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ADM IL-12-01 Policy on Management and Approval of Conferences and Award Ceremonies

GENERAL SERVICES ADMINISTRATION
      Washington, D.C. 20417

 

ADM IL-12-01
April 15, 2012



GSA INSTRUCTIONAL LETTER



SUBJECT:  Policy on Management and Approval of Conferences and Award Ceremonies

1.  Purpose.  This Instructional Letter (IL) provides internal General Services Administration (GSA) policy, controls, and procedures for conference and award ceremonies to effectively and efficiently use GSA resources and minimize costs.

2.  Background.  Executive Order 13589, Promoting Efficient Spending, directed agencies to cut waste in Federal Government spending and identify opportunities to promote efficient and effective spending, including a reduction in conference and travel costs.  Additional guidance related to conferences, awards, meals, travel, and procurement is contained in:

 

3. Expiration date.  This IL is effective immediately; however, any comments are due 30 days from the signature date.  This IL will remain in effect for one year from the signature date or until amended or incorporated into a new GSA Order, whichever is sooner.

4.  Applicability.  The provisions of this IL apply to all components and employees of GSA and to all GSA events, without regard to funding source, including no-cost contracts.  This IL does not apply to conferences sponsored or funded by other agencies or organizations that GSA employees are attending.

5.  Definitions.  The following definitions apply to this IL:

     a.  Award - a monetary or non-monetary recognition of a significant achievement by an employee or group of employees presented in accordance with the GSA awards policy (see GSA Order 9451.1 CPO P, APRS for additional awards policy and procedures). 

 

     b.  Conference – a symposium, seminar, workshop, or other organized or formal meeting, lasting portions of one or more days, whether conducted face-to-face or through the use of information technology, where individuals assemble to exchange information and views or explore or clarify a defined subject, problem or area of knowledge, whether or not a published report results from such meeting.  The term may include training activities that meet the definition of training under the Government Employees Training Act, 5 U.S. C. § 4101(4).  The term does not include technical and administrative site visits, whether conducted face-to-face and/or through the use of information technology.

 

     c.  Conference Costs - all costs paid by the Government for a conference, whether paid directly by agencies or reimbursed by agencies to travelers or others associated with the conference (e.g., speakers, persons contracted to plan the conference or assist with the conduct or logistics of the conference, etc.).  Such costs include, but are not limited to the cost of pre-conference planning activities, travel to and from the conference, ground transportation, lodging, meals and incidental costs, meeting room rental, audiovisual costs, registration fees, speaker fees, honoraria, and other conference-related administrative fees, and the cost of employees time spent at the conference, and traveling to and from the conference.

 

     d.  Government facility - property owned or substantially controlled by the Government and the services of any civilian and military personnel of the Government.

 

     e.  Meeting - an assembly of persons to discuss general matters as part of a course of doing business, which is held in Federal or non-Federal space.

 

     f.  Training - the process of providing for and making available to an employee, and placing or enrolling the employee in a planned, prepared, and coordinated program, course, curriculum, subject, system, or routine of instruction or education, in scientific, professional, technical, mechanical, trade, clerical, fiscal, administrative, or other fields, which will improve individual and organizational performance and assist in achieving the agency’s mission and performance goals (5 U.S.C. Chapter 41- Training, § 4101).

 

6.  Policy.  GSA’s mission is to use expertise to provide innovative solutions for our customers in support of their missions, and by so doing, to foster an effective, sustainable, and transparent Government for the American people.  It is GSA’s policy that video-conferencing, teleconferencing or webinars are preferred methods for conducting meetings.  Conferences should only be held if they are the most cost effective means to achieve GSA’s mission.  Conferences and award ceremonies must be approved prior to the obligation of any funds.  Every effort must be made to minimize costs associated with conferences and award ceremonies.    

     a.  Use of Government facilities.  Every effort should be made to conduct conferences or events in a Government facility when practicable, cost effective, and within commuting distance of most of the attendees.

     b.  Per diem.  When travel is involved and the use of Government facilities are impracticable, GSA conferences and award ceremonies will be held at sites that are within the established lodging portion of the per diem rate.  Any lodging above per diem is considered an “Actual expense” authorization (i.e., up to 300% of per diem) and may only be allowed on an individual or case-by-case basis, when approved by the Office of Administrative Services (OAS) based upon sufficient justification provided by the Heads of Services and Staff Offices (HSSOs) or Regional Administrators (RAs).

     c.  Use of third party event planners.  Third party event planners may be utilized after approval by the HSSO or RA, and the OAS.  Associated expenses will be included in the proposed plan for the event.

     d.  Site selection.  Conference planners will not exclude from potential consideration any geographical location or facility when planning for events.  Planners will obtain fair and reasonable price proposals for the Government.  Other relevant factors in FTR § 301-74.4 will be considered when recommending a site to the HSSO or RA (reference FAR § 13.106-3(a), § 13.202, § 15.406-3, and § 8.405-2(d), in regard to determining prices fair and reasonable).

     e.  Use of Government funds.

