PAC Contributions

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Approved for development

Contribution Eligibility Requirements

When the term "individual member" is used in this requirements document, it refers to an individual member that does not have an address on file that is outside of either the United States, U.S. territories or military bases (APO/AE addresses). AANP does not verify the legal citizenship status of our members. This is a best effort to ensure compliance with PAC contribution regulations. If a member's address is updated to an international address, they will no longer be able to view any content related to PAC on our websites, should not see products related to the PAC category, and should not be able to make a payment for any product related to the PAC category.

Staff with the appropriate permissions should have an option to override these requirements for specific members based on their unique circumstances. This action should be documented in the system for compliance purposes.

Contribution Limits

When the terms "contribution limits" or "aggregate limits" are used in this requirements document, the aggregate only accounts for contributions made to products categorized as contributions to the AANP-PAC within the orders. If an order was placed with a mix of membership and PAC contributions, for example, only the products categorized as PAC contributions count against these aggregate limits.

Summary

The American Association of Nurse Practitioners Political Action Committee (AANP-PAC) has the purpose to create an articulate and forceful voice for the members of the American Association of Nurse Practitioners (AANP) and to accept contributions and make disbursements to influence the selection, nomination or election of any individual to any federal office who has demonstrated their beliefs in the purposes, principles and mission of AANP. Also, the PAC encourages and strives for government improvement by encouraging and stimulating nurse practitioners and others to take a more active and effective part in governmental affairs and concerns.

The AANP-PAC is a separate legal entity from AANP and maintains a separate bank account. These contributions are governed by Federal Election Commission (FEC) regulations, ensuring compliance with all legal requirements. Only individual members of AANP who meet the contribution requirements outlined above should be able to view PAC related materials online and make contributions. Contributions are not tax deductible.

AANP-PAC funds are distributed by the AANP-PAC Trustees, who include regional representation from across the United States. Decisions to support or oppose a candidate for election are based on the candidate's support for the AANP legislative agenda, likelihood of electoral success, and the recommendations of AANP staff or political advisors.

The AANP-PAC is registered with the Federal Election Commission and must follow strict rules when accepting and distributing contributions. Reporting and auditing are critical components of PAC management, ensuring transparency and accountability.

Current Processes

Currently, PAC contributions can be made through the AANP website, Aptify, and a mobile Point of Sale (POS) solution for on-site contributions at events. The POS solution allows staff to accept PAC contributions in person, ensuring that all business logic and contribution limits are enforced.

Specific payment types are applied based on the location and type of payment made. For example, PAC Cash and PAC Check are used for in-person cash and check contributions received by the government affairs staff and deposited directly into the PAC bank account. Credit card payments are also accepted for PAC contributions, but are submitted to the AANP merchant account and then transferred to the PAC account, regardless of if the credit card contribution is made online or in-person. Physically mailed checks for membership and/or PAC contributions (including checks that are combined for membership and PAC) that are mailed to the AANP headquarters are deposited into the AANP bank account and then transferred to the PAC account. All contributions, regardless of type, are processed through Aptify/Salesforce.

Compliance with PAC contribution regulations is essential for maintaining the PAC's integrity and ensuring that all contributions are accurately tracked and reported. Failure to comply with these requirements jeopardizes the PAC’s ability to operate and accept/make contributions. We currently partner with DDC, a political compliance and fundraising firm, to provide the necessary financial and demographic compliance reports on a weekly, monthly, and quarterly basis. These reports are delivered via FTP to DDC for review and compliance verification.

Complexities and Challenges

While all contributions are processed in Aptify/Salesforce, legal compliance requires that the PAC make any required refund directly from the PAC, which again, is a separate bank account from AANP. Therefore, total contribution amounts listed in Aptify/Salesforce may not be correct.

For instance, if a credit card payment is made to AANP directly for a PAC contribution, those funds are transferred over to the PAC bank account on a regular basis. However, if a contribution is requested to be refunded, the refund is processed in DDC and comes out of the PAC bank account, not the AANP bank account. This is a necessary step to ensure compliance, but also makes it difficult to track PAC contributions accurately as an aggregate total in Salesforce.

