Department of Homeland Security
 

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DHS' Policies and Procedures 


Over Conferences 


OIG-13-96 June 2013
 
OFHCE OF INSPECTOR GE~ERAL 

Pc:partmenl (If Homeland Security 

June 11, 2013

MEM ORANDUM FOR: The Honorable Peggy Sherry 

Chief Financial Offker 

Depa rtment of Homeland Security 

FROM : 

~:'::; I~'~~:::~,"""I ~n -t ~~ SUBJECT: OHS' PoIKies and P,oretiV(f!S ~r Conferences 

Anadled for your action is our final repon, DHS' Policies and Proci!dvres Over Con/eren(1!S. 

We incorporJled the formal c:ommenu from the Department In the final repon , 

The report (ontains one re tommenda tion to assil;tthe Management Oirettorate in 

improving oversight and reportin g of conference planning and approval of actMtles across 

the Oepartment_ Your office concurred with the recommendation. Based on Information 

provided in your response to the draft report, we consider the recommendation re olved. 

Once your office has fully implemented the recommendation, ple~ e submit B formal 

closeout letter to us within 30 d~ys so that we may close the re<:ommendatlon. The 

memorandum shOtJld be accompanied bv evidence of rompletion of ~g lKl up on corrective 

actions and of the disposition of any monetary amounts_ 

COnsistent with our responsibility under the Inspecror Geflf'rol Act, we .life providing copies 

of our repon to i1ppropriate congressional committees with oversight and appropriation 

responsibility over the Depa rtment of Homeland 5&urity. We win pou the repon on our 

website for public dissemination. 

Please call me with any questions, or your staff m~y contact Anne L. Richards, Assist;mt 

Inspector General for Audits, at (202) 254·4100. 

Attachment 
 

 

 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

Executive Summary............................................................................................................. 1 


Background ........................................................................................................................ 2 


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


Compliance with Federal Policies and Requirements ............................................ 3 


Recommendation ................................................................................................... 8 


Management Comments and OIG Analysis ........................................................... 8 


Appendixes 

Appendix A: Objectives, Scope, and Methodology ............................................ 11 


Appendix B: Management Comments to the Draft Report ............................... 13 


Appendix C: Major Contributors to This Report ................................................ 18 


Appendix D: Report Distribution ........................................................................ 19 


Abbreviations 

CFO Chief Financial Officer 

DHS Department of Homeland Security 

FMPM Financial Management Policy Manual 

FY fiscal year 

OCFO Office of Chief Financial Officer 

OIG Office of Inspector General 

OMB Office of Management and Budget 

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Executive Summary 

The Department of Homeland Security (DHS) conducts and participates in conferences 

for various purposes, including employee and stakeholder training, information sharing, 

and mission support. According to the Department, it participated in 1,094 conferences 

in fiscal year 2012, with expenditures totaling approximately $21.6 million. We conducted 

this audit in response to a mandate from the House Appropriations Committee, which 

directed the Office of Inspector General to report, no later than 30 days after the date 

of enactment of the DHS Fiscal Year 2013 Appropriations Bill, whether DHS has effective 

procedures in place to ensure compliance with all applicable Federal laws and 

regulations on conferences. The Fiscal Year 2013 Appropriations Bill was enacted on 

March 26, 2013. 

The Department has established policies and procedures to ensure that conference 

spending is appropriate and in the best interest of the U.S. Government and taxpayers, 

but further improvements are needed. Although the Department complies with most 

aspects of the Office of Management and Budget’s guidance, it has not finalized its 

guidance on conferences, and has not always adhered to its policies on conference 

oversight. To that end, DHS cannot be assured that all conference spending is 

appropriate or in the best interest of the U.S. Government and taxpayers. 

We made one recommendation to assist the Management Directorate in improving 

oversight and reporting of conference planning and approval of activities across the 

Department. Once fully implemented, this recommendation will enhance oversight. 

The Department agrees with our recommendation. To further assist the Department in 

its efforts to oversee conference spending, we are conducting a separate audit 

examining the controls over conference spending at selected Components. 

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Background 

DHS secures the Nation from many threats through five core mission areas: prevent 

terrorism and enhance security, secure and manage U.S. borders, enforce and administer 

immigration laws, safeguard and secure cyberspace, and ensure resilience to disasters. 

