DEFENSE 

MANAGEMENT

DOD's Conference 

Policy Is Generally 

Consistent with 

OMB's Requirements

Report to Congressional Committees

January 2014

GAO-14-150

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-150, a report to 

congressional committees

January 2014

DEFENSE MANAGEMENT

DOD’s Conference Policy Is Generally Consistent 

with OMB’s Requirements

Why GAO Did This Study

DOD hosts conferences and sends its 

personnel to external conferences for 

training, professional development, 

and continuing education. However, 

concerns about executive agencies’ 

spending on conferences prompted 

OMB in 2012 to direct agencies to 

establish policies and practices for 

conference hosting and attendance. 

DOD issued its policy in September 

2012 to improve oversight of 

conference costs and updated it in 

November 2013, citing lessons learned 

from implementing the September 

2012 policy, among other things.

The conference report accompanying 

the National Defense Authorization Act 

for Fiscal Year 2013 mandated that 

GAO review DOD’s oversight and 

management of conferences. This 

report assesses (1) the extent to which 

DOD’s conference policy is consistent 

with OMB’s conference requirements

and (2) how DOD components have

implemented DOD’s conference policy.

GAO assessed DOD’s 2012 

conference policy and 2013 update

against OMB requirements and

reviewed components’ implementation 

of the policy. GAO analyzed responses 

to a questionnaire completed by

officials from 72 components and 

military commands and reviewed 563 

requests for conferences planned for

the second and third quarters of fiscal 

year 2013.

GAO is not making recommendations 

in this report. In written comments, 

DOD concurred with GAO’s findings 

and noted that it remains committed to 

balancing conference spending 

oversight with the benefits of hosting 

and allowing personnel to attend

conferences.

What GAO Found

The Department of Defense’s (DOD) September 2012 policy on conferences and its 

November 2013 update are generally consistent with the requirements established by 

the Office of Management and Budget (OMB) in May 2012. The key elements of 

OMB’s May 2012 requirements for agencies are the prohibition of conferences with 

costs in excess of $500,000 unless the agency head signs a waiver, establishment of 

a Deputy Secretary-level review process for conferences with estimated costs in 

excess of $100,000, and public reporting annually on the costs of these conferences. 

DOD adopted a tiered approval structure for the senior-level approval of waivers and

all conference-related costs. DOD’s policy, which cites the department’s size and 

complexity, places the approval authority for conference waivers and for conferences 

costing less than $500,000 at lower levels than called for by OMB. For example, 

OMB requires that waivers approving conferences with costs in excess of $500,000 

be signed by the head of an agency, while DOD’s policy delegates this authority to 23 

senior leaders throughout the department. DOD’s policy is more expansive as it 

requires senior-level review and pre-approval of all conference-related costs, 

compared to OMB’s requirement for senior-level review of conferences only when the

estimated costs exceed $100,000. DOD’s policy also fully addresses OMB’s 

requirement to publicly report conference costs annually and adds a requirement for 

quarterly internal reporting of conference costs.

In implementing DOD’s September 2012 policy (the existing policy when GAO 

conducted the majority of its review), DOD components—including the military 

departments—have taken various approaches to reviewing and approving 

conference requests, all of which are consistent with the policy. For example, DOD’s 

policy allows senior officials within each component to delegate certain approval 

authority to lower-level officials for DOD-hosted conferences costing $500,000 or less

and non-DOD hosted conferences costing $100,000 or less, but the components 

have delegated approval authority to different degrees. A majority of the 563 

conference requests that GAO reviewed addressed and documented key elements 

consistent with DOD and component-level guidance. In requests that were missing 

documentation of one or more key elements, GAO found that a specific element was

not missing from a significant number of requests. While the components’ 

implementation of the conference review and approval process has generally been 

consistent with DOD’s policy, some officials within the components and military 

service commands have identified concerns, particularly with the lengthy approval 

process. The officials explained that requests to attend conferences have to pass 

through multiple offices and individuals, sometimes taking several months to be 

approved. In particular, officials raised questions about the efficiency of reviews for 

requests to attend conferences that incurred no cost or a low cost (under $20,000) to 

DOD, which at the time of GAO’s review went through the same process as highercost conferences. Almost 94 percent of the 405 requests to attend non-DOD hosted 

conferences that GAO reviewed were for conferences with no cost or a low cost to 

DOD. DOD in November 2013 updated its policy to state that approval is not required 

for conferences incurring no cost for DOD. However, a DOD official involved in writing 

DOD’s conference policy stated that components still have the option to review 

conferences with no cost to DOD to facilitate senior leaders’ visibility over conference 

attendance by personnel within their component. View GAO-14-150. For more information, 

contact Johana Ayers at (202) 512-5741 or 

AyersJ@gao.gov.
Page i GAO-14-150 Defense Management

Letter 1

Background 4

DOD’s Policy Is Generally Consistent with OMB’s Requirements 

for Approving and Reporting Conference Costs 5

DOD Components Vary in Their Approaches to Implementing 

DOD’s Conference Policy, and Some Officials Expressed 

Concerns about the Lengthy Approval Process 12

Agency Comments 21

Appendix I Scope and Methodology 24

Appendix II Comments from the Department of Defense 32

Appendix III GAO Contact and Staff Acknowledgments 33

Figures

Figure 1: Tiered Approval Structure Outlined in DOD’s Conference 

Policy 7

Figure 2: Cost of 405 Requests to Attend Second and Third 

Quarter Fiscal Year 2013 Non-DOD Hosted Conferences 20

Abbreviations

DCMO Deputy Chief Management Officer

DOD Department of Defense

OMB Office of Management and Budget

Contents

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Page 1 GAO-14-150 Defense Management

441 G St. N.W.

Washington, DC 20548

January 21, 2014

Congressional Committees

The Department of Defense (DOD), like other executive agencies, hosts 

conferences and allows personnel to attend non-DOD conferences1 to 

help personnel be more effective in their jobs. Conferences provide 

agency personnel with the opportunity to achieve or maintain professional 

accreditations; the efficient delivery of training to large numbers of people; 

and the ability to collaborate with industry or foreign nationals. DOD 

personnel attend conferences on a range of topics, such as antiterrorism 

activities, force requirements, and religious ministry. However, Inspectors 

General have reported2 excessive costs for conferences hosted by other 

federal agencies. In November 2011, the President signed an executive 

order3 that cited the need for federal agencies to ensure efficient 

spending on conferences and other activities. To this end, the Office of 

Management and Budget (OMB) issued a memorandum in May 2012 

directing executive agencies to establish an approval process to review 

all future conference expenses in excess of $100,000 and to report 

agency-sponsored conferences with costs in excess of $100,000

annually.4

 1

“Conference” is defined in the Federal Travel Regulation 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 federal regulation 

(41 C.F.R. § 300-3.1). However, DOD’s policy provides that, for purposes of conference 

oversight requirements, this definition is only a starting point and that what constitutes a 

conference is a fact-based determination.

2

For example, U.S. General Services Administration’s Office of Inspector General, Office 

of Investigations, Management Deficiency Report: General Services Administration Public 

Buildings Service, 2010 Western Regions Conference (Apr. 2, 2012) and U.S. Department 

of Justice, Office of the Inspector General, Audit Division, Audit of Department of Justice 

Conference Planning and Food and Beverage Costs Audit Report 11-43 (Oct. 2011).

3

White House, Executive Order 13589, Promoting Efficient Spending, 76 Fed. Reg. 