A specific scenario to consider is when a member pays for a membership renewal and a PAC contribution with one check. Membership staff must create two separate orders, with the check payment split between the two orders. This is to ensure compliance for the PAC team's reporting and tracking requirements.

Payments are processed through the AANP merchant account and then transferred to the PAC account. Physically mailed checks for membership and/or PAC contributions that are mailed to AANP headquarters are processed into Aptify/Salesforce and deposited into the AANP bank account and then transferred to the PAC account. This process is necessary to ensure compliance with FEC regulations and maintain the integrity of PAC contributions.

Once the payment is transferred to the PAC account, it is difficult to track in Salesforce due to any requested refund as discussed above. There are generally very few refunds per year, so this is not widespread, but it does create a disparity for aggregate totals within Salesforce.

However, this data is accurately tracked within DDC and reported correctly using DDC for our federal compliance filings. This is because the PAC account is separate from AANP's general funds, and the data is not easily accessible in Salesforce. This creates challenges for reporting and tracking PAC contributions accurately as an aggregate total in Salesforce.

Here's another real scenario to consider:

A member means to give the PAC $500 and accidently does $5000 and asks for a refund. We would process that $5000 refund in DDC (external compliance tool) because we cut a check from our PAC account. But in Salesforce, it would still show $5000. So then if they were to send us a new $500 contribution, Salesforce wouldn’t allow it to be processed.

The concern would be if we tried to manually enter the refund it into Salesforce so that the aggregate would be correct, it would process it as a refund through AANP when the funds have already been refunded through the PAC. Therefore, we only process the refund through DDC.

When this occurs in Aptify, it means reporting isn't accurate. Once the money is transferred to the PAC, AANP's Aptify system doesn't know what happens with it - refunds, etc. However, again, DDC does have the most updated information, so our federal compliance reporting is correct.

Requirements

note

Please use the definition of "individual member" from the contributions requirement note at the top of this document whenever mentioned below.

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Please use the definition of "contribution limits" and "aggregate limits" from the note at the top of this document whenever these terms are mentioned below.

External User Requirements

1. Contribution Eligibility and Processing:

   • As an individual member, I should be able to contribute to the PAC.
   • As an individual member, I should be able to enter my Occupation and Current Employer in my profile
   • As an individual member, I should be able to review and update my Occupation and Current Employer when my calendar year aggregate PAC giving exceeds $200.

2. Auto-Renew and One-Off Contributions:

   • As an individual member, I should be able to add auto-renewal for PAC contributions at the same time as my membership renewal. Auto-renewals should allow for yearly, quarterly, or monthly contributions.
   • As an individual member, I should be able to establish/add an auto-renewing PAC contribution at any time while my membership is active.
   • As an individual member, I should be able to complete a one-time contribution to the PAC at any time, even if I am currently contributing to PAC via auto-renewal.

3. Contribution Options and Management:

   • As an individual member, I should be stopped from contributing if the intended contribution would exceed my daily ($100 in cash) or annual ($5,000 per calendar year) contribution limits for PAC contributions.
   • As an individual member, I should be able to select contribution types (one-time, monthly, quarterly, and annually) and also bundle them with another product.
   • As an individual member, I should be able to bundle multiple PAC products together in one transaction.
   • As an individual member, I should be able to add auto-renewal for PAC contributions at the same time as my membership renewal.
   • As an individual member, I should be able to have visibility into PAC contribution options and eligibility criteria within the application.
   • As an individual member, I should be able to receive automated notifications and reminders about PAC contribution opportunities based on my membership type.
   • As an individual member, I should be able to make an auto-renewing PAC contribution at any time while my membership is active. This function ceases when the individual member is no longer an active member or if they add address onto their account that is either outside of the US, territories, or military bases (APO AE).
   • As an individual member, I should be able to complete a one-time contribution to the PAC at any time, even if I am currently contributing to PAC via auto-renewal.
   • As an individual member, I should be able to purchase products tagged for inclusion in the point of sale system, including items in the PAC product category, if I meet the requirements for those products.
   • As an individual member, I should be able to manage my recurring PAC contributions on my account page.
   • As either a non-member, a member that is not an individual member (as defined above), or as an international member, I should not be able to view any content or features related to PAC, nor make any contributions to the PAC.

