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GAO-03-312R: 

United States General Accounting Office: 
Washington, DC 20548: 

January 23, 2003: 

The Honorable Charles H. Taylor: 
Chairman: 
Subcommittee on Interior and Related Agencies: 
Committee on Appropriations: 
House of Representatives: 

The Honorable James P. Moran: 
Ranking Minority Member: 
Subcommittee on Legislative: 
Committee on Appropriations: 
House of Representatives: 

Subject: Library of Congress: Special Events Gift Fund Operations and
Accountability: 

Pursuant to your request, we are reporting on selected aspects of the 
Special Events Gift Fund of the Library of Congress. We are also 
providing a copy of this report today to the incoming Chairman of the 
Subcommittee on Legislative, House Committee on Appropriations. 

The Library of Congress holds a variety of special event activities in 
its public areas, including official receptions, dinners, conferences, 
and cultural, educational, and scholarly presentations. To facilitate 
the planning and coordination of its special event activities, the 
Library maintains a special events support staff, which is part of the 
Library’s Office of Special Events and Public Programs (OSEPP). For 
fiscal year 2001, the Library reported that the special events support 
staff planned over 490 individual event activities, which were 
recognized in the Library’s supporting records, as approximately 360 
special events. [Footnote 1] Of these, about one-third, or 
approximately 120, were accounted for in the Special Events Gift Fund 
(Gift Fund). [Footnote 2] Events accounted for in the Gift Fund can be 
sponsored or cosponsored by the Library, members of Congress, and 
outside organizations. The approximately 240 other special events held
in fiscal year 2001 were, according to Library officials, accounted for 
in other funds available to the Library, which include other gift and 
appropriated funds. 

The Library’s event-specific costs associated with holding the 
approximately 120 events accounted for in the Gift Fund are financed 
through contributions received from the sponsors of those events. To 
finance the salary and benefit costs of the Library staff [Footnote 3] 
who plan and coordinate all of the Library’s annual special event
activities, the Library requests from outside sponsors or cosponsors of 
events an additional contribution to the Gift Fund that is based on the 
particular room requested for the event. The room contributions on 
which the Library depends the most to fund its special events staff 
payroll come from a limited number of events that involve the use of 
the Great Hall in the Library’s Jefferson Building. The Library
reported that it held a total of 13 Great Hall events in 2001, for 
which it requested and received room contributions. 

The current suggested room contribution levels associated with the 
limited number of outside-sponsored events in the Great Hall are 
$50,000 for for-profit organizations and $15,000 for nonprofit 
organizations. These amounts were increased in January 2001 from the 
previous levels of $25,000 for for-profit organizations and $8,000 for
nonprofit organizations. The increase in suggested room contributions 
responded to the Library’s 5-year forecast that showed that funding 
needed to pay for increased salary and benefit costs associated with 
the Library’s event staff would deplete the Gift Fund’s available 
balance. According to Library officials, the increased salary and 
benefit costs were associated with needed increases in the full-time 
staffing level for the Special Events program and projected annual 
increases in the salary and benefit costs for the event staff. 

You requested that we review the Library’s Special Events Gift Fund. As 
agreed with your staff, we focused our review on the Library’s analysis 
supporting its June 2000 decision to increase suggested room 
contributions associated with the Great Hall effective January 2001, 
and key policies, procedures, and controls associated with holding the 
approximately 120 fiscal year 2001 special events that were accounted 
for in the Gift Fund. Specifically, we agreed with your staff to: 

(1) review and comment on the analysis behind the Library’s January 
2001 increase in the suggested room contributions from outside sponsors 
of events held in the Great Hall of the Jefferson Building; 

(2) identify key policies and procedures applicable to requesting, 
approving, and planning those special events accounted for through the 
Gift Fund and determine whether the Library is following those policies 
and procedures; and; 

(3) identify key accounting and control policies and procedures over 
receipts, expenditures, and the fund balance of the Gift Fund and 
determine whether the Library is following those policies and 
procedures. 

Results in Brief: 

The January 2001 increase in the suggested room contributions from 
outside-sponsored Great Hall events was based on the Library’s decision 
to fund the projected salary and benefit costs of its special events 
support staff with contributions from outside sponsors of those events 
while trying to limit the number of such events in response to concerns 
about the wear and tear on the Great Hall. To identify the level of 
contributions needed to fund the forecast salary and benefit costs of 
special events support staff over a 5-year period, in May 2000, the 
Library analyzed alternative combinations of contribution levels and 
numbers of outside-sponsored Great Hall events. [Footnote 4] 

In performing the analysis, the Library did not take into account 
alternatives for funding the forecast salary and benefit costs other 
than suggested room contributions and sponsorship for Great Hall 
events. According to Library officials, at the time of the analysis, 
demand for use of the Great Hall had been increasing. However, in the
aftermath of the terrorist attacks and the anthrax incidents on Capitol 
Hill, the Library received less in suggested room contributions from 
outside sponsors and cosponsors of Great Hall events for 2001 than it 
had projected in its the analysis. Specifically, the Library reported 3 
fewer (13 instead of 16) total events than projected for 2001: 4 fewer 
(5 instead of 9) for-profit sponsored events and one additional non-
profit event. 

The types of special event activities that can be held at the Library 
are governed by Library regulations, which also establish policies and 
procedures that guide the processes through which events are requested, 
approved, planned, and held. Library procedures provide for documenting 
the implementation of these policies and procedures, and OSEPP 
establishes what it refers to as event files to maintain this 
documentation. We examined files for 93 events that, according to 
Library officials, involved Gift Fund receipts, disbursements, or both, 
and we found that, at the time of our review, key supporting 
documentation was missing from 73 of those event files. Among the 
missing items were letters requesting approval to hold events, direct
evidence of the Library’s approval for events, key agreements required 
for the use of the facilities, and certificates of tax status for 
nonprofit sponsors. In four cases, OSEPP had difficulty finding entire 
files, which according to OSEPP staff had been misplaced following an 
office move. However, based on additional inquiries and procedures, we 
were able to conclude that the Library had generally followed its 
policies and procedures for requesting, approving, and planning these 
special events. 

