PAC Compliance and Contributions
VIDEO TRANSCRIPT | Recorded: 2025-12-19 | Verify against current system state
Abstract¶
This session provides a comprehensive overview of AANP-PAC compliance requirements and contribution processing. Jeff explains the separate organizational structure of the PAC, FEC regulatory requirements, contribution eligibility rules, daily and annual limits, and the conference operations that drive significant PAC activity. The session covers the PacSwipe tool used at conferences, fund segregation between AANP and AANP-PAC bank accounts, and the automated compliance reporting to DDC Public Affairs. Key considerations for Salesforce migration and the need for a new point-of-sale solution are also discussed.
Key Procedures¶
AANP-PAC Overview¶
- AANP-PAC is a separate entity from AANP with its own bank account
- Staff associated with PAC are AANP employees working under the PAC umbrella
- Purpose: Pool member contributions to support NP advocacy at federal and state levels
- Funds support lobbying and legislation affecting nurse practitioners
- Regulated by Federal Election Commission (FEC)
Contribution Eligibility¶
- Must be current AANP member - non-members cannot contribute
- Must be US resident - international members are not eligible
- International membership type - even if US resident, not eligible (keeps verification clean)
Contribution Limits¶
| Limit Type | Amount | Enforcement |
|---|---|---|
| Daily Cash | $100 per contributor | Warning in PacSwipe, staff can override |
| Annual | $5,000 per contributor | Report-based review (rarely hit) |
| Reporting Threshold | $200+ in year | Requires occupation and employer |
Notable Statements¶
- 0:00:21 "The PAC is part of the American Association of Nurse Practitioners, but it is a separate entity with a separate bank account."
- 0:01:22 "There is a regulatory body that audits PAC contributions, the Federal Election Commission."
- 0:01:37 "To be eligible to contribute to the PAC, you must be an AANP member, current AANP member. If you are not a member, you cannot contribute."
- 0:03:33 "Each day, a person can submit up to $100 in cash... we put up a warning saying, hey, this person is reaching their limit today."
- 0:06:08 "At conference, I've mentioned it before, but we have something called swipe and pack swipe. Pack swipe is just a fork basically of normal swipe that is focused on only pack type contributions."
- 0:08:11 "There are FEC violations, there's fines, legal penalties, and of course, media coverage if we do something that does not follow the rules of PAC contributions."
- 0:13:33 "Within Aptify, there are two organizations. There is AANP and then there is AANP PAC."
- 0:15:12 "PAC cash and PAC check directly get deposited into the AANP PAC checking accounts. It never reaches AANP accounts."
- 0:19:34 "Usually, by the time a refund is requested, the funds have been moved over to the AANP PAC bank account."
Systems & Configurations¶
Systems Mentioned¶
- Aptify (current AMS with PAC organizations)
- Salesforce (future AMS)
- PacSwipe (conference point-of-sale)
- DDC Public Affairs (third-party auditor)
- BluePay (merchant account)
- SFTP Server (compliance reporting)
Two Organizations in Aptify¶
| Organization | Purpose | Bank Account |
|---|---|---|
| AANP | Main operations | AANP Operating Account |
| AANP-PAC | Political contributions | PAC Bank Account |
Payment Types and Fund Flow¶
| Payment Type | Flow | Bank Destination |
|---|---|---|
| Credit Card (online/phone) | BluePay → AANP → Transfer to PAC | AANP first, then PAC |
| Credit Card (conference) | BluePay → AANP → Transfer to PAC | AANP first, then PAC |
| PAC Cash (conference) | Direct deposit | PAC Bank directly |
| PAC Check (conference) | Direct deposit | PAC Bank directly |
| Mailed Check | AANP deposit → Transfer | AANP first, then PAC |
PAC Products¶
| Product Type | Description | Sales Channel |
|---|---|---|
| Lapel Pins | Collectible pins sold annually | Online + Conference |
| Event Tickets | Howl at the Moon event | Online + Conference |
| Sweepstakes Entry | State-dependent terminology | Conference |
| Auction Bids | Silent auction items | Conference |
| One-time Contribution | Direct donation | Online |
| Recurring Contribution | Monthly/Quarterly/Annual | Online |
Specific Configurations¶
| Item | Value/Setting | Timestamp | Notes |
|---|---|---|---|
| Daily cash limit | $100 per contributor | 0:03:33 | Warning only, can override |
| Annual limit | $5,000 per contributor | 0:04:13 | Report-based monitoring |
