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FROM: M – Brian J. Bulatao

SUBJECT: Waiver of OMB M-12-12 Policy Prohibiting Expenditures in Excess of $500,000 on a Single Conference for the Global COM Conferences

BLUF: This memo requests your approval to waive the OMB prohibition to incur net expenses greater than $500,000, retroactively for the 2019 COM Conference and prospectively for the 2020 COM Conference. The conferences provide a crucial opportunity to coordinate your global leadership team.


That you:

  1. In accordance with OMB Memorandum 12-12, document your waiver of the prohibition to incur net expenses greater than $500,000 on a single conference for the 2019 Global COM Conference held January 16-17, 2019, in Washington, DC, because the conference was the most cost-effective option to achieve a compelling purpose.
    (Approve/Disapprove by 12/19/19)
  2. In accordance with OMB Memorandum 12-12, waive the prohibition to incur net expenses greater than $500,000 on a single conference for the Global 2020 COM Conference to be held February 25-26, 2020, because the conference is the most cost-effective option to achieve a compelling purpose.
    (Approve/Disapprove by 12/19/19)


On May 11, 2012, OMB issued OMB Memorandum 12-12 (M-12-12), which sets forth a policy prohibiting any executive-branch agency from incurring costs in excess of $500,000 from its own funds on a single conference, including conferences that the agency sponsors or hosts.  The policy authorizes the agency head to provide a waiver “if he or she determines that exceptional circumstances exist whereby spending in excess of $500,000 on a single conference is the most cost-effective option to achieve a compelling purpose.” The grounds for such a waiver must be in writing and signed by the agency head.

The 2019 COM Conference was held January 16-17, 2019, in Washington, DC. The total estimated cost of the event is currently $663,269, which included travel expenses, catering, materials, and IT and audio-visual costs. Although the 2019 Global COM Conference was scheduled before the FY2019 lapse in appropriations, you authorized it to proceed despite the government shutdown. You found that convening your leadership team from the field was essential to ensuring that the Administration’s priorities were clearly conveyed, and that developing your COM strategies was necessary for ensuring the safety, security, and prosperity of the United States. However, there is no contemporaneous documentation of your specific determination that a waiver to expend more than $500,000 was justified given the exceptional circumstances of the conference.

As such, we request you confirm your determination that there were exceptional circumstances, whereby spending in excess of $500,000 on the 2019 COM Conference was the most cost-effective option to achieve a compelling purpose. Specifically, the Department had not been able to hold a COM Conference since 2016, and the global landscape had changed significantly since then, with shifts in regional and global alliances and new threats in security, trade, and the cyber sphere. Convening your leadership team at the 2019 Global COM Conference allowed COMs to engage directly with you and other senior Administration officials at the start of the new year on ways to operate effectively in this changed global context to fulfill their obligations to protect and defend American interests abroad.

In light of known expenses and the cost of the 2019 Global COM Conference, we are confident that expenses for the 2020 COM Conference will also exceed $500,000. Thus we are requesting your approval for spending in excess of $500,000 on the COM Conference to be held in February 2020 in Washington, DC. The final sum of all expenses will be submitted via the Conference Tracking and Approval System. COM travel expenses, approved and funded by each regional bureau, account for a large percentage of the total cost.

As the leader of a globally-dispersed foreign-policy establishment with nearly $50 billion in appropriated funds, you are responsible for ensuring that leaders of Department components have a consistent and coordinated approach for pursuing U.S. foreign-policy goals. The 2020 Global COM Conference will be an opportunity to assemble the Department’s senior leadership from overseas and domestic offices; to express your vision; and to leverage the knowledge, experience, and wisdom of your team in addressing today’s foreign-policy challenges. In addition, this in-person conference provides a crucial opportunity to share updates and guidance on our most pressing issues, including our management of risks abroad.

On the margins of the two-day event, each COM also attends a one- or two-day conference with her/her specific regional bureau. This allows the Department to maximize the return on travel costs and provides each COM and the relevant bureau an opportunity to focus on key regional issues in addition to the global agenda. By hosting the conference at Department-owned facilities in Washington, COMs have the opportunity to conduct internal consultations with a range of Department offices and external consultations with members of Congress and other agencies. This avoids separate travel expenses for the purpose of consultations and regional conferences and minimizes overall Department costs. For these reasons, we believe hosting this conference in Washington is justified and represents a responsible use of appropriated funds, despite costing more than $500,000. As in past years, we expect the majority of costs to be attributed to travel costs, which each regional bureau directly approves and funds.

U.S. Department of State

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