IM OA 2015-02, Conference and Sponsorship Management and Reporting

Issuance Date: May 7, 2015

Expiration Date: Effective until Rescinded

1. Purpose. 

This U.S. Geological Survey (USGS) Instructional Memorandum (IM) supersedes IM AEI 2014-03 and provides policy on conference-related activities and spending.

2.  References. 

A.  Department of the Interior Financial Management Memorandum (DOI FMM) 2015-010 (Vol. VI.B.), Revised Authorization and Reporting Guidance on Conference-Related Activities and Spending.

B.  Office of Management and Budget Memorandum M-12-12, Promoting Efficient Spending to Support Agency Operations (OMB Memorandum M-12-12) (https://www.whitehouse.gov/sites/default/files/omb/memoranda/2012/m-12-12.pdf). 

C.  Consolidated and Further Continuing Appropriations Act, 2015, P.L. 113-235, and the Consolidated Appropriations Act, 2014, P.L. 113-76 (Public Laws).   

D.  Federal Travel Regulations (FTR) (http://www.gsa.gov/portal/content/104790).

E.  Federal Acquisition Regulation (FAR) (http://www.acquisition.gov/far/).

F.  The Campaign to Cut Waste SharePoint site includes all conference guidance, approval package template, and other related materials posted for convenient access  (https://collaboration.usgs.gov/aei/cctw/default.aspx).

3.  Definitions.  Conference, sponsorship, and travel definitions are identified in the DOI FMM, OMB Memorandum M-12-12, the Public Laws, and the FTR. 

4.  Policy.

All events held or attended should be evaluated to determine if they should be managed according to conference policy.  The appropriate USGS Executive Leadership Team (ELT) member determines if an event is a conference based on a fact-based evaluation of the event using the definitions and criteria in the DOI FMM, OMB Memorandum M-12-12, and the FTR.  The determination of mission (operational) or formal training is submitted by the ELT member to the appropriate USGS Deputy Director for review and approval.  If an event is determined to be mission (operational) or formal training versus a conference, attendance is not managed under conference guidelines.  All conference planning, attendance, approvals, and reporting must be in accordance with the DOI FMM and this IM. 

5.  Approvals.

A.  Conferences.

(1)  Conference attendance is approved based on guidelines in the DOI FMM. 

(2)  Conferences with total costs estimated to be $40,000 or more require DOI approval. 

(3)  Conferences with total costs estimated to be $20,000 or more require USGS Director approval.

(4)  Conferences with total costs estimated to be less than $20,000 will be managed according to the DOI FMM, Paragraph 2, Duties, Part A, paragraphs 1-4, which require oversight of conference attendance and spending for all conferences.  Managers and supervisors who approve conference attendance are responsible for complying with this guidance. 

(5)  The conference lead is responsible for managing the approval process, including, coordinating with the Office of Acquisition and Grants and sponsorship lead, managing attendance and after-conference reporting requirements. 

(6)  Proposed conference attendees may not attend or make irrevocable financial conference arrangements until the conference is approved.

B.  Sponsorships.

(1)  All sponsorships require approval before obligating funds or making firm commitments with conference hosts, cooperative partners, or grantees.

(2)  Sponsorships totaling $10,000 or more for a single event must be approved by the Deputy Secretary of the Interior. 

(3)  Sponsorships totaling less than $10,000 are approved by the USGS Director. 

(4)  Sponsorship approval requests must be coordinated with the conference lead (if one has been assigned), surnamed by the appropriate ELT member, and submitted to the USGS Director’s Office through the DOI Data Tracking System (DTS) using the format specified in the DOI FMM.

6.  Planning.

A.  Conference planning will be accomplished in accordance with the above-mentioned references. 

B.  The Bureau maintains automated conference planning tool(s) to provide a comprehensive repository of planned conference attendance and total conference costs.



C.  All employees are required to enter all projected conference costs (attendance, travel, contracts, etc.) into the automated planning tool(s).

D.  The Bureau Conference Coordinator assigns conference leads for each conference estimated to reach $10,000, including sponsorship.

E.  If required, the conference lead is responsible for managing the approval process, including:

(1)  Preparing a conference package, entering it into DTS, and obtaining all required surnames for approval.

(2)  Coordinating conference package with sponsorship.

(3)  Attendance and after-conference reporting requirements. 

