Defense Management: DOD's Conference Policy Is Generally Consistent with OMB's Requirements
Published: 2014-01-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: DOD hosts conferences and sends its personnel to external conferences for training, professional development, and continuing education. However, concerns about executive agencies' spending on conferences prompted OMB in 2012 to direct agencies to establish policies and practices for conference hosting and attendance. DOD issued its policy in September 2012 to improve oversight of conference costs and updated it in November 2013, citing lessons learned from implementing the September 2012 policy, among other things.
The conference report accompanying the National Defense Authorization Act for Fiscal Year 2013 mandated that GAO review DOD's oversight and management of conferences. This report assesses (1) the extent to which DOD's conference policy is consistent with OMB's conference requirements and (2) how DOD components have implemented DOD's conference policy. GAO assessed DOD's 2012 conference policy and 2013 update against OMB requirements and reviewed components' implementation of the policy. GAO analyzed responses to a questionnaire completed by officials from 72 components and military commands and reviewed 563 requests for conferences planned for the second and third quarters of fiscal year 2013.
GAO is not making recommendations in this report. In written comments, DOD concurred with GAO's findings and noted that it remains committed to balancing conference spending oversight with the benefits of hosting and allowing personnel to attend conferences.
section_title: What GAO Found
paragraphs: The Department of Defense's (DOD) September 2012 policy on conferences and its November 2013 update are generally consistent with the requirements established by the Office of Management and Budget (OMB) in May 2012. The key elements of OMB's May 2012 requirements for agencies are the prohibition of conferences with costs in excess of $500,000 unless the agency head signs a waiver, establishment of a Deputy Secretary-level review process for conferences with estimated costs in excess of $100,000, and public reporting annually on the costs of these conferences. DOD adopted a tiered approval structure for the senior-level approval of waivers and all conference-related costs. DOD's policy, which cites the department's size and complexity, places the approval authority for conference waivers and for conferences costing less than $500,000 at lower levels than called for by OMB. For example, OMB requires that waivers approving conferences with costs in excess of $500,000 be signed by the head of an agency, while DOD's policy delegates this authority to 23 senior leaders throughout the department. DOD's policy is more expansive as it requires senior-level review and pre-approval of all conference-related costs, compared to OMB's requirement for senior-level review of conferences only when the estimated costs exceed $100,000. DOD's policy also fully addresses OMB's requirement to publicly report conference costs annually and adds a requirement for quarterly internal reporting of conference costs.
In implementing DOD's September 2012 policy (the existing policy when GAO conducted the majority of its review), DOD components--including the military departments--have taken various approaches to reviewing and approving conference requests, all of which are consistent with the policy. For example, DOD's policy allows senior officials within each component to delegate certain approval authority to lower-level officials for DOD-hosted conferences costing $500,000 or less and non-DOD hosted conferences costing $100,000 or less, but the components have delegated approval authority to different degrees. A majority of the 563 conference requests that GAO reviewed addressed and documented key elements consistent with DOD and component-level guidance. In requests that were missing documentation of one or more key elements, GAO found that a specific element was not missing from a significant number of requests. While the components' implementation of the conference review and approval process has generally been consistent with DOD's policy, some officials within the components and military service commands have identified concerns, particularly with the lengthy approval process. The officials explained that requests to attend conferences have to pass through multiple offices and individuals, sometimes taking several months to be approved. In particular, officials raised questions about the efficiency of reviews for requests to attend conferences that incurred no cost or a low cost (under $20,000) to DOD, which at the time of GAO's review went through the same process as higher-cost conferences. Almost 94 percent of the 405 requests to attend non-DOD hosted conferences that GAO reviewed were for conferences with no cost or a low cost to DOD. DOD in November 2013 updated its policy to state that approval is not required for conferences incurring no cost for DOD. However, a DOD official involved in writing DOD's conference policy stated that components still have the option to review conferences with no cost to DOD to facilitate senior leaders' visibility over conference attendance by personnel within their component.

section_title: Letter
paragraphs: The Department of Defense (DOD), like other executive agencies, hosts  conferences and allows personnel to attend non-DOD conferences to  help personnel be more effective in their jobs. Conferences provide  agency personnel with the opportunity to achieve or maintain professional  accreditations; the efficient delivery of training to large numbers of people;  and the ability to collaborate with industry or foreign nationals. DOD  personnel attend conferences on a range of topics, such as antiterrorism  activities, force requirements, and religious ministry. However, Inspectors  General have reported excessive costs for conferences hosted by other  federal agencies. In November 2011, the President signed an executive  order that cited the need for federal agencies to ensure efficient  spending on conferences and other activities. To this end, the Office of  Management and Budget (OMB) issued a memorandum in May 2012  directing executive agencies to establish an approval process to review  all future conference expenses in excess of $100,000 and to report  agency-sponsored conferences with costs in excess of $100,000  annually.
In response to OMB’s May 2012 memorandum, DOD issued interim  guidance in June 2012 and a policy in September 2012 to improve the  oversight of conference costs across DOD. In the policy, the Deputy  Secretary of Defense identified the Deputy Chief Management Officer  (DCMO) as the point of contact for conferences within DOD and assigned  the DCMO responsibility for establishing and executing processes to  implement DOD’s policy and issuing additional policies as necessary. On  November 6, 2013, the DCMO issued an updated conference policy,  effective on November 20, 2013. According to a DCMO memorandum  accompanying the November 2013 policy, updates were based upon  lessons learned from implementation of the September 2012 policy, the  budget uncertainty faced by DOD, and legislative changes.