In addition to event-related policies and procedures, OSEPP has 
established accounting and internal control–related policies and 
procedures for Gift Fund receipts and expenditures. While Library 
records showed that these policies and procedures were generally 
followed, we found that the policies and procedures were not sufficient 
to achieve full accountability over Gift Fund transactions and funds.
Specifically, OSEPP lacked basic financial management records for 
events involving the Gift Fund, such as schedules of receipts and 
expenditures approved by OSEPP, and thus did not have a basis for 
reconciling approved receipts and expenditures to the receipts and 
expenditures recorded in the Library’s financial management system 
(FMS) for the Gift Fund. We found errors that could have been 
identified by Library staff if the basic financial records for events 
had been maintained and reconciled to the Library’s financial 
management system. Also, OSEPP did not have a policy or related 
controls to ensure that final accountings for events were performed 
within an established time period. We found that for the files we 
reviewed, final accountings were performed on average about 5 months 
after their respective events, with some final accountings occurring 
roughly a year or more after the event. 

We are making recommendations to the Librarian of Congress to analyze 
the Library’s options for funding OSEPP staff and to strengthen 
internal control to improve the integrity of event files and strengthen 
accountability over event finances and reporting. 

In commenting on a draft of this report, the Chief of Staff of the 
Library agreed with our recommendations and has described planned 
actions to respond to them. 

Background: 

Library Special Events: 

Library of Congress regulations describe special events as gatherings 
in the Library’s public areas that involve guests and that may involve 
food and beverage service. It is the Library’s policy to encourage the 
planning and implementation of special events and public programs that 
relate to its mission, that share the treasures of its collections and 
the talents of its staff with members of other cultural and scholarly
organizations, and that attract targeted groups and individuals who 
normally might not come to the Library, potentially expanding the 
Library’s base of support. 

As a general rule, the Library limits the use of its facilities to 
Library-sponsored functions. However, the Great Hall and other public 
spaces may be used for special events sponsored or cosponsored by 
members of Congress [Footnote 5] and, since 1993, by outside 
organizations—both for-profit and nonprofit—that satisfy certain terms 
and conditions. According to Library regulations, special events 
sponsored by outside organizations must be under the full control 
[Footnote 6] of the Library, must be hosted by the Library, and must 
involve Library staff and the Library’s collections. 

The unit responsible for carrying out Library policy for special events 
is OSEPP, under the Chief of Staff of the Library. OSEPP provides the 
overall coordination and management of all special events at the 
Library. Depending on the nature of the event, OSEPP’s specific 
responsibilities can range from scheduling and coordinating the set-up 
of a room to planning and coordinating all event-related activities 
including preparing budgets; arranging for caterers, entertainment, 
security, parking, Library displays, and cleanup; and preparing the 
final accounting for events. 

According to the Library, the special events support staff planned more 
than 490 individual event activities during fiscal year 2001, 
including, in some cases, multiple activities related to what the 
Library categorized as one event. The Library treats related special 
event activities as a single event for purposes of budgeting and 
maintaining supporting documentation. According to Library records, the 
more than 490 special event activities identified by the Library were 
related to approximately 360 special events. For purposes of our 
review, events with multiple event activities were treated as a single 
event. 

Special Event Gift Fund Operations: 

Section 160 of Title 2 of the United States Code authorizes the 
Librarian of Congress to accept gifts or bequests of money for 
immediate disbursement by the Librarian in the interest of the Library, 
its collections, or its service. Contributions are to be deposited into 
the Gift Fund and are to be used consistent with the purposes of the
gift as indicated by its donor. Pursuant to its gift authority, the 
Library, in 1990, accepted a donation to establish the Special Events 
Gift Fund. In establishing the Gift Fund, the donor requested that the 
funds be made available for food, beverage, and entertainment expenses 
as well as the costs of special events personnel and miscellaneous 
related expenses. The donor also requested that others be permitted to
contribute and add to the Gift Fund subject to the purposes and 
conditions for which it was established. Of the approximate 360 special 
events held by the Library in fiscal year 2001, Library officials 
identified 123 special events involving receipts to or disbursements 
from the Special Events Gift Fund. 

Sponsoring organizations wishing to hold approved special events are 
expected to contribute the amount needed to pay the event-specific 
costs of holding the event. Library regulations refer to these event 
costs as “recoverable costs.” It is OSEPP’s responsibility to ensure 
that it receives and deposits into the Gift Fund the contribution 
needed to pay all estimated recoverable costs of a planned special event
before obligating money for the event. OSEPP staff identify and 
estimate the anticipated recoverable costs for each event. Recoverable 
costs include, but are not necessarily limited to, the direct costs of 
services such as food and beverage, audiovisual and lighting, overtime 
for Library staff, a tent at the Great Hall loading dock, production of 
signs and printed materials, and vendor charges for cleaning and other 
services. In addition to these direct costs associated with the event, 
Library policies require OSEPP to add an indirect-cost charge of 9.79 
percent of applicable direct costs. [Footnote 7] 

It is also Library policy to use funds available in the Gift Fund to 
pay the salaries and benefits of all but one of the special events 
support staff, which consists of six full-time OSEPP staff members 
[Footnote 8] and two full-time staff of the Public Program Services 
Division. In addition, the Gift Fund is used to cover the costs of 
special events for which event-specific donations were not made. To 
cover these staff and event costs, the Library suggests specific room 
contributions for events sponsored by outside organizations. [Footnote 
9] OSEPP is responsible for maintaining a schedule of suggested room 
contributions applicable to outside sponsors. The schedule provides for 
lower suggested room contributions for events that are sponsored or 
cosponsored by nonprofit organizations. In addition, for Madison 
Building events that are cosponsored by a member of Congress and an 
outside organization, the Library requests a room contribution that is 
half the amount that would apply to an event sponsored solely by an 
outside organization. 

