AUDIT OF DEPARTMENT OF 

JUSTICE CONFERENCE PLANNING 

AND FOOD AND BEVERAGE COSTS 

U.S. Department of Justice 

Office of the Inspector General 

Audit Division 

Audit Report 11-43 

Originally Issued September 2011 

Revised Version Issued October 2011
 

U.S. Department of Justice 

Office of the Inspector General 

Washington, D.C. 20530 

Preface to the Revised Report 

This revised report supersedes the original version of the Office of 

the Inspector General’s (OIG) report, “Audit of Department of Justice 

Conference Planning and Food and Beverage Costs,” Audit Report 11-43, 

published in September 2011. The original report, which examined event 

planning and food and beverage costs at 10 Department of Justice (the 

Department) conferences between October 2007 and September 2009, 

contained a discussion of costs for food and beverages purchased for an 

Executive Office for Immigration Review (EOIR) conference at the Capital 

Hilton in Washington, D.C., in August 2009. Among other things, the 

report concluded that the EOIR had spent $4,200 for 250 muffins, or $16 

per muffin, a finding that brought significant negative publicity to the 

Department and the Capital Hilton. 

After publication of the report, we received additional documents 

and information concerning the food and beverage costs at the EOIR 

conference. After further review of the newly provided documentation and 

information, and after discussions with the Capital Hilton and the 

Department, we determined that our initial conclusions concerning the 

itemized costs of refreshments at the EOIR conference were incorrect and 

that the Department did not pay $16 per muffin. We have therefore 

revised the report based on these additional documents and deleted 

references to any incorrect costs. We regret the error in our original 

report. 

Finally, we hope that our correction of the record for this 1 

conference among the 10 conferences we reviewed does not detract from 

the more significant conclusion in our report: government conference 

expenditures must be managed carefully, and the Department can do 

more to ensure that taxpayer dollars are spent wisely and accounted for 

properly. 
This page is intentionally left blank. 
 

 

 

 

AUDIT OF DEPARTMENT OF JUSTICE CONFERENCE
 

PLANNING AND FOOD AND BEVERAGE COSTS 

EXECUTIVE SUMMARY
 

Department of Justice (DOJ) components host and participate in 

conferences to work with officials from other DOJ and federal entities, state 

and local law enforcement agencies, Native American and Alaskan Native 

tribes, and non-profit organizations. A DOJ Office of the Inspector General 

(OIG) audit issued in September 2007 examined expenditures for 10 major 

DOJ conferences held between October 2004 and September 2006.1 The 

audit found that DOJ had few internal controls to limit the expense of 

conference planning and food and beverage costs at DOJ conferences. We 

identified several conference expenditures that were allowable but appeared 

to be extravagant. For example, one conference had a luncheon for 120 

attendees that cost $53 per person, and another conference had a $60,000 

reception that included platters of Swedish meatballs at a cost of nearly $5 

per meatball. The audit further found that DOJ components permitted event 

planners to charge a wide array of costs for logistical services, such as venue 

selection and hotel negotiations. We made 14 recommendations intended to 

help the Justice Management Division (JMD) and other DOJ components 

implement stronger oversight of conference expenditures. In response to 

these recommendations, JMD implemented guidelines in April 2008 that 

established DOJ-wide conference food and beverage spending limits based 

on meals and incidental expenses (M&IE) rates set by the General Services 

Administration (GSA). 

Since 2008, DOJ appropriation acts have required that the Office of the 

Attorney General report conference costs quarterly.2 For fiscal years 

(FY) 2008 and 2009, DOJ reported that it hosted or participated in 1,832 

conferences. As shown in the exhibit below, the reports detailed that the 

conference activity over these 2 years cost a total of $121 million. 

1

 U.S. Department of Justice Office of the Inspector General, Department of Justice 

Conference Expenditures, Audit Report 07-42 (September 2007). 

2

 The Attorney General must submit quarterly reports to the DOJ Inspector General 

regarding the costs and contracting procedures for each conference held by DOJ for which 

the cost to the government was more than $20,000. Pub. L. No. 110-161 § 218 (2008) and 

Pub. L. No. 111-8 § 215 (2009). The Attorney General has delegated the responsibility to 

compile these reports to the Finance Staff of the Justice Management Division (JMD). Each 

component therefore submits to JMD a quarterly report of its respective conference costs. 

i 
 

REPORTED DOJ CONFERENCE COSTS 

FYs 2005 TO 2009 

40.2 

45.9 

N/A 

47.8 

73.3 

0 

10 

20 

30 

40 

50 

60 

70 

80 

2008 2009 

Amount ($ in millions) 

2005 2006 2007* 

Fiscal Year 

Source: DOJ component conference expenditures reports. Conference cost reports 

for FYs 2005 and 2006 were completed at the request of the U.S. Senate 

Committee on Homeland Security and Governmental Affairs, Subcommittee 

on Federal Financial Management, Government Information and 

International Security. Conference cost reports for FYs 2008 and 2009 

were issued through DOJ appropriation act requirements. 

Note: DOJ did not compile conference expenditure reports for FY 2007 because 

there were no requests from Congress or legislative requirements to 

compile and report this information. 

OIG Audit Approach 

For this audit, the OIG reviewed a judgmental sample of 10 DOJ 

conferences that occurred between October 2007 and September 2009 to 

determine whether DOJ components properly accounted for and minimized 

costs of conference planning, meals, and refreshments. The 10 sampled 

conferences cost $4.4 million, as detailed in the following exhibit. 

ii 
LIMITED OFFICIAL USE

DOJ CONFERENCES SELECTED FOR REVIEW3 

Sponsoring Component(s) Conference Title Location - Da

Criminal Division and the Organized Crime Drug Enforcement Task Force (OCDETF) 

OCDETF National Leadership Conference (OCDETF National Conference) 

Washington, D.C. July 20 – 23, 2009 

Drug Enforcement Administration (DEA) International Drug Enforcement Conference (DEA IDEC) Istanbul, Turkey July 8 – 10, 2008 

Executive Office for Immigration Review (EOIR) 

Legal and Interpreters Training Conference (EOIR Legal Conference) 

Washington, D.C. Aug. 3 – 7, 2009 

Executive Office for U.S. Attorneys (EOUSA) 

2008 U.S. Attorneys National Conference (EOUSA National Conference) 

Washington, D.C. Feb. 11 – 14, 200

Federal Bureau of Investigation (FBI) Director’s Advisory Committee Symposium (FBI Director’s Symposium) Washington, D.C. April 14 – 16, 200

Office of Justice Programs (OJP), Bureau of Justice Assistance (BJA) and Office of Sex Offender Sentencing, Monitoring, Apprehending, Registering, and Tracking (SMART Office) (Co-sponsors) 

Indian Country Sex Offender Pre-Conference Institute (BJA and SMART Office Indian Country Pre-Conference) 

Palm Springs, CA Dec. 10, 2008 

OJP, Office for Victims of Crime (OVC) 11th National Indian Nations Conference (OVC Indian Nations Conference) Palm Springs, CA Dec. 11 – 13, 200

OJP, BJA BJA Walking on Common Ground II Palm Springs, CA Dec. 9 – 10, 2008 

OJP, Office of Juvenile Justice and Delinquency Prevention (OJJDP) 

America’s Missing: Broadcast Emergency Response (AMBER) Alert National Conference (OJJDP AMBER Alert Conference) 

Denver, CO Nov. 13 – 16, 200

Office on Violence Against Women (OVW) 

Enhancing Judicial Skills in Domestic Violence Cases Workshop (OVW Enhancing Judicial 

Skills Workshop) 

San Francisco, CA March 28 – April 1

Source: FY 2008 and 2009 DOJ conference expenditure reports Note: Total cost based on OIG audit figures. For the OVC Indian Nations Conference, the event planner re

applied almost $78,000 in non-DOJ contributions and other fees to pay for conference costs. 

3 See Appendix II for additional details and summaries of these 10 conferences. 

iii 
 

 

 

 

For each of the 10 selected conferences, we assessed event planning 

and food and beverage costs to identify whether there were expenditures 

indicative of wasteful or extravagant spending. 

Appendix I contains a more detailed description of our audit objective, 

scope, and methodology. 

Results in Brief 

DOJ spent over $4.4 million on the 10 conferences reviewed by this 

audit. The audit focused on two major conference cost categories that our 

September 2007 report revealed as most potentially susceptible to wasteful 

spending – event planning services and food and beverages. For event 

planning services, DOJ spent $600,000 (14 percent of costs) to hire training 

and technical assistance providers as external event planners for 5 of the 10 

conferences reviewed.4 This was done without demonstrating that these 

firms offered the most cost effective logistical event planning services. 

Further, these event planners did not accurately track and report conference 

expenditures. 

In addition, DOJ spent about $490,000 (11 percent of costs) on food 

and beverages at the 10 conferences. All the conferences occurred at major 

hotels that applied service fees – usually around 20 percent – to the cost of 

already expensive menu items. Our assessment of food and beverage 

charges revealed that some DOJ components did not minimize conference 

costs as required by federal and DOJ guidelines. For example, one 

conference served Beef Wellington hors d’oeuvres that cost $7.32 per 

serving. Coffee and tea at the events cost between $0.62 and $1.03 an 

ounce. At the $1.03 per-ounce price, an 8-ounce cup of coffee would have 

cost $8.24.5 

4

 Training and technical assistance providers are firms or personnel procured by DOJ 

awarding agencies to provide support and offer specialized assistance on specific grant 

initiatives. 

5

 Components and event planners reviewed procured beverages (coffee and tea) by 

the gallon and not by single serving size. Because there are 128 ounces in each gallon and 

conference attendees could have received different serving sizes of hot beverages, our audit 

applies the standard 8-ounce measurement for one cup as a single serving of beverages 

procured by the gallon but served individually. 

iv 
 

 

 

 

 

In April 2008, JMD implemented new conference reporting and meal 

and refreshment cost limits for some DOJ conferences.6 These rules 

required that components hosting conferences minimize costs at every 

opportunity and made components responsible for tracking and reporting 

conference expenditures. The meal and refreshment limits generally 

prohibited components from spending more than 150 percent of the 

applicable GSA per diem rate for meals served at a DOJ conference.7 

However, these limits specifically did not apply to conferences funded via 

cooperative agreements, which are a type of funding vehicle awarded by a 

DOJ component (particularly an awarding agency) when it expects to be 

substantially involved in the work performed. 

Of the 10 conferences reviewed, 5 conferences were planned by 

training and technical assistance providers hired by two DOJ components: 

the Office of Justice Programs (OJP) and the Office on Violence Against 

Women (OVW).8 We found that OJP and the OVW did not collect salary and 

benefit cost data from their external event planners for these five 

conferences. As a result, the mandated DOJ conference cost reports did not 

include over $556,000 – or 93 percent of the total estimated $600,000 – 

spent on event planning services for these five events. 

6

 Appendix III presents the April 2008 JMD policy that established meal and 

refreshment cost limits for DOJ conferences. 

7

 The term “per diem” refers to the travel allowance provided to federal employees 

for meals and incidental expenses. GSA breaks down the daily per diem rate into 

allocations for breakfast, lunch, dinner, and incidentals. For example, when a federal 

traveler receives $64 per day, GSA allocates $12 for breakfast, $18 for lunch, and $31 for 

dinner, with the remaining $3 for incidentals, such as gratuities. Under the JMD rules, the 

150 percent threshold is applied to each of these individual meal allocations and includes 

applicable service charges. 

8

 The five other conferences were planned internally by full-time DOJ employees. 

v 
 

 

 

 

The OJP and OVW training and technical service providers that were 

hired via cooperative agreements to serve as event planners charged over 

$242,000 in indirect costs, which was about 40 percent of the total event 

planning cost for the five OJP and OVW events.9 We found that some of the 

event planners applied indirect rates only to their staff salary and benefit 

expenses, while others applied indirect rates to the cost of every service or 

item procured for a conference, such as employee travel, food and 

beverages, and audio-visual rentals. We concluded that applying indirect 

rates to all costs, although allowable under some cooperative agreement 

terms, increased the final price of already-expensive conference services and 

items.10 

We also found that even though JMD established food and beverage 

cost thresholds in April 2008 – no more than 150 percent of the GSA per 

diem meal allocation – DOJ guidelines still provide conference hosts with a 

large amount of discretion over the food and beverages served at their 

events.11 

Some conferences featured costly meals, refreshments, and themed 

breaks that we believe were indicative of wasteful or extravagant spending – 

especially when service charges, taxes, and indirect costs are factored into 

the actual price paid for food and beverages. For example, with these other 

charges, the OVW spent $76 per person on the “Mission Dolores” lunch for 

65 people at the Enhancing Judicial Skills Workshop in San Francisco, 

California. This conference was planned under a cooperative agreement and 

the JMD meal price thresholds were therefore not applicable to it. Had the 

9

 Indirect costs are those expenses that cannot readily be identified with a particular 

cost objective (activity or item) of a cooperative agreement. Indirect costs can include 

items such as administrative salaries and benefits, printing, telephone, supplies, postage, 

leases, insurance, rent, audit, and property taxes. Generally, indirect cost rates are agreed 

upon percentages of direct costs charged by cooperative agreement recipients to recover 

administrative and overhead expenses incurred while performing award work. These rates, 

however, must first be approved by the recipient’s cognizant federal agency before it can 

apply the rate to recover costs. 2 C.F.R. § 230 (2011). 

10 For example, when one event planner applied an approved 15-percent indirect 

cost rate to the price of food and beverages at a conference, the cost of one soda increased 

from $4.84 to $5.57. 

11 We could only apply the JMD thresholds that limited meals and beverage 

expenses as a benchmark to gauge the extravagance of conference meals and 

refreshments. JMD issued this guidance in April 2008, by which time 2 of the 10 

conferences included in our audit had occurred and several others were in planning stages. 

In addition, five conferences included in our review were planned under cooperative 

agreements, and therefore did not have to follow the April 2008 JMD thresholds. 

vi 
 

JMD rules been applicable, this lunch would have exceeded the allowable 

JMD per person rate of $27 by $49 (181 percent). OVW conference 

attendees received Cracker Jacks, popcorn, and candy bars at a single break 

that cost $32 per person. Coffee and tea also cost the OVW about $1.03 per 

ounce. A single 8-ounce cup of coffee at this price would have cost $8.24. 

Another example of a costly item at a DOJ conference included $7.32 Beef 

Wellington hors d’oeuvres at an Executive Office for U.S. Attorneys (EOUSA) 

conference. 

We concluded that DOJ components hosting conferences in FY 2008 

and FY 2009 did not adequately attempt to minimize conference costs as 

required by federal and DOJ guidelines. Two of the audited conferences 

occurred prior to April 2008, when the DOJ issued new policies and 

procedures to control conference spending. The Attorney General, the 

Deputy Attorney General, and the Assistant Attorney General for 

Administration have each issued memoranda to DOJ component heads 

directing them to reign in conference spending. JMD has also developed an 

internal website that consolidates relevant policies and other rules for DOJ 

conference planners. JMD officials stated that due to these efforts, 

components have improved compliance with meal and refreshment 

thresholds from the time since our audit scope (FYs 2008 and 2009). 

However, we note that 8 of the 10 reviewed conferences occurred 

after the April 2008 DOJ policy.12 Thus, we remain concerned that not all 

components will take into account service fees, taxes, and indirect costs 

when deciding what food and beverages – if any – should be served at a DOJ 

conference. In our opinion, the lack of documentation we found regarding 

the necessity of costly food and beverage items indicated that not all 

sponsors were seriously questioning the need for expensive meals and 

refreshments at their events. 

In addition, because the JMD policy limiting meal and refreshment 

costs did not apply to conferences planned under cooperative agreements, 

DOJ awarding agencies can circumvent meal and refreshment cost limits by 

using cooperative agreements to support their conferences. We therefore 

recommend that DOJ apply its meal and refreshment cost limits to all 

conferences regardless of the type of procurement vehicle used to fund a 

conference. 

12 Because some major conferences reportedly require up to a year or more to plan, 

we were not able to determine definitively how many of the conferences audited were in the 

planning stages prior to the implementation of the April 2008 policy. 

vii 
 

 

 

 

In our report, we make 10 recommendations to assist DOJ in properly 

accounting for and minimizing conference costs. 

Our report contains detailed information on the full results of our 

review of DOJ conference expenditures. The remaining sections of this 

Executive Summary describe in more detail our audit findings. 

External Event Planning 

The Federal Travel Regulation and DOJ policies require that agencies 

sponsoring conferences – and consequently any entity hired to plan such an 

event – minimize conference costs, including expenses associated with event 

planning. Some DOJ components hire outside firms as event planners to 

perform many of the logistical services associated with hosting a conference, 

such as selecting venues, negotiating food, lodging, and meeting space 

prices with hotels, drafting and sending invitations, and booking travel. 

We analyzed the various costs associated with event planning and 

found that outside firms provided logistical event planning services for 5 of 

the 10 conferences we reviewed.13 Both OJP and the OVW used their awardmaking authority to hire firms that served as their training and technical 

assistance providers as well as their event planners for the remaining five 

conferences. As training and technical assistance providers, many of these 

firms worked on an assortment of grant project activities unrelated to the 

conferences they planned, such as developing training, and producing 

newsletters, publications, and other documents to promote the different 

grant program objectives. Outside firms serving as event planners did not 

always distinguish costs associated with event planning from these other 

programmatic functions. We therefore had to rely on cost estimates 

prepared by event planners to determine how much they spent planning 

these five conferences. 

As shown in the following exhibit, event planning services cost an 

estimated $600,000, or 37 percent of the $1.6 million total cost of the 5 

conferences that used external event planners. 

13 The Drug Enforcement Administration (DEA), the Executive Office of Immigration 

Review (EOIR), the Executive Office of United States Attorneys (EOUSA), the Federal 

Bureau of Investigation (FBI), the DOJ’s Criminal Division, and the Organized Crime Drug 

Enforcement Task Force (OCDETF) planned their conferences internally and therefore did 

not procure external (non-DOJ) event planning costs. 

viii 
EXTERNAL EVENT PLANNING COSTS 

Conference Award Number 

Award 

Amount 

($) 

Award Funds 

Used on 

Conference 

Event 

Planning 

($) 

Total 

Conference 

Cost 

($) 

C

BJA and SMART Office Indian Country Pre-Conference 2008-DD-BX-K002 600,000 7,000 90,201 

OVC Indian Nations Conference 2005-VR-GX-K001 500,000 267,966 583,392* 

BJA Walking on Common Ground II 2007-IC-BX-K001 1,420,000 75,644** 132,222 

OJJDP AMBER Alert Conference 2005-MC-CX-K034 4,913,216 180,479 657,773 

OVW Enhancing Judicial Skills Workshop*** 

2006-WT-AX-K046 1,700,000 

69,186 148,877 

2008-TA-AX-K038 600,000 

TOTALS $9,733,216 $600,275 $1,612,465 

Source(s): OIG review of actual and estimated external event planning costs Notes: * The total cost of the OVC Indian Nations Conference is greater than the amount of the aw

conference’s event planner received non-DOJ contributions and charged other fees to pay 

costs. 

** The $75,644 in event planning costs for the Walking on Common Ground II conference in

subrecipient event planning costs. 

*** The OVW procured event planning services from two separate entities for its Enhancing Ju

Workshop. 

ix 
 

Overall, the following sections detail the specific concerns we identified 

pertaining to cooperative agreement event planning costs. 

Unreported Event Planning Costs 

Event planners incurred an estimated $600,000 in salary and benefit 

costs associated with employee time spent facilitating and planning 

conferences. However, neither OJP nor the OVW required event planners to 

track and report salary and benefit costs. OJP and the OVW furthermore did 

not report the cost of these salaries and benefits to JMD. As a result, we 

found that over $556,000, or 93 percent of the total estimated $600,000 

spent on event planning services, was not reported on DOJ conference cost 

reports. 

UNREPORTED COOPERATIVE AGREEMENT 

RECIPIENT EVENT PLANNING COSTS 

Component and 

Program Office Conference Title 

Identified 

Unreported 

Costs 

($) 

OJP – BJA and 

SMART Office Indian Country Pre-Conference 7,000 

OJP – OVC Indian Nations Conference 240,588 

OJP – BJA Walking on Common Ground II 70,760 

OJP – OJJDP AMBER Alert Conference 170,338 

OVW Enhancing Judicial Skills Workshop 67,903 

TOTAL $ 556,589 

Source: OIG assessment of salaries, benefits, and indirect costs 

Cooperative agreement recipients should report all relevant costs 

incurred from conference activity so that required DOJ conference cost 

reports are accurate. We therefore recommend that OJP and the OVW 

update guidance provided to award recipients that ensures reporting of all 

conference costs, including expenses associated with staff salaries and 

benefits. 

Unallowable Event Planning Direct Costs 

The audit identified two unallowable costs associated with event 

planning for the OVC Indian Nations Conference. First, the event planning 

firm hired a consultant located in Anchorage, Alaska, to act as the liaison 

with the conference hotel located in Palm Springs, California. The 

consultant, who worked under contract with the event planner for prior OVC 

Indian Nations Conferences, was hired for the 2008 event without the 

x 
 

 

benefit of an open solicitation. The hiring of the consultant was part of the 

event planner’s conference budget approved by the OVC. 

In our judgment, the OVC and its event planner missed an opportunity 

to minimize costs by not soliciting a public bid for a consultant that was 

closer to the conference’s venue in Palm Springs. Because the consultant 

was based in Anchorage, Alaska, the consultant had to travel the 2,400-mile 

distance to Palm Springs at least 3 times and subsequently billed $3,454 in 

travel costs. While we believe costs associated with travel can be necessary 

and allowable, we consider the travel costs for this consultant unreasonable 

due to the traveling distance between Palm Springs, California, and 

Anchorage, Alaska. Therefore, we believe that the event planning firm did 

not minimize conference costs, as required by DOJ guidelines, and we 

question the consultant’s travel expenses totaling $3,454 as unallowable 

costs.14 

Additionally, OVC’s event planner held a conference planning 

committee meeting in January and February 2008, about a year before the 

conference took place, at the Palm Springs hotel. The purpose of this 

meeting was to assess what was needed for a successful conference and 

generate interest among all relevant parties about the upcoming event. The 

planning meeting had 36 attendees, mostly representatives from the hosting 

firm, other training and technical service providers, OJP, and the OVW. The 

event planner incurred a total of $29,365 in travel, lodging, and food and 

beverage costs for the face-to-face meeting. 

The decision to conduct a face-to-face planning meeting that incurred 

nearly $30,000 in costs is troubling to us. An event planning official told us 

that the OVC specifically directed it to host a “major meeting” for the 

conference’s planning committee. Nevertheless, we found that the firm’s 

cooperative agreement application stated that the conference planning 

committee did not require a face-to-face meeting to perform its work 

effectively. In fact, this document said that planning committee work could 

be effective via long distance. We also note that the conference’s venue had 

been the same for the prior three (2002, 2004, and 2006) Indian Nations 

conferences. Considering these points, we believe it was unnecessary to 

have attendees from across the United States travel to Palm Springs in 

January and February to have a face-to-face planning meeting at the same 

14 Questioned costs are expenditures that do not comply with legal, regulatory or 

contractual requirements, or are not supported by adequate documentation at the time of 

the audit, or are unnecessary or unreasonable. Questioned costs may be remedied by 

offset, waiver, recovery of funds, or the provision of supporting documentation. 

xi 
 

 

 

hotel where the conference had been held biennially since at least 2002. 

Had the OVC event planner instead conducted a planning meeting via 

teleconference, we believe that participants could still have discussed the 

planning issues without incurring travel, lodging, and food and beverage 

costs. 

Planning meetings represent important opportunities for sponsoring 

components to gauge the conference’s potential programmatic success. 

While planning meetings may be justifiable, extensive costs associated with 

traveling, lodging, and providing food may not be appropriate if the costs 

were not necessary. The cooperative agreement application submitted by 

the event planner for this conference indicates that a face-to-face planning 

meeting was not necessary. As a result, we do not believe the $29,365 

spent on lodging, travel, and food and beverages costs was necessary. 

Because the costs were unnecessary, we question them as an unallowable 

use of OJP grant funds. We recommend that OJP: (1) remedy $29,365 in 

questioned planning meeting travel, lodging, and food and beverage costs 

and (2) ensure that its event planners justify the need for significant costs 

associated with future face-to-face conference planning meetings. 

Indirect Costs 

Indirect costs are a type of expense that cannot easily be attributed to 

a particular cost objective (activity or item) funded by an award. Examples 

of indirect costs include administrative salaries, rent, and utility charges. 

Cooperative agreement recipients may charge indirect costs to recover 

expenses incurred as a result of their work, provided that their cognizant 

federal agency reviews and approves an indirect cost rate or application 

method for each recipient. As shown by the following exhibit, external event 

planners charged over $242,000 in indirect costs incurred while planning OJP 

and OVW conferences.15 

15 One external event planner hired by OJP did not charge indirect costs to its event 

planning award. 

xii 
 

 

INDIRECT COSTS FOR OJP AND OVW CONFERENCES
 

Conference Planner 

Indirect 

Cost Rate 

Charged 

(%) 

Amount 

($) 

OVC Indian Nations Conference Event Planner 

n/a 

(allocation 

plan) 

102,622 

BJA Walking on 

Common Ground II 

Primary Event Planner 31.4 968 

Subrecipient 1 96 27,270 

Subrecipient 2 20 1,839 

OJJDP AMBER Alert Conference Event Planner 15 85,797 

OVW Enhancing Judicial 

Skills Workshop 

Event Planner 1 17.51 16,936 

Event Planner 2 24.1 6,847 

TOTAL $242,279

 Source: OIG review of event planning records 

The $242,000-figure represents about 40 percent of the total 

$600,000 spent to plan the OJP and OVW events. 

As demonstrated by the exhibit above, the indirect cost rates varied 

widely from 15 percent to 96 percent among the different event planners. 

In addition, the event planners applied their respective indirect cost rates to 

different categories of direct costs. The event planner with a 96-percent 

indirect cost rate applied the rate only to salary or labor costs, while the 

event planner with a 15-percent indirect cost rate applied the rate to all 

conference expenses – including the cost of food and beverages served at 

the Office of Juvenile Justice and Delinquency Prevention (OJJDP) America’s 

Missing: Broadcast Emergency Response (AMBER) Alert Conference. 

Although allowable, this practice increased the price OJP was charged for 

food and beverages at this conference by 15 percent. For example, while 

the event planner incurred a cost of $4.84 for each soda, after the indirect 

cost rate, OJP was charged $5.57 for each soda. 

xiii 
 

The training and technical assistance providers reviewed for this audit 

generally require personnel with specialized skills – such as attorneys and 

professors – to provide programmatic support necessary for OJP and OVW 

grant initiatives. For example, in addition to providing event planning 

services, the OJJDP training and technical assistance provider developed and 

hosted a series of seminars on responding to missing and exploited children. 

Such programmatic services are not logistical in nature. We believe that 

organizations that perform programmatic tasks generally require far more 

overhead and administrative support, which results in these firms incurring 

more indirect costs and applying higher indirect cost rates to recover these 

costs. This is especially troubling to us because the training and technical 

assistance providers that served as event planners applied the same indirect 

rate to costs associated with performing programmatic and logistical 

activities. Consequently, these firms might be applying high indirect rates to 

OJP and the OVW for logistical activities that do not require specialized 

programmatic skills when they: (1) provide programmatic support as a 

training and technical assistance provider and (2) charge the same indirect 

rates to all expenses (regardless of whether the expense was associated 

with a programmatic or logistical activity). 

Both the Federal Travel Regulation and DOJ conference planning 

policies seek to ensure that the government receives the best value for all 

event planning services, including logistical tasks. Indirect costs totaled 

$240,000 and constituted about 40 percent of the total event planning cost 

for the five OJP and OVW conferences. DOJ components that hired outside 

event planners that charged indirect costs need to ensure that these costs 

are minimized. We therefore recommend that OJP and the OVW 

demonstrate that a training and technical assistance provider offers the most 

cost-effective logistical services before awarding a cooperative agreement 

that supports conference planning to such a firm. To accomplish this, we 

believe that OJP and the OVW should: (1) identify the specific event 

planning activities that are logistical (and therefore do not require 

specialized programmatic support) and (2) solicit bids from different vendors 

to perform these activities. Such solicitations should be directed to all firms 

capable of performing logistical tasks and not just to training and technical 

assistance providers. 

xiv 
The event planner for the December 2008 Indian Nations Conference 

in Palm Springs, California, used an allocation plan instead of an indirect rate 

to recover indirect costs. Under this method, the event planner charged 

$102,622 in indirect costs to OJP based on the proportion of its total payroll 

costs specifically associated with planning the conference. However, the 

indirect cost allocation plan did not receive the required approval by OJP or 

any other federal agency beforehand. This meant that the charges were not 

allowable and should not have been charged to the OJP cooperative 

agreement. As a result, we recommend that OJP remedy the $102,622 that 

the event planner charged in unallowable indirect costs. 

Food and Beverages 

Food and beverages at the 10 conferences cost DOJ components 

nearly $490,000, or 11 percent of the total $4.4 million estimated cost of 

these events. The exhibit below details the food and beverage costs 

incurred for each conference. 

xv 
DOJ CONFERENCE FOOD AND BEVERAGES 

Conference Title 

Location 

(City, State or 

Country) 

Length of 

Conference 

(Days) 

Number of 

Participants 

or 

Attendees* 

Overview of meals 

to participant

EOUSA National Conference Washington, D.C. 4 166 325 breakfasts, 285 l

and 247 dinners over 

EOIR Legal Conference Washington, D.C. 5 534 No full meals, only refreshments served 

OCDETF Conference Washington, D.C. 4 1,348 925 lunches, and 1,20

over 3 days 

OJJDP AMBER Alert Conference Denver, CO 4 367 1,461 breakfasts, 1,0

lunches over 4 days 

OVC Indian Nations Conference Palm Springs, CA 3 750 322 breakfasts, 505 l

and 530 dinners over 

BJA Walking on Common Ground II Palm Springs, CA 2 153 300 breakfasts and 30

lunches over 2 days 

BJA and SMART Office Indian Country Pre-Conference Palm Springs, CA 1 144 150 breakfasts over 1 

OVW Enhancing Judicial Skills Workshop San Francisco, CA 4 66 195 breakfasts and 65 

over 4 days 

DEA IDEC Istanbul, Turkey 3 368 320 lunches over 1 da

FBI Director’s Symposium Washington, D.C. 3 242 No full meals, only refreshments served 

Source: OIG analysis of vendor invoices Notes: * We applied the total number of participants (presenters, facilitators, and attendees) if that figure 

and these personnel received food and beverages at the respective conference. 

** Number of meals provided at official conference events paid for with DOJ funds. Meal counts exc

to planning staff or presenters at pre-events. The cost of food served at pre-events is included i

*** Total DOJ food and beverage costs includes hotel service charges but does not include indirect ch

xvi 
 

 

As shown in the exhibit above, DOJ components typically provided 

breakfasts, lunches, and dinners to conference participants. Hotels that 

catered meals and refreshments also routinely applied service charges, 

generally about 20 percent, to the total cost of the food and beverages. 

