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Treasury Directive 12-70

DATE:  February 24, 2014

 
SUBJECT:  Policy and Guidance for Conference Approval, Planning, and Reporting
 
1.      PURPOSE.  This directive provides guidance with respect to the planning and approval of Treasury-hosted or sponsored conferences.  This directive also provides guidance with respect to Treasury participation or attendance at conferences that are sponsored or hosted by other Federal or non-Federal entities.  The directive also requires the issuance of bureau-specific publications as further described in Sections 5 and 6.        
 
2.      SCOPE.  This Directive applies to all bureaus, offices, and organizations in the Department of the Treasury, excluding the Office of the Comptroller of the Currency, the Office of the Inspector General, the Treasury Inspector General for Tax Administration, and the Special Inspector General for the Troubled Asset Relief Program.  The provisions of this Directive shall not be construed to interfere with or impede the authorities or independence of the Department’s Inspectors General. 
 
3.      POLICY.  The Department of the Treasury’s policy is to minimize all conference costs and to ensure expenditures are properly reviewed, justified, and approved prior to incurring obligations.
 
4.      DEFINITIONS.  The following terms are defined to provide clarification for the purpose of this Directive. 
 
Conference:  Conferences include meetings, retreats, seminars, symposiums, or training activities. See 41 C.F.R. § 300-3.1.  A conference typically is a pre-arranged formal event with at least some of the following characteristics: designated participants and/or registration, a published substantive agenda, and scheduled speakers or discussion panels on a particular topic, and involves Treasury expenses (other than the salaries of attendees), such as expenses for refreshments, meals, mementos, or travel (including transportation, lodging, or other expenses authorized under the FTR).
 
      Hosted Conference:  A hosted conference is arranged by a bureau[1], held in either a          government or commercial facility, which may include both employees and non-          employees as attendees.  The bureau provides or arranges for all resources required to             hold the conference/event. 
 
      Sponsored Conference:  A sponsored conference is a conference in which the bureau      pays another entity to host the conference, such as through a contract or grant.  Paying an   established per-attendee fee does not constitute sponsorship.
 
5.      Exemptions.  The Assistant Secretary for Management may exempt certain activities from the definition of “conference” so as to remove those activities from coverage under this policy.  Note, however, that any exempted activity may be covered by other statutes, regulations, policies and approval requirements, and should only be held when it is essential to accomplishing a core mission requirement. Further, any related expenditures of Department funds must be fiscally prudent; in particular, costs of travel, food and beverages, where permitted, must be kept to a minimum.
 
6.      GUIDANCE.  The following guidance applies to all conferences hosted by the Department of the Treasury and its bureaus and shall be followed when preparing for and hosting a conference.  
 
a.       Contracting for Venues or Other Services Related to the Conference.
1)      Conference-related costs, including supplies and services, must be purchased by authorized officials through appropriate procurement vehicles, such as purchase cards, contracts, or purchase orders.  Travel cards may be used only for travel-related expenditures incurred by individual travelers.  
 
2)      In general, the use of contract event planners is not advantageous because it can reduce Treasury’s control over conference expenses and can increase cost.  If circumstances make the use of such a planner necessary, the contract with the planner must cover only the planning and logistical support provided by that vendor.  A separate contract must be issued by a government contracting officer for all other conference-related expenses as identified in Section 7, except for travel expenses reimbursed as provided in the FTR.  The use of third-party contract planners does not eliminate the requirement for reporting total conference costs.  The use of a third-party planner for assistance in site selection must be approved in advance by the Office of the Assistant Secretary for Management (ASM).
 
b.      Registration Fees.  Absent statutory authority, bureaus may not collect conference fees, including exhibitor fees and individual attendees’ fees, to reimburse the appropriation from which the conference is funded.   (Comptroller General Decision B-300826, March 3, 2005)
 
c.       Gifts and Ethical Conduct.  Employees must not accept gifts unless authorized under the ethics regulations or the FTR.  This includes accepting free travel and lodging for site visits, as might be offered in a familiarization tour of a potential conference site, or under other circumstances.  
 
d.      Sustainability.  Bureaus must comply with the Green Meeting Strategies issued in GSA Bulletin FTR 10-06 regarding sustainability related to conference hosting (e.g., reducing materials used, use of videoconferencing and web tools in lieu of travel).
 
e.       Travel.  Bureaus must comply with the FTR and any implementing Treasury directive or policy.  This includes reducing the meals component of the meals and incidentals expense (M&IE) per diem on the travel voucher when employees on temporary duty travel are provided meals at government expense. 
 
f.       Colocation and Facilities.  In the course of all conference planning, Bureaus must consider alternative means of accomplishing collaboration, including the use of remote collaboration tools and other real-time communication methods.  When physical colocation is necessary, Bureaus should look to host or sponsor conferences in space controlled by the Federal Government in order to reduce costs.
 
g.      Conferences in excess of $500,000.  Bureaus may not expend more than $500,000 on any single conference, whether or not it is hosted or sponsored by Treasury, unless the Secretary determines that exceptional circumstances exist that make spending that amount the most cost-effective way to achieve a compelling purpose (OMB Memorandum M-12-12, “Promoting Efficient Spending to Support Agency Operations”).
 