          (1)  Promotional or memento items.  GSA funds should not be used to purchase promotional or memento items.  Typically, items or tokens given to individuals are considered personal gifts.  However, the purchase of promotional or memento items may be permitted under circumstances where their purchase is reasonably necessary to further an authorized Agency function or mission such as marketing activities or employee awards.  There is no authority to use appropriated funds to provide memento items such as souvenirs, keepsakes, or as informal appreciation to employees or others.  Even when permissible, the purchase of promotional or memento items must be carefully considered as employees can be held personally liable for improper expenses.  Refer to GSA Order 5090.1A OGC for GSA policy on the purchase of such items.

          (2)  Food.  Refer to GSA Order 4290.1 PFM P Chapter 8 paragraph 12b and General Counsel Memorandum dated July 22, 2005, Use of Agency Funds for Meals and Refreshments (Attachment A) for exceptions under which government funds may be used to purchase food.

          (3)  Entertainment, extraneous items and activities.  GSA sponsored conferences may not include entertainment or other extraneous and unnecessary items and activities (e.g., purchase or rental of clothing items).  GSA planners should exercise sound judgment and prudency regarding necessary expenses to carry out GSA’s mission, as well as consider public perception regarding the use of taxpayer dollars. 

          (4)  Training materials.  The Government Employees Training Act (GETA) (5 U.S.C. Chapter 41 – Training, § 4101-4119) authorizes the funding of such items as pens, pads, and notebooks at training which qualifies as such under the Act.  Mere reference to meetings and other events as "training" is not sufficient.

 

     f.  Awards ceremonies.  Awards ceremonies may be held as part of a conference.  Awards must be given in recognition of a significant achievement by an employee or a group of employees related to agency business and/or enhancing agency mission in accordance with GSA Orders 9451.1 CPO P and 5090.1A OGC.  Under no circumstances should events be improperly designated as award ceremonies in order to justify the purchase of food.  

     g.  Receipt of gifts.   GSA employees must comply with the provisions of Subpart B of 5 C.F.R. Part 2635, Gifts from Outside Sources - of the Standards of Ethical Conduct for Employees of the Executive Branch.  As such, GSA employees may not solicit or accept gifts from any entity doing business with the Agency, or use their positions to induce another person to provide any benefit, financial or otherwise, to themselves, their friends or their relatives.  While employees on travel may accept promotional materials (e.g., complimentary rooms, free meals) from a travel service provider under certain circumstances (see 41 C.F.R. Part 301-53), employees may not retain promotional materials associated with planning conferences FTR § 301-74.1(d).  To the maximum extent possible, promotional materials must be used to help defray costs of conducting the event.  Consult with the Office of General Counsel for further guidance.

     h.  Printing.  Planners will limit the publication and printing of hard copy documents.  Printing and publication of hard copy materials must be consistent with GSA’s mission, objectives, and existing policies.  It must also represent efficient and effective use of taxpayer funds, while not creating barriers for the public in obtaining Agency information.  Information should be provided in an electronic format, whenever practicable, permitted by law, and consistent with applicable records and retention requirements.

     i.  Internal controls.  Managers are responsible for exercising appropriate oversight and following established internal controls to ensure that key duties and responsibilities in planning, authorizing, processing, recording, and reviewing conference and award ceremony transactions are separated among individuals.

     j.  Acquisition of conference-related services.  Only warranted contracting officers are authorized to bind the Government for these services.  Planning officials should consult with the assigned contracting officer regarding specific requirements under the FAR and GSAM.

 

7.  Roles and responsibilities.

     a.  The OAS is responsible for:

          (1)  Overseeing and contracting for conference space, related activities, and amenities; 

          (2)  Reviewing and approving all proposed conferences for relevance to GSA’s mission (see Attachment B for format); 

          (3)  Reviewing and approving any award ceremony where food is provided by the Federal Government (see Attachment B for format); 

          (4)  Reviewing and approving budgets for proposed conferences, as well as, budget changes (see Attachment B for data requirements); 

          (5)  Overseeing and coordinating with GSA conference and event planners and contracting officers on conference planning; 

          (6)  Reviewing travel and accommodations related to conference planning and execution; and

          (7)  Handling procurement for all internal GSA conferences.

 

     b.  The HSSOs and RAs are responsible for: 

          (1)  Ensuring that funds are not obligated by any means (e.g., contract, purchase order, purchase card) to support a conference or award ceremony, prior to the written approval from OAS using Attachment B or an automated application provided by OAS;

          (2)  Reviewing and approving staff and program office conferences before submission to the OAS;

          (3)  Reviewing and approving of award ceremonies where food is planned for staff and program offices for submission to the OAS;

          (4)  Planning and conducting approved GSA-sponsored conferences and award ceremonies in accordance with GSA’s policy and mission; 

          (5)  Ensuring that expenditures at all conferences and award ceremonies comply with all applicable regulations and policies;

          (6)  Exercising good stewardship of GSA resources by ensuring costs for conferences and award ceremonies are minimized and best value is obtained by the Government, and that attendee travel expenses stay within per diem rates;

          (7)  Designating a central point of contact for their respective organizations that will be responsible for controlling the conference and award ceremony authorization process and be responsible for copies of documentation specified in paragraph 8c, below; and

          (8)  Ensuring that conference planners are trained, use the tools identified in this guidance document, and are familiar with and adhere to the guidance in FTR § 301-74, Appendix E to Chapter 301 of the FTR, and other guidance contained herein.