In April 2008, JMD issued guidelines requiring that components limit 

the cost of conference meals to 150 percent of the applicable M&IE per diem 

rate that the GSA allocated to each meal.16 For example, in a location where 

the M&IE per diem rate was $39, GSA allocated $11 of that amount for 

lunch. Under the JMD guidelines, a component could provide lunch at a 

conference so long as the cost of that lunch did not exceed 150 percent of 

the $11 allocation, or $16.50. The JMD guidelines also required that DOJ 

components not spend more than 23 percent of the total per diem rate for 

light refreshments per attendee each day.17 

However, because the JMD guidance was not implemented until April 

2008, the meal and refreshment cost thresholds may not have applied to 

many of the 10 conferences we reviewed because they were either held or 

were being planned by the time the rules were issued. Further, the JMD 

policy stipulated that the meal and refreshment limits did not apply to 

conferences funded through cooperative agreements. As a result, the event 

planners for the OJP and OVW conferences we reviewed (all of which were 

planned with cooperative agreements) were not required to follow the 150­

percent meal and 23-percent refreshment thresholds. We nevertheless 

applied the April 2008 JMD thresholds as a benchmark to ascertain 

objectively whether the meals and refreshments appeared to be extravagant 

or wasteful uses of taxpayer funds. 

Meals 

Eight of the conferences we reviewed provided at least one meal to 

attendees. The cost of 29 out of the 35 total meals (83 percent) provided at 

the conferences exceeded 150 percent of the per diem meal allocation. 

These meals exceeded the JMD cost threshold by varying amounts (up to 

$49 per meal per person). Detailed below are the costs associated with five 

meals provided to participants. 

16 JMD cost limitations (included in the policy found at Appendix III) require that the 

maximum percentage include any applicable service charge and tax. 

17 Light refreshments include coffee, tea, milk, juice, soft drinks, donuts, bagels, 

fruit, pretzels, cookies, chips, or muffins. 41 C.F.R. § 301-74.11 (2011). 

xvii 
	 On the first night of the 2008 U.S. Attorneys National Conference, 

84 officials attended a dinner with the Attorney General. The 

dinner cost $5,431, or almost $65 per person, which is $18.50 (40 

percent) more than the $46.50 that would have been permitted 

under the JMD thresholds for dinner. This conference was held in 

February 2008, about 2 months before the JMD issued its food and 

beverage cost thresholds. 

	 On the second day of the 2008 U.S. Attorneys National 

Conference, 118 participants attended a dinner in Alexandria, 

Virginia, at the Mount Vernon Inn. The dinner featured a choice of 

entrees including crusted red snapper, stuffed chicken breast, or 

beef medallions, all with an assortment of hors d’oeuvres, side 

dishes, and salads. The dinner cost $58 per person, or almost $12 

more (25 percent) than the $46.50 that would have been 

permitted under the JMD thresholds for dinner. 

	 At the OJJDP AMBER Alert Conference, one of the lunches cost 

almost $15,000 for 360 people, or $47 per person, including 

service and indirect charges. The lunch, served on the second day 

of the conference, included “five-spiced beef short rib” entrees with 

vegetables and crème brulee for dessert. This meal cost $27.50 

(141 percent) more than the $19.50 that would have been 

permitted under the JMD thresholds for lunch. This conference 

occurred in November 2007 and was planned under a cooperative 

agreement. The JMD meal price thresholds were therefore not 

applicable to the conference. 

	 At the Indian Nations Conference, OJP’s Office for Victims of Crime 

provided a hot breakfast for 322 people that cost $28.80 per 

person. This cost would have exceeded the JMD food and 

beverage thresholds by $12.30 (74 percent) per person had the 

conference not been planned under a cooperative agreement and if 

the JMD meal price thresholds were applicable. 

	 At the Enhancing Judicial Skills Workshop, the OVW provided the 

“Mission Dolores” lunch for 65 people. The menu price of this 

lunch was $49 per person. However, added to this cost were 

service charges, taxes, and event planner indirect cost rates, 

resulting in the OVW incurring $76 for each “Mission Dolores” lunch 

served. This conference was planned under a cooperative 

agreement and the JMD meal price thresholds were not applicable 

to it. Considering this price, had the JMD rules been applicable, 

xviii 
 

the OVW would have exceeded the allowable JMD lunch rate of $27 

by $49 (181 percent). 

Refreshments 

The conferences selected for our review included breaks when 

attendees received refreshments such as coffee, soda, cookies, bagels, and 

pastries. Under the April 2008 JMD conference food and beverage price 

policy, DOJ components should not spend more than 23 percent of the 

applicable M&IE rate each day for refreshments per attendee. As detailed 

below, in our opinion, the price of individual food items served as 

refreshments appeared excessive. 

	 At the AMBER Alert Conference, the OJJDP spent over $23,000 on 

a continuous beverage service that provided 367 attendees with 

coffee and soda over 4 days. The high cost of refreshments was 

caused in part by applying hotel service charges and event planner 

indirect costs to each food and beverage item, resulting in each 

can of soda costing $5.57 and each ounce of coffee costing $0.65. 

At this price, one 8-ounce cup of coffee would cost $5.20. 

	 At the OVW Enhancing Judicial Skills Workshop, the 66 conference 

participants received, on average, $30 in refreshments per day, or 

about $15 more than the $14.72 allowed per day under the JMD 

guidelines. However, because this conference was planned under 

a cooperative agreement, the JMD thresholds did not apply to the 

OVW or its conference planner. During a single break, attendees 

were served items like Cracker Jacks, popcorn, and candy bars 

that cost $32 per person, including service charges and indirect 

costs. The OVW also provided a “deluxe” ice cream assortment 

that cost $10 per person including service charges and indirect 

costs. By applying service charges and taxes, each ounce of coffee 

and tea purchased cost $1.03. At this price, a single 8-ounce cup 

of coffee or tea would have cost $8.24 and account for almost 56 

percent of the 23-percent per diem limit ($14.72) that JMD 

established for refreshments. 

	 At the Drug Enforcement Administration (DEA) International Drug 

Enforcement Conference (IDEC), 300 participants attended two 

coffee breaks on the same day at a total cost of $15,600. 

Therefore, the DEA spent $52 per person on breaks during this 

day, which was about double the $26.22 limit for breaks under the 

JMD guidelines. 

xix 
 

 During the Federal Bureau of Investigation (FBI) Director’s 

Symposium, the FBI spent almost $20,000 on refreshments for 

over 240 people over 3 days. The FBI spent $26.62 on 

refreshments per person each day, even though the limit under 

JMD guidelines was $14.72. This resulted in the FBI spending 

$8,925 more than it should have over the 3-day period on 

refreshments. 

Justifications for Meals and Refreshments 

Sponsoring components and event planners were unable to provide 

adequate justifications for the expensive food and beverages at the reviewed 

FY 2008 and 2009 conferences. Event planners sometimes attributed the 

expense of food and beverages to the high cost of locations where some of 

the reviewed conferences were held, such as San Francisco, California. 

Other event planners said that because previous conferences always 

featured meals, attendees have come to expect meals at their conferences. 

We do not believe that these reasons appropriately justify using DOJ funds 

to serve expensive meals. 

In addition to the April 2008 policy, the Attorney General, the Deputy 

Attorney General, and the Assistant Attorney General for Administration 

have each issued memoranda to DOJ component heads directing them to 

reign in conference spending.18 In addition, JMD has developed an internal 

website that consolidated relevant policies and other rules for DOJ 

conference planners. Considering these efforts, JMD officials stated they 

believed that components improved compliance with meal and refreshment 

thresholds during more recent events (FYs 2010 and 2011) compared to 

what we found during the scope of our review (FYs 2008 and 2009). 

Despite the JMD conference cost thresholds, consolidated conference 

planning website, and memoranda from DOJ leadership to component heads, 

we remain concerned that components will not take into account service 

fees, taxes, and indirect costs when deciding what food and beverages – if 

any – should be served at a conference. In our opinion, the lack of 

justifications component sponsors provided for food and beverages served at 

the 10 audited conferences makes it appear as though many sponsors did 

18 Copies of the memoranda from the Attorney General, the Deputy Attorney 

General, and the Assistant Attorney General for Administration are included in Appendices 

IV, V, and VI. 

xx 
 

not seriously question the need for expensive meals and refreshments at 

their events. 

We also identified several instances when event planners reported that 

hotels waived meeting space rental fees when the event planners incurred a 

minimum food and beverage cost. Although free meeting space may 

provide an opportunity for DOJ components to save money, we found no 

evidence that components or event planners determined that the cost of 

meals and refreshments was less than what the cost of meeting space would 

have been had the meeting space not been provided for free. Without this 

type of cost-benefit analysis, DOJ components and event planners cannot 

demonstrate that they complied with the Federal Travel Regulation or DOJ 

guidelines that require that conference costs are kept to a minimum. 

DOJ components provided expensive food and beverages to attendees 

regardless of whether internal DOJ staff planned the conference or the 

sponsoring component hired an external event planner via a cooperative 

agreement. The April 2008 JMD policy specifically excludes cooperative 

agreement recipients from complying with meal and beverage threshold 

limits. Although the OJP Financial Guide (which the OVW also applies as 

criteria for its awards) requires cooperative agreement recipients to ensure 

that the cost of food and beverage is reasonable and work-related, it does 

not establish strict food and beverage limitations like those found in the JMD 

policy. As a result, DOJ awarding agencies can circumvent meal and 

refreshment cost limits by simply using a cooperative agreement instead of a 

grant or contract to support a conference. 

Guidance limiting meal and refreshment costs should be in place 

regardless of the funding instrument used to fund a conference. Therefore, 

we recommend that OJP and the OVW ensure that cooperative agreement 

recipients comply with established JMD conference food and beverage 

thresholds that limit meals to 150 percent of the M&IE allocated to that meal 

and refreshments to 23 percent of the total applicable daily per diem. 

Conclusion and Recommendations 

DOJ components sponsoring conferences have a responsibility to: 

(1) minimize conference planning costs and (2) ensure the food and 

beverages provided are incidental, reasonable, and only provided at workrelated events. Our audit determined that DOJ components that sponsored 

conferences did not track and report external event planning costs as 

required, and that these costs, especially indirect costs, varied widely. In 

addition, individual conferences featured full meals, beverages, and snacks 

xxi 
that were costly, especially after hotel service charges and event planner 

indirect costs were applied to each meal and refreshment. By itemizing each 

item of food or beverage provided to conference attendees, we found that 

one conference had coffee and tea that cost more than $1 per ounce. 

Our audit work and findings resulted in 10 recommendations to help 

DOJ components properly account for and minimize conference costs. For 

example, we recommend that pertinent DOJ components ensure that: 

	 Conference cost reports are accurate in that they include all salaries, 

benefits, and other costs charged to the government by all associated 

funding recipients, and 

	 Cooperative agreements with training and technical assistance 

providers are used to procure logistical event planning services only 

once it is demonstrated that this method is the most cost effective 

approach. 

xxii 
 

 

 

 

 

 

 

 

AUDIT OF DEPARTMENT OF JUSTICE CONFERENCE
 

PLANNING AND FOOD AND BEVERAGE COSTS 

TABLE OF CONTENTS
 

Page 

INTRODUCTION ................................................................................1 

Prior OIG Audit........................................................................... 3 

OIG Audit Approach and Objective ................................................ 4 

FINDINGS AND RECOMMENDATIONS.................................................7 

I. EXTERNAL EVENT PLANNING ........................................................7 

 Use of External Event Planners ..................................................... 8 

 Accounting for External Event Planning Costs .................................. 9 

Assessment of External Event Planning Costs ................................ 14 

Recommendations..................................................................... 22 

II. FOOD AND BEVERAGES ..............................................................23 

DOJ Conference Food and Beverage Guidelines ............................. 23 

Itemized Conference Food and Beverage Costs ............................. 25 

Analysis of Itemized Food and Beverage Costs .............................. 50 

Recommendations..................................................................... 54 

STATEMENT ON INTERNAL CONTROLS.............................................55 

STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS .......56 

SCHEDULE OF DOLLAR-RELATED FINDINGS ....................................57 

ACRONYMS ......................................................................................58 

APPENDIX I: OBJECTIVE, SCOPE, AND METHODOLOGY ..................59 

APPENDIX II: CONFERENCE FACTS AND SUMMARIES.....................69 

APPENDIX III: APRIL 2008 JUSTICE MANAGEMENT DIVISION 

CONFERENCE COST POLICY .....................................................79 
APPENDIX IV: ASSISTANT ATTORNEY GENERAL FOR 

ADMINISTRATION MEMORANDUM SUMMARIZING 

 CONFERENCE POLICY ..............................................................95 

APPENDIX V: DEPUTY ATTORNEY GENERAL MEMORANDUM ...........97 

APPENDIX VI: ATTORNEY GENERAL MEMORANDUM .......................99 

APPENDIX VII: JUSTICE MANAGEMENT DIVISION RESPONSE 

TO THE DRAFT REPORT .........................................................101 

APPENDIX VIII: OFFICE OF JUSTICE PROGRAMS RESPONSE 

TO THE DRAFT REPORT .........................................................103 

APPENDIX IX: OFFICE ON VIOLENCE AGAINST WOMEN 

RESPONSE TO THE DRAFT REPORT ........................................110 

APPENDIX X: OFFICE OF THE INSPECTOR GENERAL ANALYSIS 

AND SUMMARY OF ACTIONS NECESSARY TO CLOSE THE 

REPORT .................................................................................114 
 

 

INTRODUCTION 

Department of Justice (DOJ) components host and participate in 

conferences to work with officials from other DOJ and federal entities, state 

and local law enforcement agencies, Native American and Alaskan Native 

tribes, and non-profit organizations. To mitigate the potential waste and 

abuse of appropriated funds, every DOJ component that sponsors a 

conference must ensure that the event not only is necessary, but also incurs 

the minimal costs required to achieve its objective. 

Since 2008, DOJ appropriation acts have required that the Office of the 

Attorney General report conference costs quarterly.19 For fiscal years (FY) 

2008 and 2009, DOJ reported that it hosted or participated in 1,832 events. 

The reports detailed that the conference activity over these 2 years cost a 

total of $121 million. DOJ spent about $73 million to host conferences 

during FY 2009, which, as shown in Exhibit 1, is $25.5 million (53 percent) 

more than what was reported spent on conferences in FY 2008. 

19 The Attorney General must submit quarterly reports to the DOJ Inspector General 

regarding the costs and contracting procedures for each conference held by the DOJ for 

which the cost to the government was more than $20,000. Pub. L. No. 110-161 § 218 

(2008) and Pub. L. No. 111-8 § 215 (2009). The Attorney General has delegated the 

responsibility to compile these reports to the Justice Management Division (JMD) Finance 

Staff. Each component therefore submits to JMD a quarterly report of its respective 

conference costs. 

1 
EXHIBIT 1: REPORTED DOJ CONFERENCE COSTS 

FYs 2005 TO 2009 

40.2 

45.9 

N/A 

47.8 

73.3 

0 

10 

20 

30 

40 

50 

60 

70 

80 

2008 2009 

Amount ($ in millions) 

2005 2006 2007* 

Fiscal Year 

Source: DOJ component conference expenditures reports. Conference cost reports 

for FYs 2005 and 2006 were completed at the request of the U.S. Senate 

Committee on Homeland Security and Governmental Affairs, Subcommittee 

on Federal Financial Management, Government Information and 

International Security. Conference cost reports for FYs 2008 and 2009 

were issued through DOJ appropriation mandates. 

Note: DOJ did not compile conference expenditure reports for FY 2007 because 

there were no requests from Congress or legislative requirements to 

compile and report this information. 

According to Justice Management Division (JMD) officials charged with 

compiling the conference cost reports, the increase in costs reported 

between 2008 and 2009 is partially attributable to components improving 

how they internally report conference costs. Since mid-2008, individual DOJ 

components have been required to submit cost data to JMD on a quarterly 

basis by specified cost categories, such as meals and refreshments, event 

planning, and audio-visual costs. 

2
 
 

 

Prior OIG Audit 

In September 2007, the DOJ Office of the Inspector General (OIG) 

released an audit report on conference expenditures associated with 10 

major DOJ events held between October 2004 and September 2006.20 The 

conferences reviewed included 9 events that were held in the United States 

and 1 international event. The audit detailed how DOJ components procured 

event planning services from outside firms and assessed the prices of food 

and beverages served to conference attendees. The audit found that 

components used different methods to hire external event planners for 

logistical service support (such as selecting venues, negotiating lodging 

rates, and working with hotels on menus). Some event planners were hired 

as contractors, others via a cooperative agreement, which is a type of 

funding vehicle a DOJ agency can award if it expects to be substantially 

involved in the work performed. As a result, event planners charged a wide 

array of costs associated with event planning services. A major January 

2006 conference supported by a cooperative agreement incurred over 

$600,000 in planning costs, while another major conference in August 2006 

planned via a contract with a professional event planner incurred about 

$145,000 in planning costs. 

The audit also concluded that while using appropriated funds to pay for 

food and beverages at DOJ conferences might be allowable, some of the 

food and beverage costs – particularly those associated with meals and 

receptions – appeared to be extravagant. For example, the audit found that 

one DOJ event in Los Angeles, California, featured a 2-entrée lunch for 120 

attendees that cost $53 per person. In another instance, a DOJ component 

spent $60,000 on a reception that featured chef-carved roast beef and 

turkey, a penne pasta station, and platters of Swedish meatballs at a cost of 

nearly $5 per meatball. The audit made 14 recommendations to JMD and 

other DOJ components to help implement stronger policies that oversee 

conference expenditures and ensure that conference planners justify 

significant food and beverage costs. 

20 U.S. Department of Justice Office of the Inspector General, Department of Justice 

Conference Expenditures, Audit Report 07-42 (September 2007). 

3
 
 

 

 

 

In response to the recommendations included in the September 2007 

audit, JMD updated its guidelines on conference planning and expenditure 

reporting in an effort to help minimize conference costs DOJ-wide. In April 

2008 JMD established DOJ food and beverage thresholds based on General 

Services Administration (GSA) per diem rates.21 This guidance provides that 

components should not spend more than: (1) 150 percent of the applicable 

GSA per diem rate allocated to each meal and (2) 23 percent of the total per 

diem per person on refreshments.22 

OIG Audit Approach and Objective 

The objective of this audit was to review a sample of conferences that 

occurred between October 2007 and September 2009 to determine whether 

DOJ components properly accounted for and minimized costs associated with 

conference planning, meals, and refreshments. Using DOJ conference cost 

reports, we selected a judgmental sample of 10 high-dollar DOJ 

conferences.23 Our audit determined that DOJ sponsoring components spent 

an estimated $4.4 million on these 10 events. 

Exhibit 2 details the 10 conferences selected for our review. 

21 The term “per diem” refers to the travel allowance provided to federal employees 

for meals and incidental expenses. Per diem rates are generally established for each county 

in the United States. However, when a per diem rate is not established for a particular 

locale, the base continental United States per diem rate applies. 

22 GSA breaks down the daily per diem rate into allocations for breakfast, lunch, 

dinner, and incidentals. For example, when a federal traveler receives $64 per day, GSA 

allocates $12 for breakfast, $18 for lunch, and $31 for dinner, with the remaining $3 for 

incidentals. Under the JMD rules, the 150 percent threshold is applied to each of these 

individual meal allocations and includes applicable service charges. 

23 To select this sample, we identified: (1) events sponsored by components that 

reported a large number of conferences and (2) events with high reported costs in particular 

conference cost categories, such as food and beverages. Because both federal and DOJ 

guidelines require that sponsoring components minimize the cost of their conferences, we 

assessed 2 types of costs for these 10 events that we believe constitute the most significant 

drivers of conference expenditures: outside event planning services and food and 

beverages. 

4
 
EXHIBIT 2: DOJ CONFERENCES SELECTED FOR REVIEW 

Sponsoring Component(s) Conference Title Location - Dates 

Criminal Division and the Organized Crime Drug Enforcement Task Force (OCDETF) 

OCDETF National Leadership Conference (OCDETF National Conference) 

Washington, D.C. July 20 – 23, 2009 

Drug Enforcement Administration (DEA) International Drug Enforcement Conference (DEA IDEC) Istanbul, Turkey July 8 – 10, 2008 Executive Office for Immigration Review (EOIR) 

Legal and Interpreters Training Conference (EOIR Legal Conference) 

Washington, D.C. Aug. 3 – 7, 2009 

Executive Office for U.S. Attorneys (EOUSA) 

2008 U.S. Attorneys National Conference (EOUSA National Conference) 

Washington, D.C. Feb. 11 – 14, 2008 

Federal Bureau of Investigation (FBI) Director’s Advisory Committee Symposium (FBI Director’s Symposium) Washington, D.C. April 14 – 16, 2009 Office of Justice Programs (OJP), Bureau of Justice Assistance (BJA) and Office of Sex Offender Sentencing, Monitoring, Apprehending, Registering, and Tracking (SMART Office) (Cosponsors) 

Indian Country Sex Offender PreConference Institute (BJA and SMART Office Indian Country Pre-Conference) 

Palm Springs, CA Dec. 10, 2008 

OJP, Office for Victims of Crime (OVC) 11th National Indian Nations Conference (OVC Indian Nations Conference) Palm Springs, CA Dec. 11 – 13, 2008 OJP, BJA BJA Walking on Common Ground II Palm Springs, CA Dec. 9 – 10, 2008 OJP, Office of Juvenile Justice and Delinquency Prevention (OJJDP) 

America’s Missing: Broadcast Emergency Response (AMBER) Alert National Conference (OJJDP AMBER Alert Conference) 

Denver, CO Nov. 13 – 16, 2007 

Office on Violence Against Women (OVW) 

Enhancing Judicial Skills in Domestic Violence Cases Workshop (OVW Enhancing Judicial Skills Workshop) 

San Francisco, CA March 28 – April 1, 2009 

TOTA

Source: FY 2008 and 2009 DOJ conference expenditure reports Note: Total cost based on OIG audit figures. For the OVC Indian Nations Conference, the event planner re

applied almost $78,000 in non-DOJ contributions and other fees to pay for conference costs. 

5 
 

For each conference, we assessed costs reported in specific categories 

to identify whether there were any expenditures indicative of wasteful or 

extravagant spending. We focused this audit on two major conference cost 

categories that our September 2007 audit report identified as the most 

susceptible to waste and misuse – external event planning and food and 

beverages. We used the April 2008 JMD thresholds as a benchmark to 

ascertain whether specific conference meals and refreshments appeared to 

be extravagant and therefore constituted an unreasonable use of taxpayer 

funds. This is because the 10 reviewed conferences included 2 conferences 

that occurred before April 2008 and several others that were or may have 

been in planning stages when JMD issued its meal and refreshment 

thresholds.24 We also note that events planned with cooperative agreements 

(all awarding agency sponsored events reviewed) did not need to comply 

with the 150-percent meal and 23-percent refreshment threshold. 

Appendix I contains a more detailed description of our audit objective, 

scope, and methodology, and details how we selected conferences for this 

review. 

24 Because some major conferences reportedly require up to a year or more to plan, 

we were not able to determine definitively how many of the conferences audited were in the 

planning stages prior to the implementation of the April 2008 policy. 

6
 
 

FINDINGS AND RECOMMENDATIONS 

I. EXTERNAL EVENT PLANNING 

Although firms hired by DOJ components to plan conferences 

incurred over $600,000 in planning costs, about $556,000 in 

charges (93 percent) were not included on mandated DOJ 

conference costs reports. Over $240,000 in indirect costs were 

billed to DOJ, constituting 40 percent of total external event 

planning costs. We found that over $100,000 of these indirect 

costs were charged via an unapproved allocation plan, and 

therefore were not allowable. Furthermore, the outside firms 

that served as event planners were also the training and 

technical assistance providers that offered programmatic 

services, such as curriculum development, to DOJ awarding 

agencies. These firms applied the same indirect cost rate to 

both programmatic and logistical service expenses, such as 

selecting meals and booking travel. Because logistical services 

are primarily administrative and do not require the specialization 

of programmatic services, training and technical assistance 

providers may not be offering the most cost-effective logistical 

event planning services to DOJ awarding agencies. 

DOJ conference policies state that a component hosting a conference 

should work closely with conference planners to minimize event costs. DOJ 

guidelines also mirror those outlined by the Federal Travel Regulation, which 

applies to all federal agencies hosting conferences that require federal 

employee travel.25 The Federal Travel Regulation specifies that sponsoring 

components and their conference planners should implement policies that: 

	 Minimize all conference costs, including administrative costs, 

conference costs, attendee travel costs, and conference attendee 

time costs; 

	 Maximize the use of government-owned or government-provided 

conference facilities as much as possible; and 

	 Identify opportunities to reduce costs in selecting a particular 

conference location and facility. 

25 41 C.F.R. § 301-74 (2011). 

7
 
 

The Federal Travel Regulation and DOJ conference planning policies 

seek to ensure that components sponsoring conferences receive the best 

value for logistical services. 

Use of External Event Planners 

Our September 2007 audit found that training and technical assistance 

providers served as the event planner for many DOJ conferences. Training 

and technical assistance providers are usually non-profit organizations hired 

to help awarding agencies perform an assortment of projects associated with 

a particular grant program, such as juvenile delinquency prevention, law 

enforcement outreach, and law enforcement technology development. In 

addition to offering logistical support for their particular event, training and 

technical assistance providers reviewed by the 2007 audit also provided 

programmatic conference planning services stemming from their special role 

with a particular award program office or bureau. Specialized skills and 

expertise are generally required to perform programmatic services 

successfully, such as determining the conference agenda, writing 

publications, and identifying appropriate speakers, topics, and participants. 

The audit found that when the same firm performed both logistical and 

programmatic event planning functions, the firm generally applied the same 

indirect rate to both logistical service costs and programmatic service 

costs.26 This practice resulted in increasing the amount of indirect costs 

firms charged to perform logistical services. The 2007 audit identified some 

cases in which indirect costs, once charged to an award, nearly doubled the 

cost of logistical services performed while planning an event. 

Conversely, the 2007 audit reviewed one conference that was planned 

by a professional event planning firm instead of a programmatic subject 

matter expert. The awarding agency worked on programmatic aspects of 

the event while the event planning firm worked to select meals, secure 

audio-visual services, and generate publicity for the event. That conference 

incurred the lowest costs charged for logistical event planning services 

among those conferences reviewed that used external entities to plan the 

conference. In this case, the granting agency was responsible for 

developing the programmatic aspects of the conference. 

26 Indirect costs are expenses incurred for a common or joint objective that cannot 

be readily identified with a particular activity supported by or item purchased with a grant, 

contract, or cooperative agreement. Indirect costs generally include items such as 

administrative salaries, printing, telephone, supplies, postage, leases and rents, insurance, 

and property taxes. 

8
 
 

Following the September 2007 audit, JMD issued guidance which 

emphasized that DOJ components should only use external event planners 

when necessary to achieve a cost effective and efficient conference. Of the 

10 conferences this audit reviewed, full-time DOJ employees planned 5 

conferences while external entities were hired to plan the remaining 5 

conferences, as shown in Exhibit 3. 

EXHIBIT 3: CONFERENCE PLANNERS 

Planned by DOJ Employees 

Planned by External Event 

Planners 

OCDETF National Conference BJA and SMART Office 

Indian Country Pre-Conference 

DEA IDEC OVC Indian Nations Conference 

EOIR Legal Conference BJA Walking on Common Ground II 

EOUSA National Conference OJJDP AMBER Alert Conference 

FBI Director’s Symposium OVW Enhancing Judicial Skills 

Workshop

 Source: DOJ 

When DOJ employees plan a conference, the cost of planning the 

event is comprised mostly of fixed costs associated with full-time salaries 

and benefits. Unless a DOJ component specifically hired an employee to 

plan a particular conference, these costs are retrospective or sunk costs, and 

the component would have incurred the same employee salary and benefit 

costs regardless of its decision to sponsor or host an event. Our audit did 

not identify any cases when a DOJ component hired an employee specifically 

to plan any of the conferences reviewed. We therefore do not consider 

planning costs derived from DOJ employee salaries and benefits – including 

costs associated with employees who worked with external event planners – 

as conference-related costs. 

However, when a DOJ component hires an external entity to perform 

conference planning work, we believe that salary and benefit costs should be 

viewed as a direct result of the conference. Unlike full-time DOJ salary 

costs, external event planner salary costs would not have been charged to 

the government had the conference not occurred. 

Accounting For External Event Planning Costs 

The five conferences planned by external entities were comprised of 

four Office of Justice Programs (OJP) conferences and one Office on Violence 

Against Women (OVW) conference. OJP and the OVW used their authority to 

award cooperative agreements to procure external event planners for these 

9
 
 

 

 

events. Awarding agencies may award a cooperative agreement to an entity 

instead of a formal grant or contract when the agency expects to be 

substantially involved in the project or in objective-driven work to be 

performed under the agreement.27 

Tracking Event Planning Costs 

Because the event planning firms hired under cooperative agreements 

were also training and technical assistance providers for specific grant 

programs, the cooperative agreements in some cases included funding for 

other projects in addition to planning a conference. As training and technical 

assistance providers, some firms worked on an assortment of grant project 

activities unrelated to conference planning, such as developing training, and 

producing newsletters, publications, and other documents to promote the 

different grant program objectives. Generally, we found that recipients did 

not track event planning activities separately from non-conference work. As 

a result, external event planners could not provide us specific costs 

associated with planning their conferences. 

In response to our questions, officials with these groups consulted 

time and activity reports to estimate the time spent planning the 

conferences. These estimates accounted for the time spent on both 

logistical services associated with the conference and programmatic 

activities, such as curricula development. Based on these estimates, we 

determined that the event planners spent over $600,000 to plan the five 

conferences. As shown by Exhibit 4, event planning costs ranged from 8 

percent to about 57 percent of the total cost of each event. 

27 Cooperative agreements may be awarded when: (1) the principal purpose of the 

relationship is to transfer a thing of value to the recipient to carry out a public purpose 

authorized by law instead of acquiring property or services for the direct benefit or use of 

the government; and (2) substantial involvement is expected between the executive agency 

and the recipient when carrying out the activity contemplated in the agreement. 

31 U.S.C. § 6305 (2011). 

In addition, the directors or administrators of specific bureaus and program offices 

within OJP have distinct authority to issue grants and cooperative agreements to support 

programmatic functions: See 42 U.S.C. § 10603 (C)(1)(B) (2010) for the Office for Victims 

of Crime, 25 U.S.C. § 3681 (a) (2010) and 42 U.S.C. § 3751 (2010) for the Bureau of 

Justice Assistance, and 42 U.S.C. § 5775 (2010) for the Office of Juvenile Justice and 

Delinquency Prevention. 

10
 
EXHIBIT 4: ESTIMATED EXTERNAL EVENT PLANNING COSTS 

Conference Award Numbers 

Award 

Amount 

($) 

Award Funds 

Used on 

Conference 

Event 

Planning 

($) 

Total 

Conference 

Cost 

($) 

C

BJA and SMART Office Indian Country Pre-Conference 2008-DD-BX-K002 600,000 7,000 90,201 

OVC Indian Nations Conference 2005-VR-GX-K001 500,000 267,966 583,392* 

BJA Walking on Common Ground II 2007-IC-BX-K001 1,420,000 75,644** 132,222 

OJJDP AMBER Alert Conference 2005-MC-CX-K034 4,913,216 180,479 657,773 

OVW Enhancing Judicial Skills Workshop*** 

2006-WT-AX-K046 1,700,000 

69,186 148,877 

2008-TA-AX-K038 600,000 

TOTALS $9,733,216 $600,275 $1,612,465 

Source(s): OIG review of actual and estimated external event planning costs Notes: * The total cost of the OVC Indian Nations Conference is greater than the amount of the aw

conference’s event planner received non-DOJ contributions and charged other fees to pay 

costs. 