4. Payment Methods and Receipt Notifications:

   • As an individual member, I should be able to receive receipt and confirmation messages for my PAC contributions.
   • As an individual member, I should be able to see an Update Payment section if I am on auto-renewal for PAC in the same area membership auto-renewal payment updates are managed.
   • As an individual member, I should be able to update my employer and occupation information from the AANP website.

5. Auto-Renewal Management:

   • As an individual member, I should be able to remove PAC contributions from my next upcoming auto-renewal without staff intervention (limit to "up to 24 hours prior").
   • As an individual member, I should receive notifications if my auto-renewing PAC contribution has failed to process.
   • As an individual member I should receive a notification at least 48 hours prior to my auto-renewing PAC contribution being processed (reminder).

Internal User Requirements

1. Configuration and Eligibility Management:

   • As a Salesforce Administrator, I should be able to configure PAC contribution options to comply with federal law and membership eligibility criteria with the review and approval of Federal Government Affairs staff.
   • As an internal user, I should have visibility into membership categories and eligibility criteria for PAC contributions, including restrictions for international members or those with an address outside of the US, territories, or military base (APO AE).
   • As an internal user, I should NOT be able to create quotations or invoices or similar type transactions that include PAC category products.
   • As a Salesforce Administrator, I should be able to exclude non-members, international members, or members who are not an individual member (as defined above) from accessing any product related to the PAC product category. This limitation applies until the non-member completes the membership transaction, at which time they will gain access to products related to the PAC product category, as long as they meet other PAC eligibility requirements such as not an international member and do not have any address on file outside of the US/territories/APOAE
   • As a Salesforce Administrator, I should be able to configure products in the PAC Product Category to be hidden from non-members, international members, and members that have an address on their account outside of the U.S., territories, or military base (APO AE).
   • As a Salesforce Administrator, I should only grant members in good standing who meet the requirements as an individual member (as defined above) PAC contribution access.
   • As a Salesforce Administrator, I should be able to deliver a customizable message to internal users when a PAC product is added to cart of a user that does not meet eligibility requirements for purchase.
   • As a Salesforce Administrator, I should be able to deliver a customizable message to external users when they attempt to access a product page for which they do not meet the eligibility requirements.
   • As a Salesforce Administrator, I should be able to automatically validate membership eligibility and address to access PAC contributions on the online platform or application.
   • As a Salesforce Administrator, I should be able to limit which staff have access to use the Payment Types of "PAC Cash" and "PAC Check".

2. Contribution Limits:

   • As an internal user, I should see a notification on an individual member’s record if they have met their daily or annual PAC contribution limits.
   • As an internal user, I should not be able to submit an order if the intended contribution is in cash and would exceed the individual member’s daily cash ($100) limit. Note that the internal user should be able to submit an order, even if the daily cash limit has been reached, if the intended order is using currency other than cash (i.e. PAC check, credit card, etc).
   • As an internal user, I should not be able to submit an order if the intended contribution would exceed the individual member’s annual aggregate limit for the calendar year.
   • As an internal user with specific permissions, I should be able to override the annual and daily aggregate limits for PAC contributions with an audit trial of the override provided.

3. Contribution Type and Renewal Management:

   • As an internal user, I should be able to create and manage a list of contribution types for member selections, including options for one-time, monthly, quarterly, and annual contributions.
   • As an internal user, I should be able to view the contribution tier of an individual member if it exists.
   • As an internal user, I should be able to present required Employer and Occupation fields to members when an order with a product associated with the PAC product category is being placed that triggers the over $200 aggregate for the calendar year.
   • As an internal user, I should be able to assist members in removing PAC contributions from their next upcoming auto-renewal including the 24 hours prior to the payment being processed.
   • As an internal user, I should be able to verify contributor eligibility based on the defined contributions requirements.
   • As an internal user, I should be able to process contributions and ensure they are categorized using the appropriate payment types they have access to, which can include - Cash, Check, Credit Card (which are deposited into the AANP account then transferred to PAC bank account) or PAC Cash, PAC Check (which will be deposited into a separate PAC bank account.
   • As an internal user with appropriate permissions, I should be able to override Salesforce logic and designate that an individual user with an address outside of the US, a US territory or APO/AE address, (otherwise referred to as ineligible to contribute) is able to contribute to the PAC and purchase products in the PAC product category, upon confirmation by the member that they are a US citizen or legal permanent resident. An audit trail of this confirmation should be maintained in the system.