The DHS workforce consists of more than 240,000 employees who are responsible for 

executing these missions, along with hundreds of thousands of people across Federal, 

State, local, and territorial governments; the private sector; and other nongovernmental 

organizations. DHS conducts and participates in conferences for various purposes, 

including employee and stakeholder training, information sharing, and mission support. 

According to the Department, during fiscal year (FY) 2012 it participated in 1,094 

conferences, with expenditures totaling approximately $21.6 million. The following nine 

DHS Components spent 91 percent of the total conference expenditures for FY 2012: 

• Federal Emergency Management Agency 

• National Protection and Programs Directorate 

• Science & Technology Directorate 

• Transportation Security Administration 

• U.S. Citizenship and Immigration Services 

• U.S. Coast Guard 

• U.S. Customs and Border Protection 

• U.S. Immigration and Customs Enforcement 

• U.S. Secret Service 

In June 2011, the President’s Executive Order “Delivering an Efficient, Effective and 

Accountable Government” launched the Campaign to Cut Waste, which intensified 

efforts to identify areas across the Government where waste or excess may exist, and to 

take immediate steps to address them. In September 2011, Office of Management and 

Budget (OMB) Memorandum 11-35 instructed agencies to review their conference 

policies and internal controls to ensure they are appropriate and effective. It also 

required the Deputy Secretary’s approval of all conference activity until DHS certifies 

that appropriate policies and controls are in place. In November 2011, the President 

signed Executive Order 13589, “Promoting Efficient Spending,” which requires agencies 

to develop plans to ensure efficient spending in several areas, including conferences. In 

May 2012, OMB Memorandum 12-12 was issued, instructing agencies to initiate seniorlevel review of all planned conferences and approval of all future conference expenses of 

more than $100,000, prohibit expenses in excess of $500,000 on a single conference 

unless a waiver is obtained, and report publicly on all conference expenses exceeding 

$100,000. Throughout this report, we will refer to M-11-35 and M-12-12 as OMB 

guidance. 

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We performed this audit to determine whether DHS has effective procedures to ensure 

compliance with all applicable Federal laws and regulations on conferences. To further 

assist the Department in its efforts to oversee conference spending, we are conducting 

a separate audit to examine controls over conference spending at selected Components. 

Results of Audit 

The Department has established policies and procedures to ensure that conference 

spending is appropriate and in the best interest of the U.S. Government and taxpayers, 

but further improvements are needed. Although the Department complies with most 

aspects of the OMB guidance, it has not finalized its guidance on conferences and has 

not always adhered to its policies on conference oversight. To that end, DHS cannot be 

assured that all conference spending is appropriate or in the best interest of the U.S. 

Government and taxpayers. 

Compliance with Federal Policies and Requirements 

Although the Department has taken positive steps to ensure that DHS complies 

with applicable policies and requirements governing conference spending, 

further improvements are needed. The Department currently does not have 

adequate controls to ensure that its Components adhere to the specific policy 

requirements over conferences. 

In June 2011, DHS revised its Financial Management Policy Manual (FMPM) and 

added Section 7.10 – Conferences to establish stronger controls to guard against 

inappropriate conference spending practices and to ensure conference 

attendance is driven by critical mission requirements. The updated policy— 

•	 Established a separate section dedicated to conferences to highlight 

specific controls rather than including conference-related policies in 

various places throughout the travel policy manual; 

•	 Established additional conference-related responsibilities for the Chief 

Financial Officer (CFO) and Components; 

•	 Clarified the definitions of and distinctions between conferences,
 

meetings, and training;
 

•	 Incorporated requirements to use Government facilities and costeffective alternatives to commercial facilities, and limit the number of 

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DHS attendees to conferences consistent with the Efficiency Review 

travel directive; 

•	 Added a section on the authority to collect conference fees from nonFederal participants, including the statutory reporting requirement; 

•	 Better defined DHS requirements to justify, document, and report
 

conference-related expenses; and 


•	 Added special reminders for travel approving officials to check for specific 

entries in travel authorizations, such as use of noncontract carriers, 

deductions of per diem when meals are provided at conferences, and 

reasonableness of expenses requested. 

As part of the Campaign to Cut Waste, the Administration has taken steps to 

curtail conference spending and institute strict policies and controls over 

conferences, to ensure that conference expenditures are cost-effective, to 

clearly advance the mission and programmatic goals of the agency, and to 

represent the optimal use of Federal funds. 