** The $75,644 in event planning costs for the Walking on Common Ground II conference in

subrecipient event planning costs. 

*** The OVW procured event planning services from two separate entities for its Enhancing Ju

Workshop. 

11 
 

 

 

 

We conclude that because cooperative agreement recipients did not 

track conference planning costs separately, OJP and the OVW were not in a 

position to ensure that cooperative agreements used to support the 

conference incurred only the minimum costs necessary to achieve an 

effective and efficient conference, as required by conference planning 

guidelines. We therefore recommend that OJP and the OVW require that 

award recipients using DOJ funds to plan conferences track time and 

activities performed to plan conferences. 

Unreported Event Planning Costs 

In response to JMD’s conference cost reporting guidance, OJP requires 

that cooperative agreement recipients report conference-related costs via 

the Grants Management System. However, as shown by Exhibit 5, OJP’s 

guidance does not consider costs associated with staff time (salaries and 

benefits) as reportable conference costs.28 

EXHIBIT 5: ADDITIONAL OJP CONFERENCE COST 

REPORTING GUIDANCE 

Category OJP Guidance 

Staff Time At this time, the cost of funding recipient staff time should 

generally not be included on this conference cost reporting form. 

Event 

Planner 

An event planner is a contractor (not salaried staff) hired by a 

funding recipient to perform the logistical planning necessary to 

hold a conference. "Logistical planning" may include: 

interacting with caterers, recommending venues, developing 

programs, advertising, setting the stage and audio-visual 

equipment, securing hotel rooms, and other non-programmatic 

functions. 

Event 

Facilitator 

An event facilitator is generally a contractor (not salaried staff) 

hired by a funding recipient to host the event (as distinguished 

from planning the event) and make sure the event goes according 

to plan. 

Meals and 

Incidental 

Expenses 

If the cost of an event includes travel and per diem 

reimbursements, any meals provided to conference attendees 

during the conference must be deducted from the Meals and 

Incidentals Expense (M&IE) portion of the per diem in accordance 

with the schedule listed in the Federal Travel Regulations. 

Source: OJP conference cost reporting guidance, April 2009 

OJP and the OVW did not require its event planners to report costs 

associated with staff time, such as salaries and benefits. However, the 

28 The OVW currently requires its award recipients to follow the OJP Financial Guide 

and other OJP conference-related guidance and criteria. 

12 
majority of event planning costs are associated with staff salaries and 

benefits. As shown in Exhibit 6, we found that $556,589, or 93 percent of 

the estimated $600,000 spent on event planning by outside firms, was not 

reported to OJP and the OVW. OJP and the OVW therefore did not report 

these costs to JMD for inclusion in the DOJ quarterly conference cost report. 

EXHIBIT 6: UNREPORTED COOPERATIVE AGREEMENT 

RECIPIENT EVENT PLANNING COSTS 

Component -

Program Office Conference 

Identified 

Unreported 

Costs 

($) 

OJP – BJA and 

SMART Office Indian Country Pre-Conference 7,000 

OJP – OVC Indian Nations Conference 240,588 

OJP – BJA Walking on Common Ground II 70,760 

OJP – OJJDP AMBER Alert Conference 170,338 

OVW Enhancing Judicial Skills Workshop 67,903 

TOTAL $556,589 

Source: OIG assessment of estimated salaries, benefits, and indirect costs 

incurred by event planning awardees and subrecipients 

OJP officials told us that their policy not to require event planners 

report staff time was a result of conversations with JMD over which expenses 

should be included in the quarterly conference cost reports. Under the JMD 

reporting framework, federal employee time spent planning conferences is 

not reported as an event planning cost. This is because the salaries of 

federal employees are not a direct result of the conference. In implementing 

this rule, OJP applied this exclusion to time spent by cooperative agreement 

recipients planning conferences, which resulted in entities not reporting 

event planning costs. 

However, as discussed previously, OJP and the OVW use cooperative 

agreements as vehicles to pay for conference planning activities. 

Cooperative agreement recipient personnel incur salaries, benefits, and 

indirect costs associated with planning events. Unlike federal employee 

salary and benefit costs, which are retrospective expenses and not 

attributable to a specific event, the salary and benefit costs of cooperative 

agreement recipients were the direct result of the conferences being 

planned. To ensure that DOJ conference cost reports are accurate, we 

believe that cooperative agreement recipients should report these costs to 

OJP and the OVW for inclusion in quarterly conference cost reports. By not 

reporting these event planner costs, OJP and the OVW effectively 

underreported the cost of these 5 conferences by over $550,000, or about 

13
 
 

 

35 percent of their total cost. We therefore recommend that OJP and the 

OVW update guidance provided to award recipients to ensure that they 

report all costs associated with time spent planning conferences, including 

salaries and benefits. 

OJP and the OVW also did not adequately capture conference planning 

costs when multiple organizations helped plan conferences. This is because 

sponsoring components did not combine event planning costs incurred by 

separate entities. For example, while two entities received cooperative 

agreements to help plan OVW’s Enhancing Judicial Skills Workshop, one 

entity reported $76,711 in conference costs (not including staff time, as 

noted above), while the other did not report any costs even though, 

according to estimates, it spent $35,255 to help plan the event. 

We recommend that JMD work in cooperation with OJP, the OVW, and 

other awarding components to ensure that conference cost reports include 

all salaries, benefits, and other costs charged to the government by all 

associated funding recipients. 

Assessment of External Event Planning Costs 

We reviewed costs charged by the external event planners to their 

cooperative agreements and identified two primary categories of costs. The 

first category of event planning charges is direct costs, which mostly 

consisted of staff salaries, benefits expenses, travel, and subrecipient fees. 

The other category of expenses is indirect costs, which were usually based 

on a rate charged by the event planning firm against other conferencerelated expenses. 

We reviewed event planning costs to ensure that they were supported 

and allowable under the respective cooperative agreements to which the 

costs were charged. The following sections first present an overview of our 

findings pertaining to direct costs, and the section that follows summarizes 

the results of our review of indirect costs. 

14
 
 

 

Direct Event Planning Costs 

As shown by Exhibit 7, the five conferences charged a total of almost 

$360,000 in direct costs associated with event planning. Conference 

planners and their subrecipients incurred over $258,000, or over 70 percent 

of the total amount of direct costs, for salary and benefits. 

EXHIBIT 7: OVERVIEW OF DIRECT EVENT PLANNING COSTS 

Conference 

Salaries 

and 

Benefits 

($) 

Travel 

($) 

Subrecipient 

Expenses 

($) 

Total 

Direct 

Charges 

($) 

BJA and SMART Office Indian Country 

Pre-Conference Event Planner 7,000 0 n/a 7,000 

OVC Indian Nations Conference Event 

Planner 137,967 1,124 26,254 165,345 

BJA Walking on 

Common Ground II 

Primary Event 

Planner 1,036 273 See below 1,309 

Subrecipient 1 28,406 7,928 n/a 36,334 

Subrecipient 2 6,655 1,269 n/a 7,924 

OJJDP AMBER Alert Conference Event 

Planner 36,448 10,141 48,093 94,682 

OVW Enhancing 

Judicial Skills 

Workshop 

Event Planner 1 15,712 2,464 n/a 18,176 

Event Planner 2 25,294 1,934 n/a 27,228 

TOTALS $258,518 $25,133 $74,347 $357,998 

Source: Event planner cost estimates 

Event planning staff incurred salaries and benefits performing various 

activities, such as acquiring audio-visual services, compiling registration and 

marketing materials, helping attendees make travel arrangements, and 

negotiating food and beverage costs with hotels. As stated previously, some 

event planners also provided programmatic support such as developing 

curricula, drafting the agenda, and identifying speakers for the event. 

The event planning costs we reviewed appeared to be allowable and 

supported by sufficient documentation to show that they were allocated 

appropriately to the relevant cooperative agreement, except for costs 

pertaining to two items that occurred in conjunction with the Office for 

Victims of Crime (OVC) Indian Nations Conference held in Palm Springs, 

California, in December 2008. 

15
 
 

 

 

Consultant Travel Costs 

The non-profit firm that served as the primary event planner for the 

OVC Indian Nations Conference awarded a non-competitive agreement to a 

consultant event planner in Anchorage, Alaska. Hired without the benefit of 

an open solicitation, the consultant previously worked under contract with 

the event planner.29 Event planner officials stated they worked with the 

consultant in the past and chose to work with this person for this event even 

though this person was located 2,400 miles away from the conference’s 

venue. The hiring of a consultant was part of the event planner’s budget 

approved by the OVC. The event planning firm formally hired the consultant 

after Palm Springs was selected as the conference’s venue. 

The consultant’s primary responsibility was to serve as a “hotel liaison” 

and work closely with hotel representatives to solicit bids for audio-visual 

services, coordinate travel arrangements, book rooms at the hotel for 

conference presenters, and oversee all arrangements with the hotel for 

meeting space prior to and during the conference.30 The consultant would 

also serve as the primary liaison between attendees and the event planning 

firm during the conference. 

The consultant’s contract provided a fixed-price of $22,800, plus 

travel-related expenses. The consultant subsequently billed the OVC event 

planner $3,454 for travel costs associated with three separate trips to the 

hotel in Palm Springs, California from Anchorage, Alaska. 

To be allowable, costs must be reasonable to accomplish the 

objectives of the award.31 While we believe costs associated with consultant 

travel can be necessary and allowable, we consider the travel costs for this 

consultant excessive and unreasonable because the consultant traveled to 

Palm Springs, California, from Anchorage, Alaska. In our judgment, the 

event planning firm could have minimized costs by soliciting different bids 

for consultants closer to the conference’s known venue of Palm Springs. 

Such a consultant would not have incurred such high travel costs. 

29 The consultant has worked with the OVC event planning firm for 8 years and 

specifically helped plan the past three Indian Nations Conferences. In addition, the event 

planner worked closely with employees in the firm’s Alaska office, which recently closed. 

30 The consultant’s contract also stated that this official performed some ancillary 

duties such as participating in planning committee meetings, sending awardee staff 

reminders on tasks, developing conference announcement material, and mailing 

confirmation letters for faculty, exhibitors, and entertainers. 

31 2 C.F.R. § 230 (2011). 

16
 
 

Considering these points, we believe that the OVC and its event 

planner missed an opportunity to minimize conference costs as required by 

DOJ guidelines. As a result, we question the consultant’s travel expenses 

totaling $3,454 as unallowable costs. We therefore recommend that OJP 

remedy the $3,454 and ensure that event planners in the future attempt to 

minimize costs, as applicable, by soliciting bids for sub-awards from entities 

that are closer to anticipated conference venues.32 

Early 2008 Conference Planning Committee Meeting 

The OVC event planner charged $137,967 to the cooperative 

agreement for salary and benefit costs and over $1,000 for travel 

expenses.33 Included in the labor and travel costs are those associated with 

a 2-day planning meeting at the conference’s hotel in Palm Springs in 

January and February 2008. The purpose of this face-to-face meeting was 

to assess what was needed for a successful conference and generate interest 

among all relevant parties about the upcoming event. Award recipient 

officials said the meeting was also held to ensure that agencies notified 

pertinent grantees of the conference and to persuade agencies to allow 

grantees to use award funds to attend the event. 

The planning meeting had 36 attendees, mostly representatives from 

the event planning firm, other training and technical service providers, OJP, 

and the OVW. A total of $29,365 in travel, lodging, and food and beverage 

costs for the meeting was charged to the OVC event planning award. 

The decision to conduct a face-to-face planning meeting that incurred 

nearly $30,000 in costs is troubling to us. An event planning official stated 

that the OVC specifically requested a “major” planning committee meeting 

for the conference. Nevertheless, we found that the approved cooperative 

agreement application submitted by the event planning firm stated that the 

planning committee did not require a face-to-face meeting to be effective. 

In fact, the proposal said that planning committee work could be effective 

32 Questioned costs are expenditures that do not comply with legal, regulatory or 

contractual requirements, or are not supported by adequate documentation at the time of 

the audit, or are unnecessary or unreasonable. Questioned costs may be remedied by 

offset, waiver, recovery of funds, or the provision of supporting documentation. 

33 Because the OVC event planning award recipient did not track time to a specific 

program within each cooperative agreement, we could not differentiate between the time its 

personnel spent on logistics and curriculum development. However, we consider both 

logistical planning and curricula development as part of event planning services and 

therefore all event planning costs are assessed as added costs to the government. 

17
 
 

via long distance. Moreover, the conference’s venue had been the same for 

the prior three (2002, 2004, and 2006) Indian Nations conferences. 

Considering these points, we believe it was unnecessary to have 

attendees from across the United States travel to Palm Springs in January 

and February 2008 for a face-to-face planning meeting at the same hotel 

where the conference had been held biennially since at least 2002. Had the 

event planner instead conducted this meeting via teleconference, we believe 

that the participants could still have discussed the conference planning 

issues without incurring travel, lodging, and food and beverage costs. 

Planning meetings represent important opportunities for sponsoring 

components to gauge the conference’s potential programmatic success. 

While planning meetings may be justifiable, extensive costs associated with 

traveling, lodging, and providing food and beverages may not be appropriate 

if the costs were not necessary. The cooperative agreement application 

itself indicated that such a face-to-face planning meeting was not necessary. 

As a result, we do not believe the $29,365 spent on lodging, travel, and food 

and beverages costs was necessary. 

Because these costs were unnecessary, we question them as an 

unallowable use of OJP grant funds and recommend that OJP: (1) remedy 

$29,365 in questioned planning meeting travel, lodging, and food and 

beverage costs and (2) ensure that its planners justify the need for 

significant costs associated with future face-to-face conference planning 

meetings. 

Indirect Event Planning Costs 

Indirect costs are a type of event planning expense that cannot easily 

be attributed to a particular cost objective of the event planning award. 

Examples of indirect costs include administrative salaries, rents, and utility 

charges. To recover costs associated with these items, cooperative 

agreement recipients may sometimes charge indirect costs to their award.34 

Most conference planners charged indirect costs to their cooperative 

agreements.35 As shown by Exhibit 8, DOJ was charged a total of over 

34 Indirect costs are usually recovered via indirect cost rates that are percentages of 

direct costs. Indirect rates must be approved by each recipient’s cognizant federal agency 

before it can apply the rate and recover costs. 2 C.F.R. § 230 (2011). 

35 One external event planner hired by OJP did not charge indirect costs to its event 

planning award. 

18
 
 

 

 

 

$242,000 in indirect costs for the OJP and OVW conferences. This figure is 

about 40 percent of the total cost of the event planning charges incurred for 

these events. The indirect rates applied to costs varied widely from 15 

percent to 96 percent between different organizations hired to perform event 

planning services. 

EXHIBIT 8: OVERVIEW OF INDIRECT CONFERENCE COSTS 

Conference 

Indirect 

Cost Rate 

Charged 

(%) 

Amount 

($) 

OVC Indian Nations Conference Event Planner 

n/a 

(allocation 

plan)36 

102,622 

BJA Walking on 

Common Ground II 

Primary Event Planner 31.4 968 

Sub-recipient 1 96 27,270 

Sub-recipient 2 20 1,839 

OJJDP AMBER Alert Conference Event Planner 15 85,797 

OVW Enhancing Judicial 

Skills Workshop 

Event Planner 1 17.51 16,936 

Event Planner 2 24.1 6,847 

TOTAL $242,279

 Source: OIG review of event planning records 

Exhibit 8 shows that the percentage of indirect cost rates does not 

proportionally align with the amount charged in indirect costs. This is in part 

because event planners applied their respective indirect cost rate to different 

categories of direct costs. While one event planner applied an indirect cost 

rate of 96 percent only to salary or labor costs, another firm applied a 15­

percent indirect cost rate to all conference costs, including food and 

beverages procured for attendees at the Office of Juvenile Justice and 

Delinquency Prevention (OJJDP) America’s Missing: Broadcast Emergency 

Response (AMBER) Alert Conference. Although allowable and approved by 

the firm’s cognizant federal agency (the U.S. Department of Education), 

applying the indirect cost rate in this way increased the price of all items 

procured for the conference by 15 percent. For example, although the hotel 

charged the event planner $4.84 for each soda, after applying the indirect 

rate, the event planner charged OJP $5.57 for each soda. 

36 An allocation plan is one method by which an award recipient can charge indirect 

costs. Allocation plans charge different rates to direct costs based on the activity of set 

periods of time. Indirect cost rates, however, are a fixed percentage applied to a universe 

of direct costs. 

19
 
 

Unapproved Indirect Cost Allocation 

Award recipients need to establish and receive approval from a federal 

agency for an indirect cost rate or allocation plan before they may receive 

payment for indirect expenses.37 According to the OJP Financial Guide, if an 

award recipient does not have an approved indirect cost rate or allocation 

plan, funds budgeted for indirect costs cannot be recoverable until a rate or 

allocation plan is approved. An award recipient should propose an indirect 

cost rate to OJP that: (1) outlines what costs are encompassed in its 

indirect cost pool and (2) establishes how payments will be allocated to its 

federal grants. The proposal should also certify that the indirect costs 

include only allowable expenditures.38 Once approved, the recipient can use 

its indirect cost rate or allocation plan to recoup expenses incurred when 

performing award-related activities. 

The event planner for the December 2008 OVC Indian Nations 

Conference in Palm Springs, California, used an allocation plan to charge 

indirect costs to its cooperative agreement. The allocation plan charged 

indirect costs to each award or funding source based on the total payroll 

incurred from time spent working on each project. For example, if time 

spent working on a particular project cost the firm 15 percent of its total 

payroll during a pay period, the resulting indirect cost allocation plan 

charged the project 15 percent of the total indirect costs incurred during that 

same pay period. 

Under this allocation plan, $102,622 in indirect costs was charged to 

the OVC cooperative agreement. However, the award recipient did not 

submit its indirect cost allocation plan to OJP for review and approval prior to 

charging these costs to the cooperative agreement, as required by both 

2 C.F.R. § 230 and the OJP Financial Guide. Such a submission is necessary 

to certify that all indirect costs charged to the cooperative agreement 

appropriately relate to conference activities and items. The OJP or another 

federal agency did not approve or otherwise review the appropriateness of 

the indirect cost allocation plan. The indirect costs charged to the 

cooperative agreement thus were not certified as appropriate and were not 

allowable. We recommend that OJP remedy $102,622 in questioned costs 

37 2 C.F.R. § 230 (2011). 

38 According to the limitations listed in the indirect cost agreement template, DOJ’s 

acceptance of the indirect cost rates is predicated on whether: (1) indirect costs are not 

claimed as direct costs, and (2) the grantee’s proposal accords consistent accounting 

treatment to similar types of costs. Once the rate or allocation is approved, the 

organization can apply the indirect rate to costs. 

20
 
 

and work with this award recipient to approve a future indirect cost rate or 

allocation plan. 

Different Indirect Costs for Programmatic and Logistical Services 

The training and technical assistance providers reviewed by this audit 

generally require personnel with specialized skills – such as attorneys and 

professors – to provide programmatic support necessary for OJP and OVW 

grant initiatives. For example, in addition to planning a conference, one 

training and technical assistance provider developed and hosted a series of 

seminars on responding to missing and exploited children. Such 

programmatic services are not logistical in nature. We believe firms that 

perform programmatic tasks generally require far more overhead and 

administrative support, which results in such firms incurring more indirect 

costs and applying higher indirect cost rates to recover these costs. This is 

especially troubling to us because the training and technical assistance 

providers that served as event planners applied the same indirect rate to 

costs associated with performing programmatic and logistical activities. 

Consequently, these firms might be applying high indirect rates to OJP and 

the OVW for logistical activities that do not require specialized programmatic 

skills when they: (1) provide programmatic support as a training and 

technical assistance provider and (2) charge the same indirect rates to all 

expenses (regardless of whether the expense was associated with a 

programmatic or logistical activity). 

Both the Federal Travel Regulation and DOJ conference planning 

policies seek to ensure that the government receives the best value for all 

event planning services, including logistical tasks. Indirect costs totaled 

$240,000 and constituted about 40 percent of the total event planning cost 

for the five OJP and OVW conferences. DOJ components that hire outside 

event planners that charge indirect costs need to ensure that these costs are 

minimized. We therefore recommend that OJP and the OVW demonstrate 

that a training and technical assistance provider offers the most costeffective logistical services before awarding a cooperative agreement that 

supports conference planning to such a firm. To accomplish this, we believe 

that OJP and the OVW should: (1) identify the specific event planning 

activities that are logistical (and therefore do not require specialized 

programmatic support) and (2) solicit bids from different vendors to perform 

these activities. Such solicitations should be directed to all firms capable of 

performing logistical tasks and not just to training and technical assistance 

providers. 

21
 
 

 

 

 

 

 

 

 

 

 

 

 

 

Recommendations 

We recommend that JMD: 

1. Work in cooperation with OJP, the OVW, and other awarding 

components to ensure that conference cost reports include all 

salaries, benefits, and other costs charged to the government by 

all associated funding recipients. 

We recommend that OJP and the OVW: 

2. Require that award recipients using DOJ funds to plan 

conferences track time and activities performed to plan 

conferences. 

3. Update guidance provided to award recipients to ensure that 

recipients report all costs associated with time spent planning 

conferences, including salaries and benefits. 

4. Demonstrate that a training and technical assistance provider 

offers the most cost-effective logistical services before awarding 

a cooperative agreement that supports conference planning to 

 such a firm. 

We recommend that OJP: 

5. Remedy $3,454 in questioned costs, and ensure that event 

planners in the future attempt to minimize consultant travel 

costs, as applicable, by soliciting bids for sub-awards from 

entities that are closer to anticipated conference venues. 

6. Remedy $29,365 by justifying the need for costs associated with 

travel, lodging, and food and beverages for attendees at this 

 planning meeting. 

7. Ensure that external event planners justify the need for travel, 

lodging, and food and beverage costs associated with future 

conference planning meetings. 

8. Remedy $102,622 in questioned costs and work with the event 

planner to approve a future indirect cost rate or allocation plan. 

22
 
 

 

II. FOOD AND BEVERAGES 

The 10 conferences reviewed by this audit collectively incurred 

about $490,000 in food and beverage costs. Once applicable 

service charges, local sales taxes, and indirect costs were 

factored into the final prices, some meals and refreshments not 

only exceeded what would have been allowable under April 2008 

JMD meal and refreshment cost limits, but also they appeared 

extravagant and potentially wasteful: $65 dinners, $76 lunches, 

$41 breakfasts, $32 per person refreshments at a single break, 

and coffee and tea that cost as much as $8 per 8-ounce cup. 

The JMD meal and refreshment cost limits did not apply to 

cooperative agreements, which were used to plan all reviewed 

OJP and OVW conferences. We found that this exclusion 

provided an opportunity for these event planners to circumvent 

JMD limits on conference meal and refreshment prices. DOJ 

needs to ensure that all components: (1) reassess and 

document the reasons that meals and costly refreshments are 

necessary for each future conference and (2) adhere to JMD food 

and beverage limits, regardless of whether a cooperative 

agreement is being used to support the conference. 

DOJ Conference Food and Beverage Guidelines 

Our September 2007 audit determined that DOJ components spent 

considerable funds to provide food and beverages to conference attendees. 

The audit identified several instances where food and beverages appeared to 

be extravagant and potentially wasteful considering the purpose of the 

conference. In April 2008, JMD issued new guidelines requiring that 

components stay within certain pricing limits for food and beverages at 

future conferences: 150 percent of the local per diem the GSA allocates for 

that meal and 23 percent of the total per diem rate per person for “light 

refreshments.”39 Exhibit 9 shows that, under these rules, a component may 

provide a lunch that costs less than $16.50. This is because the $16.50 

figure is 150 percent of $11, which is the amount of the $39 per diem the 

GSA allocates to lunch. 

39 JMD Financial Management Policies and Procedures Bulletin No. 08-08 

(April 2008) limits include applicable service charges and taxes (see Appendix III). Light 

refreshments include items such as coffee, tea, milk, juice, soft drinks, donuts, bagels, fruit, 

pretzels, cookies, chips, or muffins. 41 C.F.R. § 301-74.11 

23
 
 

 

 

EXHIBIT 9: EXAMPLES OF DOJ CONFERENCE 

FOOD AND BEVERAGE COST THRESHOLDS 

GSA Per Diem 

Rate 

($) 

JMD 

Breakfast 

Limit 

($) 

JMD 

Lunch 

Limit 

($) 

JMD 

Dinner 

Limit 

($) 

JMD 

Refreshments 

Limit 

($) 

39.00 10.50 16.50 27.00 8.97 

49.00 13.50 19.50 36.00 11.27 

64.00 18.00 27.00 46.50 14.72

 Source: JMD April 2008 meal policy based on GSA per diem meal allotments 

In addition, the JMD policy stipulated that these threshold limits did 

not apply to conferences funded through cooperative agreements. According 

to JMD officials, this exclusion was added to the policy because they believed 

they had limited authority to oversee funds distributed through cooperative 

agreements. As a result, the event planners for the OJP and OVW 

conferences (all five of which were planned with cooperative agreements) 

were not required to follow the 150-percent meal and 23-percent 

refreshment thresholds for their conferences. 

The OJP Financial Guide is the only DOJ or component-level policy we 

identified that applies to conferences planned under OJP and OVW 

cooperative agreements. The OJP Financial Guide allows event planners to 

pay for food and beverages at conferences, provided they meet the following 

three requirements: 

	 The food and beverage provided are incidental to a work-related 

event, 

	 The food and beverage provided during the conference are not related 

directly to amusement and social events, and 

	 The cost of the food and beverage provided is considered to be 

reasonable.40
 

40 The OJP Financial Guide defines “reasonable” costs as those that a prudent person 

would have incurred under the circumstances at the time the cost was incurred. Items to 

consider in gauging the reasonableness of food and beverage charges include the cost of the 

food or beverage, the total cost of the event, and the cost of food and beverage relative to 

the cost in the geographical area. 

24
 
 

Both JMD and OJP food and beverage guidelines provide sponsoring 

components considerable discretion regarding what food and beverages can 

be served at DOJ conferences. Because the JMD food and beverage 

thresholds do not apply to conferences funded through cooperative 

agreements and the OJP Financial Guide does not establish strict limits on 

the cost of conference food and beverages, awarding agencies and their 

event planners have even greater discretion over the meals and 

refreshments offered at events supported by cooperative agreements. 

We also note that the JMD guidance was not implemented until April 

2008. At least two of the conferences we reviewed had occurred and several 

others were in planning stages before this time. The meal cost thresholds 

established in the guidance therefore did not apply to these events. 

Even though some of the reviewed conferences were planned under 

cooperative agreements or had occurred or were being planned before JMD 

issued its meal and refreshment cost limits in April 2008, we nevertheless 

used the 150- and 23-percent thresholds as an objective benchmark to 

gauge whether the costs of meals and refreshments served at the 10 

reviewed conferences were indicative of wasteful or extravagant spending. 

The following section itemizes the cost of food and beverages served 

at each of the reviewed events. 

Itemized Conference Food and Beverage Costs 

The sponsoring DOJ components spent over $489,000 on food and 

beverages at the 10 conferences we reviewed, which is about 11 percent of 

the total $4.4 million cost of these events. Exhibit 10 overviews the food 

and beverage costs and details the number of meals served to participants 

at each conference. 

25
 
EXHIBIT 10: OVERVIEW OF CONFERENCE FOOD AND BEVERAGES

Conference Title 

Location 

(City, State or 

Country) 

Length of 

Conference 

(Days) 

Number of 

Participants 

or 

Attendees* 

Overview of meals 

to participan

EOUSA National Conference Washington, D.C. 4 166 325 breakfasts, 285 

and 247 dinners over 

EOIR Legal Conference Washington, D.C. 5 534 No full meals, only refreshments served OCDETF National Conference Washington, D.C. 4 1,348 925 lunches, and 1,2

over 3 days 

OJJDP AMBER Alert Conference Denver, CO 4 367 1,461 breakfasts, 1,0

lunches over 4 days 

OVC Indian Nations Conference Palm Springs, CA 3 750 322 breakfasts, 505 

and 530 dinners over 

BJA Walking on Common Ground II Palm Springs, CA 2 153 300 breakfasts and 3

lunches over 2 days 

BJA and SMART Office Indian Country Pre-Conference Palm Springs, CA 1 144 150 breakfasts over OVW Enhancing Judicial Skills Workshop San Francisco, CA 4 66 195 breakfasts and 6

over 4 days 

DEA IDEC Istanbul, Turkey 3 368 320 lunches over 1 d

FBI Director’s Symposium Washington, D.C. 3 242 No full meals, only refreshments served 

Source: OIG analysis of vendor invoices Notes: * We applied the total number of participants (presenters, facilitators, and attendees) if that figure 

and these personnel received food and beverages at the respective conference. 

** Number of meals provided at official conference events paid for with DOJ funds. Meal counts exc

to planning staff or presenters at pre-events. The cost of food served at pre-events is included i

*** 

Total DOJ food and beverage costs includes hotel service charges but does not include indirect ch

26 
 

The reviewed DOJ conferences included meals and refreshments 

served to attendees. In most cases, refreshments served were coffee, tea, 

soda, cookies, bagels, and pastries. Catering hotels also routinely applied 

service charges – generally about 20 percent of the menu price – to the total 

cost of the food and beverages. The following sections present a summary 

of the itemized cost of food and beverages provided at each of the 

10 reviewed conferences. 

Executive Office for United States Attorneys (EOUSA) National Conference 

The U.S. Attorneys National Conference was held at the J.W. Marriott 

in Washington, D.C., in February 2008. The conference is held annually to 

bring together the Attorney General and the U.S. Attorneys for training and 

discussion regarding DOJ’s priorities. EOUSA contracted directly with the 

hotel to provide conference services. 

The solicitation for the hotel included a statement of work detailing the 

services required. EOUSA solicited bids from area hotels and identified the 

venues that best fit their needs. An EOUSA official stated that they selected 

the J.W. Marriott hotel because it was the only four or five star venue that 

bid for the contract. The EOUSA official also told us that only a four or five 

star hotel was capable of providing the level and quality of services expected 

by senior executives and other political appointees. 

Exhibit 11 details the more than $54,000 in meals, beverages, and 

snacks provided at the EOUSA National Conference, which includes a 

22-percent service charge applied by the hotel to the price of all food and 

beverage items. 