The conference report  accompanying the National Defense Authorization  Act for Fiscal Year 2013 mandated that GAO review DOD’s oversight and  management of conferences. This report assesses (1) the extent to which  DOD’s conference policy is consistent with OMB’s requirements for  conference approval and cost reporting and (2) how the DOD  components have implemented DOD’s conference policy.
H.R. Conf. Rep. No. 112-705, at 887 (2012). and OMB staff. To determine how the DOD components have  implemented DOD’s conference policy, we identified the DOD  components’ processes and procedures for approving conference  requests and reporting conference costs. We also developed,  administered, and analyzed responses to a combination of structured  interviews and questionnaires completed by officials within DOD  components, including those at the major command-level in all four  military services. We obtained 563 approved requests for conferences  hosted by DOD or attended by DOD personnel in the second and third  quarters of fiscal year 2013 and used a standardized checklist to assess  whether the information identified by DOD’s September 2012 policy was  included. We analyzed conference requests for this time period because  the approval process established by DOD’s September 2012 policy was  not fully implemented until the second quarter of fiscal year 2013. Further,  conference requests for the fourth quarter of 2013 were not widely  available during our review. Also, we reviewed DOD’s fiscal year 2012  annual conference report and DOD’s quarterly conference reports for the  first three quarters of fiscal year 2013. We provide additional information  about our detailed scope and methodology in appendix I.
We conducted this performance audit from May 2013 to January 2014 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: Beginning in 2011, OMB issued one of two memorandums establishing  oversight requirements for conferences as part of a larger effort to help  promote efficient spending in executive agencies. First, in September  2011, OMB issued a memorandum directing all executive agencies and  departments to conduct a thorough review of the policies and controls  associated with conference-related activities and costs, and report to  OMB on the results. Further, OMB’s memorandum required that all  conference-related activities and costs be approved by the Deputy  Secretary until he or she could certify that the appropriate policies and  controls were in place for mitigating the risk of inappropriate spending  practices regarding conferences. Then in May 2012, OMB issued a  second memorandum to executive agencies and departments, outlining  new policies for conference sponsorship, hosting, and attendance. This  memorandum states that conference costs should be appropriate,  necessary, and managed in a manner that minimizes costs to taxpayers.
OMB’s May 2012 memorandum, among other requirements, outlines a  series of new policies and practices to ensure that federal funds are used  appropriately on conference-related activities and that agencies reduce  spending on conferences when practicable. These policies include the  initiation of Deputy Secretary-level review of all planned conferences  costing more than $100,000 each and of all future conferences estimated  to cost more than $100,000 each. During these reviews, agencies also  should ensure that conference attendance and costs are limited to the  levels required to carry out the mission of the conference. The  memorandum further prohibited costs in excess of $500,000 on a single  conference without a signed waiver from the head of the respective  agency. Finally, the memorandum requires each executive agency to  report annually on its official website the expenses for any agency- sponsored conference exceeding $100,000. Specific reporting  requirements include: the location, date, and total conference costs  incurred by the agency for the conference; a brief explanation of how the  conference advanced the mission of the agency; and the total number of  individuals whose travel costs or other conference costs were paid by the  agency.
Subsequent to OMB’s conference reporting requirements, the  Consolidated and Further Continuing Appropriations Act, 2013  established a requirement for executive agencies to notify their respective  Inspector General of any agency-hosted conference costing more than  $20,000, and to provide the notice within 15 days of the conference. The  notice must include the date and location of the conference, and the  number of employees attending. The act also requires agencies to submit  annual reports to the Inspector General or senior ethics official regarding  the costs and contracting procedures related to each conference when  the cost to the government exceeds $100,000.
section_title: DOD’s Policy Is Generally Consistent with OMB’s Requirements for Approving and Reporting Conference Costs
paragraphs: DOD’s September 2012 policy and November 2013 update are generally  consistent with the three key elements of OMB’s requirements for   The key  approving conferences and reporting associated costs.elements of OMB’s requirements for agencies are the prohibition of  conferences with costs in excess of $500,000 unless the head of the  respective agency signs a waiver, establishment of a Deputy Secretary- level review process for conferences with costs in excess of $100,000,  and public reporting annually of the costs of agency-sponsored  conferences with costs in excess of $100,000. DOD’s variances from  OMB’s requirements for the first two elements are attributable to DOD’s  size and complexity and, according to DOD’s policy, were done with  OMB’s concurrence. Specifically, the Secretary of Defense delegated  some responsibility for reviewing and approving conferences that is not  explicitly granted by OMB’s requirements. Despite these variances, some  provisions within DOD’s conference policy exceed OMB’s requirements  by providing additional detail for how to implement the conference  approval process and requiring additional conference cost reporting.
subsections: section_title: DOD Delegated Approval Authority for Conferences to Senior DOD Leaders in a Tiered Approval Structure
paragraphs: DOD’s policy established the need for a waiver for any conference with  costs in excess of $500,000, but placed the authority for granting those  waivers at a lower level than required by OMB. DOD’s policy prohibits  DOD components from incurring costs greater than $500,000 on a single  conference, unless a waiver is granted by certain designated officials.  OMB’s May 2012 memorandum requires that the waivers be signed by  the head of an agency, which for DOD is the Secretary of Defense;  however, the Secretary of Defense delegated this authority to 23 senior  leaders across DOD. These leaders include the Secretaries and Under  Secretaries of the military departments, the Chief of the National Guard  Bureau, the Director of the Joint Staff, the Commanders of the combatant  commands, the Under Secretaries of Defense, and the DCMO.
