Audit of Department of 

Homeland Security's 

Fiscal Years 2014 and 

2015 Conference 

Spending 

July 10, 2017 

OIG-17-94 
 

 

 

 

 

 

DHS OIG HIGHLIGHTS

Audit of Department of Homeland Security’s 

Fiscal Years 2014 and 2015 Conference Spending
 

 July 10, 2017 

Why We Did 

This Audit 

Public Law (P.L.) 113–76, 

Consolidated Appropriations Act, 

2014, and P. L. 113-235, 

Consolidated and Further 

Continuing Appropriations Act, 

2015, require the Department of 

Homeland Security to report 

events-related spending. Our 

audit objective was to determine 

whether DHS’ spending on 

selected hosted or sponsored 

conferences for fiscal years 

2014 and 2015 was 

appropriate, reasonable, 

necessary, and in compliance 

with Federal regulations. 

What We 

Recommend 

We made five recommendations 

that, when implemented, will 

improve conference reporting 

and recordkeeping and ensure 

the accuracy and timeliness of 

conference submissions. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

DHS did not comply with the reporting of 

annual conferences as required by Federal 

regulations. The Department failed to 

report 6 conferences in FY 2014 and 14 

conferences in FY 2015 that were greater 

than $100,000 in its Annual Report to the 

Office of Inspector General and on the 

public website as required by Federal 

regulations. The total dollar value of these 

unreported conferences was $862,881 

and $2,822,561 for FYs 2014 and 2015, 

respectively. The Department also did not 

always report all hosted conferences 

greater than $20,000 to OIG within 15 

days after the end of the conference. In 

addition, the Department did not always 

enter actual conference cost data into the 

Conference Approval Tool timely or 

accurately, and in some instances DHS 

did not have appropriate documentation 

to support expenses. Accurate reporting of 

conference costs is important to ensure 

transparency. Although DHS did not 

comply with reporting requirements, its 

conference expenses for FYs 2014 and 

2015 appeared appropriate, reasonable, 

and necessary. 

DHS Response 

DHS concurred with all five of our 

recommendations and has already 

implemented corrective actions, resulting 

in the resolution and closure of all the 

recommendations. 

www.oig.dhs.gov OIG-17-94 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov 


July 10, 2017 


MEMORANDUM FOR: Stacy Marcott 

Acting Chief Financial Officer 

Department of Homeland Security 

FROM: John V. Kelly ;/ 

-~ ' 

Deputy Inspector General 

SUBJECT: Audit ofDepartment ofHomeland Security 's Fiscal 

Years 2014 and 2015 Conference Spending 

Attached for your action is our final report, Audit ofDepartment ofHomeland 

Security's Fiscal Years 2014 and 2015 Conference Spending. We incorporated 

the formal comments provided by your office. 

The report contains five recommendations to improve the overall effectiveness 

of conference reporting and recordkeeping and ensure the accuracy and 

timeliness of conference submissions. Your office concurred with the five 

recommendations. Based on information provided in your response to the draft 

report and supporting documentation provided under separate cover, we 

consider all five recommendations resolved and closed. 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will 

post the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Maureen Duddy, 

Deputy Assistant Inspector General for Audits, at (617) 565-8723. 

Attachment 
 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

Background .................................................................................................... 1 

Results of Audit .............................................................................................. 3 

Reporting Requirements ........................................................................ 4 

Actual Costs for Conferences Not Always Reported Timely or Accurately. 7 

Inadequate Supporting Documentation for Conference Expenses ........... 8 

Reportable Events Not Submitted within the Conference Approval Tool .. 8 

Annual Reporting to Congress ............................................................... 9 

Recommendations........................................................................................... 9 

Appendixes 

Appendix A: Objective, Scope, and Methodology ................................. 13 

Appendix B: Management’s Comments to the Draft Report .................. 15 

Appendix C: FY 2014 Conferences Greater than $100,000 

 Not Reported................................................................. 19
 

Appendix D: FY 2015 Conferences Greater than $100,000 

Appendix E: Results of Review of Supporting Documentation for 

 Not Reported ..................... ............................................. 20 

Conference Expenses ...................................................... 22 

Appendix F: FYs 2014 and 2015 Conferences OIG Reviewed ................ 23 

Appendix G: Office of Audits Major Contributors to This Report ........... 24 

Appendix H: Report Distribution .......................................................... 25 

Abbreviations 

CAT Conference Approval Tool
 

CFR Code of Federal Regulations 

FY fiscal year 

GAO Government Accountability Office 

GSA General Services Administration 

OCFO Office of the Chief Financial Officer 

OIG Office of Inspector General 

OMB Office of Management and Budget 

P.L. Public Law 

FTR Federal Travel Regulations 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background
 

In June 2011, the President’s Executive Order 13576, Delivering an Efficient, 

Effective, and Accountable Government, launched the Campaign to Cut Waste. 

This campaign intensified efforts to identify areas across the Government 

where waste or excess may exist, and to take immediate steps to address them. 