27
 
 

 

EXHIBIT 11: EOUSA NATIONAL CONFERENCE 

FOOD AND BEVERAGE COSTS 

Food or Beverages Quantity 

List Price 

($ per 

unit) 

Price 

Charged 

($ per 

unit)* 

Adjusted 

Total Cost 

($) 

Breakfasts 

Country Style Sausage Patty Biscuits 100 4.50 5.49 549.00 

Nut Breads and Muffins (Half-Dozen) 1 26.60 32.00 32.00 

Marquis Continental Breakfast 100 23.75 28.98 2,898.00 

Continental Breakfast (Capital) 35 21.00 25.63 897.05 

Signature Breakfast Buffet 190 34.00 41.48 7,881.20 

Lunches 

Luncheons 65 40.00 48.80 3,172.00 

“Taste of Italy” Luncheon 110 49.50 60.39 6,642.90 

“Chesapeake Classic” Luncheon 110 50.50 61.61 6,777.10 

Dinners and Hors d’Oeuvres 

Tuna Wasabi Canapé (Dozen) 8 66.00 80.50 644.00 

Miniature Beef Wellington (Dozen) 8 72.00 87.88 703.04 

Phyllo filled Spinach and Feta Cheese (Dozen) 8 72.00 87.88 703.04 

Dinner (1) 84 53.00 64.65 5,430.60 

Dinner (2) 45 54.00 65.89 2,965.05 

Snacks 

Gourmet Chips, Popcorn, Pretzels, and Candy 

(Per Person) 40 6.95 8.48 339.20 

Granola Bars and Power Bars (Per Unit) 75 4.95 6.04 453.00

 Cookies and Brownies (Dozen) 9 48.00 58.56 527.04 

Beverages 

Coffee (Gallon) 48 87.95 107.29 5,149.92 

Coffee (Half Gallon) 1 43.95 54.00 54.00 

Republic of Tea Assortment (Gallon) 9 59.95 73.11 657.99 

Iced Tea (Gallon) 5 59.95 73.20 366.00 

Assorted Regular and Diet Soft Drinks 95 4.95 6.04 573.80 

Water (Per Bottle) 3 4.95 6.00 18.00 

Fruit Juice (Per Bottle) 4 5.95 7.25 29.00 

Off-Site Dinner at the Mount Vernon Inn 

Smoked Salmon Platter (serves 50) 2 150.00 187.50 375.00 

Hot Crab Dip (serves 50) 3 80.00 100.00 300.00 

Vegetable Crudité (serves 50) 2 80.00 100.00 200.00 

Swedish Meatballs (100 pieces) 1.5 60.00 75.33 113.00 

Smoked Duck Breast Biscuits with Apricot 

Preserves (100 pieces) 1.5 90.00 112.67 169.01 

Scallops Wrapped in Bacon (100 pieces) 2 100 125.00 250.00 

Coconut Shrimp (200 pieces) 1 430.00 538.00 538.00 

Dinner 118 33.00 41.25 4,867.50 

TOTAL $54,275.44 

Source: OIG analysis of the banquet checks and invoices 

Note: Price charged per unit includes the service charge that was applied by the hotel to all 

food and beverages, as well as taxes if applicable. 

28 
 

An EOUSA official explained that EOUSA has always provided food and 

beverage items during this conference, which occurs about every year. This 

official also stated that the service of meals and beverages was necessary 

because they needed to use the time when meals were served to host 

speakers. Using meal times in this way allowed EOUSA to address a large 

amount of material in a limited amount of time. 

EOUSA provided food and beverage items in conjunction with evening 

events, which we detail below. 

Event 1: Hotel Dinner and Reception 

On the first night of the conference, EOUSA invited attendees to a 

dinner and reception with the Attorney General. The total cost of the dinner 

and reception for 84 attendees, including service charges, was $7,481. The 

dinner cost $5,431, or almost $65 per person, while the hors d’oeuvres 

served at the reception preceding the dinner cost $2,050, or $24 per person. 

As shown in Exhibit 12, the reception included an assortment of hors 

d’oeuvres: Beef Wellington, tuna canape, and spinach and feta cheese-filled 

phyllo. With service charges, each piece of Beef Wellington and spinach and 

feta filled-phyllo cost $7.32, while each tuna canape cost $6.71. 

29
 
 

EXHIBIT 12: EOUSA NATIONAL CONFERENCE 

RECEPTION AND DINNER COSTS 

 Source: Banquet event orders 

This conference took place in February 2008, before JMD issued its 

guidelines in April 2008. Had the JMD threshold (150 percent of the GSA per 

diem meal allocation) been in effect, EOUSA should have spent only 

$46.50 per person for dinner. The $65 per person dinner therefore would 

have exceeded JMD’s dinner limit by $18.50, or 40 percent, per person. 

Event 2: Dinner at the Mount Vernon Inn 

On the second day of the conference, participants attended a working 

dinner at the Mount Vernon Inn located in Alexandria, Virginia. According to 

an EOUSA official, the dinner at Mount Vernon offered a better price than 

dinners offered at the hotel and also provided an opportunity for attendees 

to see Mount Vernon, the home of George Washington, which is about 

20 miles south of the conference’s venue in Washington, D.C. 

The dinner held at Mount Vernon featured a choice of entrees (crusted 

red snapper, stuffed chicken breast, or beef medallions), all with an 

assortment of hors d’oeuvres, side dishes, and salads. All the food served at 

the dinner cost over $6,800 for 118 attendees, or $58 per person. If the 

JMD threshold for this dinner had been in effect, EOUSA should have spent 

only $46.50 per person for the meal. The cost of the Mount Vernon dinner 

30
 
 

therefore would have exceeded JMD’s dinner limit by almost $12, or 

25 percent, per person. 

Executive Office for Immigration Review (EOIR) Legal Conference 41 

The 5-day EOIR Legal Training Conference was held at the Capital 

Hilton in Washington, D.C., in August 2009. The purpose of the conference 

was to provide mandatory training to EOIR staff members, on various topics 

including ethics, religious freedom, and immigration law and policies. The 

EOIR told us that it estimated that 550 people would attend the conference. 

Attendance records provided by the EOIR list 410 people (including invited 

guests and speakers) at the conference. An EOIR official told us that at 

least 534 people actually attended the conference because the list did not 

include staff and interpreters attending a corresponding event held at the 

same time and location. EOIR officials said that since the staff and 

interpreters attended the breaks, they should be counted when averaging 

costs. 

To minimize the cost of food, an official said that the EOIR purposefully 

did not serve full meals at the event and only refreshments at breaks. The 

hotel prepared a proposal stating that it would provide refreshments costing 

no more than $14.29 per person per day. The EOIR told us that it 

specifically negotiated this per person cost for refreshments based on its 

estimated 550 attendees. 

The EOIR spent nearly $40,000 on refreshments at the conference. 

The service and gratuity charges applied to each bill equaled 20 percent of 

the total price of refreshments. Applying the 534-attendee figure to the 

total cost of refreshments over the 5 days of the event, EOIR spent an 

average of $14.74 per person per day on refreshments – just above the 

$14.72 (23 percent of the applicable $64 per diem rate) JMD limit. We 

credit the EOIR for generally complying with JMD refreshment price limits by 

limiting the number of food and beverage items served and deciding to only 

serve refreshments and not full meals at its 5-day conference. 

We reviewed invoices, banquet checks, and event orders that detailed 

the food and beverages served to attendees each day, along with the prices 

charged for each item reported served, as shown in Exhibit 13. 

41 As described in the preface of this report, we received additional documents 

concerning this EOIR conference after publication of our original report. Accordingly, we 

have revised this section to reflect information included on these additional documents. 

31
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EXHIBIT 13: EOIR LEGAL CONFERENCE FOOD AND BEVERAGE COSTS 

(AT $14.74 PER PERSON DAILY AVERAGE RATE) 42 

Refreshments 

Quantity 

Reported 

Served 

OIG 

Calculated 

Price Per 

Reported 

Unit Served 

($)* 

Total 

Charged Per 

Break 

($) 

Monday, August 3, 2009 

Early Morning Break 

 Modified Continental Breakfast** 300 16.80 5,040.00 

Morning Break

 Coffee and Tea 300 7.20 2,160.00 

Afternoon Break

 Fruit and Granola Bars (with iced tea) 300 9.60 2,880.00 

Tuesday, August 4, 2009 

Early Morning Break 

 Modified Continental Breakfast** 300 16.80 5,040.00 

Morning Break

 Coffee and Tea 300 7.20 2,160.00 

Afternoon Break

 Jumbo Cookies and Brownies (with coffee) 300 9.60 2,880.00 

Wednesday, August 5, 2009 

Early Morning Break 

 Modified Continental Breakfast** 300 16.80 5,040.00 

Morning Break

 Coffee and Tea 300 7.20 2,160.00 

Afternoon Break

 Bags of Chips, Pretzels, Popcorn (with iced tea 

and a total of 200 pieces of fruit) 300 9.60 2,880.00 

Thursday, August 6, 2009 

Early Morning Break 

 Modified Continental Breakfast** 250 16.80 4,200.00 

Morning Break

 Coffee and Tea 250 7.20 1,800.00 

Afternoon Break

 Fruit, Granola Bars, and Soft Drinks 250 9.60 2,400.00 

Friday, August 7, 2009 

Morning Break

 Coffee and Tea 100 7.20 720.00 

TOTAL COST OF FOOD AND BEVERAGES $39,360.00 

Source: OIG analysis of banquet checks, event orders, and invoices 

Notes: * Price charged per unit includes 16.5 percent gratuity and 3.5 percent service 

charge applied by the hotel to food and beverage prices. **	 Hotel banquet event orders indicate that attendees received a modified 

continental breakfast, which consisted of items such as pastries, fruit, coffee, 

tea, and juice. 

42 In regard to the “OIG Calculated Price Per Reported Unit Served,” DOJ stated that 

the unit prices were not the basis on which EOIR paid for its food and beverages. According 

to DOJ, EOIR paid on a per person per day basis. DOJ also stated that the displayed unit 

prices exclude the imputed value of the complimentary meeting space. The provision of 

complimentary meeting space is discussed in the following section. 

32
 
 

 

As shown above, attendees received three breaks with refreshments 

each day, except for the last day of the conference, when there was only 

one refreshment break. EOIR officials stated that the breaks played an 

integral role in the conference because the breaks provided opportunities for 

attendees to interact and discuss immigration law issues between formal 

presentations. 

Provision of Complimentary Meeting Space 

Because the hotel provided complimentary meeting space to the EOIR, 

DOJ stated that a complete accounting of food and beverage costs would 

consider waived expenses associated with “staff services and function 

space.” The DOJ noted that the purchase order stated that the EOIR sought 

to procure “Conference/Meeting Spaces and Catering Services” from the 

hotel, and that the hotel’s proposal stated that the hotel agreed to provide 

complimentary meeting space based on “sleeping room and food and 

beverage usage.” Therefore, the DOJ stated that an itemized list of 

refreshment costs should deduct the value of the meeting space from the 

cost of individual refreshments. 

While it is correct that the proposal stated that the hotel agreed to 

provide complimentary meeting space for EOIR’s conference based on 

anticipated revenues from both lodging and food and beverage purchases, 

we note that the anticipated lodging expenses were $310,000 while the 

anticipated refreshment costs were $39,298.43 Given the disparity between 

the anticipated lodging and refreshment revenues, we believe the 

Department may have been able to secure complimentary meeting space 

based on anticipated lodging costs alone. Moreover, Capital Hilton officials 

stated to us after our initial report was issued that the anticipated revenue 

from lodging rooms alone would have been sufficient for waiving meeting 

space rental fees. As we discuss later in the report, it is important for the 

Department to negotiate carefully and consider what expenses are actually 

necessary to obtain concessions such as complimentary meeting space. 

43 The proposal included reserving a block of 1,877 sleeping rooms over the dates of 

the conference. At the $165 per room rate, 1,877 rooms would have generated revenue of 

nearly $310,000. In comparison, the proposal stated that the hotel would charge a total of 

$39,298 for refreshments at the per person rate of $14.29 per day. 

33
 
 

 

Organized Crime Drug Enforcement Task Force (OCDETF) National 

Conference 

The Criminal Division and OCDETF sponsored the OCDETF National 

Conference in July 2009 at the Omni Shoreham Hotel in Washington, D.C. 

A total of about 1,300 people attended at least part of the 4-day conference, 

which is held every 2 or 3 years to share information and recognize the 

program achievements of different federal, state, and local law enforcement 

agencies. 

As shown in Exhibit 14, the food and beverages served at the OCDETF 

National Conference cost over $137,000. This figure comprised 38 percent 

of the total $360,000 the OCDETF and Criminal Division spent on the 

conference. 

34
 
 

 

EXHIBIT 14: OCDETF NATIONAL CONFERENCE 

FOOD AND BEVERAGE COSTS 

Food or Beverages Quantity 

List Price 

Per Unit 

($ per 

unit) 

Price 

Charged 

($ per 

unit)* 

Adjusted 

Total Cost 

($) 

Breakfast Items 

Assorted Breakfast Pastries (Dozen) 128 49.00 57.82 7,400.96 

Bagels with Cream Cheese (Dozen) 67 49.00 57.82 3,873.94 

Lunches 

2-Course Plated Lunch 925 22.88 27.00 24,975.00 

Assorted Sandwiches 10 8.00 9.40 94.00 

Dinners 

Plated Dinner 1,200 39.41 46.50 55,800.00 

Snacks and Assorted Fare 

Jumbo Cookies (Dozen) 183 42.00 49.56 9,069.48 

Large Display of Fresh Vegetables 3 550.00 649.00 1,947.00 

Large Fresh Fruit Display 2 600.00 708.00 1,416.00 

Large Mediterranean Mezze Display 1 795.00 938.00 938.00 

Baked Brie en Croute Display 1 150.00 177.00 177.00 

Large Antipasto Supreme Display 2 795.00 938.00 1,876.00 

Large International Cheese Display 2 850.00 1003.00 2,006.00 

Vegetable Spring Rolls 100 3.75 4.43 443.00 

Chicken Satay with Thai Peanut Sauce 100 3.75 4.43 443.00 

Beverages 

Coffee (Gallon) 139 67.00 79.06 10,989.34 

Decaf (Gallon) 38 67.00 79.05 3,003.90 

Tea (Gallon) 25 67.00 79.08 1,977.00 

Lemonade (Gallon) 5 30.00 35.40 177.00 

Soda and Water 2,371 3.95 4.66 11,048.86 

TOTAL $137,655.48 

Source: OIG analysis of banquet checks and invoices 

Note:	 Price charged per unit includes the service charge that was applied by the hotel to all 

food and beverages. 

OCDETF officials stated that providing meals at the event was 

necessary for two reasons. First, requiring people to leave the venue for 

lunch would require additional time from the agenda and they would not be 

able to stay on schedule if the attendees left the hotel for lunch. Second, 

meals provided opportunities for speakers and presentations. 

To decide what meals and beverages to serve, OCDETF officials 

indicated that they stipulated the total meal budget in the statement of work 

provided to the hotel. Rather than choosing options from the menu, 

OCDETF officials worked with the hotels to select items that fit within their 

budget. OCDETF officials stated that they showed the hotel the JMD policy 

and the policy’s associated food and beverage cost limits. OCDETF officials 

35
 
 

told us that in general, hotels have been receptive to working with them to 

ensure that the conference complies with the food and beverage rules. 

Morning and Afternoon Breaks 

Over a 4-day period, the OCDETF National Conference featured 15 

breaks with snacks and beverages. Served at the breaks were 202 gallons 

of coffee and tea and 2,371 bottles of soda and water. With service charges 

and taxes, the coffee and tea cost $79 per gallon (or just less than $0.62 

per ounce) while the bottles of water and soda cost $4.66 each. At the 

$0.62 per-ounce price, an 8-ounce cup of coffee or tea would have cost 

OCDETF almost $5. 

 Awards Banquet 

An awards banquet reception and dinner was held at the conclusion of 

the third day of the OCDETF National Conference. Along with these costs, 

the OCDETF spent nearly $6,000 on appetizers at this reception: two $550 

vegetable displays, a $600 fruit display, two $795 “antipasto supreme” 

displays, and two $850 cheese displays as detailed in Exhibit 15. 

36
 
 

EXHIBIT 15: OCDETF NATIONAL CONFERENCE 

AWARDS BANQUET RECEPTION MENU 

Source: Event banquet order 

Following the reception, which cost about $5 per person, the Criminal 

Division and OCDETF hosted a formal, three-course dinner for 1,200 

participants. Including the hotel service charge, each dinner cost $46.50. 

At the time of the conference (July 2009) the GSA per diem allotment for 

dinner was $31. This means that the amount spent on dinner per person 

was exactly at the JMD 150-percent threshold. Exhibit 16 details the full 

menu served to participants at the awards dinner. 

37
 
 

EXHIBIT 16: OCDETF NATIONAL CONFERENCE 

DINNER MENU 

 Source: Event banquet order 

We determined that the lunches and dinners provided to OCDETF 

National Conference attendees fell within the established JMD meal price 

thresholds. 

OJJDP AMBER Alert Conference 

The OJJDP held a 4-day AMBER Alert Conference for 367 attendees at 

the Grand Hyatt in Denver, Colorado, in November 2007. The purpose of 

this event was to increase collaboration between state AMBER Alert 

coordinators and their media and transportation partners. The conference 

provided a continental breakfast, a lunch, and multiple breaks each day. 

As discussed previously, the external event planner hired by OJJDP via 

a cooperative agreement applied a 15-percent indirect cost rate to food and 

beverages purchased for the conference. Although allowable under the 

cooperative agreement terms, the practice of charging indirect costs to these 

items increased the total cost of food and beverages (including service 

charges) by about $13,500, from just over $90,000 to almost $104,000. 

Exhibit 17 details the menu price, the price with service charges, and the 

price with indirect costs of food and beverages served across the 4 days of 

the OJJDP AMBER Alert Conference. 

38
 
EXHIBIT 17: OJJDP AMBER ALERT CONFERENCE 

FOOD AND BEVERAGE COSTS 

Food or Beverages Quantity 

List Price 

($ per unit) 

Price with 

Hotel 

Service 

Charges 

($ per unit) 

Subtotal 

Service 

Charges 

($) 

Price with 

Event 

Planner 

Indirect 

Costs 

($ per unit) 

Subt

Eve

Plan

Indi

Cos

($

Breakfasts 

Daily Continental 

Breakfast 1,461 17.00 20.57 30,052.77 23.66 4,5

Lunches 

Plated Lunch (Day One) 350 29.00 35.09 12,281.50 40.35 1,8

Plated Lunch (Day Two) 360 34.00 41.14 14,810.40 47.31 2,2

Plated Lunch (Day Three) 370 29.00 35.09 12,983.30 40.35 1,9

Continuous Beverage Service 

Coffee (Gallon) 187.5 60.00 72.60 13,612.50 83.49 2,0

Cans of Soda 1,334 4.00 4.84 6,456.56 5.57 9

TOTALS $90,197.03 $13,5

Source: OIG analysis of banquet checks 

39
 

Food and Beverage Charges for Free Meeting Space 

The event planner contracted with the hotel to secure free meeting 

space for the conference provided. The event planner told us that the hotel 

waived meeting space fees so long as the conference incurred at least 

$50,000 on food and beverages, not including service charges. Excluding 

service charges, the event planner nevertheless spent over $74,543 on food 

and beverages, or more than $24,000 over the minimum amount 

established for free meeting space. Because the firm did not conduct a costbenefit analysis comparing the price of meeting space rentals to the meal 

and refreshment price, we could not determine if the amount spent on food 

and beverages was less expensive than the cost of meeting space would 

have been had the space not been provided for free.44 

An official told us that meals and refreshments were provided because 

good meal options helped ensure that the conference was “a nice event” for 

attendees. This official also stated that the meals and beverages helped 

ensure that the conference was an appropriate “showcase” for the DOJ 

AMBER Alert program. 

Continuous Beverage Service 

The event planner procured from the hotel what was referred to as 

“continuous beverage service” throughout the 4 days of the conference. As 

implied by its name, the continuous beverage service provided attendees 

with unlimited soda, water, coffee, and tea during conference sessions. With 

service charges and the 15-percent indirect cost rate charged on all items 

provided for the conference, the total cost of the beverage service was over 

$23,000. Each can of soda cost the OJP $5.57 while each gallon of coffee 

cost more than $83, or $0.65 per ounce. At this price, an 8-ounce cup of 

coffee would have cost $5.20. 

 $47-Per-Person Lunch 

On the second day of the conference, 360 attendees were served 

3-course lunches that featured “five-spiced beef short rib” entrees with 

vegetables and crème brulee desserts. Including service charges and 

indirect cost rates, the lunch cost OJP over $47 per person. Had the April 

44 We were told that hotels determine the price of meeting space on a case-by-case 

basis. The price a hotel charges for meeting space depends on a number of factors, such as 

the size of the group, time of the year, and the duration of the conference. As a result, we 

were unable to determine how much the meeting space would have cost had the hotel not 

waived the requirement to rent the space after enough food and beverages were ordered. 

40
 
 

2008 JMD meal and refreshment threshold applied, the price of the lunch 

should not have cost more than $19.50 per person. The price for the lunch 

at this event was $27.50 (141 percent) more than the JMD limit price. 

OVC, Bureau of Justice Assistance (BJA), and the Office of Sex Offender 

Sentencing, Monitoring, Apprehending, Registering, and Tracking (SMART 

Office) Conferences Held in Palm Springs, California 

In December 2008, three OJP grant program offices – the OVC, BJA, 

and SMART Office – held a series of three events in Palm Springs, California, 

that focused on addressing specific criminal justice needs of Native American 

and Alaskan Native tribes. All three events were planned by outside firms 

hired via cooperative agreements, and therefore did not have to comply with 

JMD April 2008 thresholds that limit the amount spent on meals to 

150 percent of the applicable GSA per diem meal allocation. 

	 The OVC hosted its 2008 Indian Nations Conference to train a total 

of 750 victim service providers, law enforcement officials, court 

officials, health professionals, and victim advocates from tribal, 

federal, state, and local levels. 

	 The BJA and the SMART Office co-hosted an Indian Country PreConference immediately before the OVC Indian Nations Conference 

to review tribal community efforts to monitor and register sex 

offenders. This event had 144 participants. 

	 The BJA also hosted the Walking on Common Ground II conference 

as an initiative to sustain and enhance ongoing tribal court-related 

program efforts. This event had 153 participants. 

The Wyndham Hotel served as the venue for all these events. Because 

these events were held in conjunction with each other, the three events 

used the same hotel contract that the OVC event planner established to 

procure meals. The meals and refreshments were from the same menu and 

had the same service charges. Exhibit 18 details the food and beverages 

served at the Palm Springs conferences. 

41
 
 

 

 

 

 

 

 

 

 

EXHIBIT 18: FOOD AND BEVERAGES SERVED AT THE PALM 

SPRINGS, CALIFORNIA CONFERENCES 

Food or Beverages Quantity 

List Price 

($ per unit) 

Price 

Charged 

($ per unit)* 

Adjusted 

Total Cost 

($) 

OVC INDIAN NATIONS CONFERENCE** 

Breakfasts 

Hot Breakfast Buffet 322 24.00 28.80 9,273.60 

Lunches 

Tortellini and Smoked Chicken 505 23.00 27.60 13,938.00 

Dinners 

Prime Rib 430 36.00 43.20 18,576.00 

Breast of Chicken 85 36.00 43.20 3,672.00 

Penne Pasta 15 36.00 43.20 648.00 

Beverages and Snacks 

Cookies (Dozen) 2 30.00 36.00 72.00 

Iced Tea (Gallon) 4 38.00 45.50 182.00 

Coffee and Tea (Gallon) 6 40.00 48.00 288.00 

Breaks 

2 Breaks Per Day 100 20.00 24.00 2,400.00 

1 Break Per Day 900 24.00 28.80 25,920.00 

Subtotal $74,969.60 

BJA WALKING ON COMMON GROUND II 

Breakfasts 

Continental Breakfast 312 18.25 23.60 7,363.20 

Lunches 

The Sportsman 150 19.50 25.21 3,781.50 

Deli Lunch Buffet 150 28.95 37.43 5,614.50 

Beverages and Snacks 

Coffee (Gallon) 12 40.00 51.75 621.00 

Cookies and Brownies (Dozen) 12 28.00 36.17 434.04 

Subtotal $17,814.24 

BJA AND SMART OFFICE INDIAN COUNTRY PRE-CONFERENCE 

Breakfasts 

Continental Breakfast 150 18.25 23.60 3,540.00 

Breaks 

“Stay Fit” Break 150 9.25 11.96 1,794.00 

Beverages 

Coffee and Tea (Gallon) 4 40.00 51.75 207.00 

Subtotal 

TOTAL 

$5,541.00 

$98,324.84 

Source: OIG analysis of banquet checks 

Notes: * Price charged per unit includes the service charge that was applied by the 

hotel to all food and beverages, as well as taxes if applicable. 

** Food and Beverages shown for the OVC Indian Nations conference do not 

include almost $2,500 in costs associated with breakfasts, cookies, soda, and 

coffee for the 40 attendees at the January 2008 pre-conference planning 

meeting. These costs are instead questioned as unnecessary expenses in the 

External Event Planning finding of this report. 

42
 
 

 

 

 

An average of 540 people per day attended the 3 Palm Springs events 

that spanned the dates December 9 to 13, 2008. The meals and 

refreshments (including service charges) provided for these events cost 

more than $98,000. The food and beverages provided by the OVC during 

the Indian Nations Conference cost over three-quarters of this amount, or 

nearly $75,000, for 750 people.45 

Food and Beverage Charges for Free Meeting Space 

To secure free meeting space for all three events, the sponsoring 

components and event planners were contractually obligated to purchase a 

minimum of $35,000 in food and beverages excluding service charges. The 

cost for food and beverages at these three events was over $82,000 

excluding service charges, which was more than $47,000 over the minimum 

required by the contract. Obtaining free meeting space by agreeing to incur 

a set amount of food and beverage charges may achieve cost savings only 

when the price of the meeting space (that was waived) would have been 

greater than the price of the food and beverages that the conference was 

obligated to order. 

None of the sponsoring components or event planners for the three 

Palm Springs events conducted a cost-benefit analysis to show that ordering 

more than $82,000 (or $98,325 with service charges and taxes) worth of 

food and beverages achieved cost savings over the waived price of the 

meeting space at the hotel. As discussed previously, because hotel meeting 

space rental prices depended on a number of variables, we were unable to 

make this comparison and determine whether the cost of meals and 

refreshments was less than what the cost of meeting space would have been 

had the hotel not provided its meeting space for free. 

45 Cooperative agreement officials stated that the firm collected non-DOJ funds via 

contributions, conference registration fees, and private sponsorships, which it used to pay 

for some of the food and beverage costs. The officials also stated that it used non-DOJ 

funds to also pay for other types of conference costs, particularly music performances held 

during the conference. 

The cooperative agreement recipient did not always segregate DOJ funds from 

contributions and registration fees when paying for conference costs. As a result, the firm 

was not able to detail the food and beverage costs that were offset by contributions and 

registration fees. Therefore, we assessed the reasonableness of all food and beverage 

charges associated with the Indian Nations Conference. 

43
 
Breakfast and Lunch 

Over the course of the 3-day event, the OVC Indian Nations 

Conference included one hot breakfast and one lunch for participants. The 

hot breakfast was served to 322 attendees and included fruit, french toast, 

scrambled eggs, bacon, sausage, potatoes, and pastries, while the lunch was 

tortellini and smoked chicken. The OVC spent $28.80 per person on the 

breakfast and $27.60 per person on the lunch. The cost of the breakfast 

and lunch exceeded JMD per person meal limits by $12.30 (74 percent) and 

$3.60 (15 percent) respectively. 

OVW Enhancing Judicial Skills Workshop 

The March 2009 Enhancing Judicial Skills Workshop was one in a series 

of training courses offered by the OVW for state judges overseeing domestic 

violence cases. Held at a Hilton hotel in San Francisco, California, the 

conference had an initial planning day for the faculty and 4 days of course 

work for the participants. The conference, which was planned by two 

different OVW training and technical service providers, included breakfasts, 

lunches, and several themed breaks. 

As shown by Exhibit 19, one event planner applied a 17.51-percent 

indirect cost rate to food and beverage charges. Although the application of 

the indirect rate was allowable under the terms of the cooperative 

agreement, the indirect rates applied to the direct food and beverage 

charges increased the OVW’s cost of meals and refreshments by $3,573. 

44
 
EXHIBIT 19: ENHANCING JUDICIAL SKILLS WORKSHOP

FOOD AND BEVERAGE COSTS 

Food or Beverages Quantity 

List Price 

($ per unit) 

Price With 

Hotel Service 

Charges 

($ per unit) 

 Subtotal 

Service 

Charges 

($) 

Price with 

Event 

Planner 

Indirect 

Costs 

($ per 

unit) 

Su

E

Pl

In

C

Breakfast 

Continental Breakfast (3 days) 145 31.00 41.03 5,949.35 48.21 1

Arise Breakfast (1 day) 65 30.00 39.71 2,581.15 46.66 

Lunches 

Restaurant Lunch 16 14.13 18.69 299.04 21.96 

“Mission Dolores” 65 49.00 64.86 4,215.90 76.22 

Beverages 

Coffee and Tea (Gallon) 11 85.00 112.55 1,238.05 132.26 

Water and Soda 242 5.00 6.62 1,602.04 7.78 

Themed Breaks (Per Person) 

Cheese Tasting 17 14.50 19.18 326.06 22.54 

“The Ballpark” 65 20.50 27.14 1,764.10 31.89 

The “Awake” Break 65 8.00 10.58 687.70 12.43 

The “Aware” Break 65 14.00 18.54 1,205.10 21.79 

“Deluxe” Ice Cream Break 65 6.25 8.28 538.20 9.73 

TOTALS $20,406.69 $3

Source: OIG analysis of banquet checks 

45
 

 

 

Not including the $1,900 cost of food and beverages served to faculty 

on the day before the workshop, the OVW spent $22,063 on food and 

beverages for the 66 attendees during the 4 days of the Enhancing Judicial 

Skills Workshop. The meals and refreshments cost the OVW almost $84 per 

person each day. In particular, the conference spent, on average, almost 

$30 each day on just refreshments (beverages and break snacks) for each 

attendee. Although the JMD guidance did not apply to this event since it 

was planned under a cooperative agreement, the $30 spent on refreshments 

per person is about $15 more than the $14.72 (103 percent) that would 

have been allowable under JMD guidelines. 

Food and Beverage Charges for Free Meeting Space 

The Enhancing Judicial Skills Workshop was held in conjunction with 

the Continuing Judicial Skills Workshop, a separate OVW event that was also 

for state judges overseeing domestic violence cases.46 The event planning 

firms entered into one hotel contract that covered meeting space and food 

and beverages for both events. The hotel agreed to waive the cost of 

renting meeting space if the workshops collectively incurred more than 

$25,000 in food and beverage costs. However, the OVW and its event 

planners spent $49,743 on food and beverages. This means that the 

workshops – one of which was the Enhancing Judicial Skills Workshop – 

collectively exceeded the minimum for free meeting space by $24,743. 

As discussed in previous sections, we could not determine the cost of 

meeting space. Similar to the other event planners, the OVW event planners 

did not conduct a cost-benefit analysis to determine if the amount spent on 

food and beverages was less than the cost of what the meeting space would 

have been had the hotel not waived the rental fees. 

Officials with one of the OVW event planners said that attendees have 

come to expect food and beverages at these workshops. Officials also 

explained that the high prices associated with food and beverages were due 

to the fact that “San Francisco is an expensive city.” We asked why 

San Francisco was chosen as the location of the conference if it was known 

to be so expensive. Officials told us that San Francisco was selected 

because it draws a large number of judges for attendance. 

The sections below detail the most expensive food and beverage costs 

of this event. 

46 The audit did not examine the OVW Continuing Judicial Skills workshop expenses. 

46
 
 

 

 “Mission Dolores” Lunch 

On the third day of the conference, 65 workshop participants received 

a “Mission Dolores” lunch that had a menu price of $49 per person. Exhibit 

20 details the “Mission Dolores” menu selection. 