To address OMB’s requirements regarding the review and approval of  conferences, DOD’s policy established a tiered approval structure. Like  the delegation of waivers for conferences costing over $500,000, DOD’s  policy places the approval authority for conferences costing less than  $500,000 at lower levels than called for by OMB. Specifically, OMB’s May  2012 memorandum specified that Deputy Secretaries within agencies are  responsible for approving spending on conferences that will cost more  than $100,000 but not in excess of $500,000. In DOD’s policy, these  responsibilities and authorities are delegated to the same 23 senior  leaders that have responsibility for approving waivers for conferences  costing in excess of $500,000. These officials may, in turn, delegate  approval authority to 81 other specific officials identified in the policy.  Figure 1 depicts DOD’s tiered approval structure for conferences.
DOD’s policy notes that the Secretary of Defense and the Deputy  Secretary of Defense remain accountable for all of DOD’s conference- related activities, but explains that delegation to these senior leaders is  being done in recognition of DOD’s size and complexity and with OMB’s  concurrence. According to DCMO officials, it was infeasible to keep the  waiver and approval authorities at the level of the Secretary or Deputy  Secretary because the Secretary of Defense and Deputy Secretary of  Defense did not have time to review and approve the number of DOD  conferences expected to cost over $100,000. They also told us that they  informed OMB of the Deputy Secretary of Defense’s decision to delegate  approval and waiver authorities, and received verbal concurrence from  OMB staff to do so.
While DOD’s policy vests approval and waiver authority at a lower level  than called for by OMB, DOD’s policy provides additional oversight by  requiring senior-level review and pre-approval of all conference-related  costs, regardless of the total, compared to OMB’s requirement for senior- level review of conferences only when the estimated cost is more than  $100,000. Under DOD’s tiered approval structure, higher-cost DOD- hosted or attended conferences must be reviewed and pre-approved by  senior leaders who have the option to delegate the approval authority for  lower-cost conferences. The DOD policy explains that such requirements  are intended to ensure that conferences hosted by DOD are executed in  a responsible manner and that DOD is prudent when sending personnel  to conferences hosted by others.
The conference policy updated in November 2013 also explicitly states  that if it becomes apparent that the cost for a DOD-hosted conference will  exceed the estimated cost and breach the next approval threshold,  approval must be obtained from the higher-level approval authority as  soon as possible. Additionally, if a DOD component initially estimates that  the total cost of attendance at a non-DOD hosted conference will exceed  $100,000 for that DOD component, then the conference must be  approved by that DOD component’s highest tier of approval authority.  The November 2013 policy also states that approval is not required for  conferences that incur no cost to DOD, including instances where all  conference costs are paid for by a non-DOD entity in accordance with  DOD’s gift acceptance rules.
In explaining the conference review and approval authorities, DOD’s  policy provides criteria for personnel to determine whether an event  meets the definition of a conference and is subject to the approval  process. It notes that some conferences subject to DOD’s policy are  referred to by other terms, such as conventions and seminars. The policy  provides key indicators of a conference that include, but are not limited to:  registration and registration fees, a published agenda, and scheduled  speakers. Also, the policy describes activities that should not be  considered conferences even if they meet the general definition of a  conference and are, therefore, exempt from the review and approval  process. These exemptions include
DOD meetings necessary to carry out:  statutory command and staff oversight functions, such as  investigations, inspections, audits, or non-conference planning site  visits;  internal agency business matters, such as meetings that take  place as part of an organization’s regular course of daily business;  or planning or execution of operational exercise activities or pre- deployment, deployment, or post-deployment activities.
Events where participation by DOD personnel is required for:  change of command, official military award, funeral, or other such  ceremonies; or military or civilian recruiting or recruitment advertising.
Formal classroom training, such as regular courses of instruction or  training seminars. These activities may be offered by government  organizations, institutions of higher learning or professional licensure  or certification, or other training entities. However, events are not  exempt simply because they offer continuing education credits or the  equivalent.
Meetings of advisory committees where one or more of the members  is not a full-time or permanent part-time federal officer or employee.
DOD’s policy also describes elements to be included in the calculation of  the estimated total cost of each planned conference, which then  determines the approving official who must approve or reject the related  request. For example, the cost estimate should include, among other  elements, attendees’ authorized travel costs and per diem, audiovisual  and other equipment usage, and registration fees. Costs are not to  include such expenses as federal employee time for conference planning  or attendance. Also, DOD policy prohibits the use of department funds for  any entertainment expenses at DOD conferences.
section_title: DOD’s Policy Addresses and Expands on OMB’s Requirements for Reporting on Conference Costs
paragraphs: DOD’s policy addresses OMB’s requirement that all agencies issue an  annual public report on agency-sponsored conferences with costs of  more than $100,000 that occurred during the prior fiscal year, as well as  subsequent statutory reporting requirements. DCMO officials told us that  no department-wide data were maintained on conference costs prior to  the adoption of the annual reporting requirement. DOD’s policy requires  each DOD component to track the required reporting elements, which are  monitored and consolidated by the Office of the DCMO for reporting. In  addition to the total conference costs, the DOD components are to track  information on which DOD component hosted the conference, the dates  and location of the conference, the number of individuals whose  expenses were paid by the agency, and a brief description of how the  conference advanced DOD’s mission.