OMB guidance issued in September 2011 requires that until the Deputy 

Secretary, or equivalent, certifies the appropriate policies and controls exist to 

mitigate the risk of inappropriate spending practices regarding conferences, 

approval of conference-related activities and expenses need to be cleared 

through the Deputy Secretary, or equivalent. In response to this guidance, the 

Department issued Acquisition Alert 11/28, also in September, which was 

effective immediately and mandated that all Component heads must submit 

conference approval requests to the Deputy Secretary through the Department’s 

Office of Chief Financial Officer (OCFO). 

On September 13, 2012, the Department amended its FMPM, and added Section 

7.10.1 – Conference Controls guidance to incorporate the reviewing requirement 

and set thresholds. It required Components to obtain proper approval for all 

conferences prior to obligating funds or entering into any agreement that plans 

or supports a conference. DHS’ estimated total cost of the conference determines 

the approval authority. The Department requires agency-sponsored conferencerelated spending above $10,000 to obtain the Deputy Secretary’s approval prior 

to obligating funds. The Component’s senior financial officers approve those 

conferences not exceeding $10,000. OMB’s guidance requires review of all 

conferences whose estimated net expense will exceed $100,000. 

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 OFFICE OF INSPECTOR GENERAL 

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The Department relies on the Components to have adequate controls and 

submit all proposed conferences with estimated expenditures totaling more 

than $10,000 for review. For example, during our audit, one of the nine 

Components we reviewed did not submit proposed conferences over $10,000 

for review by the Department. According to a policy oversight official, the 

Component did not comply because when the guidance was issued, personnel 

believed there was a typographical error with the new threshold amount 

requirement. Instead of $10,000, they believed it to be $100,000, and therefore 

they disregarded it. 

The Department also did not have controls in place to track conference 

attendance at the consolidated level for non-DHS hosted conferences. The 

Department did not have a means to ensure Department review and Deputy 

Secretary, or equivalent, approval of any attended conference with estimated 

costs to the Department exceeding $100,000. In FY 2012 alone, the Department 

reported it attended or hosted 53 conferences where costs exceeded $100,000. 

The Department reports that it has now implemented an attendance tracking 

tool. This should assist the Department in meeting OMB guidance expectations 

in the future. 

Additionally, OMB guidance instructs each agency to publish on its website a list 

of all agency-sponsored conferences where the net expenses exceed $100,000. 

The U.S. Coast Guard’s Innovation Expo was published in the Department of 

Homeland Security Fiscal Year 2012 Annual Report on Conferences, per OMB 

guidance. Based on costs of $1.2 million, the conference should have been 

reviewed. However, this conference was not reviewed, and would have been 

noncompliant with subsequent OMB guidance, which prohibited conferences 

costing more than $500,000 unless a waiver was obtained. According to a 

Department official, the conference was not reviewed because the U.S. Coast 

Guard’s Innovation Expo took place just as the DHS CFO started reviewing 

conferences and therefore it did not go through the review process. This 

indicates that the Department did not review and the Deputy Secretary did not 

approve conferences costing more than $10,000 during the first month of 

FY 2012. In October 2011, expenses exceeded $10,000 at 38 conferences. Of 

these 38, 5 (including the U.S. Coast Guard’s Innovation Expo) were more than 

$100,000, which may have not been reviewed. 

Department Policies 

The Department has updated its policies and procedures several times since 

FY 2011 because of the changing OMB requirements and issues identified within 

other departments. As a result, the Components are still updating their policies 

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 OFFICE OF INSPECTOR GENERAL 

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and procedures to ensure compliance with all applicable Department guidance 

as well as Federal laws and regulations. 

In response to the September 2011 OMB guidance, the Department issued 

Acquisition Alert 11/28, which directed all Components to submit conference 

approval requests to the Deputy Secretary through the Department’s CFO. The 

Department’s FMPM, Section 7.10 – Conferences distinguishes between a 

conference and training if all conditions are met under Title 5, Section 410.404 of 

the Code of Federal Regulations. For example, certain professional organizations 

sponsor professional development conferences that should be considered 

training. To qualify as training, all of the following conditions have to be met: 

•	 The announced purpose of the conference is educational or instructional; 

•	 More than half of the time is scheduled for a planned, organized
 

exchange of information between presenters and audience;
 

•	 The content of the conference is germane to improving individual and/or 

organizational performance; and 

•	 Development benefits could be derived through the employee’s
 

attendance.
 

