DOD’s Policy Is Generally Consistent with OMB’s Requirements for Approving and Reporting Conference Costs

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. 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. To address OMB’s requirements regarding the review and approval of  conferences, DOD’s policy established a tiered approval structure. 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. DOD Components Vary in Their Approaches to Implementing DOD’s Conference Policy

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. 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. 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. Some Officials Expressed Concern over DOD’s Lengthy Approval Process, Especially for Conferences with Low or No Cost to DOD

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. Some officials raised specific concerns about the number of personnel  required for conference reviews. 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. 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. 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. 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. Appendix I: Scope and Methodology

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. 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.
Why GAO Did This Study

DOD hosts conferences and sends its personnel to external conferences for training, professional development, and continuing education. However, concerns about executive agencies' spending on conferences prompted OMB in 2012 to direct agencies to establish policies and practices for conference hosting and attendance. DOD issued its policy in September 2012 to improve oversight of conference costs and updated it in November 2013, citing lessons learned from implementing the September 2012 policy, among other things.
The conference report accompanying the National Defense Authorization Act for Fiscal Year 2013 mandated that GAO review DOD's oversight and management of conferences. This report assesses (1) the extent to which DOD's conference policy is consistent with OMB's conference requirements and (2) how DOD components have implemented DOD's conference policy. GAO assessed DOD's 2012 conference policy and 2013 update against OMB requirements and reviewed components' implementation of the policy. GAO analyzed responses to a questionnaire completed by officials from 72 components and military commands and reviewed 563 requests for conferences planned for the second and third quarters of fiscal year 2013.
GAO is not making recommendations in this report. In written comments, DOD concurred with GAO's findings and noted that it remains committed to balancing conference spending oversight with the benefits of hosting and allowing personnel to attend conferences.

What GAO Found

The Department of Defense's (DOD) September 2012 policy on conferences and its November 2013 update are generally consistent with the requirements established by the Office of Management and Budget (OMB) in May 2012. The key elements of OMB's May 2012 requirements for agencies are the prohibition of conferences with costs in excess of $500,000 unless the agency head signs a waiver, establishment of a Deputy Secretary-level review process for conferences with estimated costs in excess of $100,000, and public reporting annually on the costs of these conferences. DOD adopted a tiered approval structure for the senior-level approval of waivers and all conference-related costs. DOD's policy, which cites the department's size and complexity, places the approval authority for conference waivers and for conferences costing less than $500,000 at lower levels than called for by OMB. For example, OMB requires that waivers approving conferences with costs in excess of $500,000 be signed by the head of an agency, while DOD's policy delegates this authority to 23 senior leaders throughout the department. DOD's policy is more expansive as it requires senior-level review and pre-approval of all conference-related costs, compared to OMB's requirement for senior-level review of conferences only when the estimated costs exceed $100,000. DOD's policy also fully addresses OMB's requirement to publicly report conference costs annually and adds a requirement for quarterly internal reporting of conference costs.
In implementing DOD's September 2012 policy (the existing policy when GAO conducted the majority of its review), DOD components--including the military departments--have taken various approaches to reviewing and approving conference requests, all of which are consistent with the policy. For example, DOD's policy allows senior officials within each component to delegate certain approval authority to lower-level officials for DOD-hosted conferences costing $500,000 or less and non-DOD hosted conferences costing $100,000 or less, but the components have delegated approval authority to different degrees. A majority of the 563 conference requests that GAO reviewed addressed and documented key elements consistent with DOD and component-level guidance. In requests that were missing documentation of one or more key elements, GAO found that a specific element was not missing from a significant number of requests. While the components' implementation of the conference review and approval process has generally been consistent with DOD's policy, some officials within the components and military service commands have identified concerns, particularly with the lengthy approval process. The officials explained that requests to attend conferences have to pass through multiple offices and individuals, sometimes taking several months to be approved. In particular, officials raised questions about the efficiency of reviews for requests to attend conferences that incurred no cost or a low cost (under $20,000) to DOD, which at the time of GAO's review went through the same process as 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.