70,861 (Nov. 9, 2011).

4

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

Operations (May 11, 2012).
Page 2 GAO-14-150 Defense Management

In response to OMB’s May 2012 memorandum, DOD issued interim 

guidance in June 20125 and a policy in September 20126 to improve the 

oversight of conference costs across DOD. In the policy, the Deputy 

Secretary of Defense identified the Deputy Chief Management Officer 

(DCMO) as the point of contact for conferences within DOD and assigned 

the DCMO responsibility for establishing and executing processes to 

implement DOD’s policy and issuing additional policies as necessary. On 

November 6, 2013, the DCMO issued an updated conference policy, 

effective on November 20, 2013.7

The conference report

According to a DCMO memorandum 

accompanying the November 2013 policy, updates were based upon 

lessons learned from implementation of the September 2012 policy, the 

budget uncertainty faced by DOD, and legislative changes.

8

To determine the extent to which DOD’s conference policy is consistent 

with OMB’s requirements, we assessed DOD’s September 2012 policy 

and the updated November 2013 policy against the three key elements 

specified in OMB’s May 2012 memorandum. The three elements are (1) 

the prohibition of conferences with costs in excess of $500,000 unless the 

head of the respective agency signs a waiver, (2) Deputy Secretary-level 

review of conferences with costs in excess of $100,000, and (3) public 

reporting annually of agency-sponsored conferences with costs in excess 

of $100,000.

accompanying the National Defense Authorization 

Act for Fiscal Year 2013 mandated that GAO review DOD’s oversight and 

management of conferences. This report assesses (1) the extent to which 

DOD’s conference policy is consistent with OMB’s requirements for 

conference approval and cost reporting and (2) how the DOD 

components have implemented DOD’s conference policy.

9

 5

DOD, Deputy Secretary of Defense Memorandum, Implementation of May 11, 2012, 

Office of Management and Budget Memorandum, Promoting Efficient Spending to 

Support Agency Operations (June 3, 2012).

We also interviewed officials from the Office of the DCMO 

6

DOD, Deputy Secretary of Defense Memorandum, Implementation of Conference 

Oversight Requirements and Delegation of Conference Approval Authority (Sept. 29, 

2012).

7

DOD, Deputy Chief Management Officer Memorandum, Implementation of Updated 

Conference Oversight Requirements (Nov. 6, 2013).

8

H.R. Conf. Rep. No. 112-705, at 887 (2012).

9

The three elements encompass all of the new policies and practices for conference 

hosting and attendance in OMB M-12-12. 
Page 3 GAO-14-150 Defense Management

and OMB staff. To determine how the DOD components have 

implemented DOD’s conference policy, we identified the DOD 

components’ processes and procedures for approving conference 

requests and reporting conference costs. We also developed, 

administered, and analyzed responses to a combination of structured 

interviews and questionnaires completed by officials within DOD 

components,10 including those at the major command-level in all four 

military services. We obtained 563 approved requests for conferences 

hosted by DOD or attended by DOD personnel in the second and third 

quarters of fiscal year 201311 and used a standardized checklist to assess 

whether the information identified by DOD’s September 2012 policy was 

included.12

We conducted this performance audit from May 2013 to January 2014 in 

accordance with 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 on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

We analyzed conference requests for this time period because 

the approval process established by DOD’s September 2012 policy was 

not fully implemented until the second quarter of fiscal year 2013. Further, 

conference requests for the fourth quarter of 2013 were not widely 

available during our review. Also, we reviewed DOD’s fiscal year 2012 

annual conference report and DOD’s quarterly conference reports for the 

first three quarters of fiscal year 2013. We provide additional information 

about our detailed scope and methodology in appendix I.

 10The DOD components within the scope of our review included the Army, Navy, Air 

Force, Marine Corps, offices of the Under Secretaries of Defense, Joint Staff, National 

Guard Bureau, and combatant commands. For a full list of the components we contacted, 

see appendix I.

11We reviewed 424 conference requests for the second and third quarters of fiscal year 

2013 from the DOD components, Army, Air Force, and Marine Corps. For the Navy, we 

reviewed 139 conference requests for the third quarter of fiscal year 2013 because 

second-quarter conference requests that had been archived in the Navy’s document 

management system were inaccessible.

12We assessed the conference requests against key elements in DOD’s September 2012 

policy and against implementing guidance issued by some of the components, including 

the military departments. 
Page 4 GAO-14-150 Defense Management

Beginning in 2011, OMB issued one of two memorandums establishing 

oversight requirements for conferences as part of a larger effort to help 

promote efficient spending in executive agencies. First, in September 

2011, OMB issued a memorandum13

OMB’s May 2012 memorandum, among other requirements, outlines a 

series of new policies and practices to ensure that federal funds are used 

appropriately on conference-related activities and that agencies reduce 

spending on conferences when practicable. These policies include the 

initiation of Deputy Secretary-level review of all planned conferences 

costing more than $100,000 each and of all future conferences estimated 

to cost more than $100,000 each. During these reviews, agencies also 

should ensure that conference attendance and costs are limited to the 

levels required to carry out the mission of the conference. The 

memorandum further prohibited costs in excess of $500,000 on a single 

conference without a signed waiver from the head of the respective 

agency. Finally, the memorandum requires each executive agency to 

report annually on its official website the expenses for any agencysponsored conference exceeding $100,000. Specific reporting 

requirements include: the location, date, and total conference costs 

incurred by the agency for the conference; a brief explanation of how the 

conference advanced the mission of the agency; and the total number of 

individuals whose travel costs or other conference costs were paid by the 

agency.

directing all executive agencies and 

departments to conduct a thorough review of the policies and controls 

associated with conference-related activities and costs, and report to 

OMB on the results. Further, OMB’s memorandum required that all 

conference-related activities and costs be approved by the Deputy 

Secretary until he or she could certify that the appropriate policies and 

controls were in place for mitigating the risk of inappropriate spending 

practices regarding conferences. Then in May 2012, OMB issued a 

second memorandum to executive agencies and departments, outlining 

new policies for conference sponsorship, hosting, and attendance. This 

memorandum states that conference costs should be appropriate, 

necessary, and managed in a manner that minimizes costs to taxpayers.

 13OMB, Memorandum M-11-35, Eliminating Excess Conference Spending and Promoting 

Efficiency in Government (Sept. 21, 2011).

Background
Page 5 GAO-14-150 Defense Management

Subsequent to OMB’s conference reporting requirements, the 

Consolidated and Further Continuing Appropriations Act, 201314

established a requirement for executive agencies to notify their respective 

Inspector General of any agency-hosted conference costing more than 

$20,000, and to provide the notice within 15 days of the conference. The 

notice must include the date and location of the conference, and the 

number of employees attending. The act also requires agencies to submit 

annual reports to the Inspector General or senior ethics official regarding 

the costs and contracting procedures related to each conference when 

the cost to the government exceeds $100,000.

DOD’s September 2012 policy and November 2013 update are generally 

consistent with the three key elements of OMB’s requirements for 

approving conferences and reporting associated costs.15

 14Pub. L. No. 113-6, § 3003(c), 127 Stat. 435 (2013).