EXHIBIT 20: LUNCH AT THE OVW 

ENHANCING JUDICIAL SKILLS WORKSHOP
 

Source: Banquet event order 

Including the hotel service charge, taxes, and indirect costs, each 

Mission Dolores lunch actually cost the OVW $76. Although the JMD 

thresholds did not apply to this conference because it was planned under a 

cooperative agreement, the final cost of the meal exceeded the JMD lunch 

rate of $27 by $49 – or 181 percent – per person. 

47
 

 

 

 

 

 Themed Breaks 

Throughout the workshop, expensive themed break packages were 

offered to attendees. Food items in these snack packages included popcorn, 

Cracker Jacks, candy, and ice cream. 

EXHIBIT 21: THEMED BREAKS AT THE 

ENHANCING JUDICIAL SKILLS WORKSHOP
 

Source: Banquet event orders 

Applying service charges, taxes, and indirect charges to the base 

prices listed in the menu above, the “Ballpark” and “Deluxe” Ice Cream 

Assortment ended up costing the OVW about $32 and $10 per person 

respectively. 

Coffee and Tea Costing More Than $8 Per 8-ounce Cup 

The 11 gallons of coffee and tea served at the conference had a menu 

price of $85 per gallon. Considering that there are 128 ounces in one gallon, 

the price for a single ounce of coffee or tea at the menu price would have 

been more than $0.66. However, the OVW also paid service fees, taxes, and 

indirect costs for each gallon of coffee or tea. We found that these costs 

increased the price paid for each gallon of coffee or tea by 55 percent to 

over $132. The actual price of coffee or tea at the workshop ultimately cost 

the OVW more than $1.03 an ounce. An 8-ounce cup of coffee at this price 

would cost $8.24 and account for almost 56 percent of the 23-percent per 

diem limit ($14.72) that JMD established for refreshments. 

48
 

 

 

 

In total, the 11 gallons of coffee and tea served over 5 days to a total 

of 66 conference participants cost the OVW almost $1,500. 

Drug Enforcement Administration (DEA) International Drug Enforcement 

Conference (IDEC) 

The DEA co-hosted the 26th IDEC with the Turkish National Police at 

the Conrad Hotel in Istanbul, Turkey, in July 2008. The event served as a 

forum for international law enforcement officials to share drug investigation 

information, identify common targets, and coordinate law enforcement 

efforts against regional and international drug cartels. The Association of 

Former Federal Narcotics Agents (AFFNA) sponsored most of the food and 

beverages for the event. As a result, the DEA only spent a total of $26,980 

on food and beverages for the 368 attendees throughout the 3-day event. 

This equals $24 per person per day for meals and refreshments.47 

July 10 Coffee Breaks 

According to summary documents, the food and beverage charges 

paid directly by the DEA stemmed from the cost of refreshments served 

during various coffee breaks. What appeared to be the two most costly of 

these breaks occurred on the morning and the afternoon of July 10, the last 

day of the conference. Both breaks served an average of 300 attendees and 

cost a total of $15,600, or $26 per attendee. 

According to JMD conference cost thresholds, total refreshments 

provided to attendees should cost no more than 23 percent of the applicable 

GSA meals and incidental expenses (M&IE) per diem rate. The DEA 

provided documents showing that its employees who helped plan the 

conference were cognizant of the established DOJ limits for the cost of meals 

and refreshments served during the event. At the time of the conference, 

the per diem rate for Istanbul, Turkey, was $114. However, attendees 

received two breaks that each cost $26 per person on July 10. This means 

that the DEA actually spent $52 per person on breaks during this day. 

Applying the JMD’s 23-percent GSA M&IE limit to the $114 per diem, the 

DEA should have spent no more than $26.22 on each attendee for both 

breaks. By spending $52 per attendee total on these breaks, the DEA spent 

almost twice as much as the DOJ threshold allows. 

47 According to the DEA, the AFFNA directly paid the Conrad Hotel $132,000 for 

meal and refreshment costs associated with an evening reception, lunches, and coffee 

breaks. Because the DEA did not incur and pay these costs directly, we did not include 

these expenses in our review of IDEC food and beverage costs. 

49
 
Federal Bureau of Investigation (FBI) Director’s Symposium 

The FBI’s Office of the Ombudsman holds a symposium every other 

year to provide training and information to members of the Director’s 

Advisory Committees. The 3-day conference was held at the L’Enfant Plaza 

Hotel in Washington, D.C., in April 2009. The FBI reported that at least 242 

Advisory Committee members and other officials attended the event. The 

FBI provided two coffee breaks each day to all conference attendees at a 

total cost of $19,965. 

According to the hotel banquet orders, the FBI purchased 

refreshments for the attendees at each of the breaks. The refreshments 

served included fruit, bagels, muffins, cookies, brownies, coffee, and soda 

charged on a per person basis instead of a la carte. According to JMD food 

and beverage guidelines, the FBI was allowed to spend $14.72 each day on 

refreshments for each person, which equates to a total allowance of $3,680 

per day on refreshments. 

However, the FBI spent $26.62 per person per day on just 

refreshments. This is $11.90 more than what would have been allowed 

under the JMD threshold. As a result, the FBI overspent on refreshments by 

$2,975 per day for 3 days, for a total of $8,925. 

Analysis of Itemized Food and Beverage Costs 

Food and beverages served to attendees of the 10 reviewed 

conferences cost a total of almost $490,000. While JMD food and beverage 

cost limits were not in effect or otherwise did not apply to most of these 

events, we considered the April 2008 JMD thresholds (150 percent of the 

GSA per diem meal allocation for limits to costs of meals served and 23 

percent of the GSA per diem rate for the limit of the cost of daily 

refreshments) during our review to gauge whether the food and beverage 

costs were indicative of extravagance or waste. We also note that 5 of the 

10 conferences were funded by OJP or OVW cooperative agreements 

governed by the OJP Financial Guide, which requires that food and beverage 

costs be reasonable. 

Our review of food and beverage prices leaves us concerned about the 

broad discretion that components and event planners have regarding the 

provision of meals and refreshments at DOJ events. Of the 35 instances in 

which meals were served at the 10 conferences, 29 (83 percent) had meals 

that exceeded JMD thresholds of 150 percent of the GSA per diem M&IE 

allocation. In our opinion, some of the prices incurred for meals and 

refreshments appear particularly expensive and indicative of wasteful or 

50
 
 

 

extravagant spending once service and indirect charges are applied to the 

cost of each meal or refreshment. For example, we note that OVW incurred 

$76 per person for a lunch and over $8 per cup of coffee or tea (after 

applying service fees and indirect charges to each item). 

Lack of Justifications for Costly Food and Beverages 

We found that event planners were unable to provide adequate 

justifications for the high cost of food and beverages at their FY 2008 and 

2009 conferences. Many event planners stated that full meals were always 

provided at past conferences and therefore should be provided at current 

and future events to meet participant expectations. Event planners also 

explained that they viewed the provision of food and beverages as a very 

important part of the perceived success of the conference. 

We find such justifications to be inadequate considering the high cost 

of the food and beverages at the reviewed events. The respective goal of 

each of the reviewed conferences was to offer attendees an opportunity to 

receive and discuss necessary programmatic information with DOJ partners. 

In no instance did an event planner or component successfully demonstrate 

to us that providing food and beverages with costs that exceeded JMD 

thresholds was needed to achieve the goals of the conference. 

We discussed our concern of costly food and beverage prices with JMD 

officials responsible for developing the April 2008 policy. The Attorney 

General, the Deputy Attorney General, and the Assistant Attorney General 

for Administration have each issued memoranda to DOJ component heads 

directing them to reign in conference spending.48 In addition, JMD has 

developed an internal website that consolidated relevant policies and other 

rules for DOJ conference planners. Considering these efforts, JMD officials 

stated they believed that components improved compliance with meal and 

refreshment thresholds during more recent events (FYs 2010 and 2011) 

than we found was the case during the scope of our review (FYs 2008 and 

2009). 

48 On June 5, 2008, the Assistant Attorney General for Administration wrote to DOJ 

component heads to highlight the April 2008 JMD policy that established meal and 

refreshment cost limits, see Appendix IV. About a year later, on May 4, 2009, the Deputy 

Attorney General also issued a memorandum to DOJ component heads highlighting 

important aspects of the JMD policy. In particular, the memorandum emphasized that 

conferences should only occur if there was a business need and that costs must be 

minimized, see Appendix V. In a January 21, 2011 memorandum that announced a 

temporary DOJ-wide hiring freeze, the Attorney General specifically instructed component 

heads to suspend all non-essential travel, training, and conferences and minimize the 

number of DOJ attendees at such events, see Appendix VI. 

51
 
 

The JMD conference cost thresholds, consolidated conference planning 

website, and memoranda from leadership to component heads constitute 

positive steps towards mitigating the purchase of high-priced food and 

beverages at future DOJ conferences. Nevertheless, because 8 of the 10 

reviewed conferences occurred following the April 2008 policy, we remain 

concerned that not all components are taking into account service fees, 

taxes, and indirect costs when deciding what food and beverages – if any – 

should be served at a conference. We are also troubled by the lack of 

justifications components provided for food and beverages at the 

10 conferences reviewed by this audit. In our opinion, the lack of 

documentation makes it appear as though many were not seriously 

questioning the need for their events to include expensive meals and 

refreshments. 

Documenting Savings as a Result of Free Meeting Space 

Another justification offered for food and beverages at conferences is 

that hotels sometimes agree to waive meeting space rental fees provided 

that DOJ purchase a minimum amount of food and beverages for the event. 

For the reviewed conferences, this minimum amount ranged from between 

$25,000 and $50,000; however, conference planners spent much more on 

food and beverages than what would have been required for free space. For 

example, the OVC alone spent almost $30,000 more on food and beverages 

than the minimum $35,000 the hotel required for free meeting space. 

Although free meeting space may provide an opportunity to save 

money, no component or event planner reviewed assessed whether the cost 

of meals and refreshments was less than the cost that meeting space would 

have been had it not been provided by the hotels for free. Without a costbenefit analysis that compares the value of free meeting space to the cost of 

meals and refreshments, we could not determine whether conference costs 

were reduced by a component or event planner ordering a set amount of 

food and beverages and receiving meeting space at no cost. 

The waiver of meeting space rental fees can only serve as a 

justification for serving food and beverages at conferences when it results in 

saving DOJ money. As a result, we recommend that JMD require that 

components and their event planners conduct a cost-benefit analysis 

whenever they justify ordering food and beverages to obtain free meeting 

space for their conferences. Such a cost-benefit analysis should show that 

the cost of the meeting space would have been greater than the food and 

beverage cost had the hotel not waived its meeting space rental charges. 

52
 
Need for Food and Beverage Limits for Cooperative Agreements 

The JMD meal and refreshment thresholds are based on individual GSA 

per diem rates. These rates consider cost of living and price disparities 

between different cities across the United States. The GSA updates per 

diem rates at least annually, and some rates are even seasonable to account 

for times when costs at a particular locality are potentially at a premium. 

Because the JMD price limits are based on GSA per diem rates, the price 

limits need not be updated and are higher in cities experiencing a higher 

cost of living. 

As stated previously, although the April 2008 JMD guidance sets strict 

limits on the cost components can incur for meals and refreshments, it 

specifically does not apply to conferences funded through cooperative 

agreements. Other than the OJP’s Financial Guide rule that requires award 

recipients to ensure that the cost of food and beverage is “reasonable,” no 

criteria exists that actually limits or otherwise minimizes the cost of food and 

beverages served at OJP and OVW conferences. 

We believe that OJP’s rule requiring that conference food and beverage 

prices be “reasonable” falls short of ensuring that cooperative agreement 

recipients select lower-priced food and beverages for their events and 

minimize DOJ conference costs. The OJP rule is difficult to apply 

retroactively and we could not determine whether a cooperative agreement 

recipient complied with the “reasonable” requirement. This is because the 

OJP Financial Guide circularly defines “reasonable” prices as the prices that 

would have been incurred under the circumstances at the time the cost was 

incurred by a prudent person. As shown by the high cost of individual meals 

and refreshments incurred by the OJP and OVW events reviewed – $47 and 

$76 lunches and $8 cups of coffee – we do not believe that event planners 

took the steps necessary to minimize meal and refreshment costs. 

By not ensuring that cooperative agreement recipients comply with 

JMD cost limits, cooperative agreement recipients are afforded an 

opportunity to circumvent what otherwise would be strict limits on meal and 

refreshment prices. Without clear cost limits, OJP and the OVW are not 

adequately ensuring that their event planners are complying with the 

Federal Travel Regulation and other DOJ guidelines that require that 

conference costs be minimized. We therefore recommend that OJP and the 

OVW establish and implement guidelines on conference food and beverage 

limits for cooperative agreement recipients congruent with DOJ-wide rules. 

53
 
 

 

 

Recommendations 

We recommend that JMD:

 9.	 Require that components and their event planners conduct a 

 cost-benefit analysis whenever they justify ordering food and 

beverages to obtain free meeting space for their conferences. 

We recommend that OJP and the OVW: 

10. Establish and implement guidelines on conference food and 

beverage limits for conferences supported with cooperative 

agreement funds congruent with DOJ-wide rules. 

54
 
 

STATEMENT ON INTERNAL CONTROLS 

As required by the Government Auditing Standards, we tested, as 

appropriate, internal controls we considered significant within the context of 

our audit objectives. A deficiency in an internal control exists when the 

design or operation of a control does not allow management or employees, 

in the normal course of performing their assigned functions, to timely 

prevent or detect: (1) impairments to the effectiveness and efficiency of 

operations, (2) misstatements in financial or performance information, or 

(3) violations of laws and regulations. Our evaluation of each sponsoring 

component’s internal controls was not made for the purpose of providing 

assurance on its internal control structure as a whole. Component level 

management is responsible for the establishment and maintenance of 

internal controls. 

As noted in the Findings and Recommendations section of this report, 

within the context of the audit objectives and based upon the audit work 

performed, we identified certain deficiencies in DOJ’s internal controls that 

we believe adversely affect the DOJ conference sponsors’ ability to use 

appropriated funds efficiently and effectively. During our review, we 

identified reportable conditions relating to how component conference 

sponsors incur and report conference expenditures. 

Because we are not expressing an opinion on DOJ’s or DOJ 

component’s internal controls over conference expenditures as a whole, this 

statement is intended solely for the information and use of DOJ and its 

components in planning and paying for conferences. This restriction is not 

intended to limit the distribution of this report, which is a matter of public 

record. 

55
 
 

STATEMENT ON COMPLIANCE
 

WITH LAWS AND REGULATIONS
 

As required by the Government Auditing Standards we tested, as 

appropriate given our audit scope and objectives, selected records, 

procedures, and practices, to obtain reasonable assurance that DOJ and its 

components complied with federal laws and regulations for which 

noncompliance, in our judgment, could have a material effect on the results 

of our audit. DOJ and its component level management are responsible for 

ensuring compliance with federal laws and regulations applicable to 

conference planning. In planning our audit, we identified the following laws 

and regulations that concerned the operations of DOJ and its components 

that were significant in the context of the audit objectives: 

 Pub. L. No. 110-161 § 218 (2008). 

 Pub. L. No. 111-8 § 215 (2009). 

 41 C.F.R. § 301-74 (2011). 

 2 C.F.R. § 230 (2011). 

 31 U.S.C. § 6305 (2011). 

 42 U.S.C. § 10603 (C)(1)(B) (2010). 

 25 U.S.C. § 3681 (a) (2010). 

 42 U.S.C. § 3751 (2010). 

 42 U.S.C. § 5775 (2010). 

Our audit included examining, on a test basis, whether different DOJ 

components complied with the laws and regulations cited above and whether 

non-compliance could have a material effect on DOJ components’ 

operations. Through interviews with responsible officials, analyzing 

conference cost reports, obtaining and testing cost data, we determined that 

components did not always work to minimize conference costs, and did not 

appropriately track and report conference costs. Our report provides 

recommendations that, once implemented, will help ensure that the audited 

components comply with the regulations while planning, hosting, and 

reporting conference cost data. 

56
 
 

 

 

 

 

 

SCHEDULE OF DOLLAR-RELATED FINDINGS 

QUESTIONED COSTS49 AMOUNT ($) PAGE 

Unallowable Costs 

1. Consultant travel costs 3,454 16 

2. Planning meeting travel, lodging, and 

food and beverage costs 

29,365 17 

Less consultant travel costs to 

planning meeting questioned as 

unallowable in Line 1. 

(1,009) 

3. Unapproved indirect costs 102,622 20 

Total Questioned Costs $134,432 

49 Questioned costs are expenditures that do not comply with legal, regulatory or 

contractual requirements, or are not supported by adequate documentation at the time of 

the audit, or are unnecessary or unreasonable. Questioned costs may be remedied by 

offset, waiver, recovery of funds, or the provision of supporting documentation. 

57
 
 

ACRONYMS 

AFFNA Association of Former Federal Narcotics Agents 

AMBER America’s Missing: Broadcast Emergency Response 

ATF Bureau of Alcohol, Tobacco, Firearms and Explosives 

BJA Bureau of Justice Assistance 

C.F.R. Code of Federal Regulations 

COPS Office Office of Community Oriented Policing Services 

DEA Drug Enforcement Administration 

DOJ Department of Justice 

EOIR Executive Office for Immigration Review 

EOUSA Executive Office for United States Attorneys 

FBI Federal Bureau of Investigation 

FY Fiscal Year 

GSA General Services Administration 

IDEC International Drug Enforcement Conference 

JMD Justice Management Division 

M&IE Meals and Incidental Expenses 

OCDETF Organized Crime Drug Enforcement Task Force 

OIG Office of the Inspector General 

OJJDP Office of Juvenile Justice and Delinquency Prevention 

OJP Office of Justice Programs 

OVC Office for Victims of Crime 

OVW Office on Violence Against Women 

SMART Sex Offender Sentencing, Monitoring, Apprehending, 

Registering, and Tracking 

U.S.C. United States Code 

USMS United States Marshals Service 

58
 
 

APPENDIX I 

OBJECTIVE, SCOPE, AND METHODOLOGY 

Objective 

The objective of this audit was to review a sample of conferences that 

occurred between October 2007 and September 2009 to determine whether 

Department of Justice (DOJ) components properly accounted for and 

minimized conference planning, meal, and refreshment costs. 

Scope and Methodology 

We conducted this performance audit 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. 

In order to achieve the audit objectives, we reviewed 10 high-dollar 

DOJ conferences from fiscal years (FY) 2008 and 2009. We included tests 

and procedures to identify unallowable and extravagant costs. To test and 

develop conclusions regarding both the overall cost of each conference and 

the cost of each conference category, we (1) assessed how components 

obtained event planning services, (2) evaluated whether components and 

event planners used effective and efficient procurement methods, and 

(3) identified food and beverage items provided by sponsoring components 

indicative of potentially extravagant and wasteful spending. 

Throughout the audit, we relied on computer-generated data provided 

by the Justice Management Division (JMD), component-level conference 

planners, and training and technical assistance providers. This data included 

conference cost reports, expense summaries, and invoices considered while 

conducting the analysis necessary to accomplish our audit objectives. 

Although we did not assess the reliability of such computer-derived 

information, we do not believe our reliance on this data affects our findings 

and recommendations. 

Conference Universe and Selection 

JMD prepared a listing of the 1,832 conferences hosted by DOJ during 

FYs 2008 and 2009. To accomplish our audit objectives, we selected a 

59
 
 

 

OJP 

23% 

OVW 

4% 

Other 

13% 

DEA 

4% 

FBI 

56% 

judgmental sample of conferences reported on this list to evaluate the 

nature of the event and their respective level of expenditures. From this 

initial sample, we would select 10 events to test for this audit. 

For the initial selection, we identified primarily high-dollar events that 

listed high total conference costs, high costs in any single cost category – 

including high food and beverage costs per person per day – and the most 

expensive international conference. We also identified events held in what 

appeared to be resort locations. Finally, we identified conferences that were 

held in conjunction with other reported events. We applied this judgmental 

sampling design to identify events that provided a broad exposure to 

numerous facets of the universe of DOJ conferences held during the scope of 

our audit. This non-statistical sample design applied to identify conferences 

worthy of review precludes us from projecting the results of our testing to all 

DOJ hosted conferences. 

As shown in Exhibit I-1, the Federal Bureau of Investigation (FBI) and 

the Office of Justice Programs (OJP) accounted for 79 percent of the 

reported 2008 and 2009 conference expenditures. 

EXHIBIT I-1: DOJ COMPONENT CONFERENCE 

EXPENSES FY 2008 AND 2009 

Component 

Total Cost 

($) 

Drug Enforcement 

Administration 

(DEA) 

4,830,298 

FBI 67,748,009 

OJP 27,599,265 

Office on Violence 

Against Women 

(OVW) 

5,240,666 

Other 15,846,209 

TOTAL $121,264,447

 Source: JMD FY 2008 and 2009 Conference Expenditure Reports 

The FBI reported a number of training events in its conferences report 

submissions. For example, for FY 2009, we estimated that the FBI included 

about $28 million in costs associated with training. Although we do not take 

issue with the FBI including these events in its conference reports, we did 

60 
not find other components uniformly reporting training events on their 

respective reports. As a result, we believe the total reported costs for the 

FBI was disproportionate to the total cost reported by other DOJ 

components. Nevertheless, because the FBI and OJP accounted for a very 

large part of the reported conference costs, we included in our initial 

selection of 37 a representative sample of FBI and OJP conferences. 

Considering these facets, and based on JMD reported conference costs 

for FYs 2008 and 2009, we identified 37 events hosted by 10 different 

components that, in our opinion, merited additional review. Detailed in 

Exhibit I-2 are the 37 conferences selected and reviewed during the survey 

phase of the audit. 

61
 
EXHIBIT I-2: CONFERENCES SELECTED FOR PRELIMINARY REVIEW 

Agency Conference Title Location A

ATF Columbus Field Division All Hands Columbus, OH ATF Grade 14 Assessment Center Grapevine, TX 

COPS SEARCH/COPS Tech TA Mesa, AZ 

COPS CSPP Kick-Off Conference Dallas, TX CRM Organized Crime Drug Enforcement Task Force National Conference Washington, D.C. 

CRM Financial Investigations Seminar San Diego, CA 

DEA International Drug Enforcement Conference Istanbul, Turkey 

DEA Internet Telecommunications Exploitation Program Chantilly, VA 

DEA Basic Telecommunications Exploitation Program Chantilly, VA 

DEA Human Resources Leadership Conference Potomac, MD EOIR Legal Training Conference Washington, D.C. 

EOUSA 2008 U.S. Attorneys National Conference Washington, D.C. 

FBI 2008 Infragard Coordinators Annual Training Baton Rouge, LA 

FBI 2008 Infragard Conference Baton Rouge, LA 

FBI Navigating Strategic Change Evanston, IL 

FBI Navigating Strategic Change Evanston, IL 

FBI The Emerging Executive Ashland, MA 

FBI National Executive Institute Sydney, Australia 

FBI Directors Advisory Committee National Symposium Washington, D.C. 

OJP AMBER Alert the Media Denver, CO 

OJP AMBER Forensics Training Denver, CO 

OJP AMBER Leadership Denver, CO 

OJP AMBER Alert National Conference Denver, CO 

OJP Accessing and Sustaining Resources for Community & Faith Based Organizations Philadelphia, PA 

OJP SVAA Cluster Meeting Washington, D.C. 

OJP Walking on Common Ground II Palm Springs, CA 

OJP Indian Country Sex Offender Registration and Notification Pre-Conference Institute Palm Springs, CA 

OJP Office for Victims of Crime 11th National Indian Nations Conference Palm Springs, CA OJP NLC Protects: Confronting the Challenge of Sexual Exploitation Crimes Orlando, FL 

OVW Building Momentum 2008 Anchorage, AK 

OVW IACP National Law Enforcement Leadership Initiative on Violence Against Women Charleston, SC 

OVW Leadership Institute #10 Charleston, SC 

OVW Leadership Institute #11 Chicago, IL 

OVW 2009 Regional Law Enforcement Training Symposium and Violence Against Women National Harbor, MD OVW Enhancing Judicial Skills in Domestic Violence Cases Workshop San Francisco, CA 

USMS Mobile Force Protection Training Melbourne, FL USMS Post Training Tactical Operations Division Melbourne, FL 

Source: This data is from JMD’s 2008 and 2009 consolidated quarterly reports on conference expenditures. 

data in selecting conferences to audit. Actual attendance figures and costs may have varied. 

62 
 

We subsequently met with responsible officials from these 10 

components and obtained background information on these 37 selected 

events. The information solicited included an overview of each event’s 

purpose, site selection, planning procedures, applicable contracts and 

cooperative agreements, and budget estimates. We also discussed how 

each component compiled and reported conference cost data to JMD. We 

then reviewed and analyzed the documents received and applied 20 different 

conference variables to identify the 10 conferences that we proposed 

reviewing for the audit. The exhibit below features a selection of the 

variables used to narrow our selection to 10 conferences. 

EXHIBIT I-3: SELECTION OF VARIABLES 

USED TO IDENTIFY 10 CONFERENCES 

- Resort or perceived resort area 

- Expensive food items 

- Networking receptions, banquets, 

awards ceremonies 

- Agendas with significant free time 

- Hosted at a private facility (hotel) 

- Use of outside entity to plan 

conference 

- Limited documentation provided 

during entrance conference 

Source: OIG analysis 

For our judgmental selection of ten conferences, we identified 

conferences that reported high total costs or high costs in one cost category. 

For example, we analyzed cost of meals and refreshments provided at the 

conference to further our selection and determine if any of the expenditures 

were expensive or extravagant. 

In addition to utilizing what we consider to be variables which 

represent risk factors, we eliminated certain conferences out of the 37 due 

to their distinct purpose in law enforcement training. In our narrowed 

selection of 37 conferences, these training events included both Bureau of 

Alcohol, Tobacco, Firearms and Explosives (ATF) conferences, along with 

training courses held by the Drug Enforcement Administration (DEA) and 

FBI, and both U.S. Marshals Service (USMS) conferences. For our 

judgmental selection of 10 conferences, we identified 3 OJP conferences all 

held in conjunction with each other in what appeared to be a resort location 

in Palm Springs, California with similar program-related purposes. 

Combined, these costs for the OJP Palm Springs conferences constituted one 

of the highest total costs for the component’s reported conferences. Also, 

63
 
we selected the DEA International Drug Enforcement Conference (IDEC), 

which reported the highest cost for an international DOJ conference. 

We then took into account those conferences with high food and 

beverage costs, including those with extremely high per person per day meal 

and refreshment costs. The Organized Crime Drug Enforcement Task Force 

(OCDETF) National Conference incurred the highest food and beverage costs 

to the government, totaling $137,655. Also, the OJP America’s Missing: 

Broadcast Emergency Response (AMBER) Alert Conference totaled over 

$90,000 in food and beverage costs. Finally, we chose those conferences 

that generally reported high total conference costs. 

Finally, in order to consider a sample of conferences planned through 

in-house measures and not by a third party source, we selected the FBI 

Director’s Symposium and the Executive Office for U.S. Attorneys (EOUSA) 

National Conference. 

Exhibit I-4 shows the 10 conferences from 8 DOJ components we 

selected for further review. In total, these 10 events accounted for over 

$4.4 million of the total $121 million in conference costs reported for FYs 

2008 and 2009. 

64
 
EXHIBIT I-4: FINAL DOJ CONFERENCES SELECTED FOR REVIEW

Sponsoring 

Component(s) Conference Title Location - Dates 

Criminal Division and OCDETF National Conference Washington, D.C. July 20 – 23, 2009 DEA IDEC Istanbul, Turkey July 8 – 10, 2008 

EOIR Legal Training Conference Washington, D.C. Aug. 3 – 7, 2009 

EOUSA National Conference Washington, D.C. Feb. 11 – 14, 2008 

FBI Directors Symposium Washington, D.C. April 14 – 16, 2009 

OJP, BJA and SMART Office (Co-sponsors) Indian Country Pre-Conference Palm Springs, CA Dec. 10, 2008 

OJP, OVC Indian Nations Conference Palm Springs, CA Dec. 11 – 13, 2008 

OJP, BJA Walking on Common Ground II Palm Springs, CA Dec. 9 – 10, 2008 

OJP, OJJDP AMBER Alert Conference Denver, CO Nov. 13 – 16, 2007 

OVW Enhancing Judicial Skills Workshop San Francisco, CA March 28 – April 1, 200

TOT

Source: FY 2008 and 2009 conference expenditure listings compiled by JMD Note: Total cost based on OIG audit figures. 

65
 

Audit Fieldwork 

We conducted our internal audit fieldwork with the DEA, FBI, EOUSA, 

EOIR, OJP, and OVW. We also contacted, visited, and performed fieldwork 

at private and non-profit organizations that were awarded DOJ funding to 

plan and host these conferences. 

During our fieldwork, we identified and reviewed federal acquisition 

and travel regulations, Government Accountability Office decisions, DOJ 

directives, and component-level guidance regarding conference planning, 

travel, and allowable expenditures. We also reviewed and analyzed 

conference planning documents and summaries, conference attendance lists, 

memoranda of understanding, and invoices. We subsequently met with the 

hotels and sponsors hosting the conferences we reviewed, either on site or 

via teleconference, to obtain final payment documentation and food and 

beverage banquet checks.50 

After meeting with all DOJ components, technical assistance providers, 

and hotels, we conducted our analysis of conference event planning, as 

detailed in Finding I. 

Event Planning Costs 

In our review, we considered event planning to include both logistical 

services, such as hotel arrangements, and programmatic support, such as 

curricula development. Event planners were not able to provide specific 

event planning costs relating to their DOJ conferences because they were 

not required to track and report salaries and benefits relating to their work 

on each conference. Therefore, upon meeting with the event planners 

during our audit, we asked them to estimate conference event planning 

costs. During our audit, we relied on these estimates to compute event 

planning salaries, benefits, and indirect costs previously not reported for 

those conferences planned through cooperative agreements. In some cases, 

it was not possible to match invoiced costs to specific reimbursements or 

drawdowns because some planners working under cooperative agreements 

tracked costs by award instead of by conference. 

We did not test travel vouchers when conducting analysis on 

conference costs to determine compliance with pertinent travel rules and 

regulations. We relied on those travel costs provided by the event planners 

and did not test these costs using timesheets or drawdown payments. 

50 The OIG’s contacts with the hotel hosting the EOIR conference are discussed in 

more detail below.
 

66
 
 

Food and Beverage Costs 

Upon discussing with the hotels and obtaining either from the hotel or 

from the Department components what was presented to us as final food 

and beverage invoices and payments, we analyzed the nearly $490,000 in 

food and beverage costs for the 10 conferences, as detailed in Finding II. 

For those conferences serving both food and beverages, we assessed both 

costs, while for those conferences that did not serve meals, we based our 

analysis on the refreshment costs only. 

During our audit, we had an initial teleconference with the Capital 

Hilton where we explained the scope of our audit and where they provided 

us with general information about the EOIR conference. We subsequently 

contacted the Capital Hilton’s staff by e-mail and telephone several times 

requesting additional information about the specific itemized costs reflected 

in banquet checks pertaining to the EOIR conference. The event planning 

staff acknowledged our requests, but no additional explanation or 

information was provided. 

