Why We Did This Evaluation
The Millennium Challenge Corporation (MCC) was established in 2004 to help countries promote economic growth, open markets, and increase living standards. In 2024, MCC commemorated its 20th anniversary through a series of events, including keynote speakers from MCC leaders and members of Congress, a reception cohosted with the United Nations Foundation, and executive-level dinners. Event attendees included MCC’s country partners, staff, board members, and other stakeholders.
To further mark the occasion, MCC produced and distributed commemorative promotional items. The Agency used a combination of representation and entertainment (R&E) funds and administrative funds to pay expenses.
In May 2024, we received an allegation from an anonymous complainant that MCC used taxpayer money on a “lavish” event to celebrate its 20th anniversary. The allegation also indicated that MCC used over $750,000 in taxpayer money to buy promotional items for employees, such as T-shirts, water bottles, and bags, that represented a misuse of funds and wasteful spending.
In response to the allegation, we initiated this evaluation to determine whether MCC adhered to applicable Federal requirements and internal policies and procedures when holding events to celebrate MCC’s 20th anniversary and buying promotional items for employees.
What We Found
MCC followed requirements for most anniversary-related purchases but did not always document approvals due to internal policy gaps. MCC’s expenditures for anniversary events and promotional items were consistent with its annual appropriations for R&E funds. Additionally, based on our analysis of the Agency’s planned R&E allocations and actual expenditures, MCC did not exceed the total R&E funds available under its appropriations and internal policy.
We also concluded that MCC’s use of administrative funds for support of anniversary-related activities aligned with its statutory authority. However, MCC did not have documented approvals for selected promotional items purchased under a contract amounting to approximately $26,900 in administrative funds because there was no internal policy to govern the approval of those funds at the time.
In September 2024, about 4 months after the completion of its 20th anniversary activities, MCC issued interim guidance on the review and pre-approval process to purchase items using administrative funds. As of September 2025, the policy was still in draft form. The lack of an approved policy on the use and approval of administrative funds increases the risk of inconsistent use of funding authorities for similar expenditures in the future.
What We Recommend
We made two recommendations to MCC to improve its management process for purchases made using administrative funds and to determine the allowability of approximately $26,900 in questioned costs. MCC agreed with the recommendations.