The Office of Management and Budget (OMB) issued Memorandum 11-35, 

Eliminating Excess Conference Spending and Promoting Efficiency in 

Government, in September 2011, instructing agencies to review their policies 

and internal controls for conference-related activities and expenses. 

In May 2012, OMB issued Memorandum 12-12, Promoting Efficient Spending to 

Support Agency Operations (OMB M-12-12)1, instructing agencies to initiate 

senior-level review of all planned conferences, and senior-level approval for all 

future conference expenses exceeding $100,000. This memorandum also 

prohibited expenses in excess of $500,000 on a single conference without a 

waiver, and required agencies to report publicly on all agency sponsored 

conferences with net expenses exceeding $100,000. 

In addition, Public Law (P.L.) 113-76, Consolidated Appropriations Act, 2014 

and P. L. 113-235, Consolidated and Further Continuing Appropriations Act, 

2015, require the Department to: 

x	 report annually to the Inspector General all conferences held costing 

more than $100,000; and 

x	 notify the Inspector General, within 15 days of the date a conference is

held, of the date, location, and number of employees attending such

conference, for which the cost to the United States Government was more 

than $20,000. 

The Department of Homeland Security hosts, sponsors, and conducts 

conferences to enhance its mission. These conferences also bring DHS 

employees and stakeholders together to share information, deliver education or 

training, and coordinate and collaborate with other Federal and non-Federal 

stakeholders on common issues or goals. Conferences are pre-arranged events 

that typically include designated or registered participants, a defined agenda, 

and scheduled speakers or discussion panels on defined topics. OMB M-12-12 

and the Federal Travel Regulations (FTR), §300-3.1, define ‘conference’ as “[a] 

meeting, retreat, seminar, symposium, or event that involves attendee travel. 

The term ‘conference’ also applies to training activities that are considered to 

be conferences under [Title 5 of the Code of Federal Regulations] § 410.404”. 

1

 OMB Memorandum 12-12, Promoting Efficient Spending to Support Agency Operations (OMB M-12-12) 

was revised on November 25, 2016. The audit did not take the amendment into account because the 

audit scope was FYs 2014 and 2015. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

According to data obtained from DHS’ Conference Approval Tool, DHS held 433 

conferences with total cost of approximately $11.4 million in fiscal year 2014 

and 478 conferences totaling approximately $10.4 million in FY 2015. The 

Department reported that it hosted or sponsored six conferences in FY 2014 

and four in FY 2015 with expenses greater than $100,000 each (see table 1), 

totaling $1.4 million. The Office of Chief Financial Officer (OCFO) uses the 

Conference Approval Tool (CAT) as the central repository for hosted conference 

requests and approvals. 

Table 1- FY 2014 – FY 2015 DHS Conference Summary 

FY 2014 FY 2015 

DHS Total Conferences 433 478 

DHS Reported Conferences > $100,000 62 4 

Total Conference Costs (in millions) $11.4 $10.4 

Source: Office of Inspector General (OIG)-generated table based on information provided by 

DHS OCFO. 

2 We reviewed five of the six conferences, as OCFO mistakenly reported one conference that was an 

“attended” conference in FY 2014. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Audit
 

The Department did not comply with the reporting of annual conferences as 

required by Federal regulations. The Department failed to report 6 of 12 

(50 percent) conferences in FY 2014 and 14 of 18 (78 percent) conferences in 

FY 2015 that were greater than $100,000 in its Annual Report to OIG and on 

the public website (see chart 1). The total dollar value of unreported 

conferences greater than $100,000 was $862,881 and $2,822,561 for FYs 2014 

and 2015, respectively (see appendices C and D). 

Chart 1 – DHS Conferences Not Reported 

FY 2014-15 DHS Conferences Greater Than 

$100,000 Not Reported 

FY 2014 FY 2015 

50% Not Reported 78% Not Reported 

Reported Not Reported 

0% 

20% 

40% 

60% 

80% 

100% 

Source: OIG’s analysis based upon information obtained from DHS OCFO. 

The Department failed to report these conferences on the public website as 

required by OMB M-12-12, Promoting Efficient Spending to Support Agency 

Operations, and was not transparent regarding the reporting of public funds for 

conferences.3 

DHS reported 12 hosted conferences greater than $20,000 to OIG as required 

within 15 days after the end of each conference, but reported 5 conferences 

later than 15 days and did not report 3 conferences. Furthermore, DHS 

components did not always report actual conference costs timely or accurately, 

and in some cases, DHS was unable to provide appropriate documentation to 

support expenses totaling $79,471; however, we do not question the validity of 

these expenses. Lastly, we found DHS did not report in the CAT one conference 

held in FY 2014 with a final cost of $20,253. 

Report publicly on all conference expenses in excess of $100,000. Agencies shall report on conference 

expenses on a dedicated place on their official website. By January 31 of each year (beginning on January 

31, 2013), the agency head shall provide a description of all agency-sponsored conferences from the 

previous fiscal year where the net expenses for the agency associated with the conference were in excess 

of $100,000. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We determined that the Department did not comply with reporting 

requirements of conferences greater than $100,000 because the OCFO 

misinterpreted Federal guidance and excluded training conferences. The 

Department did not always notify OIG within 15 days of a conference due to 

incomplete guidance on providing notification to OIG. 