| Reporting threshold | $200+ annually | 0:08:59 | Requires occupation/employer |
| DDC reports | Weekly, Monthly, Quarterly | 0:17:23 | Via SFTP |
| Card reader type | USB magnetic stripe only | 0:06:26 | No contactless |
Credentials/Access Mentioned¶
- DDC SFTP credentials (Sushmita manages)
- BluePay merchant account
- PacSwipe application access
Conference Operations¶
PAC Booth Locations¶
- Registration Area - First days when people are checking in
- Exhibit Hall (AANP Plaza) - When exhibit hall opens, very high traffic
Conference Activities¶
- Sweepstakes/lottery/drawing (terminology varies by state law)
- Silent auctions
- Howl at the Moon event ticket sales
- Lapel pin sales
- Direct contributions
PacSwipe Tool¶
- Web application on laptop with USB card reader
- Fork of regular Swipe tool, focused on PAC contributions
- Displays daily limit warnings
- Magnetic stripe only (no contactless)
- Critical: Needs replacement for Salesforce - no current solution
Compliance Reporting¶
DDC Public Affairs¶
- Third-party auditor for FEC compliance
- Reviews contributions for accuracy and limit compliance
- Monitors contribution patterns
Report Schedule¶
| Frequency | Contents | Delivery |
|---|---|---|
| Weekly | Recent contributions | SFTP CSV |
| Monthly | Month summary | SFTP CSV |
| Quarterly | Quarter summary | SFTP CSV |
FEC Compliance Risks¶
- FEC violations
- Financial fines
- Legal penalties
- Media coverage/reputation damage
Errors & Troubleshooting¶
- Issue: Daily cash limit exceeded
- Cause: Contributor trying to give more than $100 cash in one day
- Resolution: PacSwipe shows warning; staff can override with justification
-
Timestamp: 0:03:49
-
Issue: Member not eligible to contribute
- Cause: Non-member, lapsed membership, or international membership type
- Resolution: Verify current AANP membership with US-based membership type
-
Timestamp: 0:01:51
-
Issue: PAC validation showing on all orders in Salesforce
- Cause: ITC built extensive validation visible on every order
- Resolution: Jeff requested to hide unless caps are being hit
-
Timestamp: 0:05:48
-
Issue: PAC refunds complex
- Cause: Funds already transferred to PAC bank by refund request time
- Resolution: PAC issues check directly from PAC account; may not show in Aptify/Salesforce
- Timestamp: 0:19:34
Recurring Contributions¶
Types Available¶
- One-time contribution
- Monthly recurring
- Quarterly recurring
- Annual (attached to membership)
Rules¶
- Can have multiple recurring types simultaneously
- Continue until member cancels
- Must stop if membership lapses
- Should stop if member moves outside US (verify if implemented)
Cancellation Triggers¶
- Member cancels contribution
- Membership lapses
- Address change to non-US (needs verification)
Future Considerations¶
Salesforce Migration¶
- Daily and annual limits built into Salesforce (ITC implementation)
- PAC validation UI was hidden for non-PAC orders
- SFTP reporting process needs to be verified for go-live
- PacSwipe has no replacement yet - critical gap
Point of Sale Solution Needed¶
- Current PacSwipe won't work with Salesforce
- USB card readers becoming obsolete (no contactless)
- Required for National Conference 2026 if on Salesforce
- Jeff recommended third-party PAC-specific vendors
- Consider moving PAC process entirely outside CRM
Recommendation¶
- Move PAC to dedicated third-party platform
- Cleanest separation for finance and PAC teams
- Challenge: Removing from join/renew process limits contribution opportunities
Internal Contacts¶
| Team | Responsibility |
|---|---|
| Government Affairs (DC) | Primary PAC operations, very compliance-focused |
| Finance | Account reconciliation, GL codes, fund transfers |
| IT | PacSwipe, SFTP reporting, system integration |
External Contacts¶
| Vendor | Role |
|---|---|
| DDC Public Affairs | Third-party auditor |
| Sushmita | IT point of contact for DDC reporting |
Technical Debt & Known Issues¶
- No real-time annual limit validation - Report-based only; rarely hit so not prioritized
- Daily cash limit is warning only - Staff can override
- Refund documentation gap - PAC-issued refunds may not appear in AMS
- Point of sale obsolescence - USB mag stripe readers dying off
- Salesforce POS gap - No Chargent/Salesforce solution for conference PAC
Transcript Gaps & Quality Notes¶
- Recording from live knowledge transfer session
- Duration: ~22 minutes
- Presenter: Jeff Sikes
- Some audio repetition in transcript
- Comprehensive coverage of compliance requirements
- Audio quality: Good