While OMB called for each agency to publicly report its conference costs  by January 31 of each year, DOD’s first annual report, which covered  fiscal year 2012, was not approved by the Deputy Secretary of Defense  and posted on the DCMO’s website until February 2013. DOD otherwise  met all of OMB’s conference reporting requirements. According to its  report, DOD hosted 295 conferences during fiscal year 2012 that each  had a total cost in excess of $100,000. DOD reported that these  conferences collectively cost approximately $89 million. DOD also noted  that after the issuance of OMB’s May 2012 memorandum, the Deputy  Secretary of Defense signed waivers approving four conferences that  each cost in excess of $500,000 during fiscal year 2012. Waivers were  approved for a suicide prevention conference, a symposium on education  for military service members, a military health system research  symposium, and a conference on DOD’s information assurance mission.  DOD reported that these four conferences ranged in cost from around  $550,000 to over $2 million, with a collective cost of almost $6 million.
Additionally, DOD took actions that expanded on OMB’s annual reporting  requirement by issuing policy in September 2012 and updating its policy  in November 2013 to establish that the DCMO will submit internal, non- publicly available quarterly reports to the Deputy Secretary of Defense on  conferences hosted or attended by DOD personnel.DCMO compiled DOD’s first report on quarterly conference costs and  submitted it in March 2013 to the Deputy Secretary of Defense. This  report on conferences held in the first quarter of fiscal year 2013 repeated  the type of cost data that was included in DOD’s fiscal year 2012 annual  report for conferences that were hosted by DOD and cost over $100,000,  and included additional information on non-DOD hosted conferences  attended by DOD personnel that cost over $20,000. Later, DOD  submitted its second-quarter report for the fiscal year in May 2013, and its  third-quarter report in September 2013. For each DOD-hosted  conference, the quarterly reports included additional information not found  in the fiscal year 2012 annual report. Specifically, the quarterly reports  included a breakout of the total cost for a DOD-hosted conference and  included hosting costs (e.g., audiovisual equipment and facility rental),  registration fees collected, and attendees’ estimated travel costs. Also,  the quarterly reports included information on whether a DOD-hosted  conference involved spousal travel, use of a non-federal conference  planner, co-sponsorship with a non-federal organization, or a no-cost  contract.
Under DOD’s November 2013 updated conference policy, DOD  components are to enter conference cost data in a new, online reporting  system referred to as the DOD Conference Tool. Specifically, each  conference in excess of $20,000 must be entered into the DOD  Conference Tool within 10 working days of the approval or the signing of  the waiver memorandum. In addition, within 30 days of the completion of  each conference, the DOD components are to update their previous  estimates based on any new information, such as adjusting the number of  participants who attended or the cost factors that went into the cost  estimate. According to officials from the Office of the DCMO, the DOD  Conference Tool is intended to help standardize the reporting process  across DOD and will help DOD component officials by spreading the  administrative burden of collecting and reporting data throughout the year  instead of requiring a concentrated effort each quarter. The officials also  told us that prior to the requirement to use the DOD Conference Tool,  components could, and did, use a variety of methods to report their  conference costs. Aggregated reports from the DOD Conference Tool will  be provided quarterly to the Deputy Secretary of Defense. Further, the  DOD Conference Tool is intended to help DOD fulfill the reporting  requirements included in the Consolidated and Further Continuing  Appropriations Act, 2013. For example, personnel from the DOD  Inspector General’s office have been granted access to the DOD  Conference Tool, which meets the new requirement to report certain  conference information to agencies’ Inspectors General.
section_title: DOD Components Vary in Their Approaches to Implementing DOD’s Conference Policy, and Some Officials Expressed Concerns about the Lengthy Approval Process
paragraphs: In implementing DOD’s conference policy, DOD components have been  consistent with the policy, but have taken various approaches. For  example, the military departments have delegated approval authority—as  allowed under DOD’s policy—differently. Also, some components have  issued supplemental guidance that, among other matters, identifies the  elements that conference requests are to address. In our review of  563 approved requests for conferences in the second and third quarters  of fiscal year 2013, we found that a majority (311) of the requests  addressed key elements, such as noting how a conference is necessary  or fulfills a mission, and including a cost estimate. While the remaining  252 requests we reviewed did not contain documentation for all of the  elements, we did not find circumstances where a specific element was  consistently missing from a significant number of requests. In  implementing the policy, some officials within the components identified  concerns about the efficiency of the conference approval process.  Specifically, these officials expressed concern that DOD’s policy requires  a lengthy review process for all conference requests regardless of cost,  raising questions particularly about the process’s efficiency for low-cost  conferences (those under $20,000).
subsections: section_title: DOD Components Vary in Their Approaches to Implementing DOD’s Conference Policy
paragraphs: In implementing DOD’s policy for approving conference costs, the military  departments have taken various approaches consistent with the policy  regarding the delegation of approval authority. A senior DCMO official  noted that it is acceptable for the military departments to implement the  conference policy differently as long as they stay within the bounds of  DOD’s policy. DOD’s policy permits specified senior leaders within the  military departments to delegate their approval authority for DOD-hosted  conferences costing less than $500,000 and for attendance at non-DOD  hosted conferences costing less than $100,000. The DOD components— including the military departments—have varied in their delegation of  approval authority. For example:
The Department of the Army has delegated approval authority for  Army-hosted conferences with costs less than $100,000 to  appropriate principal officials and commanders. The Army has  restricted approval authority for attendance at all non-DOD hosted  conferences at the level of the Secretary or Under Secretary of the  Army, or to the Administrative Assistant to the Secretary of the Army.
The Department of the Navy has extended approval authority to its  Assistant for Administration for Navy-hosted conferences costing  $500,000 or less and for non-DOD hosted conferences for which  attendance costs do not exceed $100,000.