If all of these conditions were met, the conference would be considered training 

and would not need to be submitted for conference reporting purposes. 

In May 2012, OMB’s guidance redefined a conference to include training events 

that involved travel. Four months later, in September 2012, the Department 

issued FMPM Section 7.10.1 – Conference Controls, which expanded the 

definition of a conference to include training and exercises and refers to the 

FMPM Section 7.10 for additional guidance. However, a conference considered 

training under Title 5, Section 410.404 of the Code of Federal Regulation remains 

classified as a conference for reporting purposes. 

In addition, OMB’s May 2012 guidance also established a threshold for 

Department review of all planned and future conferences over $100,000. The 

Department’s FMPM Section 7.10.1 lowered OMB’s threshold for Department 

review of conferences to those exceeding net estimated costs of $10,000. 

According to officials at five of the nine Components, it was unclear what 

constituted a “conference” for reporting purposes. Components might not have 

completed all appropriate reviews of conference spending because some 

spending was not appropriately identified as conference spending. However, 

during January 2013, DHS issued FMPM, Section 7.10.2 – Conference Controls 

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 OFFICE OF INSPECTOR GENERAL 

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and Approval. This guidance clarifies and establishes thresholds for submitting 

training and travel as conferences and should help Components understand 

what conference spending should be reviewed. 

Department Oversight 

The Department did not perform its Annual Quality Control Review, which 

consists of testing conference data Components submitted in FYs 2011 and 2012 

as the FMPM requires. 

FMPM Section 7.10 established the requirement that the Department conduct 

an Annual Quality Control Review (Review) on conference spending throughout 

the Department. The Review requires the Department to analyze Components’ 

data for accuracy and supporting documentation. Each Component submits to 

the Department its Annual Conference Spending and Activity Reports. These 

reports, due each December, show data from the prior fiscal year and allow the 

Department to track conference spending by multiple categories. However, the 

Department did not analyze the data for both fiscal years because of the 

constant revisions to OMB and Department guidance. 

The Department did not conduct the Review for either FY 2011 or FY 2012. In 

lieu of the Review, it conducted an assessment of controls within Department 

policy, as OMB guidance required in FY 2011. Although the Department only 

reviewed the controls and did not conduct any substantive testing, it concluded 

that conference-related expenses and activities are conducted efficiently and 

effectively in most instances. Without substantive testing of the controls, the 

Department cannot be assured that the controls were working as designed and 

preventing inefficiencies or inappropriate spending. We did not evaluate specific 

conference spending in this audit. 

A Department official stated the Review did not occur for FY 2012 because OMB 

guidance updates affected FY 2013. Therefore, the Department felt it would not 

be an efficient use of its resources to conduct the testing in FY 2012. 

As a result of these weaknesses in Department oversight, DHS cannot be assured 

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

Government and taxpayers. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation 

We recommend that the Chief Financial Officer, Department of Homeland 

Security: 

Comply with OMB and Department guidance to ensure that— 

•	 Components are submitting all conferences for review and approval; 

•	 The attendance tracking tool actually captures attendance data and is 

being used by all Components; 

•	 All Components have updated their Conference policy requirements to 

ensure compliance with DHS-wide policy requirements; and, 

•	 The Annual Quality Control Review is conducted for FY 2013, and a plan is 

implemented to conduct testing for all future fiscal years. 

Management Comments and OIG Analysis 

The Department provided comments on this draft report. A copy of the 

response in its entirety is included in appendix B. The Department also provided 

technical comments and suggested revisions to our report in a separate 

document. We reviewed the Department’s technical comments and made 

changes throughout our report where appropriate. 

Management Comments to the Recommendation 

Concur. The Department will ensure that Components are submitting all 

conferences for review and approval. The Department has established a 

conference review process that complies with OMB and Department guidance. 

Additionally, two offices within the OCFO, Financial Management, and the Risk 

Management and Assurance division will work in conjunction to leverage 

controls and compliance work. This should ensure all conferences over the 

$10,000 threshold are reviewed and approved. The Department also developed 

a Web-based approval and tracking tool that will allow Components to request 

conference hosting activities electronically. This tool should be able to track 

actual conference expenditures and develop ad hoc reports. The estimated 

completion date is May 31, 2013. 