The key 

elements of OMB’s requirements for agencies are the prohibition of 

conferences with costs in excess of $500,000 unless the head of the 

respective agency signs a waiver, establishment of a Deputy Secretarylevel review process for conferences with costs in excess of $100,000, 

and public reporting annually of the costs of agency-sponsored

conferences with costs in excess of $100,000. DOD’s variances from 

OMB’s requirements for the first two elements are attributable to DOD’s 

size and complexity and, according to DOD’s policy, were done with 

OMB’s concurrence. Specifically, the Secretary of Defense delegated 

some responsibility for reviewing and approving conferences that is not 

explicitly granted by OMB’s requirements. Despite these variances, some 

provisions within DOD’s conference policy exceed OMB’s requirements 

by providing additional detail for how to implement the conference 

approval process and requiring additional conference cost reporting.

15The updated conference policy issued in November 2013 supersedes and cancels the 

prior policy. The policies and requirements described in our report are contained in both 

the September 2012 policy and the November 2013 update, unless otherwise noted in our

report. 

DOD’s Policy Is 

Generally Consistent 

with OMB’s 

Requirements for 

Approving and 

Reporting Conference 

Costs
Page 6 GAO-14-150 Defense Management

DOD’s policy established the need for a waiver for any conference with 

costs in excess of $500,000, but placed the authority for granting those 

waivers at a lower level than required by OMB. DOD’s policy prohibits 

DOD components from incurring costs greater than $500,000 on a single 

conference, unless a waiver is granted by certain designated officials. 

OMB’s May 2012 memorandum requires that the waivers be signed by 

the head of an agency, which for DOD is the Secretary of Defense; 

however, the Secretary of Defense delegated this authority to 23 senior 

leaders across DOD. These leaders include the Secretaries and Under 

Secretaries of the military departments, the Chief of the National Guard 

Bureau, the Director of the Joint Staff, the Commanders of the combatant 

commands, the Under Secretaries of Defense, and the DCMO.

To address OMB’s requirements regarding the review and approval of 

conferences, DOD’s policy established a tiered approval structure. Like 

the delegation of waivers for conferences costing over $500,000, DOD’s 

policy places the approval authority for conferences costing less than 

$500,000 at lower levels than called for by OMB. Specifically, OMB’s May 

2012 memorandum specified that Deputy Secretaries within agencies are 

responsible for approving spending on conferences that will cost more 

than $100,000 but not in excess of $500,000. In DOD’s policy, these 

responsibilities and authorities are delegated to the same 23 senior 

leaders that have responsibility for approving waivers for conferences 

costing in excess of $500,000. These officials may, in turn, delegate 

approval authority to 81 other specific officials identified in the policy.16

 16DOD’s September 2012 policy identified 93 officials who could be delegated authority to 

approve conferences costing between $100,000 and $500,000. 

Figure 1 depicts DOD’s tiered approval structure for conferences.

DOD Delegated Approval 

Authority for Conferences 

to Senior DOD Leaders 

in a Tiered Approval 

Structure
Page 7 GAO-14-150 Defense Management

Figure 1: Tiered Approval Structure Outlined in DOD’s Conference Policy

DOD’s policy notes that the Secretary of Defense and the Deputy 

Secretary of Defense remain accountable for all of DOD’s conferencerelated activities, but explains that delegation to these senior leaders is 

being done in recognition of DOD’s size and complexity and with OMB’s 

concurrence. According to DCMO officials, it was infeasible to keep the 

waiver and approval authorities at the level of the Secretary or Deputy 

Secretary because the Secretary of Defense and Deputy Secretary of 

Defense did not have time to review and approve the number of DOD 

conferences expected to cost over $100,000. They also told us that they 

informed OMB of the Deputy Secretary of Defense’s decision to delegate 
Page 8 GAO-14-150 Defense Management

approval and waiver authorities, and received verbal concurrence from 

OMB staff to do so.

While DOD’s policy vests approval and waiver authority at a lower level 

than called for by OMB, DOD’s policy provides additional oversight by 

requiring senior-level review and pre-approval of all conference-related 

costs, regardless of the total, compared to OMB’s requirement for seniorlevel review of conferences only when the estimated cost is more than 

$100,000. Under DOD’s tiered approval structure, higher-cost DODhosted or attended conferences must be reviewed and pre-approved by 

senior leaders who have the option to delegate the approval authority for 

lower-cost conferences. The DOD policy explains that such requirements 

are intended to ensure that conferences hosted by DOD are executed in 

a responsible manner and that DOD is prudent when sending personnel 

to conferences hosted by others.

The conference policy updated in November 2013 also explicitly states 

that if it becomes apparent that the cost for a DOD-hosted conference will 

exceed the estimated cost and breach the next approval threshold, 

approval must be obtained from the higher-level approval authority as 

soon as possible. Additionally, if a DOD component initially estimates that 

the total cost of attendance at a non-DOD hosted conference will exceed 

$100,000 for that DOD component, then the conference must be 

approved by that DOD component’s highest tier of approval authority.17

The November 2013 policy also states that approval is not required for 

conferences that incur no cost to DOD, including instances where all 

conference costs are paid for by a non-DOD entity in accordance with 

DOD’s gift acceptance rules.18

In explaining the conference review and approval authorities, DOD’s 

policy provides criteria for personnel to determine whether an event 

meets the definition of a conference and is subject to the approval 

process. It notes that some conferences subject to DOD’s policy are

referred to by other terms, such as conventions and seminars. The policy 

 17If the cost is over $500,000 for that DOD component, approval in the form of a written 

waiver must be obtained from the highest tier approval authority.

18DOD’s acceptance of gifts is regulated by statute (e.g., 31 U.S.C. § 1353, Acceptance of 

Travel and Travel-Related Expenses from Non-Federal Sources, 5 U.S.C. § 4111, 

Acceptance of Contributions, Awards, and Other Payments). 
Page 9 GAO-14-150 Defense Management

provides key indicators of a conference that include, but are not limited to: 

registration and registration fees, a published agenda, and scheduled 

speakers. Also, the policy describes activities that should not be 

considered conferences even if they meet the general definition of a 

conference and are, therefore, exempt from the review and approval 

process. These exemptions include

• DOD meetings necessary to carry out:

• statutory command and staff oversight functions, such as 

investigations, inspections, audits, or non-conference planning site 

visits;

• internal agency business matters, such as meetings that take 

place as part of an organization’s regular course of daily business; 

or

• planning or execution of operational exercise activities or predeployment, deployment, or post-deployment activities.

• Events where participation by DOD personnel is required for:

• change of command, official military award, funeral, or other such 

ceremonies; or

• military or civilian recruiting or recruitment advertising.

• Formal classroom training, such as regular courses of instruction or 

training seminars. These activities may be offered by government 

organizations, institutions of higher learning or professional licensure 

or certification, or other training entities. However, events are not 

exempt simply because they offer continuing education credits or the 

equivalent.

• Meetings of advisory committees where one or more of the members 

is not a full-time or permanent part-time federal officer or employee.

DOD’s policy also describes elements to be included in the calculation of 

the estimated total cost of each planned conference, which then 

determines the approving official who must approve or reject the related 

request. For example, the cost estimate should include, among other 

elements, attendees’ authorized travel costs and per diem, audiovisual 

and other equipment usage, and registration fees. Costs are not to 

include such expenses as federal employee time for conference planning 

or attendance. Also, DOD policy prohibits the use of department funds for 

any entertainment expenses at DOD conferences.
Page 10 GAO-14-150 Defense Management

DOD’s policy addresses OMB’s requirement that all agencies issue an 

annual public report on agency-sponsored conferences with costs of 

more than $100,000 that occurred during the prior fiscal year, as well as 

subsequent statutory reporting requirements. DCMO officials told us that 

no department-wide data were maintained on conference costs prior to 

the adoption of the annual reporting requirement. DOD’s policy requires 

each DOD component to track the required reporting elements, which are 

monitored and consolidated by the Office of the DCMO for reporting. In 

addition to the total conference costs, the DOD components are to track 

information on which DOD component hosted the conference, the dates 

and location of the conference, the number of individuals whose 

expenses were paid by the agency, and a brief description of how the 

conference advanced DOD’s mission.