As detailed in the preface to this revised report, the Capital Hilton 

provided us with documents after the publication of our audit report to 

demonstrate that individual refreshment items at the EOIR conference were 

not as expensive as initially reported. After we received this information, we 

contacted the EOIR, which told us it then searched its files and confirmed 

that it had these documents. The EOIR stated it inadvertently did not 

produce these documents to us during the audit. We issued this revised 

report to reflect the information in the documents that the Capital Hilton 

produced to us after the publication of our original audit. 

Because the JMD guidance was not implemented until April 2008, the 

meal and refreshment cost thresholds did not apply to many of the 10 

conferences reviewed because they were either held or were being planned 

by the time the rules were issued. Further, the JMD policy stipulated that 

the meal and refreshment limits did not apply to conferences funded through 

cooperative agreements. As a result, the event planners for the reviewed 

OJP and OVW conferences (all of which were planned with cooperative 

agreements) were not required to follow the 150-percent meal and 

23-percent refreshment thresholds. We nevertheless applied the April 2008 

JMD thresholds as a benchmark to ascertain objectively whether meals and 

refreshments appeared to be extravagant or wasteful uses of taxpayer 

funds. 

67
 
 

When conducting our analysis, we itemized the food costs based on 

the hotel banquet checks. We calculated an updated unit price of each food 

item offered at the conferences by adding applicable service charge and tax 

to total an updated itemized cost. Unless stated otherwise in the report, we 

relied on the banquet invoices provided by the component, planner, or hotels 

hosting the conference. Itemized costs of food and beverages throughout 

the report include minimal adjustments due to rounding the per item price to 

the nearest cent. These rounded figures did not affect the overall calculated 

cost of the conferences presented in the report. 

Because there are 128 ounces in each gallon and conference attendees 

could have received different serving sizes of hot beverages, our audit 

applied the standard 8-ounce measure for one cup as a single serving of 

beverages procured by the gallon but served individually. 

68
 
 

APPENDIX II 

CONFERENCE FACTS AND SUMMARIES 

The following charts contain facts and summaries for the 10 

conferences selected for our audit. 

1. Criminal Division and OCDETF National Conference 

Formal Name: Organized Crime Drug Enforcement Task Force and 

Asset Forfeiture and Money Laundering Section National Leadership 

Conference 

DOJ Sponsor: Criminal Division and OCDETF 

Dates Held: July 20 to 23, 2009 

Venue: Omni Shoreham Hotel 

Location: Washington, D.C. 

No. of Participants: 1,348 

Conference Summary: Conducted in partnership with the 

Department of Justice Asset Forfeiture and Money Laundering Section, 

this conference worked to prohibit financial infrastructure that supports 

drug trade. Conference attendees included United States Attorneys, 

Agency Headquarters leadership, money laundering specialists, and 

other senior leadership from agencies and components participating in 

the Department of Justice and Department of Treasury Asset Forfeiture 

Programs. 

69
 
2. DEA IDEC 

Formal Name: 26th Annual International Drug Enforcement 

Conference 

DOJ Sponsor: DEA 

Dates Held: July 8 to 10, 2008 

Venue: Conrad Hotel Istanbul 

Location: Istanbul, Turkey 

No. of Participants: 368 

Conference Summary: For the past 26 years, the DEA has 

sponsored the IDEC in partnership with a foreign law enforcement 

agency. The purpose of the conference is to share drug-related law 

enforcement information, identify common targets, and develop a 

coordinated regional and global approach to law enforcement efforts 

against international drug trafficking organizations, money laundering 

operations, and the diversion of essential and precursor chemicals. 

70
 
3. EOIR Legal Conference 

Formal Name: 2009 Legal and Interpreters Training Conference 

DOJ Sponsor: EOIR 

Dates Held: August 3 to 7, 2009 

Venue: Capital Hilton Hotel 

Location: Washington, D.C. 

No. of Participants: 534 

Conference Summary: As the first comprehensive program offered 

by the EOIR, this event served as training for attorneys, paralegals, 

immigration judges, and representatives from the EOIR Office of the 

General Counsel. The training was comprised of various breakout 

sessions covering immigration law and custody and bond issues, and 

the conference served as a means for agency and court officials to 

discuss important issues and policy reform. 

71
 
4. EOUSA National Conference 

Formal Name: 2008 United States Attorneys’ National Conference 

DOJ Sponsor: EOUSA 

Dates Held: February 11 to 14, 2008 

Venue: J.W. Marriott 

Location: Washington, D.C. 

No. of Participants: 166 

Conference Summary: The United States Attorneys’ National 

Conference is generally held annually and brings together all 93 U.S. 

Attorneys for training and to discuss the prosecution priorities of the 

Department of Justice, such as terrorism matters, Project Safe 

Childhood, and violent crime matters, among others. At the 2008 

United States Attorneys’ National Conference, EOUSA coordinated a 

half-day orientation for new United States Attorneys, held a half-day 

Attorney General’s Advisory Committee (AGAC) meeting, and held 

eight separate AGAC subcommittee meetings in an effort to enhance 

the work of each of these groups. 

72
 
5. FBI Director’s Symposium 

Formal Name: Director’s Advisory Committee National Symposium 

DOJ Sponsor: FBI 

Dates Held: April 14 to 16, 2009 

Venue: L’Enfant Plaza Hotel 

Location: Washington, D.C. 

No. of Participants: 242 

Conference Summary: This Symposium is held every other year and 

provides training and information dissemination to representatives of 

the Director’s three Advisory Committees (Special Agent, MidManagement, and Aegis). A large number of Assistant Directors and 

Unit Chiefs present information during breakout sessions. The Director 

also provides a general session to all committee representatives. 

73
 
 

6. BJA and SMART Office Indian Country Pre-Conference 

Formal Name: Indian Country Sex Offender Registration and 

Notification Pre-Conference Institute 

DOJ Sponsor: OJP/BJA and SMART Office 

Dates Held: December 10, 2008 

Venue: Wyndham Palm Springs Hotel 

Location: Palm Springs, CA 

No. of Participants: 144 

Conference Summary: The Office of Sex Offender Sentencing, 

Monitoring, Apprehending, Registering, and Tracking organized this 

pre-conference institute to focus on issues related to Sex Offender 

Registration and Notification in Indian Country. The audience was 

primarily tribal criminal justice professionals and tribal leaders. This 

institute covered essential information for tribes seeking to timely 

comply with the Sex Offender Registration and Notification Act’s 

requirements. 

74
 
7. BJA Walking on Common Ground II 

Formal Name: Walking on Common Ground II 

DOJ Sponsor: OJP/BJA 

Dates Held: December 9 to 10, 2008 

Venue: Wyndham Palm Springs 

Location: Palm Springs, CA 

No. of Participants: 153 

Conference Summary: Walking on Common Ground II brought 

together tribal, state, and federal justice communities and was a 

continuation of the 2005 Walking on Common Ground Conference. 

This gathering worked to improve the understanding, coordination, 

collaboration, and communication among tribal, federal, and state 

court relations. Those in attendance included judges, court 

commissioners, court administrators, peacemakers, and attorneys, 

among others. 

75
 
 

8. OJJDP AMBER Alert Conference 

Formal Name: 2007 National AMBER Alert Conference: AMBER Alert 

Training and Technical Assistance Program 

DOJ Sponsor: OJP/OJJDP 

Dates Held: November 13 to 16, 2007 

Venue: Grand Hyatt Denver 

Location: Denver, CO 

No. of Participants: 367 

Conference Summary: The 2007 National AMBER Alert Conference 

included a gathering of law enforcement officers, media 

representatives, transportation officials, and missing children 

clearinghouse coordinators brought together to protect children by 

improving the response to and handling of missing children and 

abduction cases. Participants worked together to establish stronger 

lines of communication, discuss promising practices used in different 

jurisdictions, and identify all available resources at their disposal. 

76
 
9. OVC Indian Nations Conference 

Formal Name: 11th National Indian Nations Conference: 

“Strengthening the Heartbeat of All our Relations” 

DOJ Sponsor: OJP/OVC 

Dates Held: December 11 to 13, 2008 

Venue: Wyndham Palm Springs 

Location: Palm Springs, CA 

No. of Participants: 750 

Conference Summary: This conference demonstrated methods and 

strategies to improve safety as well as promote justice and healing for 

crime victims through cooperation and collaboration between tribal, 

federal, state, and private entities in American Indian and Alaska 

Native communities. 

77
 
10. OVW Enhancing Judicial Skills Workshop 

Formal Name: Enhancing Judicial Skills in Domestic Violence Cases 

Workshop 

DOJ Sponsor: OVW 

Dates Held: March 28 to April 1, 2009 

Venue: Hilton San Francisco Financial District 

Location: San Francisco, CA 

No. of Registrants: 66 

Conference Summary: Held numerous times in a grant period, this 

conference offers interactive workshops that provide a foundation for 

new and experienced state and tribal court judges to enhance their 

skills in handling civil and criminal domestic violence cases. Through 

hypothetical case problems, role-play exercises, small-group 

discussions, and faculty demonstrations, judges in various jurisdictions 

learn from one another in various domestic violence case scenarios. 

78
 
APPENDIX III 

APRIL 2008 JUSTICE MANAGEMENT DIVISION 

CONFERENCE COST POLICY 

FINANCIAL MANAGEMENT
 

POLICIES AND PROCEDURES BULLETIN 

No. 08-08 April 2008 

TO: Executive/Administrative Officers 

Offices, Boards, and Divisions 

JMD Senior Staff 

Bureau Chief Financial Officers 

 /s/ 

FROM: Melinda B. Morgan 

Director 

Finance Staff 

Justice Management Division 

SUBJECT: Conference Planning, Conference Cost Reporting, and Approvals to Use 

Nonfederal Facilities 

1. PURPOSE. This policy provides guidance to components when planning and reporting on 

conferences. This policy also lays out the requirement for components to seek approval prior to 

using a non-federal facility for a predominantly internal training or conference meeting. 

2. BACKGROUND. In the summer of 2005, a subcommittee of the U.S. Senate Committee on 

Homeland Security and Governmental Affairs launched a government-wide inquiry into 

conference spending. The inquiry found that since fiscal year (FY) 2000, federal agencies spent 

at least $1.4 billion on conferences and did not consistently or transparently track funds spent on 

79
 
conferences and related travel. In September 2007, the Department of Justice's (Department) 

Inspector General (IG) released a report highlighting the high costs and inconsistent or 

nonexistent reporting procedures of 10 conferences conducted by the Department in FY 2006. 

The IG Report recommended that the Department develop and implement consistent conference 

planning and reporting procedures. The procedures contained in this policy are consistent with 

the recommendations contained in the IG Report. Additionally. Section 218 of the Department 

of Justice Appropriations Act, 2008 (Title II, Division B, Public Law 110-161), requires the 

Attorney General to submit quarterly reports to the IG regarding the costs and contracting 

procedures for each conference held by the Department for which the cost to the government was 

more than $20,000. Therefore, each component is required to submit to the Justice Management 

Division a quarterly report regarding the conferences it funds. 

Finally, section 1173 of Public Law 109-162, the Violence Against Women and Department of 

Justice Reauthorization Act of 2005, states that unless authorized in writing by the Attorney 

General, the Department (and each entity within it) shall use for any predominantly internal 

training or conference meeting only a facility that does not require a payment to a private entity 

for the use of the facility. The Act also requires the Attorney General to prepare an annual report 

to the Chairmen and ranking minority members of the Committees on the Judiciary of the Senate 

and of the House of Representatives that details each training and conference meeting that 

required specific authorization. The report must include an explanation of why the facility was 

chosen and a breakdown of any expenses incurred in excess of what would have been the cost of 

conducting the training or conference meeting at a facility that did not require such authorization. 

The Attorney General has delegated his responsibilities under this provision to the Assistant 

Attorney General for Administration (AAG/A). 

3. DIRECTIVES AND SOURCES REFERENCED. 

 5 U.S.C. §4101(6), Definitions, Non-Government Facility 

 31 U.S.C. §3302, Custodians of Money (“Miscellaneous Receipts Act”) 

 31 U.S.C. §6305, Using Cooperative Agreements 

 Department of Justice Appropriations Act, 2008 (Title II, Division B, Public Law 110-161) 

 The Violence Against Women and Department of Justice Reauthorization Act of 2005 

(Public Law 109-162) 

 Federal Travel Regulation (FTR), 41 C.F.R. §300-3.1 and §301-74 

 Department of Justice, Office of the Inspector General, “Department of Justice Conference 

Expenditures,” Audit Report 07-42, September 2007 (“IG Report”) 

 Uniform Administrative Requirements for Grants and Cooperative Agreements with NonProfit Organizations (28 C.F.R. part 70) 

 Federal Acquisition Regulation (FAR), Volume I, Part 10 

 Office of Management and Budget (OMB) Cost Principles Circular A-122, 2 C.F.R. 230 

 Office of Justice Programs Financial Guide 

 Financial Management Memorandum 08-07, Implementation Guide for Financial 

Management Policies and Procedures Bulletin 08-08, Conference Planning, Conference Cost 

Reporting, and Approvals to Use Non-federal Facilities 

4. DIRECTIVES RESCINDED. 

80
 
	 Financial Management Policies and Procedures Bulletin 06-12, Use of Non-federal 

Conference and Training Facilities 

	 Financial Management Policies and Procedures Bulletin 00-19, Refreshments at Conferences 

5. DEFINITIONS. 

a.	 Conference. The FTR defines “conference,” in part, as a meeting, retreat, seminar, 

symposium, event or training activity. 41 C.F.R. §300-3.1. A conference is typically a 

prearranged event with designated participants and/or registration, a published substantive 

agenda, and scheduled speakers or discussion panels on a particular topic. 

This Bulletin applies to any conference planned and held by components themselves, and 

conferences funded by a component but conducted by an outside entity through the use of a 

contract or a cooperative agreement. For a conference conducted through the use of a 

cooperative agreement, only §§9 and 10(b) of this guidance are applicable. With respect 

to conferences funded by more than one agency, this Bulletin applies if the Department 

provides more funding than any other agency. When reporting on such conferences, a 

component should only account for the funding provided by the Department. 

The following types of activities are excluded from the definition of “conference” for the 

purposes of the §10(a) reporting requirement only. (Examples for each of the following 

types of activities that are excluded can be found in Attachment A.) 

1)	 Law enforcement planning, staging, surveillance, undercover, or other meetings related to 

a law enforcement operation, and meetings to coordinate the Department's investigative, 

intelligence and/or prosecutorial efforts in connection with a pending case, specific 

criminal activity or a threat against the United States, including those that occur at law 

enforcement or security operational centers; 

2) Training courses taught at federal training centers, such as the National Advocacy Center, 

the Federal Law Enforcement Training Center, the Federal Bureau of Investigation 

National Academy, and the Drug Enforcement Administration Training Academy; 

3)	 Undercover activities and training conducted in accordance with the Attorney General’s 

guidelines; or 

4) Testing where the primary purpose of the event is to evaluate an applicant's qualifications 

to perform certain duties necessary to perform his or her job. In order for an event 

involving testing to be excluded from the reporting requirement, the majority of the event 

must be devoted to the administration and taking of the test. An event is not excluded 

from the reporting requirement if a test is incidental to the training course and is given 

upon its completion to determine satisfactory participation. 

b.	 Predominantly internal training or conference meeting. A predominantly internal training or 

conference meeting is one that is held by the Department and where the majority (more than 

81
 
 

50%) of the attendees are Department employees. As above, “training or conference 

meeting” is defined broadly to include a meeting, retreat, seminar, symposium, event or 

training activity. 41 C.F.R. §300-3.1. The above list of activities (§5(a)(1)-(4)) that are 

excluded from the conference reporting requirements of §10(a) are not excluded from this 

definition. For the purposes of this bulletin, “predominantly internal training or conference 

meetings” will be referred to as “predominantly internal events.” 

c.	 Federal facility. Federal facility means property owned, leased, or substantially controlled by 

the federal Government or the Government of the District of Columbia. 

d.	 Non-federal facility. Non-federal facility is any facility that is not a federal facility. For 

further clarification see the definition of “non-Government facility” in 5 U.S.C. §4101(6). 

e.	 Conference or Event planner. A conference or event planner is a contractor hired by a 

component to perform the logistical planning necessary to hold a conference. “Logistical 

planning” may include: interacting with caterers, recommending venues, developing 

programs, advertising, setting the stage and audio/visual (a/v) equipment, securing hotel 

rooms, and other non-programmatic functions. 

6. CONFERENCE PLANNING. 

a.	 Conference Justification. The decision to host any event, whether it be a conference or 

predominantly internal event, or to send employees to attend an event, requires fiscal 

prudence and is subject to the availability of funds from individual component 

appropriations. Components must document a written justification for each conference that 

includes a programmatic reason to hold the event and an approval from an appropriate 

sponsoring agency official. 

b.	 Planning Requirements. When planning a conference, components are required to follow 

Part 301-74 of Title 41 of the Code of Federal Regulations, entitled “Conference Planning.” 

These regulations, in part, require that components: 

1)	 Minimize all conference costs, including administrative costs, conference attendees' 

travel costs, and conference attendees' time costs; 

2)	 Maximize the use of Government-owned or Government provided conference facilities as 

much as possible; and 

3) Identify opportunities to reduce costs in selecting a particular conference location and 

facility (e.g., through the availability of lower rates during the off-season at a site with 

seasonal rates). 41 C.F.R. §301-74.1. 

82
 
c.	 Use of External Conference Planners. Minimizing conference costs must be a critical 

consideration in a component's decision whether to plan a conference with internal 

Department staff or to enter into a contract with an external conference planner. The use of 

an external conference planner should be used only when necessary and conference planning 

costs should always be kept to a minimum. 

d.	 Large and/or Expensive Conferences. The appropriate Component Procurement Chief must 

review and approve all conferences exceeding $500,000, or that will have over 500 attendees. 

Such approval must be in writing and submitted with the report required in §10(a). 

e.	 Charging Conference Fees. A component cannot charge fees to conference attendees to 

cover its costs unless the component has very specific statutory authority to do so. See 31 

U.S.C. §3302. However, if the component uses a private contractor (such as an external 

event planner, hotel, or other third party) to facilitate the conference or provide goods and 

services to the attendees, the contractor may charge fees. It is important that the fees charged 

by the contractor cover only the goods and/or services provided to the attendees by the 

contractor (or subcontractor(s)) and do not cover or defray costs that are the responsibility of 

the component. For example, if a contractor such as a hotel is providing attendees with 

lodging, meals and refreshments for a conference, the hotel may charge attendees directly for 

the costs of those items. The contractor must deal directly with the attendees to collect the 

fees; the component must not be involved in any such collection. 

f.	 Selecting a Location. An event location is comprised of two variables: the city and the 

facility in which the event takes place. To ensure that the government obtains the best 

conference location for the best value, conference planners must compare multiple facilities 

in multiple cities, unless an overriding operational reason is documented to hold the 

conference in a specific city. Adequate cost comparisons should compare and document the 

availability of lodging rooms at per diem rates, the convenience of the conference location, 

availability of meeting space, equipment and supplies, and the commuting or travel distance 

of attendees. 

To ensure that components maximize the use of federal facilities and minimize total costs to 

the Department, conference planners shall first consider all federal facilities in the locations 

identified via city-level cost comparison analysis. A list of some federal facilities is available 

on the Non-federal Facility Request Center web site: 

http://10.173.2.12/jmd/fs/nfrc/index.htm. If a federal facility meets the component's needs at 

a reasonable price, there is no requirement that non-federal facilities be considered. The 

component may consider non-federal facilities if: 

1)	 federal facilities are not available or do not meet the component's requirements (e.g., size 

of the meeting room, necessary technological equipment, sufficient lodging at the facility 

or in the proximity of the facility); or 

2)	 the component believes that a non-federal facility can be procured at a lower cost taking 

into account all costs described in this section. 

83
 
 

 

If a federal facility cannot meet the component's needs at a reasonable price, the conference 

planner must conduct and make available market research to determine the facility that best 

meets the needs of the conference as set forth in the Federal Acquisition Regulation (FAR), 

Volume 1, Part 10. In order for this market research to be effective, the components must 

communicate the same sufficiently detailed requirements to all potential facilities. During 

the market research, components must not make any commitments to any of the facilities. 

The market research must determine the cost of the event with respect to each of the three (or 

more) facilities, broken down as follows. Costs related to attendees (e.g., travel, lodging, per 

diem) must include costs of all attendees whose expenses are being covered by the 

component; therefore, include Department employees as well as non-Department attendees 

(e.g., facilitators, guest speakers) whose expenses are being covered by the component. 

1) conference and meeting space, including rooms for break-out sessions; 

2) audio visual services; 

3) other equipment costs (e.g., computer fees, telephone fees); 

4) printing and distribution; 

5) meals provided by the Department; 

6) refreshments provided by the Department; 

7) meals and incidental expenses for attendees (M&IE portion of per diem); 

8) lodging costs; 

9) transportation to/from conference location (e.g., common carrier, POV); 

10) local transportation (e.g., rental car, POV) at event location;
 

11) conference planners; 

12) conference facilitators; 

13) any other costs associated with the conference.
 

Any component wishing to hold a predominantly internal event at a non-federal facility that 

requires payment to that facility for the event (including any payment for meals, lodging, or 

other expenses related to the event) must obtain approval from the AAG/A before entering 

into a contract with such facility. See §8(b). Special approval is also required to hold such 

an event in certain locations. §8(b)(3). 

7. MEALS AND REFRESHMENTS. 

a.	 When permissible to provide. 

1)	 Federal Government Employees. Meals and/or refreshments51 may be paid for by the 

Department and provided to federal Government employees at conferences or training 

sessions where all three of the following are true: 

51 [Original Footnote 1] Note that the rules are the same regardless of whether the 

component is providing a meal or merely refreshments. 

84
 
 

a)	 the meals and refreshments are incidental to the conference or training; 

b)	 attendance at the meals and when refreshments are served is important for the host 

agency to ensure attendees' full participation in essential discussions, lectures, or 

speeches concerning the purpose of the conference or training; AND 

c)	 the meals and refreshments are part of a conference or training that includes not just 

the meals and refreshments and discussions, speeches, lectures, or other business that 

may take place when the meals and refreshments are served, but also includes 

substantial functions occurring separately from when the food is served. 

While as a general rule the Department does not pay for meals and/or refreshments for 

employees at their duty stations, if a conference or training meets the above criteria, 

meals and refreshments may be served to employees who are not on travel. With respect 

to Department employees who are on travel, they must deduct from their per diem the 

amount for each meal provided by the Department. 

2)	 Non-Federal Government Attendees. The Department can only pay for the meals and/or 

refreshments52 of non-federal attendees at conferences IF ONE of the following applies: 

a)	 The component has specific statutory authority permitting it (e.g., 42 U.S.C. §3788(f) 

for programs covered by the Omnibus Crime Control and Safe Streets Act; 42 

U.S.C.A. §3771 and note); 

b) The non-federal attendees qualify as individuals serving the Department pursuant to 5 

U.S.C. §5703;53 OR 

c) The expenses can be considered official reception and representation expenses (28 

U.S.C. §530C(b)(1)(D), and are counted towards the Department's Representation 

Fund limitations (see DOJ Order 2110.31 B). 

3) Charging Non-Federal Attendees. As discussed in §6(e), a private contractor (such as an 

external event planner, hotel, or other third party) can charge fees to non-federal 

attendees to cover the costs of such goods and services as meals and/or refreshments. 

The contractor must deal directly with the attendees to collect the fees for the meals 

and/or refreshments; the component must not be involved in any such collection. 

52 [Original Footnote 2] Note that the rules are the same regardless of whether the 

component is providing a meal or merely refreshments. 

53 [Original Footnote 3] Non-federal attendees who are provided any travel, lodging 

or meals and/or refreshments by the Department pursuant to 5 U.S.C. §5703 must be 

issued invitational travel orders. These are required even when a non-federal attendee is 

“local” to the conference and is only being provided meals and/or refreshments. 

85
 
 

b.	 Minimizing costs of meals and refreshments. Components (as well as contractors hired as 

conference or event planners) must adhere to the following cost thresholds, described further 

in Attachment B, for the costs of the meals and refreshments provided at the conference. 

1)	 Refreshments. Refreshments include light food and drink served at breaks, such as 

coffee, tea, milk, juice, soft drinks, donuts, bagels, fruit, pretzels, cookies, chips, or 

muffins. The cost of these items, plus any hotel service costs, cannot exceed 23% of the 

locality M&IE rate per person per day. For example, if the M&IE rate for a particular 

location is $54.00 per person per day, then the total refreshments costs cannot exceed 

$12.42 ($54.00 x 23%) per person per day. 

2)	 Meals. The cost of any meal provided, plus any hotel service costs, cannot exceed 150% 

of the locality M&IE rate per meal. For example, if dinner will be provided in a locality 

with a $49.00/day M&IE rate, the dinner rate in the locality is $24.00 per dinner. 

Therefore, the cost of the dinner provided at the conference cannot exceed $36.00 

($24.00 x 150%) per person. All Department employees attending the conference must 

ensure that the provided meal is deducted from their claimed M&IE; in this example the 

employee would deduct $24.00 from claimed M&IE for the provided dinner. 

3)	 Component Heads must request approval from the AAG/A to provide refreshments or 

meal costs that exceed these thresholds. See §8(d). 

8. SPECIAL APPROVALS. 

a.	 Use of Non-Federal Facilities for Predominantly Internal Events. 

1) Any component wishing to hold a predominantly internal event at a non-federal facility 

that requires payment to that facility for the event (including any payment for meals, 

lodging, or other expenses related to the event) must obtain approval from the AAG/A 

before entering into a contract with such facility. Such requests must be submitted by no 

lower than the management official responsible for approving the conference in the 

component and must be sent to the Director, Finance Staff, using the Conference 

Reporting and Non-federal Facility Request Center web site, 

http://10.173.2.12/jmd/fs/nfrc/index.htm. Any request for approval of a non-federal 

facility must include the following: 

a)	 Statement of the purpose of the training or conference meeting; 

b)	 Number of attendees and their organizations and duty stations (components must also 

indicate which, if any, of the attendees who are not Departmental employees will 

have their expenses paid for by the component); 

c) Frequency of the training or conference meeting and the date of the last such event, if 

applicable; 

d) Dates of the training or conference meeting; 

e) Location of the training or conference meeting (city/state) and reason(s) for choosing 

the location; 

86
 
f)	 Reason why a location where a federal facility is located was not considered, if 

applicable; 

g) List of federal and non-federal facilities considered; 

h) Estimated costs of using each of the federal and non-federal facilities considered, 

including all costs listed in §6(f) as determined by the market research, itemized and 

broken out by category; 

i) Reasons why the federal facilities did not meet the meeting's requirements, if 

applicable (refer to §6(f)); 

j) Justification for the use of a non-federal facility; and 

k) Gift acceptance approval, if required.
 

2) Approval for Certain Locations. Any request to hold a predominantly internal event in a 

non-federal facility in the following locations must be submitted by the Component 

Head, and this responsibility cannot be redelegated. 

a) Any location outside the continental United States (including Hawaii and Alaska); 

b) Any location known for gambling (e.g., Las Vegas, Nevada; Reno, Nevada; Atlantic 

City, New Jersey); 

c) Any location considered a tourist attraction or common vacation location (e.g., 

Disney World and Orlando, Florida; Niagara Falls, New York; Lake Tahoe); or 

d) Any resort facility or resort location (e.g., Hilton Head, South Carolina; Sonoma 

Valley, California). 

b.	 Large and/or Expensive conferences. The appropriate Component Procurement Chief must 

review and approve all conferences exceeding $500,000, or that will have over 500 attendees. 

Such approval must be in writing and submitted with the report required in §10(a). 

c.	 Meals and Refreshments Exceeding Thresholds. Component Heads must request approval 

from the AAG/A to provide meals and/or refreshments that exceed the cost thresholds 

described in §7(b). Component Heads must submit a memorandum to the AAG/A through 

JMD Finance Staff acknowledging that the proposed meals and refreshments exceed these 

thresholds and explaining why this is deemed necessary. This responsibility cannot be 

redelegated. When the conference at issue also requires a request to use a non-federal 

facility, this memorandum must be submitted with the non-federal facility request form. For 

all other events, the memorandum must be submitted to 

Conferences.and.Non-federal.Center@usdoj.gov. 

9. CONFERENCES HELD BY COOPERATIVE AGREEMENT RECIPIENTS. 

a.	 When to Use Cooperative Agreement. A cooperative agreement may not be chosen in order 

to avoid the statutory and regulatory requirements associated with the use of a contract. The 

decision to use a cooperative agreement, as opposed to a contract or grant, should be made in 

consultation with the component's legal counsel, applying the standards set forth in 

31 U.S.C. §6305, which, in general, authorizes the use of a cooperative agreement where the 

conference would carry out a public purpose of support or stimulation of outside entities, and 

substantial involvement by the Department is expected. Although the standards in §6305 

87
 
 

 

must govern the choice of vehicle, in determining if a conference would carry out such a 

public purpose (as opposed to merely providing a direct benefit to the Department or its 

employees), a significant factor is whether the primary beneficiaries of the conference are 

outside the federal Government. 

b.	 Cost Principles that Apply to Non-Profit Cooperative Agreement Recipients. 

1)	 Directives. Non-Profit cooperative agreement recipients must comply with the Uniform 

Administrative Requirements for Grants and Cooperative Agreements with Non-Profit 

Organizations (28 CFR Part 70), OMB Cost Principles Circular A-122, 2 C.F.R. 230, 

and, if applicable, the Office of Justice Programs Financial Guide, or any other 

component-specific guidance. According to A-122: “Costs of meetings and conferences, 

the primary purpose of which is the dissemination of technical information, are 

allowable. This includes costs of meals, transportation, rental of facilities, speakers' fees, 

and other items incidental to such meetings or conferences.” 

2)	 Reasonable Standard. The amount spent on conference costs is governed by the general 

principle that the costs be “reasonable,” which is further defined in OMB Circular A-122, 

Attachment A, paragraph 3. Furthermore, cooperative agreement recipients must comply 

with the travel guidelines at OMB Circular A-122, Attachment B, paragraph 51, and the 

OJP Financial Guide (if applicable), which require that if a recipient does not have a 

written travel policy, the recipient must abide by the rates and amounts established by the 

General Services Administration (GSA) in the Federal Travel Regulations, 41 C.F.R. ch. 

30l.54 

c.	 Required Special Condition For New Awards. All cooperative agreements that include 

holding a conference as a recipient responsibility must include the following special 

condition: 

“Within 45 days after the end of any conference, meeting, retreat, seminar, symposium, 

training activity. or similar event funded under this award, and the total cost of which 

exceeds $20,000 in award funds, the recipient must provide the program manager with the 

following information and itemized costs: 

1) name of event; 

2) event dates; 

3) location of event; 

4) number of federal attendees; 

5) number of non-federal attendees; 

6) costs of event space, including rooms for break-out sessions; 

7) costs of audio visual services; 

8) other equipment costs (e.g., computer fees, telephone fees); 

9) costs of printing and distribution; 

10) costs of meals provided during the event; 

54 [Original Footnote 4] GSA's regulations and per diem rates may be found at 

www.gsa.gov. 

88
 
11) costs of refreshments provided during the event; 

12) costs of event planner; 

13) costs of event facilitators; and
 

14) any other direct costs associated with the event.
 