Reporting and Tracking

1. Reporting and Notifications:

   • As an internal user, I should see a notification on an individual member’s record if they have met their daily or annual PAC contribution limits as defined above.
   • As an internal user, I should be able to generate the necessary financial and demographic audit reports and deliver them via FTP to DDC, or other PAC compliance vendor on a weekly, monthly, and quarterly basis.
   • As an internal user, I should be able to generate a report for specific PAC products on an annual (January 1 – December 31) basis.
   • As an internal user, I should be able to generate a report for all PAC product transactions, including PAC Cash and PAC check, on an annual (January 1 – December 31) basis.
   • As an internal user, I should be able to generate a report for all PAC product transactions, specifically excluding PAC Cash and PAC check transactions, on an annual (January 1 – December 31) basis. (This is what the Finance Department uses to reconcile with FGA staff on a weekly basis)
   • As an internal user, I should see a notification on a contact's record if they have met their daily or annual PAC contribution limits, as defined above.

2. Contribution Tracking:

   • As an internal user, I should be able to track and record all PAC contributions accurately, including cash, check, and electronic payments.
   • As an internal user, I should not be able to submit an order if the contact’s intended contribution would exceed their daily or annual PAC contribution limits, as defined above.

3. Payment Type Reporting:

   • As a Salesforce Administrator, I should be able to create PAC Cash and PAC Check payment types for in-person cash and check payments deposited directly to the PAC bank account.
   • As an internal user with appropriate permissions, I should be able to select PAC Cash or PAC Check when a product in the order is included in the PAC product category.

4. Point of Sale (POS) Management:

   • As an internal user with appropriate permissions, I should be able to use a mobile Point of Sale (POS) solution to take PAC contributions on-site at events.
   • As an internal user with appropriate permissions, I should be able to take PAC Check, PAC Cash, or Credit Card payments using the POS solution.
   • As a Salesforce Administrator, I should be able to select specific products to include in the POS solution.
   • As an internal user with appropriate permissions, I should view products in the PAC Product category within the POS solution.
   • As an internal user, I should be able to ensure all business logic around contribution eligibility and limits is enforced through the POS solution.
   • As an internal user with appropriate permissions, I should be able to use the POS solution on a portable device to walk around and take payments from individual members.
   • As an internal user, I should be able to ensure that only eligible members (individual members as defined above) are allowed to make PAC contributions through the POS solution.
   • As an internal user, I should be able to enter a zero dollar ($0.00) transaction for any product in the PAC product category.

Assumptions

• All members will be included in the Personas definition.
• Timelines will follow as outlined in each requirement.

References

1. PAC Contributions Overview
2. AANP PAC Contribution Guidelines
3. Internal Meeting Notes on PAC Contributions (Include detailed notes from internal meetings as necessary)
4. PAC Swipe App for In-Person Events
5. PAC Contributions
6. Management of PAC Contributions - Login with Auto-Renewing Contributor
7. VIDEO - I2C Discovery Session
8. VIDEO - AANP Application Walkthrough

Appendix

Note that the DDC PAC Quarterly Membership File has a column titled "State Rep" which needs to be updated with the label "State Liaison" moving forward.

Examples of DDC Files that will need to continue to be generated and delivered via FTP:

• PAC Quarterly Membership File
• PAC Quarterly SPG File
• PAC Weekly Orders

Contributions are divided into tiers based on the amount given:

• Platinum Club: $1,000 level and above
• Diamond Club: $500-$999
• Ruby Club: $250-$499
• Sapphire Club: $100-$249
• Emerald Club: $25-$99

This updated document now includes the requirements for PAC on-site contributions through a mobile Point of Sale (POS) solution, ensuring all business logic and contribution limits are enforced. It also includes a comprehensive overview and detailed requirements for both internal and external users.

Approvals / Signoffs

Role	Name	Signature	Date
Technical Lead	Jeff Sikes	JS	07/22/2024
Stakeholder	Jessica Talbert	JT	07/22/2024