F.  Program coordinators and managers with commitment authority for Federal funds must enter projected agreement and contract conference costs into the automated planning tool(s).

G.  Sponsorship requestors, in coordination with the conference lead, must enter sponsorship into the automated planning tool(s).  

7.  Reporting.

A.  Reporting will be accomplished in accordance with the DOI FMM, OMB Memorandum M-12-12, and the Public Laws, referenced above. 

B.  USGS hosted or cohosted conferences with actual total costs of $20,000 or more must be reported to the DOI Inspector General within 15 days of the conference. 

C.  Conferences with total actual costs greater than $100,000 have additional, more detailed annual reporting requirements as found in the DOI FMM. 

D.  The conference lead with assigned responsibility for a particular conference is responsible for reporting on all conferences that meet reporting thresholds.

E.  The Bureau Conference Coordinator will issue additional reporting guidance as required. 

F.  All USGS employees will support conference reporting requirements by accurately projecting costs in conference planning tools and filing travel vouchers within 5 days of the conclusion of a conference. 

8.  Responsibilities. 

A.  USGS Director, in cooperation with ELT members and Bureau Conference Coordinator:

(1)  Maintains a set of processes and internal controls that ensure all conference-related activities are directly in support of the USGS mission.

(2)  Provides scrutiny to ensure that conference hosting, sponsorship, attendance, and expenses are directly and programmatically related to their purpose and limited to only the levels required to carry out the goals of the Bureau.

(3)  Assures that there is consideration of alternative means to achieve mission goals.

(4)  Applies strict management and supervisory control to ensure reports and records are accurate, timely, and complete. 

(5)  Approves sponsorships when the total amount is less than $10,000. 

(6) Approves attendance at conferences with estimated total costs of $20,000 or more but less than $40,000

(7)  Recommends DOI approval for conferences with estimated costs of $40,000 or greater.

B.  Deputy USGS Director(s). 

(1)  Reviews and approves ELT determinations of mission (operation) meetings and formal training.

(2)  Approves conferences as delegated by the USGS Director.  

 

C.  Associate Director for Administration. 



(1)  Administers the conference and sponsorship approvals and reporting processes.



(2)  Ensures that internal controls for conference and sponsorship policies are effective.



D.  ELT Members.



(1)  Manage conference attendance to ensure:



(a)  Conference-related activities are necessary and consistent with the USGS mission.



(b)  Compliance with the overall intent of the policy to minimize conference-related spending.



(c)  Compliance with FTR (lodging, miscellaneous and incidental expenses, per diem reimbursement).



(2)  Maintain processes and internal controls sufficient to ensure that conference policies, including planning, approval, and reporting processes, are adhered to within their respective region, mission area, or office. 



(3)  Ensure that grants, cooperative agreements, and contracts are not used to pay for or defray the cost of a conference except when the conference is directly and programmatically related to the purpose for which the funds were awarded.  For example, a conference held in connection with planning, training, assessment, review, or other routine purposes related to a project funded by the grant or contract.



(4)  Evaluate and determine if a meeting, workshop, symposium, or like event meets the criteria for mission (operational) or formal training as defined by the DOI FMM, OMB Memorandum M-12-12, and the FTR. 



(a)  This determination must be documented on a signed memorandum for the record and approved by the appropriate USGS Deputy Director.



(b)  The signed memorandum is maintained in the ELT organization’s files.  At a minimum, this memorandum must include the name, date, host organization, location, estimated number of attendees, estimated total cost, and the justification.



(c)  Appoint a conference lead for their respective region, mission area, or office to administer conference approval and reporting processes within their organization. 



E.  Science Center Directors and Cost Center Managers. 



(1)  Manage conference attendance to ensure:



(a)  Conference-related activities are necessary and consistent with the USGS mission.



(b)  Compliance with the overall intent of the policy to minimize conference-related spending.



(c)  Compliance with the FTR (lodging, miscellaneous and incidental expenses, per diem reimbursement, etc.)

(2)  Maintain management processes and internal controls sufficient to ensure that conference policies, including planning, approval, and reporting processes, are adhered to within their respective science or work centers.

(3)  Ensure that grants, cooperative agreements, and contracts are not used to pay for or defray the cost of a conference except when the conference is directly and programmatically related to the purpose for which the funds were awarded.  For example, a conference held in connection with planning, training, assessment, review, or other routine purposes related to a project funded by the grant or contract.