Scope and Methodology: 

To accomplish our objectives, we: 

* reviewed the Library’s May 2000 analysis of alternative Great Hall 
room contributions to cover salary and benefits paid through the Gift 
Fund; 

* reviewed the Library’s policies and procedures for requesting, 
approving, and planning special events; 

* determined, through review of Library regulations and discussions 
with Library staff, Library policies and procedures for accounting for 
and controlling receipts, expenditures, and the fund balance of the 
Gift Fund; 

* reviewed 93 of 123 fiscal year 2001 special events identified by the 
Library as being accounted for through the Gift Fund to determine 
whether the special event folder contained documentation to support (1) 
compliance with the Library’s policies and procedures for requesting, 
approving, and planning special events, (2) the recoverable costs for 
event sponsors, and (3) the basis for the suggested room contribution; 

* reviewed the Library’s statutory gift authority; and; 

* interviewed Library officials and staff with responsibilities for 
special events operations, the Gift Fund, and related financial 
reporting, budgeting, and human resources. 

In selecting the 93 special events for review, we included all events 
held in the Great Hall, all events for which a room contribution was 
received, and all events for which the Gift Fund absorbed some or all 
of the recoverable costs of the event. In addition, we reviewed one-
half of the remaining Library- and congressionally sponsored events. In 
performing our review of the Gift Fund we considered, where appropriate,
Standards for Internal Control in the Federal Government. [Footnote 10] 

Also, we obtained written comments on a draft of this report from the 
Chief of Staff of the Library, which are included in enclosure I. 

We did our work in accordance with generally accepted government 
auditing standards from January 2002 through November 2002. 

Library’s Analysis of Suggested Contributions for Great Hall Events: 

In January 2001, the Library increased its suggested contribution for 
use of the Great Hall from $25,000 to $50,000 for for-profit 
organizations and from $8,000 to $15,000 for nonprofit organizations. 
[Footnote 11] These increases followed a May 2000 Library analysis of 
alternative combinations of suggested room contributions and numbers of 
outside-sponsored Great Hall events that would support the Library’s 
projected level of funds needed to pay forecast salary and benefit 
costs for special events support staff over the next 5 years. Following 
the analysis, the Librarian of Congress notified the members of the 
Joint Committee on the Library that, effective January 1, 2001, the 
Library would raise the suggested room contribution. 

According to Library officials, the May analysis resulted from concerns 
raised during an annual internal budget review of the Gift Fund’s 5-
year budget forecast for fiscal years 2001 through 2005. The Library 
projected that, at the existing contribution levels for the Great Hall, 
the costs that the Gift Fund would incur in filling the full-time 
special events staffing needs would, under the Library’s policy of 
funding special events support staff salaries and benefits, deplete the 
fund’s available resources within 2 years. The May 2000 analysis 
focused on identifying increases in the suggested contribution levels 
for a relatively small number of outside-sponsored Great Hall events, 
which, the Library believed at the time of its analysis, would be 
achievable. According to Library officials, at the time of the 
analysis, demand for use of the Great Hall had been increasing. The 
analysis matched different contribution levels with different totals 
and mixes of event sponsorships that could be expected to generate 
sufficient funds over the 5-year period. The objective of the analysis 
was to ensure that room contributions and the available Gift Fund 
balance would be sufficient to cover the forecast salary and benefit 
costs associated with seven full-time special events support staff 
assuming 10 percent yearly increases in the salary and benefit expense. 
Earlier, the Architect of the Capitol had raised concerns about the 
wear and tear such events might be having on the Great Hall. In light 
of those concerns, the Library’s analysis sought to identify the level 
of suggested room contributions needed to fund forecast salary and 
benefit costs while limiting the number of outside-sponsored events. 

The contribution alternative selected was based on annually holding 16 
Great Hall events sponsored by outside organizations, with 9 involving 
for-profit sponsors and 7 involving nonprofit sponsors. This 
alternative stayed within the Library’s general parameters limiting the 
number of outside-sponsored Great Hall events to help lessen wear and 
tear on the Great Hall, and was expected to provide sufficient funding 
over the 5-year period of the analysis to ensure that the Gift Fund had 
adequate resources to pay the salary and benefit costs of the seven 
full-time support staff positions charged to the Gift Fund and 
sufficient additional funding to allow the Gift Fund to cover the costs 
associated with the one remaining OSEPP staff person currently paid
from appropriated funds. 

Library officials told us that the staffing level considered in the 
analysis was the level needed to support the Library’s overall special 
events operations. However, the Library had no workload-related or 
other data to support the staffing level considered. For example, the 
Library could not provide data that related the staffing level of eight 
full-time positions to the event planning efforts associated with the
annual number of special events handled by the staff. In addition, the 
Library could not provide support for its assumption that the annual 
cost of funding those positions would increase by 10 percent per year, 
except to say that the increase was intended to cover annual cost-of-
living increases, promotions, and in-grade step increases. In this 
regard, while Office of Management and Budget (OMB) current budget 
guidelines for these factors (excluding promotions) is about half of 
what the Library used, OMB expects that agencies should base their 
estimates on their own individual data. [Footnote 12] Although the 
Library’s staffing assumptions were key to determining the amount of
and need for the suggested room contributions for the Great Hall, 
because there were no supporting data, we were unable to review the 
Library’s basis for its staffing levels or the 10 percent annual cost 
increase. 

Also, in the aftermath of the terrorist attacks and anthrax incidents 
on Capitol Hill in the fall of 2001, the Library has reported a drop in 
the expected number of outside-sponsored Great Hall events. For 
calendar year 2001, OSEPP reported a total of 13 outside-sponsored 
Great Hall events, including 5 for-profit events and 8 nonprofit 
events. This compares to the combination of 9 for-profit and 7 
nonprofit events that served as the basis for the contribution level 
needed to meet OSEPP’s salary and benefit costs as considered in the 
May 2000 analysis. The drop from the expected 16 to 13 Great Hall 
events for calendar year 2001 is even more significant given that 
actual events sponsored by for-profit organizations, which are asked to 
make the $50,000 room contribution, dropped from 9 to 5 for the year. 
This trend in the combinations of outside-sponsored Great Hall events 
continued in calendar year 2002, with the Library reporting 3 for-
profit and 11 nonprofit Great Hall events. Library officials also noted 
that the state of the economy has likely contributed to this decline. 