Additionally, DHS components did not always report actual conference costs 

timely or accurately because of lack of written guidance within the DHS 

Financial Management Policy Manual. Two components were unable to provide 

appropriate documentation to support some expenses due to changes in travel 

systems. Finally, a component official said they were aware of the reporting 

requirements in CAT; however, they mistakenly failed to report one conference. 

Although DHS did not comply with the reporting requirements, based upon the 

results of the nine conferences that we tested, DHS conference expenses for 

FYs 2014 and 2015 appeared appropriate, reasonable, and necessary. 

Accurate reporting of conference costs is important for the integrity of the 

conference cost reporting process and to ensure transparency. Without 

adequate supporting documentation, DHS cannot be assured that all 

conference spending is appropriate or in the best interest of the Government 

and taxpayers. 

Reporting Requirements 

Underreporting of Hosted Conferences Greater Than $100,000 

DHS did not always report conferences greater than $100,000, as required. The 

Department reported to OIG that it held six conferences in FY 2014 and four in 

FY 2015 with expenses exceeding $100,000 each. However, the Department 

should have reported 20 additional conferences to OIG, 6 conferences held in 

FY 2014 and 14 held in FY 2015. The Department also failed to report these 

conferences on the public website as required by OMB Memorandum 12-12, 

Promoting Efficient Spending to Support Agency Operations, and was not 

transparent regarding the reporting or use of public funds for conferences. 

During our review of the CAT data, we identified 34 conferences held during 

FYs 2014 and 2015 that had actual total costs exceeding $100,000 that were 

not reported to OIG. For these 34 conferences, we held discussions with the 

OCFO to determine the reason for not reporting them to OIG and on the 

external website. We noted that the Department should have reported 18 of 

these 34 conferences to OIG because they were training conferences. The 

OCFO also mistakenly did report one non-training conference (see table 2). The 

remaining 15 conferences were not reportable because they were either 

attended events and were not hosted conferences; mission-related meetings 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

and exempt from the reporting requirement; or DHS collected conference fees, 

which reduced the final actual cost to less than $100,000. Finally, we noted 

one unreported conference where actual costs exceeded $100,000. 

Table 2 - Summary of Underreported Conferences

Cause of Underreporting 

Number Not 

Reported 

FY 2014 FY 2015 

OCFO did not report training conferences as 

required by Federal regulations. ͸ ͳʹ

OCFO mistakenly did not report a nontraining conference. 1 

One component did not accurately report all 

actual costs into CAT. Final conference costs 

were greater than $100,000, resulting in the 

conference being reportable. 1 

Total Conferences Not Reported Greater 

than $100,000 6 14 

FY 2014 and FY 2015 Total Conferences Not Reported Greater than 

$100,000: 20 

 Source: OIG’s analysis of data obtained from DHS OCFO. 

OCFO officials said that they did not report the 6 conferences held in FY 2014 

and 12 held in FY 2015 because the conferences were considered training 

conferences and, therefore, should be excluded from the reporting requirement. 

OCFO incorrectly interpreted the General Services Administration’s (GSA) 

Bulletin FTR 14-02, Clarification of Agency Reporting Requirements for 

Conferences, resulting in their excluding training conferences from the 

reporting. However, GSA Bulletin FTR 14-02 specifically notes that “employees 

attending training activities at a conference should report the trip as a 

[conference], as required by OMB M-12-12. 

Additionally, OCFO acknowledged that it should have reported an additional 

non-training event greater than $100,000 held in FY 2015 at a cost of 

$120,592. For another conference with actual costs of $98,665 recorded in 

CAT, our review of documentation related to actual costs for that conference 

totaled $100,368. The conference met the criteria of a reportable event and 

should have been reported to OIG and on the public website. This occurred 

because the component failed to report an additional $1,703 of conference cost 

in CAT. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Public law requires DHS to report annually to OIG any conference held with a 

cost more than $100,000.4 According to GSA FTR 14-02, the term “conference” 

may also apply to training activities considered to be conferences under 5 CFR 

§ 410.404. 

Accurate reporting of conference costs is important to ensure transparency. 

Inaccurate conference cost reporting negatively affects the integrity of the 

conference cost reporting process enacted throughout the Department. 

15-Day Reporting Requirement Lacks Consistency 

DHS components did not always report conferences as required under the 

Consolidated Appropriations Act, 2014, and the Consolidated and Further 

Continuing Appropriations Act, 2015, within 15 days of hosting a conference 

with costs exceeding $20,000. DHS must report to OIG the date and location of 

the conference, and the number of employees who attended. 

On August 10, 2015, we reported that in FY 2014 and the first quarter of FY 

2015, DHS components did not report all conferences.5 For example, we noted 

DHS components reported just 13 percent of conferences in FY 2014 and 30 

percent in the first quarter of FY 2015. Because of process changes made in 

FY 2015 to correct the audit recommendations, we tested DHS’ compliance 

with the 15-day reporting requirement for the first and second quarters of FY 

2016. 

