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Chapter 1 - Home Page 409th Contracting Support Brigade - U.S. ...

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Small ―samples‖ of ethnic foods served during a formal ethnic awarenessprogram as part of the agency’s equal employment opportunity program aretypically authorized (60 Comp. Gen. 303 as expanded in B-199387).There are other exceptions to the general prohibition to providing free food togovernment employees at their official duty stations. Two exceptions are derivedfrom the Government Employees Training Act, 5 USC 4109.The first exception is called the "training" exception and it allows an agency topay for the food of government employees attending a training conference attheir official duty station if the meal is NECESSARY to obtain the full benefit ofthe training program. And it’s not enough to simply call the conference a "trainingconference." There must be actual training taking place. The Act specificallyallows the expenditure of appropriated funds to pay for "all or a part of thenecessary expenses of training" and meals can be considered a necessaryexpense of providing training, under the right circumstances. Use of thisexception requires an administrative determination, by a responsible official inthe organization, that providing meals is necessary to obtain the full benefit of thetraining.The second exception is called the "formal meetings and conferences" exception,which allows an agency to pay the cost of meals and refreshments at formalmeeting and conferences when three conditions exist: (1) the meals must beincidental to the meeting or conference (i.e., can't be a meeting that takes placeonly over lunch); (2) attendance of employees at the meals must be necessaryfor full participation in the meeting or conference (e.g., an important speaker81

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