The Department will ensure the attendance tracking tool actually captures 

attendance data and is being used by all Components. Specifically, the Financial 

Management office will continually monitor planned conference attendance 

through its Web-based tracking and reporting tool to identify those attended 

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conferences that are over $100,000 and require Deputy Secretary approval. It 

also will periodically test and evaluate the usage to ensure all Components are 

actively using the tool. The estimated completion is September 2013. 

The Department will ensure all Components have updated their conference 

policy requirements to comply with DHS-wide policy requirements. The Office of 

Financial Management and the Risk Management and Assurance division are 

currently reviewing Components’ conference policy guidance to ensure that any 

deficiencies are identified and policies are updated accordingly. The estimated 

completion date is May 31, 2013. 

The Department will ensure the Annual Quality Control Review is conducted for 

FY 2013, and a plan is implemented to conduct testing for all future fiscal years. 

The Risk Management and Assurance division has incorporated conference 

control testing into their yearly assessment plan. The plan will examine 

conferences above and below the $10,000 threshold to support assurances of 

the Department’s conference controls and compliance with OMB guidance. The 

estimated completion is January 2014. 

OIG Analysis 

We consider the ongoing actions taken by the Department to be responsive to 

the recommendation and the recommendation resolved. However, it will 

remain open until we receive and review a copy of the following: 

•	 Memorandum or other official notification sent to the Department and 

Component heads alerting them of the Web-based approval and tracking 

tool availability and use for conference hosting activities, a report of 

actual conference expenditures produced by the tool for the fiscal year 

quarter after its implementation, and any other ad hoc reports. 

o	 A report of all attended conferences over $100,000 identified through 

the attendance tracking tool for the fiscal year quarter after its 

implementation through the end of FY 2013, as well as a copy of the 

results of testing and an evaluation of evidence that the Components 

are using the tool. 

•	 A Memorandum or other official notification to OIG that all Components’ 

policies and procedures have been reviewed to identify any Component 

policy deficiencies, as well as notification that these polices have been 

updated and are compliant with DHS-wide policy requirements. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

•	 A copy of Risk Management and Assurance’s yearly assessment plan that 

depicts conference control testing will be conducted on a yearly basis, 

and a copy of the results of Risk Management and Assurance’s testing of 

the Department’s conference controls to ensure compliance with OMB 

guidance for FY 2013. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

established by the Homeland Security Act of 2002 (Public Law 107-296) 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 conducted this audit in response to a mandate from the House Appropriations 

Committee, which directed OIG to report no later than 30 days after the date of 

enactment of the DHS FY 2013 bill whether DHS has effective procedures in place to 

ensure compliance with all applicable Federal laws and regulations on conferences. The 

FY 2013 Appropriations Bill was enacted on March 26, 2013. 

Our audit scope was limited to examining Department and Component policies and 

procedures over conferences. We reviewed prior OIG and U.S. General Services 

Administration reports on conferences, as well as conference reports from the Office of 

Senator Tom Coburn, M.D., on the U.S. Department of Agriculture and the 

U.S. Department of Justice. We obtained and reviewed relevant Federal laws and 

regulations, including OMB guidance pertaining to conference spending. We obtained, 

reviewed, and analyzed policies and procedures over conference expenditures from the 

Department and the following nine Components because they represented 91 percent 

of $21.6 million of conference expenditures for FY 2012: 

• Federal Emergency Management Agency 

• National Protection and Programs Directorate 

• Science & Technology Directorate 

• Transportation Security Administration 

• U.S. Citizenship and Immigration Services 

• U.S. Coast Guard 

• U.S. Customs and Border Protection 

• U.S. Immigration and Customs Enforcement 

• U.S. Secret Service 

We conducted interviews with officials from the Department’s OCFO and officials at 

each of the above Components. We obtained and reviewed conference expenditure 

data for FY 2012 from the Department. We conducted limited testing on data obtained 

from the Department. However, the extent of our testing was not sufficient to enable 

us to verify the data’s accuracy. We did not rely on the data to make any significant 

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conclusions in the report; however, we used the Department’s data for the number of 

conferences held and the total conference expenditures reported. 

We conducted this performance audit between December 2012 and March 2013 

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. 