The drop in outside-sponsored Great Hall events has, according to 
Library officials, resulted in lower than expected amounts available to 
the Gift Fund to pay special events support staff salaries and 
benefits. Given that the Library has limited the number of outside-
sponsored Great Hall events to lessen excess wear and tear on the 
facility, it relies on relatively few events to fully fund special 
events support staff payroll. This has, at least in the short-term, 
raised a question about the Library’s ability to fund special events 
support staff salary and benefit costs. A drop of even two or three, 
especially for-profit events, can significantly affect the Library’s 
ability to fund all of the Library’s special events support staff 
salary and benefit costs from these events. 

Event Approval and Planning Is Guided by Policies and Procedures, but
Related Documentation Was Missing for Many Events: 

Through regulations, operating guidelines, and practices, the Library 
has established policies and procedures applicable to special events 
sponsored or cosponsored by the Library, members of Congress, and 
outside organizations. These policies and procedures guide the 
processes of requesting, approving, and planning events, and they 
provide for the development of supporting documentation applicable to 
each stage of preparation for an event. OSEPP is responsible for 
maintaining this documentation in event files. 

Although specific policies and procedures for reviewing and approving 
requests for special events vary by type of sponsorship, the basic 
control aspects of review and approval remain the same, as the 
following illustrate. 

* Library procedures call for requests to be documented through either 
a request form or letter submitted in advance of the event. Library 
sponsors are to submit a Special Event Request Form; outside and 
congressional sponsors are to submit a proposal letter. 

* Outside sponsors that are nonprofit organizations are required to 
submit a copy of their Certificate of Tax Status showing that they meet 
the definition of a nonprofit organization as described in Title 26, 
United States Code, Section 501(c)(3). This evidence of their status is 
needed to support the Library’s policy of suggesting lower room 
contributions for nonprofit organizations. 

* Although the specific process varies depending on the type of sponsor 
requesting the event, all requests are reviewed and considered for 
approval. Requests for events sponsored exclusively by outside sponsors 
are to be reviewed by the Library’s Facilities Committee, requests from 
members of Congress are to be reviewed and considered for approval by 
the Library’s Congressional Relations Office, and requests for Library-
sponsored events are to be reviewed and approved by Library division 
chiefs. 

Once an event has been approved, OSEPP staff work with the event’s 
sponsor to establish the nature and size of the event and then develop 
a budget for the estimated event costs. For those events sponsored or 
cosponsored by outside organizations, Library policy requires that 
event sponsors pay for the estimated recoverable costs prior to the 
event. The Library requests the applicable room contribution when the
budget of recoverable costs is presented. 

Along with written estimates of the amounts needed to fund event costs, 
OSEPP staff provide outside sponsors with guidance on how to transmit 
the contribution to the Library. Also, Library policy requires that 
outside sponsors sign a written agreement to abide by Library 
regulations and policies related to sponsoring events. OSEPP staff 
provide additional planning assistance and event oversight and control 
by requiring that guest lists, invitations and other printed material, 
seating arrangements, and entertainment and photography requirements be 
submitted for approval. 

While the Standards for Internal Control in the Federal Government 
recognize that transactions and other significant events should be 
clearly documented and the documentation properly managed and readily 
available for examination, our review found problems with key 
supporting documents in many of the events files we reviewed. 
Specifically, we found misplaced files, missing request letters or 
forms, missing evidence that events had been approved, and a lack of 
explanation or support for apparent departures from applicable 
policies. 

At the time of our review, we noted the following examples of missing, 
misplaced, or incomplete event documentation involving 73 of the 93 
event files we reviewed: 

* Files for 4 events were misplaced during a relocation of OSEPP and 
were not located until after we requested the files for our review. 

* While 72 of the events required request letters, 12 were missing from 
the event files. 

* Evidence of the Library’s approval for 54 of the total 93 events we 
reviewed was missing from the files. 

* Agreements with 12 of 28 outside sponsors were missing from the files 
or were incomplete. 

* The Certificate of Tax Status (showing that the sponsor met the IRS 
definition of a nonprofit organization) [Footnote 13] was missing from 
11 of 20 nonprofit event files. 

Federal internal control standards require that adequate supporting 
documentation be maintained and readily available to provide evidence 
that significant events have occurred and internal controls have been 
complied with. Without such documentation, the Library cannot readily 
demonstrate that special events are conducted in accordance with key 
policies and procedures or explain exceptions. Incomplete documentation 
also exposes OSEPP staff and Library management to increased risk that 
their event-related decisions may be called into question and that they 
will be unable to adequately explain or defend their decisions. While 
more than three-fourths of the OSEPP event files we reviewed were 
incomplete to some extent, we were able to conclude that the Library 
generally followed its policies and procedures related to requesting, 
approving, and planning those events through our (1) review of other 
documents in the event files, (2) understanding of the Library’s 
procedures for requesting, approving, and planning events, and (3) 
followup with OSEPP staff concerning missing records and information. 

Policies and Procedures for Receipts, Expenditures, and Fund Balance Are
Followed, but They Are Not Sufficient for Full Accountability: 

OSEPP has established policies and procedures for processing Gift Fund 
receipts and expenditures. While our review showed that these policies 
were being followed, we noted that OSEPP’s ability to achieve full 
accountability by effectively accounting for and controlling amounts 
recorded in the Gift Fund was inhibited by a lack of basic accounting 
and management records; reconciliations of receipts, expenditures, and
fund balance; and controls over event final accountings. 