While OMB called for each agency to publicly report its conference costs 

by January 31 of each year, DOD’s first annual report, which covered 

fiscal year 2012, was not approved by the Deputy Secretary of Defense 

and posted on the DCMO’s website until February 2013. DOD otherwise 

met all of OMB’s conference reporting requirements. According to its 

report, DOD hosted 295 conferences during fiscal year 2012 that each 

had a total cost in excess of $100,000. DOD reported that these 

conferences collectively cost approximately $89 million. DOD also noted 

that after the issuance of OMB’s May 2012 memorandum, the Deputy 

Secretary of Defense signed waivers approving four conferences that

each cost in excess of $500,000 during fiscal year 2012. Waivers were 

approved for a suicide prevention conference, a symposium on education 

for military service members, a military health system research 

symposium, and a conference on DOD’s information assurance mission. 

DOD reported that these four conferences ranged in cost from around 

$550,000 to over $2 million, with a collective cost of almost $6 million.

Additionally, DOD took actions that expanded on OMB’s annual reporting 

requirement by issuing policy in September 2012 and updating its policy 

in November 2013 to establish that the DCMO will submit internal, nonpublicly available quarterly reports to the Deputy Secretary of Defense on 

DOD’s Policy Addresses 

and Expands on OMB’s 

Requirements for 

Reporting on Conference 

Costs
Page 11 GAO-14-150 Defense Management

conferences hosted or attended by DOD personnel.19

Under DOD’s November 2013 updated conference policy, DOD 

components are to enter conference cost data in a new, online reporting 

system referred to as the DOD Conference Tool. Specifically, each 

conference in excess of $20,000 must be entered into the DOD 

Conference Tool within 10 working days of the approval or the signing of

the waiver memorandum. In addition, within 30 days of the completion of 

each conference, the DOD components are to update their previous 

estimates based on any new information, such as adjusting the number of 

participants who attended or the cost factors that went into the cost 

estimate. According to officials from the Office of the DCMO, the DOD 

The Office of the 

DCMO compiled DOD’s first report on quarterly conference costs and 

submitted it in March 2013 to the Deputy Secretary of Defense. This 

report on conferences held in the first quarter of fiscal year 2013 repeated 

the type of cost data that was included in DOD’s fiscal year 2012 annual 

report for conferences that were hosted by DOD and cost over $100,000, 

and included additional information on non-DOD hosted conferences 

attended by DOD personnel that cost over $20,000. Later, DOD 

submitted its second-quarter report for the fiscal year in May 2013, and its 

third-quarter report in September 2013. For each DOD-hosted 

conference, the quarterly reports included additional information not found 

in the fiscal year 2012 annual report. Specifically, the quarterly reports 

included a breakout of the total cost for a DOD-hosted conference and 

included hosting costs (e.g., audiovisual equipment and facility rental), 

registration fees collected, and attendees’ estimated travel costs. Also, 

the quarterly reports included information on whether a DOD-hosted 

conference involved spousal travel, use of a non-federal conference 

planner, co-sponsorship with a non-federal organization, or a no-cost 

contract.

 19DOD’s September 2012 policy initially required the DOD components to submit quarterly 

reports on costs for all conferences that DOD hosted or attended, regardless of cost. Prior 

to submissions for the first quarterly report, the Deputy Secretary of Defense amended 

this requirement in response to a January 2013 memorandum from the DCMO. In the 

memorandum, the DCMO noted that lessons learned indicated that the original 

requirement put too great an administrative burden on the DOD components. The Deputy 

Secretary of Defense approved the proposed change to require that the quarterly reports 

include information on DOD-hosted conferences costing over $100,000 and non-DOD 

hosted conferences costing over $20,000. This change was reflected in reporting for the 

first quarter of fiscal year 2013. In the November 2013 updated policy, the quarterly 

reporting requirement was changed to include information on any conference, either 

hosted by DOD or by a non-DOD entity, with a cost to DOD of $20,000 or more.
Page 12 GAO-14-150 Defense Management

Conference Tool is intended to help standardize the reporting process 

across DOD and will help DOD component officials by spreading the 

administrative burden of collecting and reporting data throughout the year 

instead of requiring a concentrated effort each quarter. The officials also 

told us that prior to the requirement to use the DOD Conference Tool, 

components could, and did, use a variety of methods to report their 

conference costs. Aggregated reports from the DOD Conference Tool will 

be provided quarterly to the Deputy Secretary of Defense. Further, the 

DOD Conference Tool is intended to help DOD fulfill the reporting 

requirements included in the Consolidated and Further Continuing 

Appropriations Act, 2013. For example, personnel from the DOD 

Inspector General’s office have been granted access to the DOD 

Conference Tool, which meets the new requirement to report certain 

conference information to agencies’ Inspectors General.

In implementing DOD’s conference policy, DOD components have been 

consistent with the policy, but have taken various approaches. For 

example, the military departments have delegated approval authority—as 

allowed under DOD’s policy—differently. Also, some components have 

issued supplemental guidance that, among other matters, identifies the 

elements that conference requests are to address. In our review of 

563 approved requests for conferences in the second and third quarters 

of fiscal year 2013, we found that a majority (311) of the requests 

addressed key elements, such as noting how a conference is necessary 

or fulfills a mission, and including a cost estimate. While the remaining 

252 requests we reviewed did not contain documentation for all of the 

elements, we did not find circumstances where a specific element was 

consistently missing from a significant number of requests. In 

implementing the policy, some officials within the components identified 

concerns about the efficiency of the conference approval process. 

Specifically, these officials expressed concern that DOD’s policy requires 

a lengthy review process for all conference requests regardless of cost, 

raising questions particularly about the process’s efficiency for low-cost 

conferences (those under $20,000).

In implementing DOD’s policy for approving conference costs, the military 

departments have taken various approaches consistent with the policy 

regarding the delegation of approval authority. A senior DCMO official 

noted that it is acceptable for the military departments to implement the 

conference policy differently as long as they stay within the bounds of 

DOD’s policy. DOD’s policy permits specified senior leaders within the 

DOD Components 

Vary in Their 

Approaches to 

Implementing DOD’s 

Conference Policy, 

and Some Officials 

Expressed Concerns 

about the Lengthy 

Approval Process

DOD Components Vary 

in Their Approaches to 

Implementing DOD’s 

Conference Policy
Page 13 GAO-14-150 Defense Management

military departments to delegate their approval authority for DOD-hosted

conferences costing less than $500,000 and for attendance at non-DOD 

hosted conferences costing less than $100,000. The DOD components—

including the military departments—have varied in their delegation of 

approval authority. For example:

• The Department of the Army has delegated approval authority for 

Army-hosted conferences with costs less than $100,000 to 

appropriate principal officials and commanders. The Army has 

restricted approval authority for attendance at all non-DOD hosted 

conferences at the level of the Secretary or Under Secretary of the 

Army, or to the Administrative Assistant to the Secretary of the Army.

