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HHS Policy on Use of Appropriated Funds for Conferences and Meeting Space

1.1 General

It is the Department’s policy that the conferences1  it funds shall be consistent with legal requirements and HHS’ missions, objectives, and policies; represent an efficient and effective use of taxpayer funds; and be able to withstand public scrutiny.  

The following policy rescinds and supersedes the October 27, 2011 memorandum from the Deputy Secretary “Eliminating Excess Conference Spending and Promoting Efficiency in Government,” and is in addition to and is intended to complement the requirements and procedures set forth in the following policies, or any updates thereto:

  • HHS Travel Manual, May 2008
  • Memorandum from the General Counsel “Agency Gift Acceptance Authorities and the Co-Sponsorship of Events with Outside Non-Federal Entities,” August 8, 2002

OPDIVs and STAFFDIVs shall make all appropriate efforts to conduct business, including meetings, and host or sponsor conferences in space controlled by the Federal Government, wherever practicable and cost effective.

1.2 Definitions (Update)

The following definitions apply in determining whether an event is a conference or a meeting:

  • A conference is a symposium, seminar, workshop, or any other organized and formal meeting, whether conducted face-to-face or via the Internet, where individuals assemble (or meet virtually) 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.
  • A meeting where a gathering discusses general matters as part of a normal course of doing business is not considered a conference.

1.3 Approval Requirements  

Prior to the obligation of appropriated funds (whether from an annual appropriation, multi-year appropriation, appropriated user fee, mandatory appropriation, gift funds, or reimbursements from such appropriations, etc.), by any means such as contract or purchase order2, purchase card, grant, cooperative agreement, inter- or intra- agency agreement, etc., to support a conference or to acquire meeting or conference space – whether for internal or external purposes (or a combination thereof) – the sponsoring office must obtain the approval of the appropriate OPDIV or STAFFDIV official, based on the thresholds below:

  • Under $100,000: the OPDIV or STAFFDIV Executive Officer, delegable to their direct reports without further redelegation.
  • $100,000 or over: the OPDIV or STAFFDIV Head, delegable to their direct reports without further redelegation.

This approval must be in writing, explain why the conference or meeting is critical to the mission and why the costs are considered reasonable, be granted prior to the obligation of funds, and be included in the associated administrative file, such as the purchase card request, contract file, or grant administration file.  To avoid unnecessary effort associated with disapproval, approval should be sought prior to issuance of a solicitation or funding opportunity announcement.

1.4 Reporting Requirements  

OPDIVs and STAFFDIVs shall submit a semi-annual report on all HHS funded conferences using the template provided at Attachment 1-A.  This reporting requirement applies to any conference that HHS funds in whole or in part (except for conference registration fees obligated for employee training) and to any meeting space acquired during each reporting period3.  

1.5 Exceptions for Grants and Cooperative Agreements

When a grantee conducts a conference as an ancillary effort under its grant or cooperative agreement, such grants and agreements are not subject to the above approval and reporting requirements.  However, as a matter of Departmental policy, when the primary purpose of the grant or cooperative agreement is to conduct a conference, such as NIH’s Support for Conferences and Scientific Meetings R13/U13 grants and other similar grants, the approval and reporting requirements apply.  However, when a contract includes, in addition to other requirements, a requirement to conduct a conference, the approval and reporting requirements apply to that part of the contract.

1.6 Implementation Requirements

OPDIVs and STAFFDIVs shall implement internal policies and practices to: (1) ensure consistency across their organizations regarding the documentation and approval of requests to support a conference or acquire meeting/conference space when it requires the obligation of funds, and (2) meet the semi-annual reporting requirements addressed above.

1.7 Additional Information

This policy may be supplemented as appropriate through questions and answers published on the Office of Grants and Acquisition Policy and Accountability (OGAPA) website (http://www.hhs.gov/asfr/ogapa/index.html), and may result in changes to the HHS Acquisition Regulation, Awarding Agency Grants Administration Manual, and Grants Policy Statement.  Questions regarding this policy may be addressed to Nancy Gunderson, Deputy Assistant Secretary for the Office of Grants and Acquisition Policy, at Nancy.Gunderson@hhs.gov.

See also:

 


[1] The HHS Acquisition Regulation provisions for Conference Funding and Sponsorship are found at: http://www.hhs.gov/policies/hhsar/subpart370.html#Subpart370.6.  Relevant provisions for grants and cooperative agreement are found in the Grants Policy Statement at http://www.hhs.gov/asfr/ogapa/grantinformation/hhsgps107.pdf (pages 94-97).

[2] Including but not limited to: orders under the NIH Conference, Administrative, and Travel Services II (NIHCATS II) Contracts; other events management and logistics support services contracts; contracts made directly with hotels and conference centers, etc.

[3] Based on the date of obligation of funds (such as the date of contract award, credit card transaction, notice of grant award, etc.).