Established Policies and Procedures over Gift Fund Receipts, 
Expenditures, and Fund Balance Were Generally Followed: 

OSEPP has instituted event planning and close-out policies and 
procedures that are intended to account for and control event-related 
receipts and expenditures. These policies and procedures include 
requirements for event budgets, advance payments, and final 
accountings. Regarding budgets, OSEPP policy requires that a budget be
developed for all the recoverable costs of special events. Budgets 
assist OSEPP management in planning and monitoring event costs and 
support the Library’s request to sponsors for contributions to cover 
the estimated recoverable costs of the event and, where applicable, for 
suggested room contributions. Event budgets are to itemize estimated 
event costs and include direct costs (such as catering, tent rental,
sound systems, set-up and cleaning service, and overtime for Library 
personnel), indirect costs (9.79 percent of direct costs), and 
applicable suggested room contributions. After developing the event 
budget, OSEPP staff are to inform the sponsor and request that a 
contribution for the estimated amount be made to the Gift Fund. We 
found that the Library had prepared budgets as applicable for the 93 
events we reviewed. 

OSEPP policy requires that the Library receive all funds in advance for 
those events sponsored or cosponsored by outside organizations. 
Requiring advance funding helps to ensure that the Gift Fund receives 
the amount it needs to pay for all recoverable event costs. The policy 
requires sponsors to fund an amount equal to 50 percent of the event 
budget no later than 30 days after notification that the Library has 
approved the event. The remaining balance is due no later than 30 days 
prior to the event. While we did not test the specific time frames 
provided for in the policy, our review of the 93 event files showed 
that the Library generally received the contributions it requested 
prior to the events’ being held. There were eight exceptions to this 
policy in which funds were not received in advance of the event, but 
the supporting documentation in the file did not provide a reason for 
the exceptions. Five of the eight were received within 13 days after 
the event. For the other three events, funds were not received prior to 
the Library’s final accounting. 

After an event has been held, OSEPP policy requires that a final 
accounting be performed once OSEPP staff have received and approved 
invoices from vendors and all event-related expenditures have been 
made. The final accounting represents a key control that helps ensure 
that the Gift Fund receives funds for all recoverable event costs and 
that it refunds any over-funding by sponsors. OSEPP prepares a final
accounting that itemizes event-related expenditures and compares the 
expenses to the advance contribution received. If a sponsor’s advance 
contribution is less than the actual costs identified in the final 
accounting, OSEPP is to request an additional payment from the sponsor. 
If the sponsor’s advance contribution exceeds actual expenditures, the 
Library is to offer the donor the choice of requesting a refund or 
donating the excess to the Gift Fund. At the time of our review, final 
accountings had been completed for 88 of the 93 fiscal year 2001 events 
we reviewed. Additional information on final accountings is presented 
in table 1 later in this report. 

Additional Receipt and Expenditure Policies Are Needed to Strengthen
Accountability: 

While existing policies for financial operations were generally 
followed for the events we reviewed, we determined that they were not 
sufficient to achieve full accountability over Gift Fund activity. 
Specifically, policies did not call for OSEPP to maintain certain 
accounting records that could be used to reconcile event receipts and 
expenses to the separate Gift Fund records maintained in the Library’s 
FMS. Also, final accounting policy did not call for final accounting to 
be completed promptly. 

Lack of OSEPP Accounting Records Limits Accountability: 

The Library accounts for Gift Fund transactions and the fund balance in 
its FMS. While OSEPP, as discussed previously, is to maintain 
individual event files, there were no policies and procedures for 
effectively monitoring and comparing OSEPP approved receipts and 
expenditures to amounts recorded in the Library’s FMS to ensure that 
all Gift Fund transactions are completely, promptly, and accurately
recorded. 

In addition, OSEPP staff did not maintain basic accountability records 
needed to show the status of efforts to complete final accountings, 
collect amounts owed, and refund excess amounts. Such records would 
normally include journals of payments received and expenses approved, 
records detailing how much is owed to the Gift Fund and how long it has 
been outstanding, and status reports summarizing, by event, all special 
event financial transactions. Status reports can include information
such as the event date and sponsor, the budget estimate number, 
[Footnote 14] contributions received, estimated and actual expenses, 
the date final accounting is completed, the amount owed by or to the 
sponsor, and the date the final payment is received or paid. 

The importance of OSEPP’s having the accounting information described 
above and reconciling that information to comparable information 
recorded in the Library’s FMS is demonstrated by the errors noted 
below, which thorough and timely reconciliations would be expected to 
identify. 

* OSEPP staff did not include approximately $839 in food costs in the 
final accounting for one event. Because OSEPP expense records were not 
reconciled with Gift Fund expenses recorded by the Financial Services 
Office, OSEPP staff did not detect the omission. 

* OSEPP did not identify nine Gift Fund expenditures, totaling more 
than $85,000, that were recorded in the wrong fiscal year in FMS 
records. A comparison of a complete list of events held in fiscal year 
2001 to the FMS records would have disclosed the error. 

* OSEPP did not identify approximately 12 hours of erroneous overtime 
charges to the Gift Fund totaling about $350. A comparison of overtime 
charges paid from the Gift Fund to OSEPP supporting records would have 
disclosed these erroneous charges. 

Our review of event files identified other matters that would likely 
have been identified by OSEPP staff if basic accounting records were 
maintained. Accounting records that record, summarize, and report 
amounts owed and received would have allowed OSEPP management to 
identify that the following transactions were not properly completed. 

* A sponsor’s refundable contribution of $1,604 was not identified as 
needing to be refunded until we brought the matter to OSEPP’s attention 
in August 2002, even though the event, scheduled for September 12, 
2001, had been canceled. 

* A $100 sponsor’s check was put into an event file and not processed 
for deposit by OSEPP staff. OSEPP staff said that the check was not 
deposited because the event file was one of a group of files that was 
lost for several months during an OSEPP office move. 

