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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

  1. Registration Area - First days when people are checking in
  2. 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

  1. Member cancels contribution
  2. Membership lapses
  3. 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

  1. No real-time annual limit validation - Report-based only; rarely hit so not prioritized
  2. Daily cash limit is warning only - Staff can override
  3. Refund documentation gap - PAC-issued refunds may not appear in AMS
  4. Point of sale obsolescence - USB mag stripe readers dying off
  5. 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