We judgmentally selected 20 out of 96 hosted conferences with costs greater 

than $20,000 to test DHS’ compliance with the 15-day reporting requirement 

for the first two quarters of FY 2016. Table 3 shows the results of the 20 

sampled conferences. 

Table 3 – 15-Day Reporting Requirement Testing Results 

15-Day Reporting Requirement (sample 20) 

Reported on 

Time 

Reported Late 

(2–62 days) Not Reported 

12 5 3 

Source: DHS OIG analysis of DHS’ data. 

4 P. L. 113-76, the Consolidated Appropriations Act, 2014 and P. L. 113-235, the Consolidated and Further 

Continuing Appropriations Act, 2015 

5 OIG-15-121-MA, Management Advisory on Department of Homeland Security Components' Reporting of 

Conference Spending, August 10, 2015. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Although DHS components have shown much improvement in adhering to the 

15-day reporting requirement since August 2015, more consistency is needed. 

For example, in addition to 40 percent (8 out of 20) of our sampled conferences 

reported late or not reported at all, there was a lack of consistency concerning 

where to send the reported information and whether to upload the email to OIG 

into the CAT system. OCFO officials noted that in addition to providing the 15-

day notices to OIG, components also need to update CAT to verify they have 

complied with the 15-day requirement. Untimely conference reporting could 

diminish the transparency of DHS reporting processes enacted throughout the 

Department. 

Actual Costs for Conferences Not Always Reported Timely or Accurately 

As previously stated, DHS reported nine conferences in excess of $100,000 for 

FYs 2014 and 2015; yet, components did not report accurate conference costs 

to OCFO within 45 days after the end of these conferences. An OCFO official 

said that components have 45 days from the end of a conference to update the 

CAT system with actual cost data. Although DHS does not have formal written 

guidance, CAT provides an automated notice 45 days after the conference 

concludes informing the components of the requirement. As a result, DHS does 

not have timely or accurate conference cost data, which may negatively impact 

its ability to comply with Federal reporting requirements. 

To test components’ compliance with the 45-day reporting requirement, we 

reviewed conference data uploaded to the CAT system as well as the 

components’ own internal conference documentation for these nine 

conferences. Of the nine conferences, none met the 45-day requirement. 

Furthermore, for FY 2015, we also identified 153 conferences out of total of 478 

conferences reported (32 percent) that did not have an amount entered in the 

actual conference cost field within 45 days after the end of the conference. 

Although DHS’ CAT requires components to report actual costs within 45 days 

of the end of a conference, the DHS Financial Management Policy Manual does 

not include this requirement. In addition, components cited that the 45-day 

requirement is unreasonable due to difficulty in obtaining final costs from 

invitational travel and vendors. However, OCFO officials consider the 45-day 

requirement to be reasonable and plan to update the Financial Management 

Policy Manual with the 45-day requirement. 

In addition, for these nine conferences, we noted two conferences with actual 

cost $6,290 higher and four with actual cost $70,750 lower than reported in 

CAT. The inconsistent reporting resulted from delays receiving final costs from 

invitational travelers and one component mistakenly applying a contractor’s 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

cost within CAT. The OCFO acknowledged a lack of follow-up processes with 

the components on the reporting of their actual costs. 

Inadequate Supporting Documentation for Conference Expenses 

For the nine conferences we tested, eight met the requirements for controlling 

costs and providing supporting documentation (such as travel vouchers and 

receipts). However, one component was unable to provide supporting 

documentation totaling $79,471 for some expenses because of a change in 

travel systems. Without adequate documentation, DHS cannot be assured that 

all conference spending is appropriate or in the best interest of the Government 

and taxpayers. 

Conference approval packets include documents such as a conference approval 

form; estimated costs for the conference; justification for the conference and 

site selection; evidence of using the least-costly location; and a copy of the 

conference agenda. For the nine conferences we reviewed, each approval 

package included a clearly stated purpose for the conference. Additionally, for 

eight of those nine conferences, the agendas did not indicate any inappropriate 

activities; and there were no expenses for social or entertainment activities. 

One conference approval packet did not include a copy of the agenda, so we 

could not determine whether funds were expended for social or entertainment 

activities. The actual costs for eight of the nine conferences were less than the 

estimated, approved costs; and for the one conference that exceeded the 

estimate, the difference was less than 10 percent. For each of the conferences 

we reviewed, the components chose the least-costly location (see appendix E for 

summary). 

Although DHS was not able to provide supporting documentation for $79,471, 

we did not question the validity of those expenses. Therefore, based upon the 

results of the nine conferences tested, DHS conference expenses for FYs 2014 

and 2015 appeared appropriate, reasonable, and necessary. 

