FAM No. 98-12
June 23, 1998
FINANCIAL ADMINISTRATION MEMORANDUM NO. 98-012 (II.G.1.)
To: Bureau Assistant Directors, Administration
Director, Office of Administrative Services
Bureau Finance Officers
Finance Officer, Financial Management Services
From: Focus Leader, Asset and Debt Management
Office of Financial Management
Subject: Travel of Non-Government Personnel to Attend Meetings and
Conferences
This Financial Administration Memorandum (FAM) is being issued in
response to several inquiries we have received regarding authorizing
non-Government personnel to attend conferences and meetings at
Government expense.
Title 31 U.S.C. 1345 prohibits the expenditure of appropriations for
travel, transportation, and subsistence for meetings, except as
specifically provided by law. This section does not prohibit an
agency from paying the expenses of an employee of the United States
Government performing official duty which may include participation in
a meeting or conference attendance. The Comptroller General has ruled
that a person must be providing a direct service to the Federal
government in order to qualify for travel and transportation under the
definition of an employee as stated in 5 U.S.C. 5703 (55 CG 750).
Mere attendance at a meeting or conference by a person not holding an
appointment as an employee is not enough to qualify as an employee and
allow payment of travel and/or transportation expenses, since there is
no direct service being performed for the Federal Government.
Even though the Comptroller General recognized that conference
attendance by some State and local officials could benefit an agency
by gaining more acceptance and support for its programs, he maintained
that this would not override the direct service requirement. On the
other hand, invited officials who participate in meetings and
conferences as advisors and/or by making presentations are considered
to be providing a direct service and may receive direct reimbursement
of their travel and transportation expenses, unless they are
performing as a contractor or as an employee of a Federal Government
contractor. Persons who qualify as an employee by providing a direct
service to the Federal Government may be provided a Federal Government
travel authorization and/or transportation tickets, including
Government contract fare tickets.
Federal grant funds may be used by the grantee to pay the travel
expenses for attendance at meetings and conferences, unless
specifically controlled by the terms and conditions of the grant
agreement. Thus, a grantee may pay travel expenses which cannot be
paid directly from an agency appropriation (55 CG 750). Personnel
traveling for a grantee are not eligible to receive a travel
authorization, transportation tickets or direct reimbursement of their
travel expenses from a Government agency.
Should you have questions or require additional information on this
subject, please contact Lesley Oden on (202) 208-5223.
/s/
William E. Webber