Weak Controls over Final Accounting Contribute to Unresolved Errors: 

OSEPP’s accounting procedures require a final accounting for all Gift 
Fund events. When performed promptly after all event-related 
expenditures are made, final accounting helps ensure that amounts owed, 
whether to sponsors or to the Library, are identified and paid. 
However, at the time of our review, the Library did not have a policy 
or related controls to ensure that final accountings for events were 
performed within an established time period. In addition, the Library 
did not have controls to ensure the final accountings properly included 
all relevant costs or that no costs were inappropriately charged to the 
Gift Fund. For example, overtime charged by Library staff to the Gift 
Fund is to be verified during the final accounting. However, for the 
payroll records we tested, we found that about $1,300 in overtime 
involving six events was incorrectly charged to the Gift Fund. The 
costs of these six events should have been charged to other funds 
available to the Library. Four of these six events were held between 
November 2000 and March 2001, but as of September 2002, the final 
accounting for these events had not yet been completed. 

In fiscal year 2001, all events held in the Great Hall were to be 
assessed a tent fee to recover the Library’s cost of leasing a tent to 
shelter catering preparations on the Great Hall loading dock. Library 
officials told us that the fee assessed for use of the tent varied by 
the type of event sponsor. For-profit sponsors were to be assessed a 
fee of $1,250; nonprofits sponsors, $1,000; and Library sponsors, $750. 
However, OSEPP did not have written guidance to assist OSEPP staff in 
preparing the final accounting for these events. Our review of 33 final 
accountings for events involving the use of tents showed that for 14 
events the Library’s policy on tent fees was not consistently applied. 
In some cases sponsors were charged too much, in other cases sponsors 
were not charged at all. 

Although an OSEPP official stated that OSEPP’s efforts in fiscal year 
2001 were focused on completing the final accounting of events 
sponsored by outside organizations, the Library had generally not 
established an overall policy for promptly completing final 
accountings. Our review of 87 final accountings completed for fiscal
year 2001 events showed that on the average they were completed 5.1 
months after an event was held. Table 1 also shows that for nine 
events, the final accounting took roughly a year or more to complete. 

Table 1: Timing of Final Accounting for 87 Special Events at the 
Library of Congress: 

Outside-sponsored events: 
Aging of account from day of event to final accounting: 30: 0; 
Aging of account from day of event to final accounting: Over 30: 2; 
Aging of account from day of event to final accounting: Over 60: 5; 
Aging of account from day of event to final accounting: Over 90: 11; 
Aging of account from day of event to final accounting: Over 120: 8; 
Aging of account from day of event to final accounting: Over 180: 2; 
Aging of account from day of event to final accounting: Over 360: 0; 
Aging of account from day of event to final accounting: Total events: 
28; 
Average number of days between event and final accounting: 110. 

Library-sponsored events: 
Aging of account from day of event to final accounting: 30: 0; 
Aging of account from day of event to final accounting: Over 30: 1; 
Aging of account from day of event to final accounting: Over 60: 3; 
Aging of account from day of event to final accounting: Over 90: 7; 
Aging of account from day of event to final accounting: Over 120: 6; 
Aging of account from day of event to final accounting: Over 180: 0; 
Aging of account from day of event to final accounting: Over 360: 2; 
Aging of account from day of event to final accounting: Total events: 
19; 
Average number of days between event and final accounting: 153. 

Congress-sponsored events: 
Aging of account from day of event to final accounting: 30: 0; 
Aging of account from day of event to final accounting: Over 30: 1; 
Aging of account from day of event to final accounting: Over 60: 6; 
Aging of account from day of event to final accounting: Over 90: 10; 
Aging of account from day of event to final accounting: Over 120: 13; 
Aging of account from day of event to final accounting: Over 180: 3; 
Aging of account from day of event to final accounting: Over 360: 7; 
Aging of account from day of event to final accounting: Total events: 
40; 
Average number of days between event and final accounting: 183. 

Total events: 
Aging of account from day of event to final accounting: 30: 0; 
Aging of account from day of event to final accounting: Over 30: 4; 
Aging of account from day of event to final accounting: Over 60: 14; 
Aging of account from day of event to final accounting: Over 90: 28; 
Aging of account from day of event to final accounting: Over 120: 27; 
Aging of account from day of event to final accounting: Over 180: 5; 
Aging of account from day of event to final accounting: Over 360: 9; 
Aging of account from day of event to final accounting: Total events: 
87. 

Average days: 
Average number of days between event and final accounting: 153. 

Source: GAO analysis based on Library of Congress data. 

Note: Of the 93 events we reviewed, final accounting for 1 event was 
undated, 2 were in process, and final accountings for 3 other events 
were not being prepared for various reasons. 

[End of table] 

The 87 final accountings that had been performed by the Library 
identified about $19,200 in refunds owed to 40 sponsors and about 
$68,900 due from 46 sponsors. In its comments on our report, the 
Library stated that all monies have been refunded or collected in full 
except for one event (see enclosure I). We did not attempt to verify
the refunds or collections. 

OSEPP management has indicated that the office has recently begun to 
follow an unwritten policy of completing final accounting for all 
outside-sponsored events within 3 months of the event. According to 
OSEPP management, due to time and staffing limitations, more time is 
allowed for completing the final accountings for internally sponsored 
events. 

Conclusions: 

The Library’s May 2000 analysis of funding the projected salary and 
benefits costs of its special events support staff over the next 5 
years only considered suggested room contributions from outside 
sponsors of Great Hall events. This approach leaves the funding of 
special events support staff salaries and benefits dependent on the room
contributions for relatively few events. In addition, the Library could 
not provide data or information to support the key assumptions it made 
in conducting its analysis. In the aftermath of the terrorist attacks 
and anthrax incidents on Capitol Hill in the fall of 2001, the Library 
has not held the number of outside-sponsored Great Hall events assumed 
in the analysis. Whether or not the reduced number of events is a short-
term or longer-term issue is unknown. However, the drop in outside-
sponsored events raises a question about the Library’s ability to rely 
on a limited number of events to fully fund the salary and benefit 
costs of the staff needed to support the Library’s special events 
program. 