The Department of the Air Force initially delegated approval authority  for Air Force-hosted conferences costing less than $500,000 and for  non-DOD hosted conferences costing less than $20,000 to its major  commands and certain other subordinate commands. However, since  March 2013, the Air Force has retained authority for all conference  approvals, regardless of cost, at the level of the Secretary or Under  Secretary of the Air Force as part of its broader sequestration  guidance.
Military department officials explained that one reason they decided to  maintain approval authority at a high level was to ensure close scrutiny  and management of conference costs during the current environment of  reduced budgets. Also, these officials noted that it is difficult to maintain  visibility over the total attendance costs when personnel from multiple  military service commands plan to attend the same conference. Further,  the Department of the Navy oversees personnel from the Navy and  Marine Corps, and could have personnel from both services attending the  same conference. If the approval authority is delegated, there would be a  risk that the total estimated costs would not be aggregated across military  service commands and that requests would not receive the appropriate  level of review.
In addition, officials from the Office of the DCMO and the military  departments told us that maintaining high levels for approval authority  helps mitigate risks to DOD other than the financial risk of unnecessary  spending on conferences. Specifically, these officials said that military  department leaders did not want to risk sending personnel to conferences  that could be perceived as inappropriate for representatives of DOD,  regardless of the financial cost of the conference. By maintaining  approval authority at a high level within the military departments, senior  DOD leaders are aware of the types of conferences that their civilian and  military personnel are attending and can reject requests for conferences  that they perceive as potentially damaging to DOD’s reputation. A DCMO  official commented that although DOD’s conference policy allows for  more latitude with regard to delegating approval authority than is currently  being exercised, the decision thus far to ensure minimum risk by keeping  approval levels high is an acceptable implementation of DOD’s policy.
Additionally, DOD components have, in some cases, developed  supplemental guidance to implement a conference approval process that  is consistent with DOD’s policy. Components’ guidance generally  specifies procedures for preparing and submitting requests to host or  attend conferences, including how to obtain pre-approval by the  appropriate approval authority and what information to include so that the  approval authority can determine if the conference is necessary and cost  effective. For example, several DOD components have issued templates  that standardize the required elements for senior-level reviews, such as  including the purpose of a conference, how it fulfills a DOD mission, and  specifying estimated costs.
We found that the DOD components generally were consistent with DOD  and component-level guidance in processing requests to host or attend  conferences. DOD’s September 2012 policy and some of the  implementing guidance issued by the components—including the military  departments—reference the following four key elements that help  approval authorities determine the merit of a particular conference: (1) a  statement by the requester that the conference is necessary or fulfills a  DOD mission; (2) a cost estimate; (3) an assessment of the conference  request by a legal counsel; and (4) for DOD-hosted conferences,  consideration of alternative means of delivering the information. In our  review of 563 approved requests for conferences in the second and third  quarters of fiscal year 2013, we found that a majority (311) of the  requests addressed and documented all four key elements. While the  remaining 252 requests we reviewed did not contain documentation of all  four key elements, we did not find circumstances where a specific  element was consistently missing from a significant number of requests.  Specifically, for the 563 approved conference requests we reviewed:
98 percent of all requests included a statement by the requester that  the conference is necessary or fulfills a DOD mission;
92 percent of all requests included a cost estimate;
66 percent of all requests included an assessment of the conference  request by legal counsel; and
65 percent of requests for DOD-hosted conferences included  evidence that the requester considered alternative means of  delivering the information, such as video teleconferencing, and  deemed those means infeasible.
We also found that many conference requests included additional  information for approving officials to review that was not among the  required elements, such as a description of how the requesting  organizations were reducing costs to host or attend the conference. Some  examples of cost-saving efforts were using public transportation instead  of a rental car, not approving travel costs for conference attendees unless  they were speaking or making a presentation at the conference, and  hosting conferences at government facilities instead of a hotel or  convention center. Further, where evidence of a key element was  missing, we found that in some cases, a record of the key element was  maintained somewhere other than with the conference request  documentation we reviewed. For example, officials from the three military  service commands with whom we followed up about missing evidence of  a legal review in their conference requests told us that legal reviews were  documented in a document management system or were documented at  the service headquarters level.
Each DOD component also has implemented DOD’s requirement for  quarterly reporting to the Deputy Secretary of Defense. Our review found  that the DOD components varied in how and when they obtained the data  for reporting conference costs. For example, some military service  commands and DOD components required the original conference  requester to complete a report after the conference with updated cost  information and used this data for reporting purposes. Officials from other  military service commands and DOD components told us that they  reviewed travel vouchers within DOD’s travel system or used other  financial management systems to obtain updated cost data for each  conference. DOD’s November 2013 update requires the DOD  components to enter reportable cost data into the new DOD Conference  Tool within 30 days of a conference’s completion if the conference costs  more than $20,000. According to a DCMO official, the components began  using the DOD Conference Tool in the fourth quarter of fiscal year 2013.
section_title: Some Officials Expressed Concern over DOD’s Lengthy Approval Process, Especially for Conferences with Low or No Cost to DOD
paragraphs: While we found that the components’ implementation of the conference  review and approval process has generally been consistent with DOD’s  policy, some officials within the components and military service  commands have identified concerns about the approval process. During  our interviews and in response to our questionnaire, officials cited  common concerns related to the time and resources spent on conference  approval, and the approval levels required by components for  conferences with a low or no cost to DOD.
In response to our question regarding what concerns, if any, DOD  components and military service commands had with DOD’s conference  policy, the most common concern was the amount of time and resources  spent to complete the review and approval process. Specifically, officials  from 33 percent of the 18 DOD components and 22 percent of the 54  military service commands reported concerns with time and resources.