The recipient must also itemize and report any of the following attendee (including 

participants, presenters, speakers) costs that are paid or reimbursed with cooperative 

agreement funds: 

1) meals and incidental expenses (M&IE portion of per diem); 

2) lodging; 

3) transportation to/from event location (e.g., common carrier, privately owned vehicle 

(POV)); and
 

4) local transportation (e.g., rental car, POV) at event location.
 

Note that if any item is paid for with registration fees, or any other non-award funding, then 

that portion of the expense does not need to be reported.” 

d.	 Information Gathered From Former or Existing Cooperative Agreement Recipients. 

Components are required to gather the specific information listed in section (c) from any 

cooperative agreement recipient that held a conference between October 1, 2007 and the 

present, and from any cooperative agreement recipient that holds a conference under the 

terms of an existing cooperative agreement. 

e.	 Review and Reporting. Each sponsoring component must review the itemized costs and 

clarify any of the reported information with the cooperative agreement recipient, as 

necessary. The component must also itemize all of the transportation costs, M&IE, per diem, 

and lodging costs paid by the component itself to send either its component employees or 

employees of another DOJ component to the event. The DOJ employee travel costs paid by 

the component should be added to each itemized category as well as the overall cost of the 

event. Within 45 calendar days following the close of each fisca1 quarter, the component 

shall submit a report on each conference costing more than $20,000 held by its cooperative 

agreement recipients, as described in §10(b). 

10. REPORTING. 

a.	 Quarterly Reporting of Conference Costs. The Attorney General is required to submit 

quarterly reports to the IG regarding the costs and contracting procedures relating to each 

conference held by the Department for which the total cost of the conference was more than 

$20,000. To facilitate this process, each office holding a conference as defined by §5(a) and 

costing more than $20,000, is required to submit the following information to the appropriate 

office within its component: 

1) a description of the purpose of each conference, the number of participants attending the 

conference, and how many were federal government employees; 

89
 
 

 

2)	 a detailed list of all costs categorized in §6(f), and any issues encountered in determining 

the costs related to that conference; and 

3) a description of the contracting procedures with respect to each contract relating to that 

conference, including: 

a) whether contracts were awarded on a competitive basis for that conference; and 

b) a discussion of any cost comparison conducted by the Department in evaluating 

potential contractors for that conference. 

No later than 45 calendar days following the close of each fiscal quarter, every component 

that has held a conference as defined by §5(a) during that quarter must submit a report, 

signed by the Component Head, which includes the above information for each such 

conference. The template at Attachment B should be used to compile the information and 

submit this report. The component must also submit any special approvals required by §8 

with this report. The report must be submitted to 

Conferences.and.Non-federal.Center@usdoj.gov. 

b. Quarterly Reporting on Cooperative Agreement Conferences. No later than 45 calendar days 

following the close of each fiscal quarter, every component that has held a conference as 

defined by §5(a), through the use of a cooperative agreement as described in §9 and costing 

more than $20,000, shall report on the event using the template at Attachment B. The report 

must be submitted to Conferences.and.Non-federal.Center@usdoj.gov. 

c.	 Quarterly Reporting on Use of Non-Federal Facilities for Predominantly Internal Events. 

Within 45 calendar days following the close of each fiscal quarter, every component that has 

held a predominantly internal event at a non-federal facility must submit a report, signed by 

the Component Head, to Conferences.and.Non-federal.Center@usdoj.gov. The template at 

Attachment B should be used to compile the information and submit this report. The report 

must highlight and explain any increases in costs above those submitted with the original 

request for approval. All market research data and cost analysis/actual cost information must 

remain on file with the component. 

11. QUESTIONS. Questions regarding these requirements may be directed to Lori Armold, 

Assistant Director, Financial Management Policies and Requirements Group, Finance Staff, on 

(202) 616-5216, or Melinda Jones, of her staff, on (202) 353-2527. 

Attachments 

90
 
[Attachment A] 

Activities Not Reported as Conferences under §10 (a) 

Activity Type 1: 

Law enforcement planning, staging, surveillance, undercover, or other meetings related to a law 

enforcement operation, and meetings to coordinate the Department's investigative, intelligence 

and/or prosecutorial efforts in connection with a pending case, specific criminal activity or a 

threat against the United States, including those that occur at law enforcement or security 

operational centers. 

Activity 

Meeting of attorneys to discuss a pending case 

Meeting of DOJ agents to discuss strategy in an ongoing hostage situation 

Activity Type 2: 

Training courses taught at federal training centers, such as the National Advocacy Center, the 

Federal Law Enforcement Training Center, the Federal Bureau of Investigation National 

Academy, and the Drug Enforcement Administration Training Academy. 

Activity Type 3: 

Undercover activities and training conducted in accordance with the Attorney General 's 

guidelines. 

Activity Type 4: 

Testing where the primary purpose of the event is to evaluate an applicant's qualifications to 

perform certain duties necessary to perform his or her job. In order for an event involving testing 

to be excluded from the reporting requirement, the majority of the event must be devoted to the 

administration and taking of the test. An event is not excluded from the reporting requirement if 

a test is incidental to the training course and is given upon its completion to determine 

satisfactory participation. 

Activity 

Quarterly Firearms Certification 

 

91
 
 

[Attachment A] 

(continued) 

Activities Reported as Conferences under §10(a) if over $20,000 

Activity Description 

OCDETF Financial Investigations Mandated seminar to learn financial 

Seminar investigative techniques of criminal enterprise 

Computer Analysis and Response Team Attendees meet to gain exposure to cross 

Moot Court examination from attorneys on cases they have 

investigated 

OIG Investigations Managers Conference Meeting of Senior Managers from within the 

Investigations Division 

Immigration Judge Training Immigration judges from across the U.S. gain 

training and participate in policy discussions 

Operational Medic Program Attendees are trained in order to comply with 

National Registry of Emergency Technicians 

national standards 

92
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Quarterly Report on Conference Costs

[Attachment B] 

 Component:

 Point of Contact:

 Telephone: 

 Email: 

Conferences/Events 

Conference Title: 

Event Type 

Non-Federal 

Facility 

Conference 

over $20,000 

Non-Federal 

Facility 

Conference 

over $20,000 

Non-Federal 

Facility 

Conference 

over $20,000 

Conference Data (Start & End) 

Facility Name 

City and State 

Number of Federal Attendees 

Number of non-Federal Attendees 

Total Number of Attendees 

Purpose of the Conference 

Conference Costs: 

Conference/Meeting Space (incld. 

Break out Room Cost) $0.00 $0.00 $0.00 

A/V Equipment & Services $0.00 $0.00 $0.00 

Other Equipment Costs $0.00 S0.00 $0.00 

Printing and Distribution $0.00 $0.00 $0.00 

Govt Provided Meals $0 00 $0.00 $0.00 

Refreshments $0.00 $0.00 $0.00 

M&IE $0.00 $0.00 $0.00 

Lodging $0.00 $0.00 $0.00 

Transportation $0.00 $0.00 $0.00 

Local Transportation $0.00 S0.00 $0.00 

Conference Planner $0.00 $0.00 $0.00 

Conference Facilitator $0.00 $0.00 $0.00 

Other Costs $0.00 $0.00 $0.00 

Total Conference Coat $0.00 $0.00 $0.00 

Average Cost per Attendee $0.00 $0.00 $0.00 

Describe any issue encountered in 

determining the cost related to the 

conference 1 

Description of contracting procedures 2 

For Events In Nonfederal Facilities Only 

Total Original Coat Estimate $0.00 $0.00 $0.00 

Variance (Actual vs. Estimated) $0.00 $0.00 $0.00 

Variance Justification 3 

: 

'Attach additional page to explain methodology if you are unable to capture costs as described in Policy XX or if any coats appear to be 

out of the ordinary.

2 

Attach additional pages to explain contracting procedures.

3 

Use Attachment C to provide a justification narrative for all events in which the actual coat exceeds the estimate, the justification needs 

to be itemized. 

93
 
 

 

 

 

 

 

 

 

 

 

 

 

 

[Attachment C] 

Non-federal Facility Event Variance Justification 

Conference Title: 

Conference Date: 

City and State: 

Conference Costs: Estimated Cost Reported Cost Variance Justification 1 

Conference/Meeting Space $0.00 $0.00 $0.00 

A/V Equipment & Services $0.00 $0.00 $0.00 

Other Equipment Costs $0.00 S0.00 $0.00 

Printing and Distribution $0.00 $0.00 $0.00 

Govt Provided Meals $0 00 $0.00 $0.00 

Refreshments $0.00 $0.00 $0.00 

M&IE $0.00 $0.00 $0.00 

Lodging $0.00 $0.00 $0.00 

Transportation $0.00 $0.00 $0.00 

Local Transportation $0.00 S0.00 $0.00 

Conference Planner $0.00 $0.00 $0.00 

Conference Facilitator $0.00 $0.00 $0.00 

Other Costs $0.00 $0.00 $0.00 

Total Conference Coat $0.00 $0.00 $0.00 

Conference Title: 

Conference Date: 

City and State: 

Conference Costs: Estimated Cost Reported Cost Variance Justification 1 

Conference/Meeting Space $0.00 $0.00 $0.00 

A/V Equipment & Services $0.00 $0.00 $0.00 

Other Equipment Costs $0.00 S0.00 $0.00 

Printing and Distribution $0.00 $0.00 $0.00 

Govt Provided Meals $0 00 $0.00 $0.00 

Refreshments $0.00 $0.00 $0.00 

M&IE $0.00 $0.00 $0.00 

Lodging $0.00 $0.00 $0.00 

Transportation $0.00 $0.00 $0.00 

Local Transportation $0.00 S0.00 $0.00 

Conference Planner $0.00 $0.00 $0.00 

Conference Facilitator $0.00 $0.00 $0.00 

Other Costs $0.00 $0.00 $0.00 

Total Conference Coat $0.00 $0.00 $0.00 

Attach additional pages to describe justification 

94 

1 
 

 

 

 

APPENDIX IV 

ASSISTANT ATTORNEY GENERAL FOR ADMINISTRATION 

MEMORANDUM SUMMARIZING CONFERENCE POLICY 

U.S. Department of Justice 

Justice Management Division 

Washington, D.C. 20530 

JUNE 5, 2008 

MEMORANDUM FOR COMPONENT HEADS 

FROM: Lee J. Lofthus 

Assistant Attorney General 

for Administration 

SUBJECT: Conference Planning, Conference Cost Reporting, and Approvals to Use 

 Non-federal Facilities 

Attached is Financial Management Policies and Procedures Bulletin (P&P) 08-08, Conference Planning, 

Conference Cost Reporting, and Approvals to Use Non-federal Facilities, which covers the new 

conference planning and reporting requirements. The prior Bulletin, Use of Non-federal Conference and 

Training Facilities, 06-12, has been rescinded and is combined with this policy. The attached Executive 

Summary explains the new requirements contained in this policy. The two primary goals of the new 

policy are to keep conference costs to a minimum and to ensure we can fulfill the statutory reporting 

requirements to Congress. In addition, I want to remind you of some considerations to help ensure your 

approval requests and reports are processed smoothly. 

	 Avoid locations and accommodations that give the appearance of being lavish or are resort 

destinations. Component Heads are required to submit written justification if the facility gives the 

appearance of being lavish or is a resort location. This cannot be re-delegated. 

 Ensure the selected lodging location is within per diem.
 

 Ensure the costs of meals and refreshments are within the prescribed limits.
 

 Ensure meals provided by the government are deducted from Meals and Incidentals Expenses 

(M&IE) claimed by all Department of Justice attendees (by meal). 

 Ensure that multiple facilities in multiple cities are compared when considering conference locations. 

 Ensure proper requests are submitted to the Justice Management Division in time to allow for 

appropriate review prior to your contract commitment. 

 Ensure that reporting of costs for all Non-federal Facility events and Conferences are submitted by 

Component Heads no later than 45 days following the close of each fiscal quarter. 

If you have questions, please let me know or your staff may contact Lori J. Armold, Assistant Director, 

Financial Management Policies and Requirements Group, on (202) 616-5216. 

95
 
[Attachment] 

Conference Planning, Conference Cost Reporting, and Approvals to Use
 

Non-federal Facilities Policy Executive Summary 

	 Consolidated Policy - The Conference Planning and Reporting has been combined with the Approvals 

to Use Non-federal Facilities Policy. Policy & Procedures Bulletin 06-12 has been rescinded. 

	 Conference Definition (Section 5a) - The conference definition is broad and includes the training 

activities. Exclusions are defined. 

	 Selecting a Location (Section 6f) - A location is comprised of both the city and the facility in which 

the conference will be held. 

	 Calculating Conference Costs (Section 6f) - Components are required to be able to report actual cost 

for 13 cost categories. 

	 Provided Meals and Refreshments (Section 7a) - Meals and refreshments may not be provided at 

government expense unless certain criteria is met. 

	 Minimizing costs of Meals and Refreshments (Section 7b) - Meals and refreshments must fall within 

established thresholds. 

	 Large Conferences (Section 8c) - The Component Procurement Chief must review and approve all 

conferences that exceed $500,000 or 500 attendees. 

	 Conferences held by Cooperative Agreement (Section 9) - Different planning and reporting (Section 

l0b) requirements are explained. 

	 Quarterly Reporting of Conference Costs (Section l0a) - Pursuant to Section 218 of the Consolidated 

Appropriations Act, Component Heads are required to report on all conferences exceeding $20,000. 

	 Reporting Deadline (Sections l0a, b, and c) - Reports are due 45 calendar days after the end of each 

fiscal quarter. 

	 Reporting on Events Held in Non-federal Facilities (Section 10c) - Component Heads are required to 

prepare a consolidated quarterly report of all events held in a non-federal facility rather than report 

after each event. 

	 New Email Inbox - All non-federal facility requests and reports and conference reports must be sent 

to the new address entitled Conferences.and.Non-federal.Center@usdoj.gov. The previous email 

address, Non-fed.Facility.Reguest.Center@usdoj.gov, has been deactivated. 

We understand that some components want to provide meals and refreshments to non-federal attendees 

and object to the requirement that they may be provided only under certain conditions. The Office of 

Legal Counsel recently reviewed their opinion in light of these concerns yet concluded there is no basis 

for overturning their original conclusion. 

[Note: June 5, 2008 Memorandum attached policy included at Appendix III] 

96
 
 

 

APPENDIX V 

DEPUTY ATTORNEY GENERAL MEMORANDUM 

U.S. Department of Justice 

Office of the Deputy Attorney General 

Washington, D.C. 20530 

May 4, 2009 

MEMORANDUM FOR HEADS OF DEPARTMENT COMPONENTS 

FROM:	 David W. Ogden 

Deputy Attorney General 

SUBJECT: Conference and Premium Class Travel Expenditures 

As the Department of Justice works to accomplish its vital mission on a daily basis, we must also 

make certain we do so with a focus on accountability and transparency to the American taxpayers. As 

Department leadership, we must ensure that our financial resources are utilized in the most advantageous 

and responsible manner. I am writing to highlight two areas of significant fiscal importance that receive 

significant attention from the Department's Office of the Inspector General, Congressional oversight 

offices, and the Governmental Accountability Office. Component Heads must ensure that adequate 

internal controls exist in these areas and authorizing officials are focused on their individual 

responsibilities. 

Conferences: The Department spent over $47 million on conferences and training events in fiscal 

year 2008. Section 218 of the Department of Justice Appropriations Act, 2008 (Title II, Division B, 

Public Law 110-161), requires the Attorney General to submit quarterly reports to the Inspector 

General regarding the costs and contracting procedures for each conference held by the Department 

for which the cost to the government exceeds $20,000. Justice Management Division (JMD) Financial 

Management Policies and Procedures Bulletin (P&P) 08-08, Conference Planning, Conference Cost 

Reporting, and Approvals to Use Non-federal Facilities includes guidance for keeping conference 

costs to a minimum and avoiding potentially extravagant locations, along with ensuring the 

Department can fulfill the statutory reporting requirements. Important aspects of that policy that must 

be followed include: 

	 Conference locations are to be selected based on business need and minimization of travel and 

other costs. 

	 Locations and accommodations should not be selected based on their lavish or resort qualities. 

Component Heads are required to submit a written justification in advance if a proposed facility 

gives the appearance of being lavish or is a resort location. The Component Head approval cannot 

be re-delegated. 

97
 
 

 

 

Memorandum for Heads of Department Components Page 2 

Subject: Conference and Premium Class Travel Expenditures 

	 Components must restrict the number of people traveling to conferences to the minimum 

necessary to accomplish the official purpose. 

 Ensure the selected lodging location is within per diem rates. 

 Meals should be provided on an infrequent basis and only as a working meal when necessary to 

accomplish the purpose of the event. Refreshments should be kept to an absolute minimum. 

Grant making organizations should instruct grant recipients that Department grant funding is not 

to be used for lavish food, refreshments, or entertainment purposes. 

 Ensure that travelers are aware of their responsibility to reduce per diem when meals are provided 

at the conference. 

 Ensure that reporting of costs for all non-federal facility events and conferences are submitted by 

Component Heads no later than 45 days following the close of each fiscal quarter. 

Premium Class Travel: The Federal Travel Regulations (FTR) require travel be accomplished by
 

the means most advantageous to the government. For airfare, that means using government contract 

coach fares unless certain circumstances make it absolutely necessary to use higher cost premium
 

class fares. In response to January 2008 guidance from the Office of Management and Budget, the 

JMD issued P&P 08-07, Use of Premium Class Travel Accommodations. Important aspects of the 

policy include: 

 Premium class travel includes both business and first class accommodations. 

 Premium class travel must be authorized by the Component Head or Principal Deputy.
 

 Premium class travel must be authorized on a case by case basis with an acceptable justification 

as stated in the FTR. The justification must be documented on the travel authorization. 

	 Business class travel justified on the basis of the 14-hour rule must demonstrate mission criteria 

and why coach travel, with or without a rest stop or rest period en route, cannot accomplish the 

official purpose for the travel. The 14-hour rule may not be used as a justification for first class 

travel 

In closing, I want to emphasize the need to maximize our financial resources, ensure we are prudent 

in our spending, and avoid the fact or appearance of extravagant spending, especially during these 

challenging financial times. 

98
 
 

APPENDIX VI 

ATTORNEY GENERAL MEMORANDUM 

January 21, 2011 

MEMORANDUM FOR HEADS OF DEPARTMENT COMPONENTS 

AND UNITED STATES ATTORNEYS 

FROM: THE ATTORNEY GENERAL 

SUBJECT: Temporary Freeze of Hiring and Non-Essential Spending 

The Department is currently operating under a Continuing Resolution (CR) through March 4, 

2011, with funding under the CR limited to last fiscal year's budget level. While we do not yet know 

what action will be taken to fund the Department for the remainder of the year, there is a realistic 

prospect that we will have to operate the entire year at last year's levels despite the higher cost of our 

staffing and operations this year. Accordingly, I am ordering a Department-wide temporary freeze 

on hiring. I am also ordering reductions to non-personnel spending. 

The actions I am taking, including the general freeze on hiring, are designed to keep the 

Department operating effectively within constrained funding levels. They will also help us avoid 

more severe measures such as employee furloughs. I am fully aware of the difficult situation this 

creates for your operations and that many important activities will be curtailed. Nonetheless, we 

must take these actions to maintain our essential public safety responsibilities and meet our 

responsibility to ensure our financial solvency and accountability. 

Temporary Hiring Freeze 

Effective immediately, I am directing a temporary freeze on all new hiring in all DOJ 

Components. The following conditions will apply: 

1. Written commitments formally issued by your component's servicing human resources office 

on or before the date of this memorandum will be honored. 

2. Hiring for agents, deputy U.S. Marshals, intelligence analysts, and correctional officers is 

frozen, but essential backfills in these position categories, not to exceed current staffing 

levels or available funding, are authorized to maintain public safety and national security 

protections. Current staffing levels are defined as positions filled as of the pay period ending 

January 1, 2011 . 

3. Attorney General Honors Program (HP) and Summer Legal Intern Program (SLIP) 

commitments already built into this current budget cycle will be honored. 

4. Hiring in the Working Capital Fund is frozen. Hiring in non-appropriated (e.g., fee-based) 

accounts is permitted subject to funding availability. Hiring with funding from reimbursable 

resources is subject to the same freeze restrictions as hiring with direct funding. 

99
 
 

5. Career ladder promotions are not subject to the freeze. 

6. Position changes within a component are not subject to the freeze since internal hires without 

backfill do not increase overall staffing levels, but any such changes must be within a 

component's available funding. 

7. Conversion of personnel in career trainee/intern programs into permanent appointments (e.g., 

conversion of Federal Career Intern participants, Presidential Management Fellows) are 

allowed. 

8. Other personnel actions that are not impacted by the freeze include non-competitive 

temporary promotions not to exceed 120 days, within grade increases, payroll corrections, 

retirements, voluntary early retirements, voluntary separation incentive payments, and 

disciplinary/adverse actions. 

There may be hiring circumstances affected by external entities, e.g., the Merit Systems 

Protection Board, the Equal Employment Opportunity Commission, etc. Similarly, there may be 

hiring actions resulting from formal Reemployment Priority List actions. Consult the Justice 

Management Division (JMD) Human Resources Staff for guidance in these special circumstances. 

I will consider a very limited number of exemptions from the freeze for individual positions, in 

extraordinary circumstances and on a case-by-case basis. Requests must include the position 

description and a justification regarding the critical need to fill the position, impact on mission if left 

unfilled, and why current staff levels are not sufficient to fulfill the duties during the hiring freeze. 

The request should also include confirmation that your component has available funding for the hire. 

Please submit exemption requests to the JMD Deputy Assistant Attorney General/Controller. 

Non-Personnel Expenses 

Also effective immediately and continuing through the remainder of FY 2011, components 

should suspend all non-essential travel, training, and conferences. The number of Department 

attendees at all conferences must be minimized. Component expenditures across the board - e.g., 

vehicles, employee permanent change-of-station moves, information technology (IT) projects, 

equipment, supplies, contracts - should be held to essential needs. Given the difficult funding 

environment, your reductions to non-personnel expenditures will help ensure you have the necessary 

funds for staff and essential operations. 

Components are to manage their operations within apportioned budget authority. Component 

full year operating plans should be formulated in a manner that avoids any reliance on staff furloughs 

in order to maintain solvency. 

We anticipate revisiting the freeze and the other measures discussed above once we have a better 

understanding of our full year funding situation; however, all restrictions described herein will 

remain in effect until further notice. For questions regarding these subjects, please contact Lee 

Lofthus, Assistant Attorney General for Administration, on 202-514-3101. 

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APPENDIX VII 

JUSTICE MANAGEMENT DIVISION 

RESPONSE TO THE DRAFT REPORT 

U.S. Department of Justice 

Justice Management Division 

Washington, D.C. 20530 

September 12, 2011 

MEMORANDUM FOR CYNTHIA SCHNEDAR

 ACTING INSPECTOR GENERAL 

FROM: 

/s/ 

Lee J. Lofthus 

 Assistant Attorney General 

 for Administration 

SUBJECT: Response to the Office of the Inspector General’s Draft Audit Report: Department 

of Justice Conference Planning and Food and Beverage Costs 

This responds to the Office of the Inspector General’s (OIG) draft audit report: Department of 

Justice Conference Planning and Food and Beverage Costs. The OIG recommendation numbers 

1 and 9 were addressed to the Justice Management Division and our responses to those 

recommendations are presented below. Recommendations 2, 3, 4 and 10 were addressed to the 

Office of Justice Programs (OJP) & the Office on Violence Against Women (OVW), and 

recommendations 5, 6, 7, and 8 were addressed solely to the OJP. The OJP and OVW provided 

separate memorandums to the OIG responding to the recommendations addressed to their 

component, thus JMD is not providing specific additional responses to these recommendations. 

JMD believes an important first step is that OJP and OVW have implemented the Departmental 

meal and refreshment thresholds for FY 2011 agreements and is optimistic that it will further 

ensure that conference costs are reasonable. 

Recommendation 1: Work in cooperation with OJP, the OVW, and other awarding components 

to ensure that conference cost reports include all salaries, benefits, and other costs charged to the 

government by all associated funding recipients. 

Response: The JMD concurs with the recommendation. JMD will continue to work with the 

Department’s awarding components to ensure all award recipients submit complete and accurate 

cost reports and include all salaries, benefits, and other costs charged to the government by the 

101
 
 

 

award recipients. In addition, by October 31, 2011, JMD will review the current conference 

policy to determine if there are any revisions necessary related to reporting requirements for 

award recipients. 

Recommendation 9: Require that components and their event planners conduct a cost-benefit 

analysis whenever they justify ordering food and beverages to obtain free meeting space for their 

conferences. 

Response: The JMD concurs with the recommendation. By October 31, 2011, JMD will issue 

guidance to the Department components requiring them to conduct a cost-benefit analysis 

whenever they justify ordering food and beverages to obtain free meeting space. Also by 

October 31, 2011, JMD will review the current conference policy to determine if there are any 

revisions necessary related to conducting cost-benefit analysis. 

If you have any questions on this subject, please have your staff contact Melinda Morgan, 

Director, JMD Finance Staff, on (202) 616-5809, or Christopher Alvarez, Deputy Director, JMD 

Finance Staff, on (202) 616-5234. 

cc: Raymond J. Beaudet 

Assistant Inspector General for Audit 

Office of the Inspector General 

Troy M. Meyer 

Regional Audit Manager 

Washington Regional Audit Office 

Offices of the Inspector General 

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APPENDIX VIII 

OFFICE OF JUSTICE PROGRAMS 

RESPONSE TO THE DRAFT REPORT 

U.S. Department of Justice 

Office of Justice Programs 

Washington, D.C. 20531 

August 31, 2011 

MEMORANDUM TO: Cynthia A. Schnedar 

Acting Inspector General 

United States Department of Justice 

THROUGH: Raymond J. Beaudet 

 Assistant Inspector General for Audit 

 Office of the Inspector General 

 United States Department of Justice 

FROM: 

/s/ 

 Laurie O. Robinson 

Assistant Attorney General 

SUBJECT: Response to the Office of the Inspector General’s Draft Audit 

Report, Department of Justice Conference Planning and Food 

and Beverage Costs 

This memorandum provides a response to the Office of the Inspector General’s (OIG’s) 

August 12, 2011 draft audit report, entitled Department of Justice Conference Planning and 

Food and Beverage Costs. The Office of Justice Programs (OJP) appreciates the opportunity to 

review and comment on the draft report. 

While OJP generally concurs with the recommendations and language included in this draft audit 

report, we believe that clarification is needed with regard to grantees selected by OJP to conduct 

conferences for the benefit of practitioners in the field. Specifically, OJP believes that applying 

the term “external event planner” to such grantees is misleading, as it understates the role of 

these organizations. OJP grantees are more than just event planners. These grantees are selected 

for their substantive, programmatic knowledge and expertise; and for their ability to develop a 

comprehensive training agenda that is evidence-based, and which focuses on building 

practitioners’ skills in criminal and tribal justice systems, and responding to victims’ needs. 

103
 
 

Further, when the training focuses on Indian Country, the amount of substantive knowledge 

required is even greater. Expertise in tribal culture, traditions, justice systems, and a myriad of 

jurisdictional issues that typically attach to victimization of American Indians/Alaskan Natives 

(AI/AN) is essential. 

The draft audit report contains 10 recommendations and $134,432 in questioned costs, of which 

Recommendation Numbers 2-8 and 10, and $134,432 in questioned costs pertains to OJP. For 

ease of review, these recommendations are restated in bold and are followed by OJP’s response. 

2.	 We recommend that OJP and OVW require that award recipients using DOJ funds 

to plan conferences track time and activities performed to plan conferences. 

The Office of Justice Programs agrees with the recommendation. By September 30, 2011, 

OJP will update its policies and procedures to require that award recipients, involved in 

planning OJP conferences, separately track time and activities related to conference 

planning. The Office of Justice Programs considers this recommendation resolved and 

requests written acceptance of this action from your office. 

3.	 We recommend that OJP and OVW update guidance provided to award recipients 

to ensure that recipients report all costs associated with time spent planning 

conferences, including salaries and benefits. 

The Office of Justice Programs agrees with the recommendation. By September 30, 2011, 

OJP will update its policies and procedures to require that award recipients, involved in 

planning OJP conferences, separately track and report all costs associated with 

conference planning, including salaries and benefits. The Office of Justice Programs 

considers this recommendation resolved and requests written acceptance of this action 

from your office. 

4.	 We recommend that OJP and OVW demonstrate that a training and technical 

assistance provider offers the most cost-effective logistical services before awarding 

a cooperative agreement that supports conference planning to such a firm. 

The Office of Justice Programs agrees with the recommendation. By December 31, 

2011, OJP will develop and implement a process for determining whether training and 

technical assistance providers offer the most cost-effective logistical services related to 

conference planning, prior to awarding cooperative agreements for this purpose. OJP 

will develop methods to evaluate the cost-effectiveness of the logistical component of 

these awards, which may include developing logistical services cost benchmarks, based 

upon past cooperative agreements and contracts data; or requiring award recipients, for 

certain types of conferences, to competitively bid the logistical services component of 

their awards. The Office of Justice Programs considers this recommendation resolved 

and requests written acceptance of this action from your office. 

104
 
 

5.	 We recommend that OJP remedy $3,454 in questioned costs, and ensure that event 

planners in the future attempt to minimize consultant travel costs, as applicable, by 

soliciting bids for sub-awards from entities that are closer to anticipated conference 

venues. 

The Office of Justice Programs agrees with the recommendation, and provides the 

following justification to support that the $3,454 in questioned travel costs are allowable 

under cooperative agreement number 2005-VR-GX-K001. OJP’s Office for Victims of 

Crime (OVC) conducted an in-depth review of all the facts associated with the $3,454 in 

questioned travel costs, associated with three separate trips the consultant billed to the 

cooperative agreement. OVC believes that executing the 2008 Indian Nations Conference 

required: 1) in-depth knowledge of the event location (including lodging and conference 

sites); 2) experience with Federal grant requirements; 3) substantive knowledge of Native 

American traditions and cultures; 4) expertise in multi-jurisdictional issues associated 

with crime in tribal communities; and 5) an overall understanding of the unique 

challenges that Alaska Natives face. The consultant selected was based in Anchorage, 

Alaska. Moreover, the following reasons support OVC’s decision to approve the hiring 

of the consultant in the event planner’s conference budget. 

	 The grantee indicated to OVC that the consultant was the only event planner who 

had the expertise and knowledge in all of the areas described above. 

Additionally, as the consultant had worked on earlier Indian Nations 

Conferences, they were able to assist the grantee in procuring lodging rates well 

below the government per diem rate. This resulted in substantial savings for 

conference attendees, including the grantee that paid the lodging costs of the 

trainers, and the various Federal agencies who sent employees to the conference. 

	 The grantee also had a branch office in Alaska. Several grantee employees in the 

Alaska office worked on the 2008 Indian Nations Conference with the contractor. 

As such, the grantee’s Alaska location was actually beneficial to the consultant’s 

overall effectiveness. The OIG report does not acknowledge the vital importance 

of including Alaska Native issues, Alaska Native presenters, and Alaska Native 

participants in the 2008 Indian Nations Conference. However, it should be noted 

that: (a) 229 of the 564 federally recognized tribes are located in Alaska; (b) 

many of the OVC tribal grantees (a primary target audience at the 2008 Indian 

Nations Conference) are located in Alaska. For example five of the 23 OVC 

Native American Children’s Justice Act (CJA) grantees were located in Alaska at 

the time of the conference; (c) presenters for 11 of the 60 conference workshops 

were located in Alaska; and (d) 75 of the 750 total conference participants were 

from Alaska. 

