typing) (Eff. 07-01-2020)        0.0          1.0        1.0         1.0         1.0         1.0
4800 - Staff Svcs Mgr I (Eff. 07-01-2020)             0.0          2.0        2.0         2.0         2.0         2.0
5157 - Staff Svcs Analyst (Gen) (Eff. 07-01-
                                                      0.0          9.0       10.0        10.0        10.0        10.0
2020)
Total Positions                                       0.0         12.0       13.0        13.0        13.0        13.0

Salaries and Wages
Salaries and Wages                                FY20         FY20        FY20        FY20        FY20        FY20
                                                 Current       Budget      BY+1        BY+2        BY+3        BY+4
                                                  Year          Year
1139 - Office Techn (Typing) (Eff. 07-01-2020)             0          43          43          43          43          43
4800 - Staff Svcs Mgr I (Eff. 07-01-2020)                  0       165        165         165         165         165
5157 - Staff Svcs Analyst (Gen) (Eff. 07-01-
                                                           0       433        482         482         482         482
2020)
Total Salaries and Wages                                 $0       $641       $690        $690        $690        $690
Staff Benefits
 Staff Benefits                     FY20          FY20      FY20     FY20     FY20     FY20
                                    Current       Budget    BY+1     BY+2     BY+3     BY+4
                                     Year          Year
 5150900 - Staff Benefits - Other             0       372      401      401      401      401
 Total Staff Benefits                    $0          $372     $401     $401     $401     $401

Total Personal Services
 Total Personal Services             FY20         FY20      FY20     FY20     FY20     FY20
                                    Current       Budget    BY+1     BY+2     BY+3     BY+4
                                     Year          Year
 Total Personal Services                   $0      $1,013   $1,091   $1,091   $1,091   $1,091
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