Several military service commands noted in their responses that  individuals requesting to host or attend a conference must wait months  before requests are approved or rejected. For example, officials from one  military service command reported that the process sometimes required a  60-day period to obtain conference approval. In addition, we found that  some conference requests took several months to receive final approval.  In one instance, the initial request was submitted almost five months in  advance of when the conference was scheduled to begin, but final  approval was not granted until two weeks prior to the beginning of the  conference. Officials from the military departments told us that they have  prioritized conference requests from individuals in certain career  specialties—such as chaplains and medical professionals—to ensure that  they receive the necessary training in time to maintain their professional  licensures or certifications. In addition, personnel sometimes are eligible  to receive price discounts by completing early registration for certain non- DOD hosted conferences. One non-DOD hosted conference that we  reviewed offered a $300 discount if attendees registered before a certain  date.
Some officials raised specific concerns about the number of personnel  required for conference reviews. Based on responses that we received  from 18 DOD components and 54 military service commands, we found  that conference requests often are reviewed by personnel from at least  four offices. The multiple reviews can include financial management,  administrative, and legal personnel, plus subsequent review by the  general officer, flag officer, or senior executive at that organization.  Officials from one military service command noted that there is often a  bottleneck effect created at the higher approving levels. Officials from  another command noted that the approval process for attending  conferences is cumbersome and involves significant personnel resources.  According to component and command officials, reviewing offices also  vary in how many individuals are available for part-time or full-time duty to  review conference requests. These individuals typically have other duties,  and their assignment to review conference requests is a part-time or  collateral duty. Therefore, individuals who review conference requests as  a collateral duty may sometimes have to defer their reviews if they need  to address higher priorities among their job responsibilities.
Officials from several DOD components and military service commands  reported difficulty identifying and implementing procedures to mitigate the  amount of time spent on the review process. For example, officials from  one DOD academic institution acknowledged the problem of missing  deadlines for early registration and not benefitting from a discounted rate.
However, in response to our questionnaire, these officials said that they  had difficulty instituting procedures for timely decisions on requests to  attend non-DOD hosted conferences because the requester may not  know about the conference in time to complete the approval process  before the early registration date expires. Additionally, several of the DOD  components have developed guidance to initiate conference reviews as  early as possible, such as 90 days prior to the start of the conference.  However, officials from multiple components noted the difficulty of this  requirement in that the need for conference attendance may not be  known that far in advance. According to officials from some of the military  services, many of the non-DOD entities hosting conferences frequently  attended by DOD personnel recognize DOD’s constrained budget  environment and are willing to work to minimize the costs to DOD.  Officials said that in many cases conference hosts have waived  registration fees and other conference costs for DOD personnel. For  example, Army officials told us they were able to achieve a significant  cost avoidance by accepting a professional nonprofit association’s offer to  waive registration fees and cover travel expenses for key attendees to  ensure the Army’s participation at the association’s annual conference  despite fiscal constraints. As a result, the Army saved about $1 million  over previous years’ attendance costs.
In addition, some officials raised specific concerns that the approval  process requires the same amount of time and resources regardless of  the estimated cost of the conference. Officials noted that the approval  process involves the same resources for a conference with low or no cost  to DOD as it does for a conference costing $20,000 or more. Our  questionnaire to DOD components and military service commands found  that officials at 28 percent of the 18 DOD components that responded and  14 percent of the 54 military service commands that responded  expressed concern over the approval tiers required by their component’s  conference guidance. In their responses, some officials specified that the  required tier of review was excessive for conferences for which DOD  incurred low or no cost. Because DOD invests a relatively small amount  of resources on conferences with low or no cost to DOD, some officials  felt that such conferences represented a low risk to DOD and did not  require the same scrutiny as more expensive conferences. In our review,  we found that a few conference requests that resulted in a low or no cost  to DOD took several months between the initial request and the approval.  For example, we reviewed a request for one individual to attend a three- day, non-DOD hosted conference with a total estimated cost below  $1,000, and the request was not approved for almost three months.
Most of the requests to attend non-DOD hosted conferences, according  to our review, were for conferences with low or no cost to DOD. As shown  in figure 2, in nearly 94 percent of the 405 requests for personnel to  attend non-DOD hosted conferences, the estimated cost of attendance  was less than $20,000 for each conference.
Similarly, for the 556 DOD-hosted and non-DOD hosted conference  requests that we reviewed for which cost information was available,found that the aggregate cost to DOD for all low-cost conferences was  significantly lower than the aggregate cost to DOD for more expensive  conferences, even though the number of individual requests to attend  conferences with low or no cost to DOD was much higher. Specifically,  the total estimated cost for 424 DOD-hosted and non-DOD hosted  conferences costing $20,000 or less was around $2 million, while the total  estimated cost for 132 DOD-hosted and non-DOD hosted conferences  costing over $20,000 was approximately $13.8 million.   we  Conferences with no cost to DOD often occur when a non-DOD  organization that is sponsoring DOD research in a specific field covers all  the costs for DOD officials to present the research at a conference.  Further, a low cost for a conference can occur when only one or two DOD  officials are attending a conference. According to DOD officials,  individuals may also strive to keep conference costs below $20,000 to  avoid having to report conference costs for DOD’s quarterly and annual  reports. For example, DOD components and military service commands  may limit the number of people who are allowed to attend a conference to  keep the cost below $20,000.