	 Finally, OVC determined that it was very important that the conference event 

planner be familiar with Alaska-specific issues, including unique Alaska travel 

issues. 

105
 
OJP believes that the grantee would have had to spend substantially more money to 

obtain similar services from a local event planner. The consultant was hired under a firm 

fixed-price contract, which provided substantial cost-savings for OVC. Based on the 

cost of living in the Los Angeles area, the overall cost for hiring a consultant would have 

been much greater than in Alaska. Further, the number of people in the Los Angeles area 

with the necessary skills and knowledge – especially the necessary Indian country 

knowledge and experience, including the specific knowledge and experience of Alaska 

Natives – was extremely limited. As a result, OJP believes that the $3,454 in questioned 

travel costs were reasonable, necessary, and allowable under cooperative agreement 

number 2005-VR-GX-K001. Accordingly, the Office of Justice Programs requests 

closure of the $3,454 in questioned costs associated with this recommendation. 

Additionally, the Office of Justice Programs agrees that appropriate procedures should be 

implemented to ensure that event planners minimize future consultant travel costs, as 

applicable, by soliciting bids for sub-awards from entities that are closer to anticipated 

conference venues. As such, by September 30, 2011, OJP will update its policies and 

procedures to require that event planners attempt to minimize consultant travel costs, by 

soliciting bids for sub-awards from entities that are closer to anticipated conference 

venues. The Office of Justice Programs considers this recommendation resolved and 

requests written acceptance of this action from your office. 

6.	 We recommend that OJP remedy $29,365 by justifying the need for costs associated 

with travel, lodging, and food and beverages for attendees at this planning meeting. 

The Office of Justice Programs agrees with the recommendation, and provides the 

following justification to support OVC’s approval of the $29,365 in travel, lodging, and 

food and beverage costs, charged to cooperative agreement number 2005-VR-GX-K001, 

for attendees at the pre-planning meeting for the 2008 Indian Nations Conference. 

The grantee conducted an in-person planning meeting at the direction of OVC. Although 

the grantee provided input, the OVC Director made the final decision, which included: 1) 

directing the grantee to hold the meeting; 2) selecting the attendees for the meeting; and 

3) authorizing the expenses for the meeting. 

In order to produce the most effective conference that also effectively addressed the 

myriad of complex jurisdictional issues, OVC determined that it was essential to bring 

together a proven group of experts in this field. This group considered earlier Indian 

Nations Conferences’ reports, agendas, and evaluations to craft effective training 

sessions. The planners also used this session to identify a list of proven, experienced 

trainers for the conference. Finally, the planners made critical decisions on training 

formats (i.e., lectures, plenary sessions, and workshops) and the conference agenda. The 

conference agenda was designed to meet gaps and the needs expressed by service 

providers, while the session formats were designed to produce the greatest level of 

understanding and applicability for attendees. Without the vast experience of these 

planners, the grantee’s and OVC’s planning efforts would have been severely 

constrained. 

106
 
 

 

Further, as part of its conference planning process, OVC typically requires an initial inperson, intensive planning meeting. Neither OVC, nor most tribal organizations, had 

video-conferencing capacity at the time of the meeting. Therefore, at a minimum, trying 

to conduct a planning meeting by phone for two full days would not have been effective. 

OVC believes that the planning meeting served as the foundation for a highly successful 

conference. As a result, OJP believes that the $29,365 in questioned travel, lodging, and 

food and beverage costs were reasonable, necessary, and allowable under cooperative 

agreement number 2005-VR-GX-K001. Accordingly, the Office of Justice Programs 

requests closure of this recommendation. 

7.	 We recommend that OJP ensure that external event planners justify the need for 

travel, lodging, and food and beverage costs associated with future conference 

planning meetings. 

The Office of Justice Programs agrees with the recommendation. By September 30, 

2011, OJP will update its policies and procedures to require that external event planners 

justify the need for travel, lodging, and food and beverage costs associated with future 

conference planning meetings. The Office of Justice Programs considers this 

recommendation resolved and requests written acceptance of this action from your office. 

8.	 We recommend that OJP remedy $102,622 in questioned costs and work with the 

event planner to approve a future indirect cost rate or allocation plan. 

The Office of Justice Programs agrees with the recommendation. We will coordinate 

with the grantee to remedy the $102,622 in questioned costs related to unapproved 

indirect costs associated with cooperative agreement number 2005-VR-GX-K001. If the 

costs are determined to be unallowable, we will request that the grantee return the funds 

to the DOJ, and submit a revised final Federal Financial Report for the agreement. The 

Office of Justice Programs considers this recommendation resolved and requests written 

acceptance of this action from your office. 

10. We recommend that OJP and the OVW establish and implement guidelines on 

conference food and beverage limits for conferences supported with cooperative 

agreement funds congruent with DOJ-wide rules. 

The Office of Justice Programs agrees with the recommendation. All cooperative 

agreements awarded during the fiscal year 2011 cycle, as well as future cooperative 

agreements, will include the following special condition: 

Conference Cost Limitations for Refreshments and Meals 

“Recipient understands and acknowledges that for purposes of this cooperative 

agreement, food and/or beverage expenses are deemed reasonable and allowable 

for training sessions, meetings, conferences, or other similar functions only to the 

extent that the: 1) break or other refreshment costs, plus any hotel service costs 

(e.g., labor cost for room setup), do not exceed 23 percent of the current General 

107
 
 

 

 

Services Administration (GSA) Meals and Incidental Expenses (M&IE) rate per 

attendee per day; and 2) the cost of any individual meal, plus any hotel service 

costs (e.g., labor cost for room setup), does not exceed 150 percent of the GSA 

M&IE rate for that meal in that locality per attendee. Current GSA M&IE rate 

breakdown by meal and by locality can be found at 

http://www.gsa.gov/portal/content/101518.” 

In addition, food and beverage guidance was expanded in the 2011 version of the OJP 

Financial Guide. The updated guidance is accessible on the web at 

http://www.ojp.usdoj.gov/financialguide/PostawardRequirements/chapter15page3.htm. 

Accordingly, the Office of Justice Programs requests closure of this recommendation. 

Thank you for your continued support and assistance. If you have any questions regarding this 

response, please contact Maureen A. Henneberg, Director, Office of Audit, Assessment, and 

Management, on (202) 616-3282. 

Attachments 

cc: Mary Lou Leary 

Principal Deputy Assistant Attorney General 

Phillip K. Merkle
 

Acting Deputy Assistant Attorney General 

 for Operations and Management 

Denise O’Donnell 

Director
 

Bureau of Justice Assistance 

Jeffrey W. Slowikowski 

Acting Administrator 

Office of Juvenile Justice and Delinquency Prevention

 Joye Frost 

Acting Director 

Office for Victims of Crime 

Linda M. Baldwin 

Director
 

Office of Sex Offender Sentencing, Monitoring, Apprehending, 

Registering, and Tracking 

Leigh Benda 

Chief Financial Officer
 

108
 
 

Maureen A. Henneberg 

Director 

Office of Audit, Assessment, and Management 

Jeffery A. Haley 

Deputy Director, Audit and Review Division 

Office of Audit, Assessment, and Management 

Louise M. Duhamel, Ph.D. 

Acting Assistant Director, Audit Liaison Group 

Justice Management Division 

Lee J. Lofthus 

Assistant Attorney General for Administration 

Justice Management Division 

Karol V. Mason 

Deputy Associate Attorney General 

Office of the Associate Attorney General 

OJP Executive Secretariat 

Control Number 20111510 

109
 
 

 

 

 

APPENDIX IX 

OFFICE ON VIOLENCE AGAINST WOMEN 

RESPONSE TO THE DRAFT REPORT 

U.S. Department of Justice 

Office on Violence Against Women 

Washington, D.C. 20530 

September 1, 2011 

MEMORANDUM 

TO: Troy M. Meyer

 Regional Audit Manager 

 Washington Regional Audit Office 

Office of the Inspector General 

FROM: 

/s/ 

Susan B. Carbon 

Director 

SUBJECT: Audit of Department of Justice Conference Planning and Food and Beverage 

Costs 

The Office on Violence Against Women (OVW) is providing this response to the above-titled 

audit. We will first provide a general response and then respond to the specific 

recommendations. 

General Discussion 

In general, OVW does not engage “event planners” or put on conferences. The conference 

discussed in the report was organized by the National Council of Juvenile and Family Court 

Judges (NCJFCJ) and the Family Violence Prevention Fund (FVPF) to train judges who handle 

domestic violence cases. The cooperative agreement for this conference was part of OVW’s 

Training and Technical Assistance initiative (TTA). Each year, OVW puts out a competitive 

solicitation for TTA, identifying the categories of grantees, the purpose areas for the grant 

programs, and the priority areas that OVW has identified in terms of needs for such training and 

assistance. Recipients are selected based on such factors as expertise in the subject matter, 

ability to carry out the training or technical assistance described, and the need for the project. 

The budget is also evaluated for cost-effectiveness. 

110
 
OVW’s use of cooperative agreements for its technical assistance awards was not an attempt to 

circumvent JMD’s 2008 policy revision. Since 1996, when the Office first began making 

training and technical assistance awards, it has consistently used cooperative agreements as the 

funding instrument. OVW selected the vehicle of a cooperative agreement rather than a grant 

due to the high degree of OVW involvement in these projects. However, as with a grant, a 

technical assistance project is the recipient’s project. In fact, all cooperative agreements, 

including the ones examined for this audit include the following special condition: 

All materials and publications (written, visual, or sound) resulting from award 

activities shall contain the following statements: "This project was supported by 

Grant No. 2006-WT-AX-K046 and 2008-TA-AX-K038 awarded by the Office on 

Violence Against Women, U.S. Department of Justice. The opinions, findings, 

conclusions, and recommendations expressed in this 

publication/program/exhibition are those of the author(s) and do not necessarily 

reflect the views of the Department of Justice, Office on Violence Against 

Women. 

Any materials produced for the judicial training institutes should have had this language, making 

it clear that this was not an OVW conference. 

Specific Recommendations 

OVW continues to be committed to policies and guidelines that ensure costs for conferences, 

trainings, and other events are kept as low as possible. Below are our responses to the specific 

recommendations in the report: 

I. External Event Planning 

OIG Recommendation Number 2: Require that award recipients using DOJ funds to 

plan conferences track time and activities performed to plan conferences. 

OVW will add a special condition to all cooperative agreements that include an element 

of conference planning requiring that they track time and activities for the logistics of 

their events separate from the substantive portion of the events. This special condition 

will apply to cooperative agreements funded under the FY2011 appropriations and later. 

OIG Recommendation Number 3: Update guidance provided to award recipients to 

ensure that recipients report all costs associated with time spent planning conferences, 

including salary and benefits. 

OVW will provide updated guidance that the conference reporting special condition 

includes reporting all costs associated with time spent planning conferences, including 

salary and benefits, and that the new condition will require them to track time and 

activities separate from activities spent on substantive matters of the cooperative 

agreement. 

111
 
In addition, OVW plans to address this issue at a November 14-16, 2011 meeting with its 

technical assistance providers. 

OIG Recommendation Number 4: Demonstrate that a training and technical assistance 

provider offers the most cost-effective logistical services before awarding a cooperative 

agreement that supports conference planning to such a firm. 

As discussed above, OVW is not awarding cooperative agreements for the purpose of 

conference planning but for a substantive training and technical assistance purpose. We 

do evaluate the cost-effectiveness of the proposals, but each recipient chooses the method 

for delivery of the technical assistance, whether through webinars, teleconferences or inperson and justifies that method. In addition, the recipient proposes how they will meet 

their logistical needs, whether through in-house support or through a sub-contract. 

Although cost-effectiveness is one factor, it is also important to weigh whether the 

provider is substantively qualified to provide the technical assistance that they are 

proposing, whether they will be able to reach the audience they plan to, and whether there 

is a need for the project. In this example, these organizations have a wealth of experience 

working with judges and on the subject matter and there is evidence of the harm that can 

come to victims when judges do not understand the complex dynamics of domestic 

violence. We have experienced over the years that judges learn best in person and from 

other judges, which is why this is an in person training. 

All solicitations, including TTA make it clear that we can negotiate budgets, including to 

reduce unnecessary costs. Part of our review of each application includes a 

comprehensive review of the budget to ensure, among other things that they are costeffective. We often reduce funding amounts to eliminate costs that are not cost-effective. 

II. Food and beverages 

OIG Recommendation 11: Establish and implement guidelines on conference food and 

beverage limits congruent with DOJ-wide rules for conferences supported with 

cooperative agreement funds. 

Beginning June 1, 2010, OVW’s own Grants Financial Management Division (GFMD) 

became operational and began reviewing the budgets for applications recommended for 

award, a task that previously had been performed by OJP’s OCFO. Starting with Fiscal 

Year 2010, GFMD completed OVW budget reviews and applied the JMD food and 

beverage rules to all cooperative agreements as well as making sure that the provision of 

food and beverages is linked to dissemination of technical information as required by 

Cost Principles for Nonprofit Organizations at 2 CFR Part 230, Appendix B. OVW is 

currently in the process of the final review and approval of its own Financial Guide, and 

it will be clear that the food and beverage guidelines apply to grants as well as 

cooperative agreements. 

To eliminate the possibility of any possible confusion about the application of the JMD 

food and beverage rules, OVW will add a new special condition mandating compliance 

112
 
with those rules to all technical assistance cooperative agreements awarded from FY 

2011 appropriations. 

Finally, at OVW’s upcoming meeting with its technical assistance providers, to be held 

November 14-16, 2011, OVW’s GFMD staff will provide training for these providers on 

how to implement cost-effective conference planning practices, including applying the 

JMD food and beverage rules. 

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APPENDIX X 

OFFICE OF THE INSPECTOR GENERAL 

ANALYSIS AND SUMMARY OF ACTIONS
 

NECESSARY TO CLOSE THE REPORT
 

The OIG provided a draft of this audit report to the Justice 

Management Division (JMD), which is responsible for implementing DOJ-wide 

financial policies, and the 9 components that sponsored the 10 conferences 

reviewed by this audit. We received responses from the three components 

that received report recommendations – JMD, the Office of Justice Programs 

(OJP), and the Office on Violence Against Women (OVW). The JMD response 

is incorporated in Appendix VII, the OJP response is incorporated in 

Appendix VIII, and the OVW response is incorporated in Appendix IX. 

The responses from OJP and the OVW addressed information in our 

report that did not pertain to our recommendations. The next two sections 

present our analysis first of OJP’s response and second of OVW’s response. 

The third section describes actions taken by JMD, OJP, and the OVW to 

address report recommendations. 

Analysis of OJP’s Response 

In its response, OJP stated that it believes a clarification is needed 

with regard to applying the term “external event planner” to award 

recipients that work to plan conferences and meetings. OJP highlighted that 

its award recipients were training and technical service providers and 

therefore “more than just event planners.” OJP stated that as a result, 

referring to these groups as “event planners” is misleading because such a 

designation understates both the role these organizations have as training 

and technical assistance providers and the substantive knowledge and 

programmatic expertise they maintain. 

This report stresses the important role of training and technical 

assistance providers and their focused programmatic expertise. 

Nevertheless, we remain concerned about OJP’s hiring of such organizations 

to perform the logistical services associated with hosting conferences, such 

as selecting venues and negotiating food, lodging, and meeting space prices 

with hotels, that do not require such programmatic expertise. We believe 

that efficient and effective logistical conference planning requires a different 

cohort of skills and specialties that may not be offered by training and 

technical service providers. Such skills include how best to: (1) negotiate 

low lodging and meeting space prices, (2) use technological solutions to 

114
 
minimize travel costs for planning purposes, and (3) ensure that possible 

locations have the infrastructure necessary (airports, hotels, and 

restaurants) to host a major event. 

In addition, the fact that training and technical assistance providers 

may be focused more on programmatic instead of logistical services is 

underscored by the disparate indirect rates these organizations charged OJP 

to provide logistical services. These indirect rates appeared geared to 

support programmatic functions, which traditionally require higher 

supporting costs, than logistical event planning services. As such, the report 

concludes that because OJP hired training and technical assistance providers 

to perform logistical conference planning without first ascertaining whether 

firms that specialized in event planning could have offered such services 

more cost effectively and at lower rates, OJP was not positioned to show 

that it minimized conference costs. 

Analysis of OVW’s Response 

In its response, the OVW stated that it does not engage with “event 

planners” or otherwise put on conferences. Rather, the OVW stated that 

even though the conference was funded through a cooperative agreement, it 

was organized by training and technical assistance providers selected 

following a competitive solicitation. The OVW also noted that it did not use 

cooperative agreements for its technical assistance awards to try to 

circumvent meal and refreshment cost limits. The OVW added that it 

included a special condition in its awards that “the opinions, findings, 

conclusions, and recommendations” of the event did not necessarily reflect 

its views. 

We note that the training and technical assistance providers served as 

the event planners because they performed both the logistical and 

programmatic aspects of the conference. Although our report does take 

issue with the expensive food and beverages served at the event, it does not 

dispute: (1) the method by which the OVW selected its training and 

technical assistance providers; (2) the programmatic purpose of the event or 

the use of cooperative agreements for programmatic planning; or (3) “the 

opinions, findings, conclusions, and recommendations” exchanged at the 

event. This is because such items were beyond the scope of this review. 

We note that the OVW response stated that the OVW decided to award 

the project via a cooperative agreement (instead of a grant or contract) due 

to the “high degree” of anticipated OVW involvement in the project. 

Because the conference was funded with OVW program funds, the OVW had 

an important responsibility to provide stewardship over how conference 

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funds were used regardless of whether or not it directly “put on” the 

conference. DOJ components using funds to sponsor conferences have a 

responsibility to: (1) minimize conference planning costs; and (2) ensure 

the food and beverages provided are incidental, reasonable, and only 

provided at work-related events. This responsibility, coupled with OVW’s 

stated “high degree” of involvement in the project, means that the OVW 

cannot absolve itself from how its program funds were used to pay for 

expensive food and beverages. 

Summary of Actions Necessary to Resolve and Close the Report 

1.	 Resolved. JMD concurred with our recommendation to work in 

cooperation with OJP, the OVW, and other awarding components to 

ensure that conference cost reports include all salaries, benefits, and 

other costs charged to the government by all associated funding 

recipients. JMD stated in its response that it will continue to work 

with DOJ awarding components to ensure all award recipients submit 

complete and accurate cost reports and include all salaries, benefits, 

and other costs charged to the government by the award recipients. 

JMD also stated that by October 31, 2011, it will review the current 

conference policy to determine if there are any revisions necessary 

related to reporting requirements for award recipients. 

This recommendation can be closed when: (1) we receive evidence 

that JMD has adequately worked with awarding components to 

ensure complete and accurate conference costs reports and (2) JMD 

provides evidence of a review of the current conference policy and 

documentation determining whether revisions are necessary. 

2.	 Resolved. OJP and the OVW concurred with our recommendation to 

require that award recipients using DOJ funds to plan conferences 

track the time and activities performed to plan conferences. OJP 

stated in its response that it will update its policies and procedures 

by September 30, 2011. The OVW stated in its response that it will 

add a special condition to its future cooperative agreements. 

This recommendation can be closed when we receive evidence that 

OJP and the OVW have developed and implemented these policies to 

ensure that award recipients track time and activities performed to 

plan conferences. 

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3.	 Resolved. OJP and the OVW concurred with our recommendation to 

update guidance provided to award recipients to ensure that 

recipients report all costs associated with time spent planning 

conferences, including salaries and benefits. OJP stated in its 

response that it will update its policies and procedures by 

September 30, 2011. The OVW stated in its response that it will 

provide updated guidance, which it plans to address at a November 

2011 meeting with its technical assistance providers. 

This recommendation can be closed when we receive evidence that 

OJP and the OVW have updated guidance to ensure that award 

recipients report all costs associated with time spent planning 

conferences. 

4.	 Unresolved. We recommended that OJP and the OVW demonstrate 

that a training and technical assistance provider offers the most costeffective logistical services before awarding a cooperative agreement 

that supports conference planning to such a firm. This 

recommendation is resolved with regard to OJP, but is unresolved 

with regard to the OVW. 

OJP concurred with our recommendation and stated that it will 

develop and implement a process to evaluate the cost-effectiveness 

of these logistical services by December 31, 2011. 

The OVW did not concur with this recommendation. Instead, the 

OVW stated that although it evaluates the cost-effectiveness of 

training and technical assistance proposals, the recipient chooses the 

method by which it delivers the technical assistance. The OVW 

added that the recipient also proposes how it will meet the 

conference’s logistical needs, whether through in-house support or 

through a sub-contract. Overall, the OVW stated that it is important 

to weigh whether the provider is substantively qualified to provide 

the technical assistance and emphasized that its cooperative 

agreements are awarded for a substantive training and technical 

assistance purpose rather than for conference planning purposes. 

Our report does not discredit the importance of using cooperative 

agreements as a vehicle to support programs needing the highly 

specialized subject-matter expertise of these training and technical 

assistance providers. We further do not question the programmaticbased funding provided to such firms. However, as stated 

previously, we are concerned with the cost-effectiveness of having 

training and technical assistance providers also offer logistical 

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conference planning services such as selecting venues and 

negotiating of meal and refreshment costs. The report found that 

training and technical assistance providers charge high indirect cost 

rates, which are based on maintaining the specialized services 

provided by training and technical service providers. Such skills are 

not, in our opinion, necessary to provide efficient and effective 

logistical event planning services. 

Moreover, although the OVW stated that it is the responsibility of the 

recipient to decide how to meet its logistical needs, as the awarding 

agency, the OVW must be responsible for its funding and ensure it is 

used in a cost-effective manner. As such, the report recommends 

that the OVW evaluate the cost-effectiveness of using training and 

technical assistance providers to perform logistical services before 

awarding cooperative agreements to such firms. 

Therefore, although this recommendation is resolved with regard to 

OJP, it is unresolved with regard to the OVW. The OVW can resolve 

this recommendation when we receive evidence that it agrees to 

assess the cost-effectiveness of using training and technical 

assistance providers to provide logistical event planning services. 

With regard to OJP, this recommendation can be closed when we 

receive evidence that OJP has adequately implemented procedures to 

evaluate the cost-effectiveness of logistical services before awarding 

cooperative agreements to such firms. 

5. Resolved. OJP concurred with our recommendation to remedy 

$3,454 in questioned costs and ensure that event planners in the 

future attempt to minimize consultant travel costs, as applicable, by 

soliciting bids for sub-awards from entities that are closer to 

anticipated conference venues. OJP stated that it will update its 

policies and procedures to require that event planners attempt to 

minimize consultant travel costs by September 30, 2011. The policy 

will require that event planners solicit bids for sub-awards from 

entities that are closer to anticipated conference venues. 

However, OJP stated in its response that the $3,454 in questioned 

travel costs were reasonable, necessary, and allowable under 

cooperative agreement number 2005-VR-GX-K001. OJP reported 

that the award recipient executing the 2008 Indian Nations 

Conference required: (1) in-depth knowledge of the event location 

(including lodging and conference sites), (2) experience with Federal 

grant requirements; (3) substantive knowledge of Native American 

traditions and cultures, (4) expertise in multi-jurisdictional issues 

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associated with crime in tribal communities, and (5) an overall 

understanding of the unique challenges that Alaska Natives face. 

According to OJP, the award recipient indicated that the consultant 

(who resided in Anchorage, Alaska) was the only event planner who 

had the expertise and knowledge in all of the areas described above. 

Because the consultant had worked on earlier Indian Nations 

Conferences, OJP stated that the consultant was able to negotiate 

lodging rates well below the government per diem rate from the 

venue, which resulted in substantial savings. OJP also stated that it 

believed that the award recipient would have had to spend 

substantially more money to obtain similar services from a consultant 

that lived closer to the venue (in the Los Angeles area) due to the 

high cost of living in Los Angeles and that number of people in the 

Los Angeles area with the necessary skills and knowledge was 

extremely limited. 

OJP’s response also stressed the major role that Alaska Native 

issues, presenters, and participants had in the 2008 Indian Nations 

Conference. OJP noted that 229 of the 564 federally recognized 

tribes are located in Alaska. In addition, many of the Office of 

Victims of Crime tribal grantees (a primary target audience of the 

2008 Indian Nations Conference) are located in Alaska. 

Our report does not dispute that the consultant maintained the skills 

OJP says were required to provide logistical services for the event. 

Instead, the report questions: (1) why the award recipient hired a 

consultant that lived in Anchorage, Alaska, to help plan a conference 

it knew was to be held in Palm Springs, California; and (2) the need 

of the consultant to travel three times from Alaska to California. The 

aforementioned reasons offered by OJP do not justify or address 

either of these concerns. In addition, because the consultant had 

knowledge of the hotel from prior conferences, we believe that the 

consultant should not have needed to travel to Palm Springs, 

California three times to perform the logistical services under the 

sub-agreement. 

In addition, the consultant was hired under a firm-fixed price 

agreement and the award recipient did not openly solicit applications 

from others to procure this consultant. An open solicitation would 

have provided an opportunity for all interested parties to apply for 

the sub-award. Because of this, neither OJP nor the award recipient 

can affirmatively demonstrate that: (1) the consultant was the only 

entity that had the experience required; and (2) no other entity 

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closer to the venue, regardless of whether the entity was in the Los 

Angeles area or Alaska, would have had comparable experience. 

According to documents received from the award recipient, the 

primary responsibility of the hired consultant was to serve as a “hotel 

liaison” and provide logistical conference planning services. 

Considering the role maintained by the primary award recipient, OVW 

has not demonstrated why substantive knowledge of Alaska Native 

traditions and cultures, expertise in multi-jurisdictional issues 

associated with crime in tribal communities, and an overall 

understanding of the unique challenges that Alaska Natives face were 

necessary requirements for the consultant. Even if these 

requirements are prerequisites, the fact that the consultant met them 

does not justify that the consultant took three trips from Anchorage, 

Alaska, to Palm Springs, California, to perform pre-conference 

logistical services. 

This recommendation can therefore be closed when OJP: 

(1) remedies the $3,454 in questioned costs, and (2) provides 

evidence that policies and procedures have been updated to require 

that event planners attempt to minimize consultant travel costs by 

soliciting bids for sub-awards from entities that are closer to 

anticipated conference venues. 

6. Resolved. OJP concurred with our recommendation to remedy 

$29,365 by justifying the need for costs associated with travel, 

lodging, and food and beverages for attendees at this planning 

meeting. OJP stated in its response that $29,365 in travel, lodging, 

and food and beverage costs, charged to cooperative agreement 

number 2005-VR-GX-K001, for attendees at the pre-planning 

meeting for the 2008 Indian Nations Conference were reasonable, 

necessary, and allowable, and it provided justifications for the costs. 

OJP reported that to produce the most effective conference that 

addressed the myriad of complex jurisdictional issues, OJP 

determined that it was essential to bring together a proven group of 

experts with vast experience. OJP also reported that its Office for 

Victims of Crime (OVC) typically requires an initial in-person, 

intensive planning meeting and neither OVC, nor most tribal 

organizations, had adequate video-conferencing capacities at the 

time of the meeting. Because OVC believed that trying to conduct a 

2-day planning meeting by phone would be ineffective, OJP stated 

that the Director of OVC asked the grantee to hold the planning 

meeting, selected its attendees, and authorized its expenses. 

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The audit report stresses that planning meetings with responsible 

officials and experts represent important opportunities for sponsoring 

components to gauge the conference’s potential programmatic 

success. However, given that this was the 11th time this conference 

occurred and at least the third time this conference was located at 

the same venue, we do not believe that such an extensive in-person 

meeting in Palm Springs, California, was necessary. While 

technology solutions may have been unavailable at the time, we do 

not believe that having the planning meeting in Palm Springs in 

January and February, incurring expensive travel costs, and 

providing food and beverages was necessary to accomplish program 

objectives. Therefore, we do not believe that this information 

adequately justifies the award recipient spending $29,365 on travel, 

lodging, and food and beverage costs for the planning meeting. 

As a result, this recommendation can be closed when we receive 

evidence that OJP has remedied the $29,365 in questioned costs. 

7. Resolved. OJP concurred with our recommendation to ensure that 

external event planners justify the need for travel, lodging, and food 

and beverage costs associated with future conference planning 

meetings. OJP stated in its response that by September 30, 2011, it 

will update its policies and procedures to require that external event 

planners justify the need for travel, lodging, and food and beverage 

costs associated with future conference planning meetings. 

This recommendation can be closed when we receive evidence that 

OJP’s policies and procedures have been updated to require that 

external event planners justify the need for travel, lodging, and food 

and beverage costs associated with future conference planning 

meetings. 

8. Resolved. OJP concurred with our recommendation to remedy 

$102,622 in questioned costs related to unapproved indirect costs. 

OJP stated in its response that it will coordinate with the grantee to 

remedy the $102,622 in questioned indirect costs that were charged 

to cooperative agreement number 2005-VR-GX-K001. If the costs 

are determined to be unallowable, OJP will request that the grantee 

return the funds to the DOJ, and submit a revised final Federal 

Financial Report for the grant. 

This recommendation can be closed when we receive evidence that 

OJP and has worked with the event planner to remedy $102,622 in 

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unapproved indirect costs. We note that such an effort should also 

address how the organization should properly allocate indirect costs 

on future OJP awards. 

9. Resolved. JMD concurred with our recommendation to require that 

components and their event planners conduct a cost-benefit analysis 

whenever they justify ordering food and beverages to obtain free 

meeting space for their conferences. JMD stated in its response that 

by October 31, 2011, it will issue guidance to DOJ components 

requiring them to conduct a cost-benefit analysis when justifying 

ordering food and beverages to obtain free meeting space. Also, by 

October 31, 2011, JMD stated that it will review the current 

conference policy to determine if there are any revisions necessary 

related to conducting a cost-benefit analysis. 

This recommendation can be closed when: (1) we receive evidence 

that JMD has implemented guidance to DOJ components requiring 

them to conduct a cost-benefit analysis, and (2) JMD provides 

evidence of a review of the current conference policy and 

documentation determining whether revisions are necessary. 

10. Resolved. OJP and the OVW concurred with our recommendation to 

establish and implement guidelines regarding conference food and 

beverage limits for conferences supported with cooperative 

agreement funds congruent with DOJ-wide rules.55 OJP stated in its 

response that all cooperative agreements awarded during the fiscal 

year 2011 cycle, as well as future cooperative agreements, will 

include a new special condition relating to these cost limitations. The 

OVW stated in its response that it will clearly implement these 

limitations in its own Financial Guide, which is currently in the 

process of final review and approval. The OVW also stated that it will 

add a new special condition mandating compliance with these rules 

to all technical assistance cooperative agreements awarded from FY 

2011 appropriations. Finally, the OVW stated that its staff will 

provide training to these providers to implement cost-effective 

conference planning practices. 

This recommendation can be closed when we receive evidence that 

OJP and the OVW have established and implemented guidelines 

55 In OVW’s response it appears to inadvertently refer to recommendation 10 as 

recommendation 11. Because this report only includes 10 recommendations and the text of 

OVW’s response clearly refers to recommendation 10, we considered this to be a 

typographical error. 

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regarding conference food and beverage limits for conferences 

supported with cooperative agreement funds. 

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