• The Department of the Navy has extended approval authority to its 

Assistant for Administration for Navy-hosted conferences costing 

$500,000 or less and for non-DOD hosted conferences for which 

attendance costs do not exceed $100,000.

• The Department of the Air Force initially delegated approval authority 

for Air Force-hosted conferences costing less than $500,000 and for 

non-DOD hosted conferences costing less than $20,000 to its major 

commands and certain other subordinate commands. However, since 

March 2013, the Air Force has retained authority for all conference 

approvals, regardless of cost, at the level of the Secretary or Under 

Secretary of the Air Force as part of its broader sequestration 

guidance.20

Military department officials explained that one reason they decided to 

maintain approval authority at a high level was to ensure close scrutiny 

and management of conference costs during the current environment of 

reduced budgets. Also, these officials noted that it is difficult to maintain 

visibility over the total attendance costs when personnel from multiple 

military service commands plan to attend the same conference. Further, 

the Department of the Navy oversees personnel from the Navy and 

Marine Corps, and could have personnel from both services attending the 

same conference. If the approval authority is delegated, there would be a 

risk that the total estimated costs would not be aggregated across military 

 20The failure to enact legislation to reduce the federal budget deficit by at least $1.2 trillion 

triggered the sequestration process under the Balanced Budget and Emergency Deficit 

Control Act of 1985, as amended. Pursuant to the Act, the President ordered 

sequestration of discretionary and direct spending on March 1, 2013.
Page 14 GAO-14-150 Defense Management

service commands and that requests would not receive the appropriate 

level of review.

In addition, officials from the Office of the DCMO and the military 

departments told us that maintaining high levels for approval authority 

helps mitigate risks to DOD other than the financial risk of unnecessary 

spending on conferences. Specifically, these officials said that military 

department leaders did not want to risk sending personnel to conferences 

that could be perceived as inappropriate for representatives of DOD, 

regardless of the financial cost of the conference. By maintaining 

approval authority at a high level within the military departments, senior 

DOD leaders are aware of the types of conferences that their civilian and 

military personnel are attending and can reject requests for conferences 

that they perceive as potentially damaging to DOD’s reputation. A DCMO 

official commented that although DOD’s conference policy allows for 

more latitude with regard to delegating approval authority than is currently 

being exercised, the decision thus far to ensure minimum risk by keeping 

approval levels high is an acceptable implementation of DOD’s policy.

Additionally, DOD components have, in some cases, developed 

supplemental guidance to implement a conference approval process that 

is consistent with DOD’s policy. Components’ guidance generally 

specifies procedures for preparing and submitting requests to host or 

attend conferences, including how to obtain pre-approval by the 

appropriate approval authority and what information to include so that the 

approval authority can determine if the conference is necessary and cost 

effective. For example, several DOD components have issued templates 

that standardize the required elements for senior-level reviews, such as 

including the purpose of a conference, how it fulfills a DOD mission, and 

specifying estimated costs.

We found that the DOD components generally were consistent with DOD 

and component-level guidance in processing requests to host or attend 

conferences. DOD’s September 2012 policy and some of the 

implementing guidance issued by the components—including the military 

departments—reference the following four key elements that help 

approval authorities determine the merit of a particular conference: (1) a 

statement by the requester that the conference is necessary or fulfills a 

DOD mission; (2) a cost estimate; (3) an assessment of the conference 

request by a legal counsel; and (4) for DOD-hosted conferences, 

consideration of alternative means of delivering the information. In our 

review of 563 approved requests for conferences in the second and third 

quarters of fiscal year 2013, we found that a majority (311) of the 
Page 15 GAO-14-150 Defense Management

requests addressed and documented all four key elements. While the 

remaining 252 requests we reviewed did not contain documentation of all 

four key elements, we did not find circumstances where a specific 

element was consistently missing from a significant number of requests. 

Specifically, for the 563 approved conference requests we reviewed:

• 98 percent of all requests included a statement by the requester that 

the conference is necessary or fulfills a DOD mission;

• 92 percent of all requests included a cost estimate;

• 66 percent of all requests included an assessment of the conference 

request by legal counsel; and

• 65 percent of requests for DOD-hosted conferences included 

evidence that the requester considered alternative means of 

delivering the information, such as video teleconferencing, and 

deemed those means infeasible.21

We also found that many conference requests included additional 

information for approving officials to review that was not among the 

required elements, such as a description of how the requesting 

organizations were reducing costs to host or attend the conference. Some 

examples of cost-saving efforts were using public transportation instead 

of a rental car, not approving travel costs for conference attendees unless 

they were speaking or making a presentation at the conference, and 

hosting conferences at government facilities instead of a hotel or 

convention center. Further, where evidence of a key element was 

missing, we found that in some cases, a record of the key element was 

maintained somewhere other than with the conference request 

documentation we reviewed. For example, officials from the three military 

service commands with whom we followed up about missing evidence of 

a legal review in their conference requests told us that legal reviews were 

 21We did not evaluate whether non-DOD hosted conferences could have used alternative 

means of delivering information because DOD attendees generally cannot influence 

presentations at conferences hosted by non-DOD organizations.
Page 16 GAO-14-150 Defense Management

documented in a document management system or were documented at 

the service headquarters level.22

Each DOD component also has implemented DOD’s requirement for 

quarterly reporting to the Deputy Secretary of Defense. Our review found 

that the DOD components varied in how and when they obtained the data 

for reporting conference costs. For example, some military service 

commands and DOD components required the original conference 

requester to complete a report after the conference with updated cost 

information and used this data for reporting purposes. Officials from other 

military service commands and DOD components told us that they 

reviewed travel vouchers within DOD’s travel system or used other 

financial management systems to obtain updated cost data for each 

conference. DOD’s November 2013 update requires the DOD 

components to enter reportable cost data into the new DOD Conference 

Tool within 30 days of a conference’s completion if the conference costs 

more than $20,000. According to a DCMO official, the components began 

using the DOD Conference Tool in the fourth quarter of fiscal year 2013.

While we found that the components’ implementation of the conference 

review and approval process has generally been consistent with DOD’s 

policy, some officials within the components and military service 

commands have identified concerns about the approval process. During 

our interviews and in response to our questionnaire, officials cited 

common concerns related to the time and resources spent on conference 

approval, and the approval levels required by components for 

conferences with a low or no cost to DOD.

In response to our question regarding what concerns, if any, DOD 

components and military service commands had with DOD’s conference 

policy, the most common concern was the amount of time and resources 

spent to complete the review and approval process. Specifically, officials 

from 33 percent of the 18 DOD components and 22 percent of the 54 

military service commands reported concerns with time and resources. 

 22For the purpose of our analysis, conference requests from the three military service 

commands we contacted were still included in the count of requests that did not have 

documentation of a legal review because we did not contact the remaining components 

and commands that were missing documentation of a legal review to determine whether 

that information was captured elsewhere.

Some Officials Expressed 

Concern over DOD’s 

Lengthy Approval Process, 

Especially for Conferences 

with Low or No Cost

to DOD
Page 17 GAO-14-150 Defense Management

Several military service commands noted in their responses that 

individuals requesting to host or attend a conference must wait months 

before requests are approved or rejected. For example, officials from one 

military service command reported that the process sometimes required a 

60-day period to obtain conference approval. In addition, we found that 

some conference requests took several months to receive final approval. 

