Architect of the Capitol Contributions to Employee Benefit Trust Funds on Behalf of Temporary Employees

A member of a law firm which represents the Boards of Trustees of several employee benefit trust funds, requested a ruling whether the Architect of the Capitol was empowered to make contributions directly into the trust funds rather than paying an equivalent amount to the temporary employees themselves. The Architect has been authorized to make payments on behalf of employees to nonemployee third parties only in certain specified instances and has not been authorized to make contributions to employee benefit trust funds.