DOD's Conference Policy Is Generally Consistent with OMB's Requirements
GAO-14-150: Published: Jan 21, 2014. Publicly Released: Jan 21, 2014.
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.
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.
For more information, contact Johana Ayers at (202) 512-5741 or AyersJ@gao.gov.