In one instance, the initial request was submitted almost five months in 

advance of when the conference was scheduled to begin, but final 

approval was not granted until two weeks prior to the beginning of the 

conference. Officials from the military departments told us that they have 

prioritized conference requests from individuals in certain career 

specialties—such as chaplains and medical professionals—to ensure that 

they receive the necessary training in time to maintain their professional 

licensures or certifications. In addition, personnel sometimes are eligible 

to receive price discounts by completing early registration for certain nonDOD hosted conferences. One non-DOD hosted conference that we 

reviewed offered a $300 discount if attendees registered before a certain 

date.

Some officials raised specific concerns about the number of personnel 

required for conference reviews. Based on responses that we received 

from 18 DOD components and 54 military service commands, we found 

that conference requests often are reviewed by personnel from at least 

four offices. The multiple reviews can include financial management, 

administrative, and legal personnel, plus subsequent review by the 

general officer, flag officer, or senior executive at that organization. 

Officials from one military service command noted that there is often a 

bottleneck effect created at the higher approving levels. Officials from 

another command noted that the approval process for attending 

conferences is cumbersome and involves significant personnel resources. 

According to component and command officials, reviewing offices also 

vary in how many individuals are available for part-time or full-time duty to 

review conference requests. These individuals typically have other duties, 

and their assignment to review conference requests is a part-time or

collateral duty. Therefore, individuals who review conference requests as 

a collateral duty may sometimes have to defer their reviews if they need 

to address higher priorities among their job responsibilities.

Officials from several DOD components and military service commands

reported difficulty identifying and implementing procedures to mitigate the 

amount of time spent on the review process. For example, officials from 

one DOD academic institution acknowledged the problem of missing 

deadlines for early registration and not benefitting from a discounted rate. 
Page 18 GAO-14-150 Defense Management

However, in response to our questionnaire, these officials said that they 

had difficulty instituting procedures for timely decisions on requests to 

attend non-DOD hosted conferences because the requester may not 

know about the conference in time to complete the approval process 

before the early registration date expires. Additionally, several of the DOD 

components have developed guidance to initiate conference reviews as 

early as possible, such as 90 days prior to the start of the conference. 

However, officials from multiple components noted the difficulty of this 

requirement in that the need for conference attendance may not be 

known that far in advance. According to officials from some of the military 

services, many of the non-DOD entities hosting conferences frequently 

attended by DOD personnel recognize DOD’s constrained budget 

environment and are willing to work to minimize the costs to DOD. 

Officials said that in many cases conference hosts have waived 

registration fees and other conference costs for DOD personnel. For 

example, Army officials told us they were able to achieve a significant 

cost avoidance by accepting a professional nonprofit association’s offer to 

waive registration fees and cover travel expenses for key attendees to 

ensure the Army’s participation at the association’s annual conference 

despite fiscal constraints. As a result, the Army saved about $1 million 

over previous years’ attendance costs.

In addition, some officials raised specific concerns that the approval 

process requires the same amount of time and resources regardless of 

the estimated cost of the conference. Officials noted that the approval 

process involves the same resources for a conference with low or no cost 

to DOD as it does for a conference costing $20,000 or more.23 Our 

questionnaire to DOD components and military service commands found 

that officials at 28 percent of the 18 DOD components that responded and 

14 percent of the 54 military service commands that responded 

expressed concern over the approval tiers required by their component’s 

conference guidance. In their responses, some officials specified that the 

required tier of review was excessive for conferences for which DOD 

incurred low or no cost.24

 23For comparing different cost levels, our report defines “low-cost” conferences as 

conferences costing less than $20,000.

Because DOD invests a relatively small amount 

24While DOD’s November 2013 updated policy explicitly states that approval is not 

required for conferences that have no cost to the DOD, this policy was not in effect when 

the DOD components and military service commands responded to our questionnaire. 

The September 2012 policy required Tier 1 approval of no-cost contracts with a nonfederal entity. 
Page 19 GAO-14-150 Defense Management

of resources on conferences with low or no cost to DOD, some officials 

felt that such conferences represented a low risk to DOD and did not 

require the same scrutiny as more expensive conferences. In our review, 

we found that a few conference requests that resulted in a low or no cost 

to DOD took several months between the initial request and the approval. 

For example, we reviewed a request for one individual to attend a threeday, non-DOD hosted conference with a total estimated cost below 

$1,000, and the request was not approved for almost three months.

Most of the requests to attend non-DOD hosted conferences, according 

to our review, were for conferences with low or no cost to DOD. As shown 

in figure 2, in nearly 94 percent of the 405 requests for personnel to 

attend non-DOD hosted conferences,25

 25We asked all DOD components to provide request packages for conferences held in the 

second and third quarters of fiscal year 2013. All components except those within the 

Navy provided the requested information. For the Navy, we were able to obtain and review 

conference requests only for conferences held during the third quarter of fiscal year 2013, 

and we obtained that information from a Navy database.

the estimated cost of attendance 

was less than $20,000 for each conference.
Page 20 GAO-14-150 Defense Management

Figure 2: Cost of 405 Requests to Attend Second and Third Quarter Fiscal Year 

2013 Non-DOD Hosted Conferences

Similarly, for the 556 DOD-hosted and non-DOD hosted conference 

requests that we reviewed for which cost information was available,26

 26Of the 563 conference requests that we reviewed, 7 did not include cost information. Of 

the 7, 1 was for a DOD-hosted conference and the remaining 6 were for non-DOD hosted 

conferences.

we 

found that the aggregate cost to DOD for all low-cost conferences was 

significantly lower than the aggregate cost to DOD for more expensive 

conferences, even though the number of individual requests to attend 

conferences with low or no cost to DOD was much higher. Specifically, 

the total estimated cost for 424 DOD-hosted and non-DOD hosted 

conferences costing $20,000 or less was around $2 million, while the total 

estimated cost for 132 DOD-hosted and non-DOD hosted conferences 

costing over $20,000 was approximately $13.8 million.
Page 21 GAO-14-150 Defense Management

Conferences with no cost to DOD often occur when a non-DOD 

organization that is sponsoring DOD research in a specific field covers all 

the costs for DOD officials to present the research at a conference. 

Further, a low cost for a conference can occur when only one or two DOD 

officials are attending a conference. According to DOD officials, 

individuals may also strive to keep conference costs below $20,000 to 

avoid having to report conference costs for DOD’s quarterly and annual 

reports. For example, DOD components and military service commands 

may limit the number of people who are allowed to attend a conference to 

keep the cost below $20,000.

DOD’s November 2013 policy update was issued after we received the 

responses to our questionnaires and reviewed conference requests. This 

update specified that there is no requirement for review and approval of 

requests for conferences that have no cost to DOD, including 

conferences where all costs are paid by non-DOD entities and the 

payments are in accordance with DOD gift acceptance rules. According to 

one DCMO official involved in writing the policy, even with the November 

2013 update, the components still have the option to review conferences 

that incur no cost to DOD in accordance with their conference approval 

process to facilitate senior leaders’ visibility over conference attendance 

by personnel within their component. Further, the official stated that 

components are free to institute additional conference processes and 

procedures as long as they are consistent with the minimum requirements 

in DOD’s November 2013 updated policy.

We provided a draft of this report to DOD for review and comments. In 

written comments, which are reprinted in their entirety in appendix II, 

DOD concurred with our findings. DOD noted that it remains committed to 

balancing the need for rigorous oversight of conference spending with the 

benefits of hosting and participating in conferences that are essential to 

DOD’s mission. Also, DOD noted that the balance can be difficult to 

achieve, and officials understand the concerns that the approval process 

for conferences is too long, especially for conferences with only a small 

cost. DOD stated that it will continue to monitor the situation to determine 

if additional steps are necessary. DOD also provided technical comments, 

which were incorporated into this report as appropriate.