DOD’s November 2013 policy update was issued after we received the  responses to our questionnaires and reviewed conference requests. This  update specified that there is no requirement for review and approval of  requests for conferences that have no cost to DOD, including  conferences where all costs are paid by non-DOD entities and the  payments are in accordance with DOD gift acceptance rules. According to  one DCMO official involved in writing the policy, even with the November  2013 update, the components still have the option to review conferences  that incur no cost to DOD in accordance with their conference approval  process to facilitate senior leaders’ visibility over conference attendance  by personnel within their component. Further, the official stated that  components are free to institute additional conference processes and  procedures as long as they are consistent with the minimum requirements  in DOD’s November 2013 updated policy.
section_title: Agency Comments
paragraphs: We provided a draft of this report to DOD for review and comments. In  written comments, which are reprinted in their entirety in appendix II,  DOD concurred with our findings. DOD noted that it remains committed to  balancing the need for rigorous oversight of conference spending with the  benefits of hosting and participating in conferences that are essential to  DOD’s mission. Also, DOD noted that the balance can be difficult to  achieve, and officials understand the concerns that the approval process  for conferences is too long, especially for conferences with only a small  cost. DOD stated that it will continue to monitor the situation to determine  if additional steps are necessary. DOD also provided technical comments,  which were incorporated into this report as appropriate.
We are sending copies of this report to the Secretary of Defense; the  Secretaries of the Army, Navy, and Air Force; the Director of the Office of  Management and Budget; and appropriate congressional committees. In  addition, the report is available at no charge on the GAO website at  http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-5741 or ayersj@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine the extent to which the Department of Defense’s (DOD)  conference policy is consistent with the Office of Management and  Budget’s (OMB) requirements for conference approval and cost reporting,  we reviewed an executive order and a series of memorandums issued by  OMB in fiscal years 2011 through 2013 on promoting efficiency and  eliminating excess spending within executive branch agencies. In  particular, we reviewed OMB’s May 2012 memorandum, Promoting  Efficient Spending to Support Agency Operations, which includes three  key elements for conference sponsorship, hosting, and attendance.  These elements are the prohibition of conferences with costs in excess of  $500,000 unless the head of the agency signs a waiver, Deputy  Secretary-level review of conference expenses in excess of $100,000,  and public reporting annually of agency-sponsored conferences with  costs in excess of $100,000. We assessed the extent to which DOD was  consistent with the OMB memorandum in issuing DOD’s September 29,  2012, memorandum, Implementation of Conference Oversight  Requirements and Delegation of Conference Approval Authority, and its  November 6, 2013, memorandum, Implementation of Updated  Conference Oversight Requirements. In reviewing DOD’s conference  policy, we interviewed officials from the Office of the Deputy Chief  Management Officer (DCMO) and OMB staff. We also interviewed  officials from the Office of the DCMO and obtained relevant documents to  review DOD’s planned approach for meeting reporting requirements in  the Consolidated and Continuing Appropriations Act, 2013. Specifically,  we reviewed training materials and spoke to officials about the web-based  tool planned to help facilitate reporting beginning in the fourth quarter of  fiscal year 2013.
To determine how DOD components have implemented DOD’s  conference policy, we identified the DOD components’ processes and  procedures for approving conference requests and reporting conference  costs. To that end, we developed, administered, and analyzed responses  to a combination of structured interviews and questionnaires that referred  to DOD’s September 2012 conference policy, which was the existing  policy when we conducted the majority of our review. The structured  interviews and questionnaires were completed by officials at the offices of  the Under Secretaries of Defense, Joint Staff, National Guard Bureau,  and combatant commands and all four military services (Army, Navy, Air  Force, and Marine Corps). To cover as much of the population as  possible within the services, we asked each service to provide a list of  “major subordinate commands.” Both the DOD component and military  service command questionnaires consisted of open-ended questions on  conference policies, procedures, and costs within the component or  command being questioned, a subset of which requested quantitative  responses. We pre-tested the questionnaire with one Army command,  one Navy command, one Marine Corps command, and one DOD  component. After the pre-test, we administered the final questionnaires  using a combination of phone interviews and emails. We received oral  and written responses from 100 percent of the18 DOD components and  54 military commands that we selected for interviews or emailed  questionnaires. All components and commands that provided responses  are listed at the end of this appendix.
The responses that we received to quantitative questions (e.g., the  number of conferences hosted in fiscal year 2013) were summarized as  standard descriptive statistics. To analyze the content in open-ended  responses, one GAO analyst reviewed each open-ended response from  each DOD component and military service command to identify recurring  themes. Using the identified themes, the analyst then developed  categories for coding the responses. A second GAO analyst reviewed  each response from each DOD component and military service command  and reviewed the first analyst’s themes and categories to reach  concurrence on the themes and categories. Both GAO analysts then  independently reviewed the answers to each open-ended question and  placed them into one or more of the coding categories. A third analyst  then reconciled the first and second analysts’ coding and, through  discussion, made a final decision whenever there was disagreement. The  key categories we identified and analyzed were (1) steps taken to  respond to and verify the accuracy of data provided for the annual and  quarterly reporting requirements and (2) concerns about DOD or  component conference policy. Because DOD’s September 2012 policy  was the existing policy when DOD officials responded to our structured  interviews and questionnaire, any concerns they raised about DOD’s  conference policy were in reference to the September 2012 policy.
We interviewed officials from each of the military services who were  involved in the implementation of DOD’s conference policy, and we  reviewed service guidance—including instructions, templates, and  checklists—to determine whether it was consistent with DOD’s  conference policy. Further, in evaluating how DOD collects, maintains,  and reports conference costs, we reviewed DOD’s publicly reported  annual conference report for fiscal year 2012 and assessed the extent to  which it contained all elements required by OMB’s May 2012  memorandum. We also reviewed DOD’s internal quarterly reports on  conference costs for the first three quarters of fiscal year 2013. We  compared the information included in the quarterly reports to DOD’s fiscal  year 2012 annual report to identify differences between the annual and  quarterly reporting requirements.
