This time it is the Internal Revenue Service (IRS) that has demonstrated bad judgment and lack of a full understanding of the rules governing large meetings. The revelation of extravagant IRS spending on meetings follows similar issues with the General Services Administration and the U.S. Department of Veterans Affairs. This waste shines a light on bad judgment for sure—but it also reveals a larger problem. For the most part, government personnel who are planning and coordinating government-run events do not do this as their primary function. They do not run events often enough to fully understand the travel and conference policies or the ethics and gift regulations. This leads to frequent errors and, when combined with bad judgment, to significant waste.
Government should not be in this business. The potential for failure and waste of taxpayer money is too great. For decades, the defense community has had a set of defense-related associations (DRAs), nonprofit organizations whose sole function is to support the defense community and bring together government, industry and academia. These are organizations such as AFCEA, the National Defense Industrial Association, the military service associations and functional groups that support one or more of the military services and defense agencies. Similar associations serve the civil side of the federal government and state, local and tribal governments.
These organizations possess decades of proven performance; thoroughly understand the communities they serve; understand in-depth conference policies, ethics regulations and gift rules; and have high ethical standards embedded in their structures. In addition, because they are nonprofit organizations, any positive net derived from the presentation of an event is reinvested in the community through scholarships and grants, training, studies and other forms of service to government.
The DRAs and other nonprofit organizations present conferences, symposia and training events, most often at no cost to the government except for the cost of individual government personnel participation. Importantly, these organizations take on all of the financial risk associated with an event, and they sign and administer all associated contracts. Government can be as involved in program design and development as it wishes, depending on the level of participation cost it can afford to bear. Often, government participants are not charged to attend, limiting their costs to transportation and per diem.
The Department of Defense Joint Ethics Regulation allows for free attendance by government personnel as long as all attendees are treated the same. For any such event, government legal staff can and should be involved in a review of the program and business model, from the beginning of planning through execution. In the end, this ensures compliance with applicable policies and regulations, and it insulates the government from liability. Policies and regulations in this area change periodically, and because the DRAs and other nonprofit organizations conduct events regularly, they interface with the legal community frequently to stay current and promote ongoing compliance.
The detailed familiarity that nonprofits have with the communities they serve also helps ensure quality programs and relevant, up-to-date training and education—particularly in areas requiring certification such as cybersecurity, engineering or program management. This gives the government the level of program control it wants and needs along with execution by an organization that understands the challenges. These nonprofit organizations are membership associations with members from every part of the community they serve. This generally promotes a balanced approach to the agenda for a specific topic.
It makes no sense for government at any level—defense or civil—to run its own conferences in the future. It can get high-quality events at any scale, and it can minimize cost and risk by turning to the DRAs or other nonprofit organizations to run its conferences, symposia and large-scale training meetings. The legal staff should be engaged early and often, ensuring compliance with conference policies and regulation. Government can influence the program as much as it desires. It also should demand a memorandum of agreement from the supporting DRA, or other nonprofit organization, outlining the responsibilities of government and the supporting organization—with particular focus on program control, financial responsibility by the nonprofit, government costs, if any, and risk management. Any DRA or other nonprofit organization should be willing to sign such an agreement, and this agreement would be reviewed and approved by the government legal team prior to execution.
Government should let the nonprofit organizations support it. That is the reason organizations such as AFCEA are here. We will help government communicate and train effectively, at minimum cost, and with full measure of the policy and regulatory constraints.