We are sending copies of this report to the Secretary of Defense; the 

Secretaries of the Army, Navy, and Air Force; the Director of the Office of 

Management and Budget; and appropriate congressional committees. In 

Agency Comments
Page 22 GAO-14-150 Defense Management

addition, the report is available at no charge on the GAO website at 

http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at (202) 512-5741 or ayersj@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix III.

Johana Ayers

Acting Director, Defense Capabilities and Management
Page 23 GAO-14-150 Defense Management

List of Committees

The Honorable Carl Levin

Chairman

The Honorable James Inhofe

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Dick Durbin

Chairman

The Honorable Thad Cochran

Ranking Member

Subcommittee on Defense

Committee on Appropriations

United States Senate

The Honorable Howard P. McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Rodney Frelinghuysen

Chairman

The Honorable Pete Visclosky

Ranking Member

Subcommittee on Defense

Committee on Appropriations

House of Representatives
Appendix I: Scope and Methodology

Page 24 GAO-14-150 Defense Management

To determine the extent to which the Department of Defense’s (DOD) 

conference policy is consistent with the Office of Management and 

Budget’s (OMB) requirements for conference approval and cost reporting, 

we reviewed an executive order and a series of memorandums issued by 

OMB in fiscal years 2011 through 2013 on promoting efficiency and 

eliminating excess spending within executive branch agencies.1 In 

particular, we reviewed OMB’s May 2012 memorandum, Promoting 

Efficient Spending to Support Agency Operations, which includes three 

key elements for conference sponsorship, hosting, and attendance. 

These elements are the prohibition of conferences with costs in excess of 

$500,000 unless the head of the agency signs a waiver, Deputy 

Secretary-level review of conference expenses in excess of $100,000, 

and public reporting annually of agency-sponsored conferences with

costs in excess of $100,000.

2

To determine how DOD components have implemented DOD’s 

conference policy, we identified the DOD components’ processes and 

procedures for approving conference requests and reporting conference 

costs. To that end, we developed, administered, and analyzed responses 

to a combination of structured interviews and questionnaires that referred 

We assessed the extent to which DOD was 

consistent with the OMB memorandum in issuing DOD’s September 29, 

2012, memorandum, Implementation of Conference Oversight 

Requirements and Delegation of Conference Approval Authority, and its 

November 6, 2013, memorandum, Implementation of Updated 

Conference Oversight Requirements. In reviewing DOD’s conference 

policy, we interviewed officials from the Office of the Deputy Chief 

Management Officer (DCMO) and OMB staff. We also interviewed 

officials from the Office of the DCMO and obtained relevant documents to 

review DOD’s planned approach for meeting reporting requirements in 

the Consolidated and Continuing Appropriations Act, 2013. Specifically, 

we reviewed training materials and spoke to officials about the web-based 

tool planned to help facilitate reporting beginning in the fourth quarter of 

fiscal year 2013.

 1

White House, Executive Order No. 13589, Promoting Efficient Spending (Nov. 9, 2011); 

OMB M-11-35, Eliminating Excess Conference Spending and Promoting Efficiency in 

Government (Sept. 21, 2011); OMB M-12-12, Promoting Efficient Spending to Support 

Agency Operations (May 11, 2012); OMB M-13-05, Agency Responsibilities for 

Implementation of Potential Joint Committee Sequestration (Feb. 27, 2013).

2

The three key elements encompass all of the new policies and practices for conference 

hosting and attendance in OMB M-12-12.

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 25 GAO-14-150 Defense Management

to DOD’s September 2012 conference policy, which was the existing 

policy when we conducted the majority of our review. The structured 

interviews and questionnaires were completed by officials at the offices of 

the Under Secretaries of Defense, Joint Staff, National Guard Bureau, 

and combatant commands and all four military services (Army, Navy, Air 

Force, and Marine Corps). To cover as much of the population as 

possible within the services, we asked each service to provide a list of 

“major subordinate commands.” Both the DOD component and military 

service command questionnaires consisted of open-ended questions on 

conference policies, procedures, and costs within the component or 

command being questioned, a subset of which requested quantitative 

responses. We pre-tested the questionnaire with one Army command, 

one Navy command, one Marine Corps command, and one DOD 

component. After the pre-test, we administered the final questionnaires 

using a combination of phone interviews and emails. We received oral 

and written responses from 100 percent of the18 DOD components and

54 military commands that we selected for interviews or emailed 

questionnaires. All components and commands that provided responses 

are listed at the end of this appendix.

The responses that we received to quantitative questions (e.g., the 

number of conferences hosted in fiscal year 2013) were summarized as 

standard descriptive statistics. To analyze the content in open-ended 

responses, one GAO analyst reviewed each open-ended response from 

each DOD component and military service command to identify recurring 

themes. Using the identified themes, the analyst then developed 

categories for coding the responses. A second GAO analyst reviewed 

each response from each DOD component and military service command 

and reviewed the first analyst’s themes and categories to reach 

concurrence on the themes and categories. Both GAO analysts then 

independently reviewed the answers to each open-ended question and 

placed them into one or more of the coding categories. A third analyst 

then reconciled the first and second analysts’ coding and, through 

discussion, made a final decision whenever there was disagreement. The 

key categories we identified and analyzed were (1) steps taken to 

respond to and verify the accuracy of data provided for the annual and 

quarterly reporting requirements and (2) concerns about DOD or 

component conference policy. Because DOD’s September 2012 policy 

was the existing policy when DOD officials responded to our structured 

interviews and questionnaire, any concerns they raised about DOD’s 

conference policy were in reference to the September 2012 policy.
Appendix I: Scope and Methodology

Page 26 GAO-14-150 Defense Management

We interviewed officials from each of the military services who were 

involved in the implementation of DOD’s conference policy, and we 

reviewed service guidance—including instructions, templates, and 

checklists—to determine whether it was consistent with DOD’s 

conference policy. Further, in evaluating how DOD collects, maintains, 

and reports conference costs, we reviewed DOD’s publicly reported 

annual conference report for fiscal year 2012 and assessed the extent to 

which it contained all elements required by OMB’s May 2012 

memorandum. We also reviewed DOD’s internal quarterly reports on 

conference costs for the first three quarters of fiscal year 2013. We 

compared the information included in the quarterly reports to DOD’s fiscal 

year 2012 annual report to identify differences between the annual and 

quarterly reporting requirements.

We also obtained and evaluated requests for conferences planned for the 

second and third quarters of fiscal year 2013.3

 3

We obtained and reviewed 424 conference requests for the second and third quarters of 

fiscal year 2013 from the DOD components, Army, Air Force, and Marine Corps. For the 

Navy, we reviewed 139 conference requests for the third quarter of fiscal year 2013 

because second-quarter conference requests had been archived in the Navy’s document 

management system and were inaccessible.