We also obtained and evaluated requests for conferences planned for the  second and third quarters of fiscal year 2013. We obtained requests for  this time period because the approval process established by DOD’s  September 2012 policy was not fully implemented until the second  quarter of 2013. Further, conference requests for the fourth quarter of  2013 were not widely available during our review. To obtain conference  requests, in our structured interviews and emailed questionnaires we  asked officials from each DOD component and military service command  to provide us all documents associated with requests for conferences  planned to date in fiscal year 2013, including DOD-hosted and non-DOD  hosted conferences. For the DOD components, Army, and Air Force, we  received documentation directly from the organizations we interviewed or  to which we emailed questionnaires. According to Navy and Marine Corps  officials, the necessary documentation was centrally maintained in those  services’ document management systems instead of at the major  commands or other subordinate commands; therefore, we received  conference request documentation for those two services’ major  commands from a central office within Navy and Marine Corps  headquarters, respectively. For the Navy, we were provided access to a  document management system and manually reviewed documents  associated with conference requests. For the Marine Corps, we were  emailed documents associated with conference requests from a similar  document management system.
Further, to evaluate conference requests we developed a standardized  checklist of key elements needed by approval authorities for their  determination of whether a conference should be approved or rejected.  We developed a checklist with the following four key elements based on  DOD guidance and component-level guidance: (1) an explanation of why  the conference was necessary or mission essential; (2) evidence of a  legal review of the conference request; (3) evidence of a cost estimate;  and, (4) for DOD-hosted conferences, evidence that alternative means of  delivering the information, such as video teleconferencing, was  considered and deemed infeasible. We assessed the documentation for  each conference request against the four key elements to determine if  these elements were included. Using our checklist, we reviewed and  assessed 563 approved requests for conferences hosted by DOD or  attended by DOD personnel in the second and third quarters of fiscal year  2013.
We interviewed officials and, where appropriate, obtained documentation  from the following DOD organizations:
Office of the Secretary of Defense, Office of the Deputy Chief
Department of the Army
Office of the Administrative Assistant to the Secretary of the Army
Office of the Army General Counsel
Department of the Navy
Office of the Assistant for Administration
Office of the Director, Navy Staff
Bureau of Naval Personnel
Office of the Director, Marine Corps Staff
Department of the Air Force
Office of the Administrative Assistant to the Secretary of the Air
Office of the General Counsel  The following 72 offices responded to our questionnaire. These offices  were either emailed a copy of the questionnaire and provided written  responses or were contacted by phone and responded orally to the  questionnaire in a structured interview. We also requested copies of all  fiscal year 2013 conference requests from these organizations and used  the requests from the second and third quarters of fiscal year 2013 in our  analysis, as described earlier in this report.
Army (3)
U.S. Army Forces Command
U.S. Army Materiel Command
U.S. Army Training and Doctrine Command   (24)
Commander, Navy Reserve Force
Commander, Navy Installations Command
Commander, Operational Test and Evaluation Force
Commander, U.S. Pacific Fleet
Office of Diversity and Inclusion
Naval Air Systems Command
Naval Facilities Engineering Command
Naval Sea Systems Command
Naval Supply Systems Command
Space and Naval Warfare Systems Command
U.S. Navy Bureau of Medicine and Surgery
U.S. Fleet Cyber Command
U.S. Fleet Forces Command
U.S. Naval Academy
U.S. Naval Forces Central Command
U.S. Naval Forces Europe and Africa
U.S. Naval Forces Southern Command
U.S. Naval War College
Naval History and Heritage Command
Bureau of Naval Personnel   (13)
Air Force Chief of Chaplains
Air Education and Training Command
Air Force Global Strike Command
Air Force Materiel Command
Air Force Reserve Command
Air Force Space Command
Air Force Special Operations Command
Air National Guard Readiness Center
U.S. Air Force Academy
U.S. Air Forces in Europe   (14)
Marine Corps Forces, Pacific
Marine Corps Forces Command
Marine Corps Forces Reserve
Marine Corps Forces Cyberspace Command
Marine Corps Forces Europe and Africa
Marine Corps Forces, South
Marine Corps Forces Strategic Command
Marine Corps Forces Special Operations Command
Marine Corps Combat Development Command
Training and Education Command
Marine Corps Logistics Command
Marine Corps Recruiting Command
Marine Corps Installations Command
Marine Corps Forces Central Command  DOD Components (18)
U.S. Pacific Command
U.S. Special Operations Command
Office of the Under Secretary of Defense for Acquisition, Technology
Office of the Under Secretary of Defense, Comptroller
Defense Finance and Accounting Service
Defense Contract Audit Agency
Office of the Under Secretary of Defense for Intelligence
Office of the Under Secretary of Defense for Personnel and
Office of the Under Secretary of Defense for Policy  We conducted this performance audit from May 2013 to January 2014 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Comments from the Department of Defense
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
paragraphs: Johana Ayers, (202) 512-5741 or ayersj@gao.gov.
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, key contributors to this report  were Tina Won Sherman, Assistant Director; Melissa Blanco; Richard  Burkard; Susannah Hawthorne; Greg Marchand; Amanda Miller; Richard  Powelson; Sharon Reid; Monica Savoy; Amie Steele; and Roger Stoltz.