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Appendix B 

Management Comments to the Draft Report 

U.S. Deportnlenl or Il onulAnd Security 

W.shlngton. DC 20!28 

Homeland 

Security 

May 15, 2013 

MEMORANOUM FOR: Charles K. Edwards 

Deputy Inspector General 

Office of Inspector General 

tJt-..-¥--r; 8~ FROM: Christopher T. Brothers 

Assistant Director 

Departmental GAO-OIG Liaison Office 

SUBJECT: DHS' Policies and Procedures Over Conferences (Project No. 12-

I 56-AUD-DHS) 

Thank you for the opportunity to review and comment on this draft report. We appreciate the 

Office of Inspector General's (DIG's) work in planning and conducting its review and issuing 

this report. 

We arc pleased to note thal OIG concluded the Department of Homeland Security (DHS) has 

taken positive steps to ensure the Department complies with applicable policies and requirements 

governing conference spending. DHS will continue to improve on its processes, working toward 

sustainable conference controls and ensuring that conference spending is driven by critical 

mission requirements and is in the best interest of the Government and taxpayers. 

[n addition to tlle positive steps the Department has taken to comply with applicable polices and 

requirements mentioned in the report, the following examples highlight the evolution ofDHS's 

enhancements to its conference oversight program. Since April 2009, through the Department's 

Efficiency Review initiative, DHS has proactivelr addressed the management of conference 

spending and focused on improving efficiencies. OHS's travel and conference guidance 

includes a stringent review policy, reviewing expenditures at the $10,000 level versus the 

S 1 00,000 level, and efficiency mandates that have generated cost-avoidances within DHS 

Components and offices. DI-IS conference and travel policies and controls include: 

• maximizing the use ofGovenunent office space and facilities for training events and 

meetings in lieu of renting more costly meeting space~ 

• limiting the number of DHS attendees to conferences; and 

IDHS's policy on conference spending and efficiencies predates OMB M-II-35 by more than 2 years. A complctc 

representation of Ihe timeline Dnd substance of DHS 's efforts regarding conference oversight is included in the 

Attachment. 

www.oig.dhs.gov 13 OIG-13-96 
 

 

• establishing conference and travel policies and controls to ensure conferences are costeffective and to ensure conference attendance is driven by critical mission requirements. 

DI-IS uscs policy gu idancc published in its Financial Management Policy Manual along with 

working group meetings, data calls, Chief Financial Officer (CFO) Council meetings, published 

alerts, and Web-based reporting and tracking products to ensure Component alignment to 

Departmental policy and l:,ruidance. 

The report contained one recommendation with which the Department concurs. Specifically, 

OIG recommended the Chief Financial Officer, Department of Homeland Sccurity: 

Recommendation : Comply with OMB and Departmental guidance to ensure that-

• Components are submitting all conferences for review and approval; 

• The attendance tracking tool actually captures attendance data and is being used 

by all Components; 

• All Components have updated their conference policy requirements to ensure 

compliance with DHS-wide policy requirements; and 

• The Annual Quality Control Review is conducted for FY 20 13, and a plan is 

implemented to conduct testing for all futu re years. 

Response: Concur. DHS is in compliance with OMB and Departmental guidance, and the 

Office of the Chief Financial Officer's (OCFO's) Office of Financial Management (FM), in 

coordination with the Components. has established a sustainable and reliable conference review 

process. In addition, FM will work in conjunction with OCFO's Risk Management and 

Assurance division (RM&A) to leverage controls and compliance work to ensure all conferences 

exceeding a $10,000 threshold have been reviewed and approved by the appropriate level 

fi nancial official. To enhance the current manual conference approval process, OCFO has 

developcd a Web-based approval and tracking tool that will allow Components to request 

conference hosting activities electron ically. In addition, this tool will be used to track actual 

conference expend itures and develop ad hoc reports. This functionality will be available for 

Component use as of May 31, 2013. 

Additionally, DHS is in compliance with OMB and Departmental guidance for tracking 

attendance by all Components. FM will continually monitor planned conferencc attendance 

through its central Web-based tracking and rcporting tool to identify situations where conference 

attendance may approach the OMB-imposed $100,000 threshold (for non-DHS sponsored 

events). which would require Deputy Secretary review and approval. During the remaining 

months of FY 2013, DHS wi ll periodically test and evaluate tool usage to ensure all Components 

are actively using the tool. This portion of the recommendation is estimated to be complete by 

Septcmber 2013. 