Reportable Events Not Submitted within the Conference Approval Tool 

To determine the reliability of DHS’ CAT data, we compared it to internal 

component data to identify any inconsistencies. Our comparison included 

internal source data from 73 conferences from the five components that had 

reportable conferences during FYs 2014 and 2015. We noted one component 

did not submit data to CAT for approval or report the cost of a conference it 

held in FY 2014 with a final cost of $20,253. A component official said they 

were aware of the reporting requirements; however, they mistakenly failed to 

report the conference. Lack of conference cost reporting negatively affects the 

integrity of the conference cost reporting process enacted throughout the 

Department. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Annual Reporting to Congress 

The FY 2014 and FY 2015 Senate and House Reports6 require the Inspector 

General to report to the Appropriations Committee 30 days after the end of 

each fiscal year regarding DHS spending on conferences, ceremonies, and 

similar events, based on quarterly reporting to OIG. The report should include 

the number of conferences held, the amount of funds obligated, and expenses 

by appropriation, including budget accounts and subaccounts used to pay for 

events. 

DHS officials in OCFO have indicated that CAT did not have the capability to 

capture the required appropriation and subaccount data, as they were not 

aware of the requirements placed on the Inspector General in the House and 

Senate reports. Furthermore, the Senate and House Appropriations Acts do not 

require DHS to provide quarterly data to OIG. 

However, during our audit, OCFO implemented changes to CAT to allow 

components to enter the required data. Additionally, OCFO obtained the 

required data from components and provided OIG with detailed conference 

spending data for the nine conferences we reviewed (see appendix F). As such, 

we did not provide recommendations to OCFO. 

Recommendations 

Recommendation 1: We recommend that the DHS Chief Financial Officer 

implement controls that provide reasonable assurance that components report 

all applicable conferences, including training conferences, greater than 

$100,000. 

Recommendation 2: We recommend that the DHS Chief Financial Officer 

(a) provide the components information regarding the appropriate channel to 

report to OIG conference expenditures exceeding $20,000 within 15 days; and 

(b) obtain reasonable assurance that components understand they need to 

upload the actual email notice sent to OIG into the Conference Approval Tool. 

Recommendation 3: We recommend that the DHS Chief Financial Officer 

update the Financial Management Policy Manual with specific language 

regarding the 45-day reporting requirement that components submit their 

6 Senate Report 113-77, accompanying the Department of Homeland Security Appropriations Bill, 2014

 House Report 113-91, accompanying the Department of Homeland Security Appropriations Bill, 2014

 Senate Report 113-198, accompanying the Department of Homeland Security Appropriations Bill, 2015

 House Report 113-481, accompanying the Department of Homeland Security Appropriations Bill, 2015 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

actual cost data for conferences timely and accurately within the Conference 

Approval Tool. 

Recommendation 4: We recommend that the DHS Chief Financial Officer 

continue to work with component senior financial management officials to 

define record-keeping requirements that adequate support exists for incurred 

conference costs. 

Recommendation 5: We recommend that the DHS Chief Financial Officer 

continue to work with component senior financial officials to reiterate the 

requirements that conferences are appropriately submitted and approved 

through the Conference Approval Tool. 

Management Comments and OIG Analysis 

DHS concurs with all of the recommendations. A copy of DHS’ response in its 

entirety is included in appendix B. DHS also provided technical comments and 

suggested revisions to our report in a separate document. We reviewed the 

technical comments and made changes to the report when appropriate. A 

summary of our analysis follows. 

DHS’ Comments to Recommendation #1: Concur. The DHS Office of the 

Chief Financial Officer (OCFO) revised its conference policy in November 2016 

to clearly define what conferences, including training conferences, must be 

approved through the conference process. OCFO will report all of these 

conferences to the OIG, consistent with the policy. Additionally, any event, 

mission, training, etc., that is required to go through the conference policy and 

has expenses greater than $100,000 will be reported to OIG and Office of 

Management and Budget (OMB). The updated policy has been provided to the 

OIG under separate cover. We request that the OIG consider this 

recommendation resolved and closed. 

OIG Analysis of DHS’ Comments: OCFO updated its policy/guidance on 

conferences in November 2016. Among other changes, the policy now requires 

Components’ senior officials to certify to DHS CFO the completeness of total 

conference expenditures for conferences hosted and attended. DHS’ actions 

satisfy the intent of the recommendation; and we consider the recommendation 

resolved and closed. 

DHS’ Comments to Recommendation #2: Concur. DHS’ conference policy, 

revised on November 17, 2016, clearly identifies the OIG 15-day reporting 

requirement as well as the manner of report submission to the OIG Executive 

Secretariat, the OIG Special Assistant, and the OCFO. The policy also requires 

CAT input for all events subject to the policy. In addition to providing guidance 

to all DHS Components on the revised policy, the OCFO has recently 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

implemented a new internal Standard Operating Procedure (SOP), beginning 

with the first quarter of FY 2017, to monitor reporting compliance on a 

recurring basis. The revised policy and the SOP were provided to OIG under 

separate cover. We request that the OIG consider this recommendation 

resolved and closed. 

OIG Analysis of DHS’ Comments: DHS’ actions satisfy the intent of the 

recommendation. OCFO implemented additional guidance regarding the 

appropriate channel to report to OIG conference expenditures exceeding 

$20,000 within 15 days and the required support within CAT. As a result, we 

consider the recommendation resolved and closed. 

DHS’ Comments to Recommendation #3: Concur. OCFO's updated policy 

clearly reinforces that Components' need to report actual conference costs in 

the CAT within 45 days following the conclusion of each conference. 

