Policy and Guidance for Conference Approval, Planning, and Reporting
Prior Approval
When prior approval is not required
Conference activity by grantees: The reasonable costs of conference-related activities are allowable uses of OJP funding as long as the grant budget has been approved by OJP. Meals, refreshments, and trinkets generally are not allowable.
- Prior approval not required. OJP does not require grantees to obtain additional prior approval from OJP for specific conference costs. (In very limited circumstances, grantees may seek prior approval of an exception to provide meals, refreshments, or trinkets. OJP rarely approves such requests.)
- Cost limits apply. Even though prior approval of most conference costs by OJP is not required, OJP expects grantees to make every effort to stay within the cost limitations on meeting space, audio-visual equipment/services, and conference planning, set out in this guidance. Where grantees plan to exceed (or do exceed) these cost limitations, they must maintain adequate documentation that such costs were reviewed by the grantee through some internal process, and that the costs were justified. This documentation will be subject to review during monitoring and audits.
When prior approval is required
Conference activity by cooperative agreement recipients: Cooperative agreement recipients must seek and obtain OJP's prior written approval for each event held with OJP funds, and for all conference costs associated with that event that are paid by OJP funds.
- No conference (regardless of the number of attendees) can proceed, nor can conference related contracts (e.g., hotel contracts and travel arrangements/reservations) be signed, or conference implementation funding be obligated/work authorized (whether performed by cooperative agreement staff or outside staff), until the cooperative agreement recipient has obtained the Department of Justice's approval in writing.
- Approval of the overall cooperative agreement proposal or budget does not grant prior approval to use federal funds for conferences anticipated in the budget.
- The reasonable minimal costs of identifying conference locations and developing the itemized cost estimates required to assemble and submit a conference cost approval request are allowable without prior approval by OJP although cooperative agreement recipients should work with the relevant program office to ensure that any costs authorized are reasonable and minimal.
- Those entities with conference planning contracts providing support for planning as well as implementation logistics should only authorize the tasks absolutely necessary to identify the most cost effective conference locations/services, and to prepare and negotiate cost proposals for submission to DOJ.
Contracts: Contractors must seek and obtain OJP's prior written approval for each event held with OJP funds, and for all conference costs associated with that event that are paid by OJP funds.
Timing of requests for prior approval
Conferences costing $100,000 or less; and, not exceeding any cost thresholds (Conference Space & Audio Visual Equipment and Services, Logistical Conference Planner, and Programmatic Conference Planner).
Requests must be submitted to OJP 90 calendar days in advance of the earliest of the following:
- Start date of the conference;
- Deadline for signing conference-related contracts, or
- Obligation of funds for conference costs (except for minimal costs required to assemble and submit the approval request).
Conferences costing over $100,000; or exceeding any one cost threshold (Conference Space & Audio Visual Equipment and Services, Logistical Conference Planner, or Programmatic Conference Planner)
Requests must be submitted to OJP 120 calendar days in advance of the earliest of the following:
- Start date of the conference;
- Deadline for signing conference-related contracts, or
- Obligation of funds for conference costs (except for minimal costs required to assemble and submit the approval request).
Approval Requests Submitted Less than the Required Number of Days (as noted above) in Advance. OJP may, in its sole discretion, consider requests that are submitted late, but cannot assure that these requests will receive a decision in time to avoid having to cancel the conference (particularly if there are any issues that arise with specific items of cost in the request). Cancellation costs associated with conferences that are submitted for late prior approval may be determined to be unallowable costs by OJP.
Procedures and considerations for making a prior approval request
Submitting an event request. All cooperative agreement and contract recipients must complete the Conference & Event Submission Form and obtain OJP's prior written approval for each event held with OJP funds. Each submission must contain all the applicable information (e.g., start date, end, date, conference planner, M&IE) to assist in a thorough review. The recipient must provide justification where required by the form. If additional space is needed, please add a tab to the form. All supporting documentation should be embedded and included within the spreadsheet file. This ensures one file per submission, reduces the number of questions and reduces the possibility of necessary information getting lost or separated from the main submission file. Note: Supporting calculations and agendas (submitted on a separate tab) must be included in all submissions.
To obtain a blank copy of the form click here.
Submit completed prior approval requests on the Conference & Events Approval Form to the following e-mail addresses:
BJA: BJAConferencereport@usdoj.govAll other OJP Bureaus and Offices: OJPConferencecosts@ojp.usdoj.gov
Cost estimates. Cooperative agreement and contract recipients must provide detailed cost estimates for each conference cost category (e.g., lodging rate per attendee, itemized audio visual cost, transportation). Cost comparisons should be conducted to minimize costs of contracts for services, unless a specific provider is required by a facility. See Event Planning/Location Selection for a discussion of facility and venue selection.
Determining costs. When determining the total cost of a DOJ-funded conference, all costs (see specific categories below) incurred by the recipient under the award must be included.
- Actual or estimated costs. Recipients must provide actual costs where possible, but may provide estimates for purposes of submitting requests for prior approval. For post event reporting, actual costs must be provided.
- Co-sponsors. Costs covered by non-DOJ co-sponsors are not subject to the conference cost limits and restrictions; do not require prior approval by OJP; and do not have to be reported as part of the DOJ-funded event. Such co-sponsor funding generally is not considered program income.
- Program income/fees. Conference costs covered by program income (for example, from conference fees) are not subject to the conference cost thresholds and restrictions; do not require prior approval by OJP; and do not have to be reported as part of the DOJ-funded event. For purposes of overall conference prior approval, however, if program income will be used to offset a conference cost line item, please demonstrate that in the supporting calculations. Also ensure that any agendas with meals or refreshments funded by program income or other non-DOJ funding are clearly labeled as not funded by DOJ. Recipients that are permitted to charge fees, or otherwise generate program income, must account for those funds up to the same ratio of Federal participation as funded in the project or program. Example: a discretionary award project funded with 100% Federal must account for and report on 100% of the total program income earned. If the total program income earned was $20,000, the recipient must account for and report the $20,000 as program income on the Federal Financial Report (FFR), SF-425.
- Individual purchases. Individual purchases of goods or services by attendees of the conference at the conference location are not considered to be "conference fees." An independent contractor (e.g., hotel, vendor), without any federal involvement whatsoever, may collect fees from recipients to cover the costs of specific goods or services that cannot be purchased with federal funding or are otherwise not approvable, so long as the good or service is not prohibited (i.e., alcoholic beverages). These fees are not considered program income and should only be collected to offset the costs incurred.
- Ticketed events. Related to individual purchases, a recipient may hold a session where attendees have the option of purchasing a meal or refreshment directly from the hotel (a "ticketed event"). A recipient may communicate the availability of such a session to conference attendees, and as long as the recipient is not involved in the collection of the fees, the fees are not considered program income. The conference costs provided by the independent vendor with such fee are not subject to the conference cost thresholds and restrictions; do not require prior approval by OJP; and do not have to be reported as part of the DOJ-funded event.
- Attendee costs. For prior approval and reporting purposes, a cooperative agreement recipient must report all costs of attendance supported by the award, including conference scholarships where that recipient administers the scholarships. (When determining overall conference costs, OJP may supplement the recipient's data with available data on attendance costs related to Department employees, and non-Department attendees whose attendance is supported by scholarships administered by an entity other than that primarily responsible for planning and/or hosting the conference.)