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Board Report: 2014-FMIC-B-009 June 30, 2014

The Board Should Enhance Its Policies and Procedures Related to Conference Activities

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Finding 3: The Board Should Update the Food and Beverage Request Form and Clarify the Official Meals Expenses Policy

We found that Board divisions are not maintaining sufficient documentation to demonstrate compliance with certain requirements in the Official Meals Expenses Policy. Specifically, we could not confirm that the divisions were submitting food and beverage requests in accordance with applicable requirements. Further, we found that divisions were not requesting approval for events held at non-Board facilities within the required time frame. We also were not able to confirm that (1) individuals other than Board employees attended events where alcohol was served and (2) the duration of alcohol service was limited to 90 minutes. Although the Board provides a standard form for requesting food and beverage services for events held at Board facilities that addresses some of the requirements in the Official Meals Expenses Policy, the form does not reflect all of the requirements. In addition, Food Services staff monitor events held at Board facilities where alcohol is served and obtain approval if alcohol service extends beyond the 90-minute limit; however, the approval for the extension of alcohol service is not documented. Further, the Board provides limited guidance on what information should be included in the request for events held at non-Board facilities. Instances of noncompliance with the requirement to submit requests in a timely manner and retain documentation evidencing compliance with other key components of the Official Meals Expenses Policy could impact the overall quality and efficiency of the conference planning process. Additionally, insufficient documentation for events where alcohol is served could pose a reputational risk for the Board.

Divisions Did Not Comply With Various Aspects of the Official Meals Expenses Policy

We found that Board divisions did not consistently comply with requirements in the Official Meal Expenses Policy. We noted instances of noncompliance related to the submission of food and beverage requests, the documentation to evidence compliance with requirements associated with the serving of alcohol at Board events, and approval requests submitted to Visitor Services for events held at non-Board facilities.

For events held at Board facilities, the Official Meals Expenses Policy requires that food and beverage requests be submitted 10 working days before the event. For events held at non-Board facilities, the request must be sent 25 working days before the event. The Board may serve alcohol at events if (1) individuals other than Board employees are present, (2) alcohol service is limited to 90 minutes, and (3) alcohol service does not begin before 5:30 p.m. In addition, divisions must request approval from Visitor Services to hold events at non-Board facilities. Such requests must be submitted 25 working days in advance and include a list of participants.

We found that divisions did not submit a food and beverage request for 4 of the 30 conferences in our sample. According to program officials, these requests were not submitted because the relevant division (1) had an abbreviated time frame to plan the conference, (2) was not the primary host, or (3) submitted a purchase requisition and purchase order instead of the food and beverage request form.

Further, for the 26 conferences for which a food and beverage request was submitted, we could not verify the timeliness of the requests. Divisions also could not consistently provide the documentation necessary to evidence that individuals not employed by the Board attended events where alcohol was served and that the alcohol service was limited to 90 minutes. The food and beverage request form collects some of the information associated with Official Meals Expenses Policy requirements, such as the start time of alcohol service; however, the form does not record other key pieces of information, such as the date submitted, the list of participants, and the intended duration of the alcohol service.

For 10 out of 11 conferences in our sample that were held at non-Board facilities, the host divisions did not request approval from Visitor Services 25 working days in advance. The Official Meals Expenses Policy does not specify how divisions should request approval of the use of non-Board facilities and has not established a formal mechanism by which Visitor Services would approve the request. In addition, the Official Meals Expense Policy requires that a list of participants accompany the request for approval for the use of non-Board facilities. However, we could not confirm for all of the conferences held at non-Board facilities that divisions submitted a list of participants to Visitor Services. According to Board officials, the list of participants provided to Visitor Services is considered a planning document and attendees often change as the event approaches. As a result, Board officials indicated that the document submitted to Visitor Services should, more appropriately, be a list of invitees.

We found that Food Services staff attends events held at Board facilities where alcohol is served to ensure compliance with the timing requirements associated with alcohol service. According to Food Services staff, alcohol service, while limited to 90 minutes, is not always continuous. For example, events may have a 30-minute reception at which alcohol is served, followed by a dinner that includes wine service. In addition, Food Services staff indicated that on rare occasions, alcohol service may exceed 90 minutes due to delayed arrival of guests or other circumstances. In these instances, Food Services staff obtains management approval to extend the service. However, Food Services staff does not document exceptions that deviate from the policyís requirements.

For events held at non-Board facilities where alcohol is served, the alcohol service is limited to 90 minutes through the vendors. Visitor Services staff indicated that the start time and length of the alcohol service is specified in the contract with the vendor. Further, according to Board officials, staff cannot use purchase cards to extend the alcohol service.

Recommendations

We recommend that the Director of the Management Division

  1. Coordinate with Visitor Services to clarify in the Official Meals Expenses Policy the process divisions should follow to request approval to use non-Board facilities. The updated guidance should identify:
    1. information to be included in the request.
    2. responsibility for retaining the supporting documentation.
  2. Amend the food and beverage request form to include fields for the following information:
    1. the date the form was submitted.
    2. a list of invitees.
  3. Update the Official Meals Expenses Policy to include the following requirements:
    1. if circumstances necessitate the extension of alcohol service beyond the 90-minute limit, Food Services or the division hosting the event should document the reason for the extension and document that proper approval was obtained.
    2. specify who has the authority to approve the extension of alcohol service beyond the 90-minute limit. 

Managementís Response

The Director of the Management Division concurs with the intent of recommendations three and five. The Director of the Management Division responded that Food Services is currently revising the Official Meals Expenses Policy in collaboration with the Office of the Secretary, the Division of Financial Management, and the Legal Division. The Director of the Management Division stated that these recommendations will be incorporated into the final policy and the related food and beverage request form.

For recommendation four, the Director of the Management Division stated that the food and beverage request form is automated and consequently documents the submission date. The Management Division plans to modify the food and beverage request form to include fields for indicating the presence of external attendees and attaching a related listing.

OIG Comment

We believe that the actions described by the Management Division are responsive to our recommendations. The OIG intends to follow up on the Management Divisionís actions to ensure that the recommendations are fully addressed.