Additionally, per the new SOP, OCFO will monitor compliance of Components 

reporting of actual costs. This recurring monitoring will begin during the third 

quarter of FY 2017. We request that the OIG consider this recommendation 

resolved and closed. 

OIG Analysis of DHS’ Comments: DHS’ actions satisfy the intent of the 

recommendation. OCFO updated its Financial Management Policy Manual with 

specific language regarding the 45-day reporting requirement. As a result, we 

consider the recommendation resolved and closed. 

DHS’ Comments to Recommendation #4: Concur. OCFO's revised policy 

clearly reinforces that Components need to maintain adequate documentation 

such as invoices, travel reports, contract files, and conference agendas in a 

manner that facilitates timely audit or review. We request that the OIG 

consider this recommendation resolved and closed. 

OIG Analysis of DHS’ Comments: OCFO’s corrective action satisfies the intent 

of the recommendation. OCFO updated its Financial Management Policy 

Manual with specific language defining record-keeping requirements for 

Components to adequately support conference costs. As a result, we consider 

this recommendation resolved and closed. 

DHS’ Comments to Recommendation #5: Concur. OCFO's revised policy 

provides data tables showing what types of events need to be entered into the 

CAT. The policy identifies what events are exempted from entering into the CAT 

and clarifies reporting thresholds. As compared to the most recent OMB 

guidance, current DHS policy thresholds are more restrictive than is required 

of federal agencies. Also, per the revised policy, OCFO requires each 

Component Senior Financial Official to annually certify their review of CAT data 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

for accuracy and completeness of conference activity. We request that the OIG 

consider this recommendation resolved and closed. 

OIG Analysis of DHS’ Comments: DHS’ actions satisfy the intent of the 

recommendation. OCFO implemented additional guidance that depicts what 

types of events need to be entered into the CAT. The policy identifies what 

events are exempted from entering into the CAT and clarifies reporting 

thresholds. As a result, we consider the recommendation resolved and closed. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, and Methodology 

The Department of Homeland Security Office of Inspector General was 

established by the Homeland Security Act of 2002 (Public Law 107ï296) by 

amendment to the Inspector General Act of 1978. This is one of a series of 

audit, inspection, and special reports prepared as part of our oversight 

responsibilities to promote economy, efficiency, and effectiveness within the 

Department. 

We performed this audit to determine whether DHS’ spending on hosted or 

sponsored conferences was appropriate, reasonable, and necessary, and in 

compliance with Public Law 113–76, Consolidated Appropriations Act, 2014, 

and Public Law 113-235, Consolidated and Further Continuing Appropriations 

Act, 2015. To achieve our audit objective, we identified and reviewed applicable 

Federal laws and regulations, Office of Management and Budget’s guidance, 

DHS policies and procedures, and other Federal agencies’ best practices 

regarding conferences. We interviewed DHS officials within the Office of the 

Chief Financial Officer directly involved in the DHS conference approval, 

reporting, and oversight process. We interviewed officials from DHS’ Risk 

Management and Assurance Division and reviewed oversight processes for 

conferences held during FYs 2014 and 2015. Based on conferences reported for 

FYs 2014 and 2015, we interviewed employees from the United States Customs 

and Border Protection, United States Immigration and Customs Enforcement, 

Office of Intelligence and Analysis, Science and Technology Directorate, United 

States Coast Guard, and the National Protection and Programs Directorate. 

Our audit scope covered those DHS-hosted or sponsored conferences exceeding 

$100,000 during FYs 2014 and 2015. DHS reported to OIG it hosted 10 

conferences exceeding $100,000 during FYs 2014 and 2015. However, we 

determined DHS mistakenly reported one conference; as a result, we reviewed 

nine conferences in excess of $100,000 to determine whether conference 

spending was reasonable, appropriate, and necessary. DHS reported the cost of 

the nine conferences totaled $1.3 million. 

For these nine conferences reviewed, we analyzed both actual and estimated 

costs, and approval packages submitted to DHS. We reviewed contracts, 

invoices, procurement requisitions, travel expenditure reports, and vouchers; 

and other documentation such as agendas, registration or attendance listings, 

and justifications related to the conferences. We also reviewed whether the 

applicable conferences were correctly reported on the DHS external website, as 

required by Federal regulations. We also viewed documentation to determine 

whether components were submitting actual costs for conferenceV timely and 

accurately. To test reporting requirements, we judgmentally selected 20 of 96 

conferences (21 percent) with costs greater than $20,000 the first two quarters 

www.oig.dhs.gov 13 OIG-17-94 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

of FY 2016 that required reporting notices to OIG within 15 days of conference 

completion. We tested the 15-day notification for the first two quarters of FY 

2016 because DHS implemented corrective actions to address 

recommendations in our August 2015 report (OIG-15-121-MA). 

To test whether there were conferences under the $100,000 threshold that 

should have been reported as greater than $100,000, we selected an additional 

6 of 14 conferences ranging from $85,000 to $99,999 to determine the 

accuracy of the reporting process. 