7.      RESPONSIBILITIES.  The Office of the ASM is responsible for the oversight of Treasury-wide conference planning and approvals.  The Office of the ASM is responsible for conference related policy development, standardizing meeting planning, and procurement related activity for the Department.
 
Bureaus shall establish and maintain supplemental guidance related to hosting and sponsoring conferences that will address the guidance provided in section 6 of this Directive.  Supplemental guidance should also include:
 
a.       Bureau office(s) responsible for planning and record keeping, including tracking and reporting conference costs as directed in Section 9.
b.      Guidance on the provision of food and beverage at functions.
c.       List of delegated authorities as provided in Section 8.
d.      If needed, additional guidance not referenced in this Directive that is required by any bureau or office for requesting approval for hosted or sponsored conferences. 
 
8.      APPROVAL.    Many provisions of this Directive apply only to conferences hosted or sponsored by Treasury bureaus or DO.  However, OMB Memorandum 12-12 imposes certain approval requirements with respect to conferences that are sponsored by other Federal or non-Federal entities.  Approval thresholds for both types of conference are as follows:

Total bureau costs:
Approver:
Up to $19,999
Delegation by Bureau Head
$20,000-$49,999
Bureau Head
$50,000-$99,999
ASM
$100,000-$249,999
Deputy Secretary
$250,000 and above
Secretary
 
 
a.       Calculation of Conference Costs
 
For purposes of this section, total conference costs include all direct and indirect expenses paid by the Treasury Department, including but not limited to:
 
a)      Travel costs for attendees, speakers, panelist (e.g., transportation, lodging, meals, incidental expenses, and travel management fees)
b)      Rental of rooms for official business (e.g., meeting rooms, banquet halls) and audiovisual equipment including computer access fees (internet costs) Light refreshments or meals
c)      Printing costs
d)     Registration fees and administrative costs (including contract planner fees)
e)      Conference facilitator or trainer or instructor fees
 
b.      Requesting Approval
 
Approval requests that require ASM approval (between $50,000 and $99,999) must be submitted no later than 30 days in advance of the conference.  Approval requests that require Deputy Secretary or Secretary approval must be submitted no later than 60 days in advance of the conference.  All requests should be sent to the Office of Conference, Event and Meetings Services within the Office of the ASM.  Requests must include the conference title, location and date(s) of the conference, purpose of the conference and how it furthers the mission of the Department/Bureau, conference planner or point of contact, number of attendees, and detail on total conference cost as listed in Section 8a.  Requests must also include an explanation for concluding that the objectives of the conference cannot be accomplished through remote collaboration or other alternative means. 
 
9.      TRACKING AND REPORTING.  The ASM will administer the tracking database and oversee any internal and external requests for data related to conferences.  For conferences that have total costs of $20,000 or greater, the following details of the conference must be entered into the online tracking database within 15 days of the conference being held: 
i)        Conference date
ii)      Conference location
iii)    Number of employees attending the conference
iv)    Point of contact for conference details
 
Within 45 days of the conference being held, the following additional information must be entered into the online tracking database:
i)        Justification for conference with a brief explanation of how the conference furthers the mission of the Department
ii)      Justification for use of non-governmental space
iii)    Actual conference costs (see Section 8 for definition of total costs)
iv)    a description of the contracting procedures used including whether contracts were awarded on a competitive basis and details for any cost comparison conducted by the department in evaluating potential contractors for the conference
v)      Documented approval by the Secretary for any conference that exceeds the $500,000 threshold
 
10.    AUTHORITIES.
 
a.       Presidential Executive Order 13514, “Federal Leadership in Environmental, Energy, and Economic Performance”
b.      OMB Memorandum M-12-12, “ Promoting Efficient Spending to Support Agency Operations”
c.       OMB Memorandum M-11-35, "Eliminating Excess Conference Spending and Promoting Efficiency in Government.”  
d.      Federal Travel Regulation
e.       Federal Acquisition Regulations (FAR) and Department of the Treasury Acquisition Regulations (DTAR)
f.       Travel Green “Green Meeting Strategies” GSA Bulletin FTR 10-06
g.      Food and Beverage - GAO Comptroller General Letter B-288266, Use of Appropriated Funds to Purchase Light Refreshments at Conferences, January 27, 2003.
 
11.  OFFICE OF PRIMARY INTEREST. Office of Conference, Events, and Meeting Services, Departmental Offices Operations, Deputy Assistant Secretary for Management and Budget, Deputy Assistant Secretary for Human Resources, Office of the Assistant Secretary for Management.
 
 
 
/S/
Nani A. Coloretti
Assistant Secretary for Management
 


  
[1] For the purposes of this Directive, "bureau" includes the Departmental Offices (DO).  
Last Updated: 3/7/2014 3:28 PM

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