Department of Justice Conference Expenditures

Audit Report 07-42
September 2007
Office of the Inspector General

Chapter 4: Site Comparisons

The FTR requires that, before selecting a conference’s location, conference planners compare the costs of different sites. The FTR defines a conference “site” as both its geographic location and the specific facility used to hold the event. According to the FTR, adequate cost comparisons should compare the availability of lodging rooms at per diem rates; the convenience of the conference location; availability of meeting space, equipment, and supplies; and the commuting or travel distance of attendees. Additionally, the FTR states that conference planners must also keep records of the comparisons to show that the comparisons were performed and that there was an appropriate rationale in selecting where to hold a conference.24

OJP and the FBI have developed additional policies governing conference site selection to supplement cost comparison guidance provided by the FTR. The policy at OJP requires conference planners to consider at least three sites for each event. The policy also gives OJP’s Office of Administration, Acquisition Management Division (AMD) the responsibility for both maintaining the records showing the selection of a conference site and assuring that appropriate cost analysis has been conducted and documented.25 In 2006, AMD proposed a “Best Practices Guide” to be used by OJP conference planners. Although not yet final, the draft guide requires that conference sponsors document the purpose of the meeting, the reason for choosing the location, a justification for use of non-federal facilities, and cost estimates for market surveys.

Since FY 2005, FBI training and conference planners have been required to contact the TDD to determine if space is available to hold a conference at the FBI Academy in Quantico, Virginia. If space is not available, the TDD performs market surveys of potential locations that compare one primary and two alternative sites. TDD market surveys are completed on a standardized form and also include estimates for applicable audio-visual and food and beverage costs. In 2006, the TDD expanded this market analysis to include a review of three government and three non-government facilities for availability, location, and cost.

Analysis of Conference Site Comparisons

We interviewed officials who planned or coordinated each conference to ascertain whether they performed site comparisons required by the FTR. Some event planners told us that they were not certain what type of comparisons – whether by city, by venue, or by city and venue – were specifically required by the FTR. For example, although the FTR requires conference planners to conduct a minimum of three site comparisons, the FTR does not specify that these comparisons need to include different cities or just directly comparable facilities in the same market.

As shown in table 4-1, planners for only 3 of the 10 conferences performed and documented cost comparisons for both alternate cities and venues within the selected city. The FBI’s TDD performed market surveys that compared different cities and venues for the FBI Polygraph Conference and the FBI ITEC Conference. Conference planners for the NIJ Technology Conference also compared logistics for both cities and venues.

Table 4-1


Conference Name City Venue Both Other
OVC National Symposium X      
FBI Polygraph Conference     X  
Weed and Seed Conference       X
NIJ Technology Conference     X  
OJJDP National Conference   X    
FBI Cambodia Conference       X
PSN National Conference X      
COPS National Conference   X    
FBI ITEC Conference     X  
LEC National Conference       X
Source: DOJ component and event planning files

The conference planners for the PSN National Conference and the OVC National Symposium documented site comparisons for different cities but not venues within the city selected for their respective events. For example, the event planning contractor for the OVC National Symposium compared per diem rates and airfare costs for Atlanta, Dallas, Houston, and Memphis. OJP officials told us they chose Atlanta based on its convenience and lower travel cost as a major airline hub. We were also told that OJP contacted large hotel chains to negotiate favorable rates, but these discussions were not documented in the conference file.

Certain conference sponsors selected a particular city for logistic and programmatic considerations. Since both the OJJDP National Conference and the COPS National Conference were to be held in Washington, D.C., which mitigated most federal employee travel costs, sponsors performed no city cost comparisons. However, the sponsoring organizations or their event planners each reviewed alternative venues within Washington, D.C.

FBI Cambodia Conference planners did not conduct site selection comparisons, but organizers told us that Cambodia was selected for the Asia Region’s training because of programmatic considerations. An FBI official said that Phnom Penh was selected because the FBI wanted to show interest in Cambodia as a potential legal attaché office and to provide support to a training conference for local Cambodian National Police leaders scheduled for the same week. We asked why the conference planners did not compare venues within Cambodia for this event. The planner stated that the classified nature of the topics discussed at the conference required a level of security that could only be achieved by the U.S. Embassy and therefore the FBI relied on arrangements made by the embassy. The FBI event planner also told us that U.S. embassies often find western-style hotels for visiting officials based on security, proximity to the embassy, and acceptance of government per diem.

We found that the OJP’s Community Capacity Development Office (CCDO) did not document uniform cost comparisons when it selected locations for either the LEC Conference and the Weed and Seed Conference. In both instances, however, CCDO told us that it was primarily concerned with selecting host cities for programmatic reasons. For the LEC Conference, CCDO officials told us that they requested hosting proposals from several different cities, but only two, Seattle, Washington, and Phoenix, Arizona, submitted proposals. Event planners told us that because the LEC Conference was held “off-season” and the Phoenix Convention Center was “brand new,” CCDO was not charged for breakout meeting room space in Phoenix. Furthermore, Seattle could not guarantee hotel rooms at authorized per diem rates. Consequently, CCDO chose to hold the LEC Conference in Phoenix.

For the Weed and Seed Conference, CCDO and OJP officials said they selected Los Angeles as the host city for programmatic reasons. CCDO told us that Los Angeles was selected because a primary topic of the Weed and Seed Conference was anti-gang initiatives. CCDO and OJP then received a presentation from a private, not-for-profit travel bureau located in Los Angeles. As part of this presentation, CCDO was told that the only hotel in Los Angeles large enough to host the Weed and Seed Conference was the Westin Bonaventure Hotel and Suites (Bonaventure).

We researched the travel bureau and found that representatives from area hotels comprise a portion of its board of directors. Since the leadership of the travel bureau includes representatives of certain area hotels, recommendations made by the travel bureau may not be unbiased and in the best economic interest of the government. Consequently, by relying solely on a travel bureau with vested interests to recommend site locations, we do not believe that CCDO conducted adequate site comparisons that ensured the best location for the best available price.


Event planners for the 10 conference we reviewed told us that they were not always certain what types of site cost comparisons are required by the FTR. Conference planners for only 3 conferences provided us documentation showing that they conducted both city and venue comparisons. To ensure that the government obtains the best conference location for the best value, conference planners should compare multiple sites in multiple cities. When an overriding programmatic reason justifies holding an event in a particular city, we believe that conference planners should at least conduct site comparisons of different venues within that city.


We recommend that JMD:

  1. Implement specific guidance regarding what comparisons of costs between different sites conference planners should perform to ensure the best location for the best value.

We recommend that OJP:

  1. Ensure that its conference planners develop and retain documents that evidence complete site cost comparisons.

  1. 41 C.F.R. § 301-74 (2006).

  2. OJP memorandum, dated March 27, 2001.

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