We obtained requests for 

this time period because the approval process established by DOD’s 

September 2012 policy was not fully implemented until the second 

quarter of 2013. Further, conference requests for the fourth quarter of 

2013 were not widely available during our review. To obtain conference 

requests, in our structured interviews and emailed questionnaires we 

asked officials from each DOD component and military service command 

to provide us all documents associated with requests for conferences 

planned to date in fiscal year 2013, including DOD-hosted and non-DOD 

hosted conferences. For the DOD components, Army, and Air Force, we 

received documentation directly from the organizations we interviewed or 

to which we emailed questionnaires. According to Navy and Marine Corps 

officials, the necessary documentation was centrally maintained in those 

services’ document management systems instead of at the major 

commands or other subordinate commands; therefore, we received 

conference request documentation for those two services’ major 

commands from a central office within Navy and Marine Corps 

headquarters, respectively. For the Navy, we were provided access to a 

document management system and manually reviewed documents 

associated with conference requests. For the Marine Corps, we were 
Appendix I: Scope and Methodology

Page 27 GAO-14-150 Defense Management

emailed documents associated with conference requests from a similar 

document management system.

Further, to evaluate conference requests we developed a standardized 

checklist of key elements needed by approval authorities for their 

determination of whether a conference should be approved or rejected. 

We developed a checklist with the following four key elements based on 

DOD guidance and component-level guidance: (1) an explanation of why 

the conference was necessary or mission essential; (2) evidence of a 

legal review of the conference request; (3) evidence of a cost estimate; 

and, (4) for DOD-hosted conferences, evidence that alternative means of 

delivering the information, such as video teleconferencing, was 

considered and deemed infeasible. We assessed the documentation for 

each conference request against the four key elements to determine if 

these elements were included. Using our checklist, we reviewed and 

assessed 563 approved requests for conferences hosted by DOD or 

attended by DOD personnel in the second and third quarters of fiscal year 

2013.

We interviewed officials and, where appropriate, obtained documentation 

from the following DOD organizations:

• Office of the Secretary of Defense, Office of the Deputy Chief 

Management Officer

• Department of the Army

• Office of the Administrative Assistant to the Secretary of the Army

• Office of the Army General Counsel

• Department of the Navy

• Office of the Assistant for Administration

• Office of the Director, Navy Staff

• Bureau of Naval Personnel

• Office of the Director, Marine Corps Staff

• Department of the Air Force

• Office of the Administrative Assistant to the Secretary of the Air 

Force

• Office of the General Counsel

The following 72 offices responded to our questionnaire. These offices 

were either emailed a copy of the questionnaire and provided written 

responses or were contacted by phone and responded orally to the 
Appendix I: Scope and Methodology

Page 28 GAO-14-150 Defense Management

questionnaire in a structured interview. We also requested copies of all 

fiscal year 2013 conference requests from these organizations and used 

the requests from the second and third quarters of fiscal year 2013 in our 

analysis, as described earlier in this report.

Army (3)

• U.S. Army Forces Command

• U.S. Army Materiel Command

• U.S. Army Training and Doctrine Command

Navy4

• Chief of Chaplains

(24)

• Commander, Navy Reserve Force

• Commander, Navy Installations Command

• Commander, Operational Test and Evaluation Force

• Commander, U.S. Pacific Fleet

• Office of Diversity and Inclusion

• Naval Air Systems Command

• Naval Facilities Engineering Command

• Naval Postgraduate School

• Naval Safety Center

• Naval Sea Systems Command

• Naval Supply Systems Command

• Space and Naval Warfare Systems Command

• Strategic Systems Programs

• U.S. Navy Bureau of Medicine and Surgery

 4

We requested that all recipients of the questionnaire respond directly to GAO. Instead, 

Navy commands transmitted their responses to a central office within Navy headquarters, 

and the responses were then transmitted to GAO. In comparing Navy commands’ written 

responses to those of Navy commands that we interviewed and to other military service 

responses, we believe that the Navy commands’ responses are reliable for our purposes.
Appendix I: Scope and Methodology

Page 29 GAO-14-150 Defense Management

• U.S. Fleet Cyber Command

• U.S. Fleet Forces Command

• U.S. Naval Academy

• U.S. Naval Forces Central Command

• U.S. Naval Forces Europe and Africa

• U.S. Naval Forces Southern Command

• U.S. Naval War College

• Naval History and Heritage Command

• Bureau of Naval Personnel

Air Force5

• Air Force Chief of Chaplains

(13)

• Air Combat Command

• Air Education and Training Command

• Air Force Global Strike Command

• Air Force Materiel Command

• Air Force Reserve Command

• Air Force Space Command

• Air Force Special Operations Command

• Air Mobility Command

• Air National Guard Readiness Center

• Pacific Air Forces

• U.S. Air Force Academy

• U.S. Air Forces in Europe

 5

The Air Force initially included four additional organizations in its list sent to GAO: Office 

of the Air Force Surgeon General; Headquarters Air Force Learning Office; Secretary of 

the Air Force/Office of Information Dominance and Chief Information Officer; and 

Secretary of the Air Force/Administrative Assistant. However, we determined that these 

offices were not “major commands” and dropped them from our scope. We received no 

conference request packages from these offices.
Appendix I: Scope and Methodology

Page 30 GAO-14-150 Defense Management

Marine Corps6

• Marine Corps Forces, Pacific

(14)

• Marine Corps Forces Command

• Marine Corps Forces Reserve

• Marine Corps Forces Cyberspace Command

• Marine Corps Forces Europe and Africa

• Marine Corps Forces, South

• Marine Corps Forces Strategic Command

• Marine Corps Forces Special Operations Command

• Marine Corps Combat Development Command

• Training and Education Command

• Marine Corps Logistics Command

• Marine Corps Recruiting Command

• Marine Corps Installations Command

• Marine Corps Forces Central Command

DOD Components (18)

• Joint Staff

• National Guard Bureau

• U.S. Africa Command

• U.S. Central Command

• U.S. European Command

• U.S. Northern Command

• U.S. Pacific Command

 6

Several Marine Corps major commands did not transmit their responses directly to GAO, 

as requested, and instead sent them to a central office within Marine Corps headquarters, 

and the responses were then transmitted to GAO. Based on our comparisons of Marine 

Corps commands’ written responses to other military services’ responses, we believe that 

the Marine Corps commands’ responses are reliable for our purposes.
Appendix I: Scope and Methodology

Page 31 GAO-14-150 Defense Management

• U.S. Southern Command

• U.S. Special Operations Command

• U.S. Strategic Command

• U.S. Transportation Command

• Office of the Under Secretary of Defense for Acquisition, Technology 

& Logistics

• Office of the Under Secretary of Defense, Comptroller

• Defense Finance and Accounting Service7

• Defense Contract Audit Agency

• Office of the Under Secretary of Defense for Intelligence

• Office of the Under Secretary of Defense for Personnel and 

Readiness

• Office of the Under Secretary of Defense for Policy

We conducted this performance audit from May 2013 to January 2014 in 

accordance with 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 on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 7

Even though the Defense Finance and Accounting Service and Defense Contracting 

Audit Agency are offices under the purview of the Under Secretary of Defense 

(Comptroller), both offices responded separately to our request for conference request 

packages. Therefore, we analyzed their questionnaire responses separately.
Appendix II: Comments from the

Department of Defense

Page 32 GAO-14-150 Defense Management

Appendix II: Comments from the

Department of Defense
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 33 GAO-14-150 Defense Management

Johana Ayers, (202) 512-5741 or ayersj@gao.gov.

In addition to the contact named above, key contributors to this report 

were Tina Won Sherman, Assistant Director; Melissa Blanco; Richard 

Burkard; Susannah Hawthorne; Greg Marchand; Amanda Miller; Richard 

Powelson; Sharon Reid; Monica Savoy; Amie Steele; and Roger Stoltz.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(351816)
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