The Library of Congress has policies and procedures to guide OSEPP in 
managing special events at the Library. Because special event records 
were missing from many of the event files we reviewed, the Library did 
not have ready assurance that special events were conducted in 
accordance with Library policies and procedures and that departures 
from policy had been approved. Unless OSEPP takes actions to strengthen 
its control over its event files, it may not be able to show that its 
events are being conducted in accordance with its policies and 
procedures or to explain exceptions. Also, OSEPP has instituted 
policies and procedures to account for and control event-related 
receipts and expenses, which it generally follows. However, it does not 
have the basic accounting and management records it needs to provide 
full accountability for the Gift Fund. Without accounting information 
that can be readily summarized, reviewed, and reconciled, those 
responsible for the Gift Fund cannot adequately monitor final 
accountings for events or the appropriateness and completeness of the 
receipts and expenditures recorded in the Gift Fund. 

Recommendations: 

To help ensure that the Library of Congress has the ability to fund the 
salary and benefit costs of personnel who support the Library’s overall 
special events activities, the Librarian of Congress should direct the 
Library’s Financial Services Director to work with OSEPP to conduct a 
new analysis that considers various options for funding forecast salary 
and benefits costs of special events support staff. In conducting this 
analysis, the Library should develop and maintain documentation to 
support the assumptions incorporated into the analysis. 

To help improve the Library’s internal control over event files and 
their contents, the Librarian of Congress should direct the Library’s 
Financial Services Director to work with OSEPP to: 

* develop documentation standards for maintaining event files; 

* require periodic review of event folders to ensure compliance with 
Library policies and procedures, and; 

* develop policies for including in events files documentation for 
exceptions or deviations from policies. 

To improve the Library’s accounting for and control of the funds in the 
Special Events Gift Fund, the Librarian should direct the Financial 
Services Director to work with OSEPP to: 

* establish basic accounting records in OSEPP for the Gift Fund, 
including receipts, expenses, amounts due, and amounts owed by event; 

* establish a policy to reconcile, on a monthly basis, OSEPP’s Gift 
Fund receipts and disbursements to amounts maintained in the Library’s 
FMS; 

* compile a monthly status report as a tool for monitoring the 
operations and finances of the Gift Fund. The report could include 
event-specific information, such as event date, sponsor, budget event 
number, budgeted expenses, payments received to date, expenses incurred 
to date, amount and date of final billing, and amount owed to or from 
event sponsor; and; 

* establish a policy for completing all final accountings on a timely 
basis. 

Agency Comments: 

We provided the Chief of Staff of the Library with a draft of our 
report for review and comment. In written comments on the draft, the 
Chief of Staff agreed with our recommendations and noted the Library’s 
planned actions to respond to our recommendations. In addition, the 
Chief of Staff’s comments noted the need for a few technical 
clarifications, which have been incorporated into our final report as
appropriate. 

The Chief of Staff’s comments are reprinted in enclosure I. 

We are sending copies of this report to the Chairman, Subcommittee on 
Legislative, House Committee on Appropriations; the chairmen and 
ranking minority members of the House Committee on Government Reform; 
the Senate Committee on Governmental Affairs; and the Subcommittee on 
Legislative Branch, Senate Committee on Appropriations. We are also 
sending it to the Chairman and Vice Chairman of the Joint Committee on 
the Library and the Librarian of Congress. This report will also be 
available on the GAO’s home page at [hyperlink, http://www.gao.gov]. 

If you have any questions concerning this report, please contact me at 
(202) 512-9406, or by e-mail at franzelj@gao.gov, or John Reilly, 
Assistant Director, at (202) 512-9517 or by e-mail at reillyj@gao.gov. 
Key contributors to this report were Louis Fernheimer, Jacquelyn N. 
Hamilton, Benjamin W. Smith, and Gail F. Vallieres. 

Signed by: 

Jeanette M. Franzel: 
Director: 
Financial Management and Assurance: 

Enclosure: 

[End of correspondence] 

Enclosure 1: 

The Library Of Congress: 
Office of the Librarian: 
Washington, D.C. 20510-1000: 

January 7, 2002: 

Ms. Jeanette M. Franzel: 
Director: 
Financial Management and Assurance: 
United States General Accounting Office: 
Washington, DC 20548: 

Dear Ms. Franzel: 

Thank you for the opportunity to review and comment on the General 
Accounting Office (GAO) draft report on the results of your review of 
the operations of and accountability for the Library of Congress's 
Special Events Gift Fund. As you are aware, the Library requested that 
the Congress approve the Library's guidelines and policies for the 
hosting of special events and programs, which is a prerequisite for 
implementation of a new Special Events and Programs revolving fund. 

GAO's draft is very timely and helpful in supporting our efforts to 
implement a new revolving fund structure for this program. In general, 
we agree with the GAO draft recommendations and plan to incorporate 
their implementation into the new revolving fund structure. We are 
pleased that GAO found that the Special Events Office generally follows 
its policies and procedures relating to requesting, approving, and 
planning events. The enclosure presents a detailed response to each of 
the GAO draft recommendations and provides a few technical 
clarifications to the draft report. 

I very much appreciate your thoughtful attention to our concerns 
throughout this review. 

Sincerely, 

Signed by: 

JoAnn C. Jenkins: 
Chief of Staff: 

Enclosure: 

January 7, 2003 

Library Of Congress: 
Response To GAO's Review Of The Special Events Gift Fund: 

Funding Salary and Benefit Costs: 

1. GAO recommendation: CFO and OSEPP should conduct a new analysis that 
considers various options for funding OSEPP's forecast salary and 
benefits costs. Develop and maintain documentation to support the 
assumptions incorporated into the analysis. 

Library of Congress Response: The Financial Services Directorate and 
OSEPP will collaboratively review and evaluate available options, and 
maintain a record of factors considered, for funding of OSEPP 
salaries/benefits as planning for revolving fund status continues. 

Internal Controls Over Event Files: 

2. GAO recommendation: Develop documentation standards for maintaining 
the files. 

Library of Congress (LC) Response: OSEPP staff currently uses an event 
checklist, one component of which concerns required documentation for 
events files. As part of the revolving fund implementation, the Library 
plans to automate this check list review, thereby improving oversight 
of events management and file maintenance. 

