[Request for Reconsideration Concerning Funding of Receptions at Arlington House]

The Department of the Interior requested reconsideration of a decision in which it was concluded that two receptions hosted by the Secretary of the Interior and his wife at the Custis-Lee Mansion during the 1981 Christmas season were social rather than official in nature. It was also concluded that neither the funds appropriated to Interior for salaries and expenses nor moneys donated to the Cooperating Association Fund of the National Park Service could be used to pay for these events. Interior argued that: (1) under its mandate to promote and regulate the use of national parks, monuments, and reservations, receptions which introduce the guests to historical buildings are a most effective and appropriate method to promote the national park system; (2) GAO has not disallowed expenditures for receptions from the Fund in the past, even though the Fund has traditionally been used to pay for receptions similar to those at issue here; (3) its reports to Congress provide implicit congressional approval of all expenditures for receptions; and (4) if a reception promotes Park Service objectives, the presence of the Secretary or any other Government official is not necessary. GAO held that the facts in this case were of critical importance, for they indicate that the two events in question were essentially personal and social in nature. The justification provided by Interior to Congress characterized them as such. Visits to the Custis-Lee Mansion by the attendees of the evening reception were at the election of the guests since the reception itself was held in a tent on the grounds. There was no agenda in which Park Service objectives were presented at either of the events, and any promotion of the objectives would appear to have been by random choice. There was no determination nor any evidence that Park Service objectives could not have been served as satisfactorily or as effectively without expenditures of donated funds for the two events. In cases where GAO has approved the use of donated funds for entertainment, the entertainment was clearly incidental to an authorized agency activity. Accordingly, the prior decision was affirmed. Park Service officials who certified the improper payments are personally liable to restore the funds concerned, but Interior should seek reimbursement from the Secretary and his wife, pursuant to the Claims Collection Act.