IM OA 2014-05, Sponsorship Approval Request
U.S. Geological Survey Instructional Memorandum
No: IM OA 2014-05
Issuance Date: July 7, 2014
Expiration Date: Retain Until Superseded
1. Purpose.
This instructional memorandum provides policy for determining if a sponsorship approval is required.
2. References.
The Department of the Interior Financial (DOI) Management Memorandum 2013-024, “Authorization and Reporting Guidance on Conference - Related Activities and Spending,” dated June 27, 2013.
3. Responsibilities.
A. Associate Director for the Office of Administration. The USGS designated the Associate Director, Office of Administration (AD-OA), as having primary responsibility for interpreting the application of Federal and Departmental policies regarding sponsorship as they relate to USGS requirements that are effected using procedures in the Federal Acquisition Regulation (i.e., an acquisition, including a contract and interagency agreement) or accomplished under authority of the Federal Grant and Cooperative Agreement Act (i.e., a financial assistance action, including a grant or cooperative agreement). The AD-OA is assisted by the Chief, Office of Acquisition and Grants, who is responsible for providing policy, guidance, and recommending approval or denial of sponsorship requests.
B. USGS Leadership. Executive Leadership Team members, managers, and supervisors are responsible for ensuring their employees comply with sponsorship and conference regulations, policies, and procedures.
C. USGS Employees. USGS employees are responsible for being knowledgeable of and in compliance with sponsorship and conference policy procedures
4. Policy.
As described in the DOI Financial Management Memorandum 2013-024, “Authorization and Reporting Guidance on Conference-Related Activities and Spending,” dated June 27, 2013, bureaus and offices are to ensure that sponsorships are approved in advance and conform to acquisition requirements. Bureaus are responsible for the clearance of all legal and ethical matters relating to sponsorships, cooperative agreements, and/or other issues with the Solicitor’s Office and for review of contracting actions by the bureau/office acquisition official to ensure that they are compliant with Federal Acquisition Regulations.
A. For the purpose of implementing DOI policy, the following definitions will be used to determine whether an event falls within the category of sponsorship and subject to the requisite approvals:
(1) Sponsorship is defined as a cash and/or in-kind fee paid to an entity in return for access to conference or meeting benefits not provided otherwise, and includes expending funds for sponsoring, advertising, corporate membership, and all other support to a hosting organization.
(2) Sponsorship approval requirements apply regardless of source of funds, including sponsorships entirely funded by non-DOI (e.g., reimbursable) sources.
(3) Events that are organized or managed on behalf of the USGS through contract or cooperative agreement, including technical, science- and project-based workshops and meetings, are not sponsorships. These are considered USGS-hosted events which may require approval based on the rules applicable to conferences. (See IM AEI 2014-03 “Conference-Related Activities and Spending.”)
B. Examples of applying sponsorship policy are as follows:
(1) The USGS becomes a “Bronze Level” contributor to a national scientific conference.
Sponsorship does apply because value received by the USGS will be intangible and not directly relatable to reasonable incurred costs supporting USGS science (i.e., benefits are being realized that are not provided otherwise). (Conference approval policy applies if conference approval thresholds are met.)
(2) The USGS pays for a booth at a national conference. In addition to the space, the USGS is given three free entrance tokens.
Sponsorship does apply because the USGS is receiving a tangible benefit not otherwise provided (e.g., cost of three entrance tokens). (Conference approval policy applies if conference approval thresholds are met.)
(3) The USGS funds a scientific workshop through a contract or cooperative agreement.
Sponsorship does not apply because USGS is hosting the event through a third party. (Conference approval policy applies if conference approval thresholds are met.)
(4) The USGS funds a project for conducting a field study and reports on the results.
Sponsorship does not apply because no conference or meeting event has been defined. (Conference approval policy does not apply.)
(5) The Corps of Engineers funds, through an interagency agreement, a workshop being organized through a cooperative agreement.
Sponsorship does not apply because this is considered a USGS-hosted conference, regardless of the source of funds. (Conference approval policy applies if conference approval thresholds are met.)
(6) The USGS funds fair market value for a booth (paying the same cost as would any other booth sponsor) at a national conference but does not realize any other tangible benefit from the meeting such as reduced admission, free additional passes, or food.
Sponsorship does not apply because the USGS is not receiving any benefit not provided otherwise. (Conference approval policy applies if conference approval thresholds are met.)
5. Sponsorship Approval Request.
All sponsorships, regardless of dollar amount, require the DOI Deputy Secretary’s approval prior to expending funds. Requests for sponsorships must include the following:
A. The name, date, number of attendees, and location of the event.
B. The amount of sponsorship.
C. The benefits and/or services provided with the sponsorship (e.g, free attendance by some number of attendees, logo posted on the Web site, meals, etc.).
D. The identity of the sponsoring entity.
E. The funding source and Mission Area or Region supporting the sponsorship.
F. A narrative demonstrating why sponsorship is consistent with the mission of the USGS and/or DOI and in the best interest of the DOI and the taxpayers. You may want to indicate the history of sponsorship with this entity.
An example of an approved sponsorship memorandum is available internally.
/s/ Paul M. McEnrue July 7, 2014
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Paul M. McEnrue Date
Acting Associate Director for Administration and Human Capital