3. GAO recommendation: Require periodic review of event folders to 
ensure compliance with Library policies and procedures. 

Library of Congress (LC) Response: The Office currently reviews folders 
regularly until the final accounting of actual event costs is prepared. 
The new automated system will enable the Office to produce daily 
reports for multiple events, facilitating more frequent review to 
ensure compliance with Library policies and procedures. The Chief, 
OSEPP has established a policy requiring periodic review of event 
folders and will advise the staff. 

4. GAO recommendation: Develop policies for including in its events 
files documentation for exceptions or deviations from policies. 

Library of Congress (LC) Response: The Special Events Office has 
emphasized the importance of documenting all exceptions and deviations 
from policies in event files. As OSEPP moves to revolving fund 
implementation, it will continue to document all exceptions and 
deviations from policies. The policy requiring periodic event files 
review should ensure necessary documentation is included in events 
files. The Chief, OSEPP has established a policy requiring 
documentation for exceptions/deviations and will advise the staff.
Accounting for and Control of the Special Events Gift Fund 

5. GAO recommendation: Establish basic accounting records in OSEPP for 
the Gift Fund, including receipts, expenses, amounts due, and amounts 
owed by event. 

LC Response: As part of the revolving fund implementation, the Library 
plans to establish two new funds in the central financial management 
system (CFMS) to account for special events-indirect and direct fund. 
The direct fund will be used to track all receipts and expenses for 
events funded by outside entities through the new special events 
revolving fund. The Library also plans to establish subsidiary 
accounting records for individual special events that can be reconciled 
to the new CFMS fund. The indirect fund will be used to track all 
indirect receipts (e.g., room contributions) and expenses (e.g., 
salaries not chargeable to a specific event). 

6. GAO recommendation: Establish a policy to reconcile on a monthly 
basis OSEPP's Special Events Gift Fund receipts and disbursements to 
amounts maintained in the Library's CFMS. 

LC Response: As described above, the Library plans to establish a 
reconciliation requirement as part of the new revolving fund 
implementation. 

7. GAO recommendation: Compile a Gift Fund monthly status report as a 
tool for monitoring the operations and finances of the fund. The report 
could include event-specific information, such as event date, sponsor, 
budget event number, budgeted expenses, payments received to date, 
expenses incurred to date, amount and date of final billing, and amount 
owed to or from event sponsor. 

LC Response: The Library agrees that a status report for the new direct 
fund is needed, but the timing and content of that report will develop 
during the implementation of the new revolving fund. 

8. GAO recommendation: Establish a policy for completing all final 
accountings on a timely basis. 

LC Response: In FY 2002, OSEPP began completing final accountings 
within three months following an event. OSEPP will continue to follow 
this policy as part of the new revolving fund implementation, assisted 
by the new automated system. 

Technical Clarifications: 

Technical clarification: The report on page 1 states that OSEPP planned 
over 360 events in FY 2001. The auditors counted events based on 
assignment of budget control numbers. However, more than one event may 
be encompassed within one budget control number. Accordingly, OSEPP 
statistics reflect that 493 events were planned in FY 2001. 

Technical clarification: The report on page 5 and 7 states that OSEPP 
provides overall coordination and management of special events with 
eight full-time staff positions. OSEPP has six full-time positions, all 
of which are funded through the Special Events Gift Fund, with the 
exception of the Special Events Officer position which is an 
appropriated fund position. The Public Program Services Division also 
works with OSEPP in supporting Library events. Two other full-time 
positions in the Public Program Services Division are supported by the 
Special Events Gift Fund. 

Technical clarification: The report on page 20 states that 87 final 
accountings that had been performed by the Library identified about 
$19,200 in refunds owed to 40 sponsors and about $68,900 due from 46 
sponsors. With the exception of one event, all monies have been 
refunded or collected in full. 

[End of enclosure] 

Footnotes: 

[1] For final accounting and control purposes, the Library treats 
related special event activities as a single event. 

[2] Pursuant to its gift fund authority and a 1990 donation, the 
Library created the Special Events Gift Fund to make funds available 
for food, beverages, entertainment, personnel, and other miscellaneous
expenses related to hosting special events. 

[3] The Gift Fund pays salaries and benefits of all OSEPP staff except 
for the Special Events Officer, who is currently paid from appropriated 
funds. 

[4] Because the Library could not provide data or other information 
used in preparing the analysis, we were unable to review the support 
underlying the assumptions about projected costs. 

[5] Congressionally cosponsored events involve a member of Congress and 
an outside organization. 

[6] Library of Congress regulations (LCR) define “full control” as 
final approval of and responsibility for invitation texts, guest lists, 
budgets, caterers, support personnel, and facilities management (LCR 
1818-3 Section 4.B.1.b, reviewed May 28, 1998). 

[7] The indirect-cost charge is intended to recover for the library 
indirect costs associated with support provided to the special events 
activities by various Library administrative functions, including 
financial services, general building overhead, information technology 
support, and management and human resources. 

[8] The salary and benefits of the Special Events Officer, one of the 
six OSEPP full-time staff, are currently paid from appropriated funds. 

[9] The suggested room contribution applies to outside sponsors who 
request the use of the Great Hall, which is located in the Jefferson 
Building, and the Montpelier Room, Mumford Room, Pickford Theater, 
Madison Hall, and selected dining rooms, which are located in the 
Madison Building. 

[10] U. S. General Accounting Office, Standards for Internal Control in 
the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 
1999). 

[11] The suggested room contributions for the various Madison Building 
rooms (which range from $500 to $5,000) were not changed. 

[12] While OMB guidance in not applicable to the Library of Congress, 
we used it for contextual purposes. 

[13] 26 U.S.C. 501(c)(3). 

[14] The budget estimate number is the unique number assigned to each 
event on the form Estimated Expenditure of Funds for Entertainment. The 
library uses the budget estimate form internally to approve the budgets 
for each special event. 

[End of section] 

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