We reviewed CAT data and identified an additional 34 conferences during FYs 

2014 and 2015 that had actual conference costs over $100,000 that were not 

reported to OIG. For those 34 conferences, we held discussions with the OCFO 

to determine the reason for not reporting them to OIG and on the external 

website per Federal regulations. 

To determine the reliability of DHS’ CAT data, we compared it to internal 

component data to identify any inconsistencies. Our comparison included 

internal source data from 73 conferences from the five components that had 

reportable conferences during FYs 2014 and 2015. We determined that the 

components reported 72 of 73 conferences in CAT as required. As a result, we 

concluded that the conference spending data in CAT was sufficiently reliable 

for meeting our audit objective and supporting our audit findings. 

We conducted this performance audit between March and November 2016 

pursuant to the Inspector General Act of 1978, as amended, and according to 

generally accepted government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based upon our 

audit objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based upon our audit objectives. 

www.oig.dhs.gov 14 OIG-17-94 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Management’s Comments to the Draft Report 

www.oig.dhs.gov 15 OIG-17-94 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 16 OIG-17-94 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 17 OIG-17-94 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 18 OIG-17-94 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

FY 2014 Conferences Greater than $100,000 Not Reported 

Component Conference 

Name 

Start 

Date End Date Actual Costs Type 

U.S. Customs 

and Border 

Protection 

Office of Air and 

Marine Senior 

Leadership 

Meeting 

9/15/14 9/17/2014 $148,285 Training 

U.S. 

Immigration 

and Customs 

Enforcement 

OPLA 101 

Training 9/8/14 9/12/14 $104,815 Training 

United States 

Secret Service 

2014 

Administrative 

Officers’ 

Conference 

7/22/14 7/24/14 $212,622 Training 

Transportation 

Security 

Administration 

TSA FSD - FAMS 

SAC Security 

Summit 

3/2/14 3/5/14 $160,438 Training 

Federal 

Emergency 

Management 

Agency 

Clean Slate 

Project 2/6/14 2/7/14 $116,021 Training 

U.S. Customs 

and Border 

Protection 

OAM Safety 

Training 

Symposium and 

Senior 

Leadership 

Meeting 

11/5/13 11/7/13 $120,700 Training 

Total $862,881 

Source: OIG table based on information provided by DHS Office of Chief Financial Officer. 

www.oig.dhs.gov 19 OIG-17-94 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

FY 2015 Conferences Greater than $100,000 Not Reported 

Component Conference 

Name 

Start 

Date 

End 

Date Actual Costs Type 

U.S. 

Immigration and

Customs 

Enforcement 

OPLA 201 

Experienced 

Attorney 

Training 

8/31/15 9/4/15 $194,886 Training 

U.S. 

Immigration and

Customs 

Enforcement 

OPLA Legal 

Support 

Operational 

Training 

8/17/15 8/21/15 $102,586 Training 

U.S. 

Immigration and

Customs 

Enforcement 

OPLA NSLS 

301 Training 8/11/15 8/14/15 $159,803 Training 

U.S. Citizenship

and Immigration 

Services 

Locally 

Employed Staff 

Training 

Seminar 

7/20/15 7/23/15 $101,924 Training 

U.S. 

Immigration and 

Customs 

Enforcement 

OPLA 101 

Training 2015 7/20/15 7/24/15 $106,034 Training 

U.S. 

Immigration and 

Customs 

Enforcement 

OPLA Human 

Rights Law 

Section 301 

Training 

6/16/15 6/19/15 $153,016 Training 

National 

Protection and 

Programs

Directorate 

Infrastructure 

Security 

Compliance 

Division 

5/19/15 5/21/15 $175,455 Training 

United States 

Coast Guard 

USCG 

Sponsored 

Certified 

Financial 

Management 

Intensive 

Review and 

Testing 

6/7/15 6/13/15 $120,341 Training 

Transportation 

Security 

Administration 

FSD FAMS 

SAC Security 

Summit 

4/14/15 4/15/15 $126,466 Training 

www.oig.dhs.gov 20 OIG-17-94 
 

 

Component 

National 

Protection and 

Programs 

Directorate 

Conference 

Name 

Protective 

Security Advisor 

Annual Meeting 

Start 

Date 

4/27/15 

End Date 

4/30/15 

Actual Costs 

$143,737 

Type 

Training 

Transportation 

Security

Administration 

Back to Basics 7/26/15 8/9/15 $1,015,948 Training 

Science and 

Technology 

Directorate 

2014 Cyber 

Security 

Division 

Principal 

Investigators 

Meeting 

12/16/14 12/18/14 $120,592 NonTraining 

Office of 

Health Affairs 

BioWatch 

Stakeholders' 

Workshop 

10/6/14 10/10/14 $201,405 Training 

U.S. Customs 

and Border 

Protection * 

Office of Air and 

Marine Senior 

Leadership 

Meeting 

8/24/15 8/27/15 $100,368 Training 

Total $2,822,561 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D - Continued 

FY 2015 Conferences Greater Than $100,000 Not Reported 

Source: OIG table based on information provided by DHS Office of Chief Financial Officer. 