FM and RM&A are also currcntly reviewing Component conference policy guidance with an 

antici pated completion date of May 31, 2013. IfOCFO identifies any Component deficiencies, 

we will notify the appropriate Components and request an updated policy within 120 days of the 

noti tication of any deficiency. 

2 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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R:vI&A has incorporated conference control testing into their yearly asscssmcnt plan. Thc plan 

will examine Department conferences on a bi-annual basis providing assessment over: Ca) 

conferences above the DHS-mandated $10,000 threshold that require Department-level approval; 

and (b) conterences below $10,000 that req uire Component Senior Financial Official approval. 

These assessments will support assurances over the Department's conference controls and 

compliance with OMB and Departmental gu ioance. Estimated Completion Date: January 2014. 

Again, thank you for the opportunity to review and comment on this draft report. Technical 

comments were previously submitted under separate cover. Please feel free to contact me if you 

have any questions. We look forward to working with you in the future. 

Attachment 

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DHS Conference Policv and Guidance History 

• April 2009 - DHS issued Efticiency Review 30-Day Initiative: Employee Travel and 

Utilization of Govemment Facilities for DHS Events 

• June 10,2011 - DHS issued revised conference policy 7./0 COI!(erences 

• September 2 1, 20 11 - OMB issued a memo, M- I 1-35, on Eliminating Excess Conference 

Spending and Promoting Efficiency in Govenunent. 

• September 23, 20 I I - DHS CFO directed Component CFOs to submit all conference 

requests through the Deputy Secretary's olliee for review. 

• September 23, 20 I I - The Depal1ment issued an updated Acquisition Alert directing 

components to suspend all procurement acti ons for DHS hosted conferences unti l a 

conference approval had bcen obtained through the Deputy Secretary's olliee. 

• October, 2011 - DHS conducted a Tcst of Design and assessed and certified 18 key 

conference controls. 

• ovcmber 11,20 11 - DHS CFO issued a conference FAQ. 

• May I I, 2012 - OMB issued mcmo M-12-1 2 on Promoting Efficient Spending in 

Support of Agency Operations. 

• July 25, 2012 - OMB issued M-12-12, FAQs. 

• September 13, 20 12 DHS CFO issued supplemental guidance on conferences, Financial 

Management Po licy Manual, Section 7.10. 1 Conference COIl/rols. The guidance clarifi ed 

the Department's definition ofa conference, and delegated to Components the authority 

to approve conferences costing up to $ 10,000. 

• October 2, 20 12 - DHS issued a revised Eftieieney Review 30-Day Initiative to with 

strengthened guidelines to eliminate non-mission critical travel; maximize the usc of 

conference calls and Web-based training and meetings. 

• On January 30, 2013 - DHS CFO issued supplemcntal guidance on conferences, 

Financial Management Policy Manual Section 7.10.2, Conference COII/rois and 

Approval. This guidance requires the use of the newly implemented conference tool fo r 

proposed attendance at nOIl-DHS hosted conferences and also increases threshold for 

Component approval lor expenses from $ 10,000 in 7. 10. 1, to a combined total of$35,000 

(Conference cxpenses less than $1 Ok and TOY less than $25k). 

Attachment 

www.oig.dhs.gov 16 OIG-13-96 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

 

• March 2013 - DHS FM rolled out Conference Tracking tool for proposed attendance at 

conferences external to DHS. 

• May 2013 - DHS FM rolled out Conference Attendance Tool (CAT) to serve as a central 

database and work flow manager for capturing and processing Component conference 

requests and assist in standardizing quarterly conference expenditure reporting. 

Attachment 

www.oig.dhs.gov 17 OIG-13-96 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Major Contributors to This Report 

Brooke P. Bebow, Director 

Maryann Pereira, Audit Manager 

James Diaz, Program Analyst 

Hortencia Francis, Program Analyst 

Brandon Landry, Program Analyst 

Michael Staver, Program Analyst 

Jeffrey Wilson, Program Analyst 

Kevin Dolloson, Communications Analyst 

Ralleisha Dean, Independent Referencer 

www.oig.dhs.gov 18 OIG-13-96 
 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief 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 

Acting Chief Privacy Officer 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as appropriate 

www.oig.dhs.gov 19 OIG-13-96 
 

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