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. 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. 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.