(4)  Provide detailed information on conference costs and conference attendance in accordance with DOI FMM reporting and planning requirements. 

F.  Program Coordinators and Managers with Commitment Authority for Federal Funds.



(1)  Ensure that grants, cooperative agreements, and contracts are not used to pay for or defray the cost of a conference except when the conference is directly and programmatically related to the purpose for which the funds were awarded.  For example, a conference held in connection with planning, training, assessment, review, or other routine purposes related to a project funded by the grant or contract.



(2)  Enter projected agreement and contract conference costs into the automated planning tool(s).

(3)  Provide detailed information to the conference lead on conference costs and attendance funded by their program in accordance with DOI FMM planning, approval, and reporting requirements. 

G.  USGS Employees.

(1)  Are responsible for being knowledgeable of and in compliance with conference policies and procedures, including:

(a)  Ensure that conference-related activities are consistent with the USGS mission.

(b)  Ensure compliance with the overall intent of the policy to minimize conference-related spending.

(2)  Support conference planning, approval, and reporting processes by:

(a)  Projecting conference attendance and costs in automated conference management tools.

(b)  Only obtaining lodging within or below per diem.

(c)  Reporting when meals are included in registration fees.

(d)  Complying with USGS guidance on conference non-technical and extracurricular events (see Deputy Director memoranda dated July 10, 2012 and September 28, 2012, available internally on the “campaign to cut waste” SharePoint site under “conferences”).



(e)  Finalizing attendance arrangements only after being notified of approval.



(f)  Filing travel vouchers within 5 days of the conclusion of conference attendance. 

H.  Chief, Office of Acquisition and Grants.

(1)  Maintains process controls and procedures to ensure that potential cooperative agreement partners and contractors are aware of the requirement to adhere to Federal conference policies and procedures, including pre-conference planning, appropriateness of expenditures, and post-conference reporting.



(2)  Develops procedures to obligate cooperative agreements and contract awards following all applicable Federal conference policies and procedures, including planning, hosting, sponsoring, and reporting requirements.



(3)  Develops internal controls to ensure that no conference sponsorships are finalized in the acquisition process prior to proper approval as prescribed in the DOI FMM.



I.  Chief, Office of Financial Management and Accounting.

(1)  Provides guidance, in the form of a Financial Operating Procedures Handbook chapter, outlining procedures for employees to follow in preparing travel authorizations for conference attendance and the location where reports can be obtained to assist with conference cost reporting.

(2)  Assesses the effectiveness of internal controls over conference and sponsorship procedures as prescribed in the DOI FMM guidance.

J.  Bureau Conference Coordinator.

(1)  Acts as a liaison between the USGS and the DOI. 

(2)  Manages Bureau planning, approval, and reporting processes for conferences and sponsorships, including:

(a)  Manages DOI reporting and data calls based on input from the conference leads. 

(b)  Determines when conferences require reporting to DOI and coordinates with conference lead to obtain required data. 

(c)  Determines when conferences require USGS or DOI approval and assigns conference leads. 

(d)  Assists conference leads with conference guidance and approval processes.

(e)  Reviews conference packages and sponsorships to ensure completeness and compliance with policies. 

(f)  Manages and coordinates development of automated conference planning tools.



(g)  Prepares and maintains the annual conference plan and quarterly updates based on input from the conference leads. 

 

(h)  Maintains an updated list of conference leads.



K.  Conference Leads.



(1)  Administer the conference policy within their respective mission area, region, or office. 

(2)  Provide detailed information on conference costs for conferences held and attended by their mission area, region, or office subordinate organizations in accordance with the DOI FMM reporting and planning requirements. 

(3)  Manage conference planning, approvals, and data calls; maintains the annual conference plan; and acts as the liaison between their mission area, respective region, or office and the Bureau Conference Coordinator. 

(4)  Manage the conference approval process, reporting requirements, and attendance for assigned conference(s) when conferences are estimated to meet approval thresholds. 

(5)  Prepare reports on all assigned conferences which meet actual cost or detailed reporting thresholds. 

(6)  Manage actual conference attendance, including notifying attendees if they are approved to attend or not, and the substitution process to ensure approved costs are not exceeded for assigned conferences. 

  



/s/ Jose R. Aragon                                                                                          May 7, 2015

                                                                                              

Associate Director for Administration