 

     c.  The Office of the Chief Financial Officer (OCFO) is responsible for:

          (1)  Reviewing and approving conference budgets for all GSA entities;

          (2)  Reviewing and approving proposed conferences sponsored by the OAS for relevance to GSA’s mission; and 

          (3)  Reviewing and approving budgets for proposed OAS conferences, as well as budget changes. 

 

8.  Procedures.

     a.  Cost comparison required.  For conferences or events with estimated costs less than the Simplified Acquisition Threshold, the conference planner must review at least three different conference sites based on the stated evaluation criteria for the conference or event.  For conferences or events estimated to cost more than the Simplified Acquisition Threshold, FAR competition requirements must be followed.  If there is a broad range of subjects requiring extensive group interaction over a period of days, the most effective approach may be to meet in one location.  

     b.  Conference city and venue selection.  Conference planners may obtain conference site data using a suite of free tools offered by GSA’s Federal Acquisition Service.  For conference city comparison and selection, planners should use GSA’s Travel Management Information System (MIS) group planning tool accessed through https://gsa.traveltrax.com.  This tool creates a cost comparison for up to 10 potential conference cities using contract air fares, per diem, and car rental for estimations.  The Travel MIS requires a login that can be provided upon request by sending an email to travelmis@gsa.gov.  Use of the Travel MIS assists in complying with FTR § 301-74.5.  When Government facilities are not available or cost effective, GSA sponsored conferences must be held at sites that are on the Federal Emergency Management Agency’s (FEMA) list of Fire Safety Act-approved accommodations.  In selecting commercial hotel/conference venues, planners should first consider using FedRooms® available at http://www.fedrooms.com.

          (1)  Specialized Conference Facilities and Services.  Commercial services may be necessary for specialized conference facilities that provide complete meeting packages, to include sleeping room, meeting space, all food and beverage, conference technology services, business center services and other related services.  Provisions for these services must be completed using Special Item Number (SIN) 599-6 at http://www.gsa.gov/portal/content/299989.

          (2)  Conference, Events & Trade Show Planning Services – Small Business Set Aside.  Commercial services may be necessary for event and trade show planning.  Provisions for these services, including expert help in advertising, marketing, and related communication fields must be completed using SIN 541 4D at http://www.gsa.gov/portal/content/104613.

          (3)  Guide to Sustainable Conferences.  The Office of Government-wide Policy has prepared guidance to lessen the environmental impact of government-planned, contracted, or sponsored conferences and events.  This guide may be accessed at www.gsa.gov/graphics/ogp/Guidance_Sustainable Conferences.doc.

 

     c.  Conference date(s).  When determining conference dates, consider that all hotels and meeting facilities have peak periods of high demand, "value" periods of low demand, and "shoulder" periods of variable demand.  For many sites, April, May, September, and October are popular meeting months.  For other sites, the summer months are more popular.  Meeting around, rather than during, a site's peak season often means a lower available rate.

     d.  Documentation.  All conference planning and cost documentation, including both pre-conference cost estimates and actual conference costs incurred, must be retained for a period of three years after final payment if the contract is at or below the Simplified Acquisition Threshold, or for a period of six years and three months after final payment, if the contract is over the Simplified Acquisition Threshold.  These documents may be inspected by the Office of General Counsel (OGC), the Office of Inspector General, Congress, Office of Management and Budget, the Government Accountability Office, and other interested parties including the public, as appropriate under law. 

     e.  Pre-conference or award ceremony review and approval.  Conference planners and award ceremony planners requesting the authorization of food will submit requests for review and approval to the OAS through their HSSO or RA (see Attachment B for request format).  Requests must be reviewed by the HSSO or RA and submitted to OAS at least 90 days before the beginning of the event.

      f.  Post-conference or award ceremony report.  The organization conducting the event will prepare a narrative and actual expense report that will be submitted to the respective HSSO or RA and OAS no later than 60 days after the end of the event.  This reporting requirement applies to any GSA sponsored event. 

          (1)  Narrative.  The narrative will:

                (a)  Provide an overview of the number of attendees and composition of attendees (e.g., GSA employees, other Government attendees, industry, contractors);

                (b)  Report the outcomes and indicate whether GSA’s mission and objectives were achieved (include conference highlights);  

                (c)  State what follow-up activities or actions are required;

                (d)  Summarize the results of any surveys conducted; and

                (e)  Provide any other information required by the HSSO or RA.

 

          (2)  Budget.  Submit a budget report with both estimated and actual expenses incurred using Attachment B, Part 3 or an automated application provided by OAS for collecting such information.

 

9.  Mandatory Training.  All employees will be required to take mandatory annual training regarding conference planning and attendance.  The OAS, OGP, OGC and FAS are responsible for developing the training course.

 

Dan Tangherlini
Acting Administrator 

Attachment A - Meals and Refreshments

Attachment B - Request for Approval of Conference or Award Ceremony

 

 

Last Reviewed 04/20/2012
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