* The component reported the conference as $98,665; however, actual costs were $100,368, and the 

Department should have reported the conference. 

www.oig.dhs.gov 21 OIG-17-94 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Results of Review of Supporting Documentation for Conference 

Expenses 

Conference Name 

15th North Pacific 

Coast Guard Forum 

Summit Meeting 

Clearly 

stated 

purpose 

Yes 

App

Supporting 

Documentation 

Yes 

roval Packet Criteria 

Actual cost 

less than or 

within 10% of 

estimate 

Less than 

estimate 

Least 

costly 

location 

Yes 

Appropriate, 

reasonable, 

and necessary 

Yes 

National Fusion Center 

Security Liaison 

Workshop 

Yes Yes Less than 

estimate Yes Yes 

2014 First Responders 

Resource Group 

Conference 

Yes No Less than 

estimate Yes Yes 

2014 Coast Guard 

Auxiliary National 

Training Conference 

Yes Yes Within 10% Yes Yes 

North Pacific Coast 

Guard Forum Experts’ 

Meeting 

Yes Yes Less than 

estimate Yes Yes 

Enforcement Systems 

Workshop Yes Yes Less than 

estimate Yes Yes 

NPPD 2014 Joint 

SAFECOM-NCSWIC 

Meetings 

Yes Yes Less than 

estimate Yes Yes 

NPPD 2015 Joint 

SAFECOM-NCSWIC 

Meetings 

Yes Yes Less than 

estimate Yes Yes 

2015 First Responders 

Resource Group 

Meeting 

Yes Yes Less than 

estimate Yes Yes 

Source: OIG table based on information provided by DHS Office of Chief Financial Officer. 

www.oig.dhs.gov 22 OIG-17-94 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

FYs 2014 and 2015 Conferences OIG Reviewed 

Component 

United 

States Coast 

Guard 

Conference Name 

15th North Pacific 

Coast Guard Forum 

(NPCGF) Summit 

Meeting 

Total Actual 

Cost 

F

$196,308 

Y 20

Appropriation 

Operating 

Expenses - 

Annual 

14 

Budget 

Account 

70 14 0610 

Budget Sub 

Account 

Operating funds 

and unit level 

maintenance 

70 14 0115 Management and 

Administration 

Support for Non70 13/14 0115 Federal Partners 

Intelligence

and Analysis 

National Fusion 

Center Security 

Liaison Workshop 

$116,492 Analysis and 

Operations Support for NonFederal Partners 

70 14/15 0115 

Mission 

Integration and 

Support 

7014/15 0115 

Science and 

Technology

Directorate 

First Responders 

Resource Group $100,471 

Research, 

Development, 

Acquisition and 

Operations 

70 13/15 0800 

Research 

Development and 

Innovation 

United 

States Coast 

Guard 

2014 Coast Guard 

Auxiliary National 

Training Conference 

$143,442 

Operating 

Expenses -

Annual 

70 14 0610 Operating funds 

and unit level 

maintenance 

United 

States Coast 

North Pacific Coast 

Guard Forum $103,136 

Operating 

Expenses - 70 14 0610 Operating funds and unit level 

Guard 

U.S. Customs 

and Border 

Protection 

Expert's Meeting 

Enforcement 

Systems Workshop 

F

$278,450 

Y 20

Annual 

Salaries and 

Expenses 

15 

70 15 0530 

maintenance 

Border Security 

and Control 

National 

Protection 

and 

Programs 

Directorate 

Joint Meeting of 

SAFECOM and 

NCSWIC 

$109,526 

Infrastructure 

Protection and 

Infrastructure 

Security 

Salaries & 

Expenses 

70 15 0565 Interoperability 

Support 

Science and 

Technology 

Directorate 

2015 First 

Responders 

Resource Group 

Meeting 

$130,255 

Research 

Development, 

Acquisitions 

and Operations 

70 15/17 0800 

Research 

Development and 

Innovation 

National 

Protection 

and 

Programs

Directorate 

Joint Meeting of 

SAFECOM and 

NCSWIC 

$130,120 

Infrastructure 

Protection and 

Infrastructure 

Security 

Salaries & 

Expenses 

70 15 0565 Interoperability 

Support 

Totals $1,308,200 

Source: OIG table based on information provided by DHS Office of Chief Financial Officer 

www.oig.dhs.gov 23 OIG-17-94 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix G 

Office of Audits Major Contributors to This Report 

Sandra John, Director 

Stephen Doran, Acting Audit Manager 

Christopher Byerly, Program Analyst 

Kalimuddin Ahmad, Auditor 

David Kinard, Auditor 

Frank Lucas III, Auditor 

Audrey Van, Auditor 

Kevin Dolloson, Communications Analyst 

Richard Joyce, Independent Referencer 

www.oig.dhs.gov 24 OIG-17-94 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix H 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

CBP Audit Liaison 

FEMA Audit Liaison 

ICE Audit Liaison 

NPPD Audit Liaison 

S&T Audit Liaison 

TSA Audit Liaison 

USCG Audit Liaison 

USCIS Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 25 OIG-17-94 
 

 

 

 

 

 

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