Principles of Federal Appropriations Law - US Government ...

Chapter 4
Availability of Appropriations: Purpose
the objectives of the training program. 48 Comp. Gen. 185 (1968); 39 Comp.
Gen. 119 (1959); B-247966, June 16, 1993; B244473, Jan. 13, 1992; B-193955,
Sept. 14, 1979. The government may also furnish meals to nongovernment
speakers as an expense of conducting the training. 48 Comp. Gen. 185.
In 50 Comp. Gen. 610 (1971), the Training Act was held to authorize the
procurement of catering services for a Department of Agriculture training
conference where government facilities were deemed inadequate in view of
the nature of the program.
The fact that an agency characterizes its meeting as “training” is not
controlling. In other words, for purposes of authorizing the government to
feed participants, something does not become training simply because it is
called training. In B-168774, Sept. 2, 1970, headquarters employees of the
then Department of Health, Education, and Welfare met with consultants in
a nearby hotel at what the agency termed a “research training conference.”
However, the conference consisted of little more than “working sessions”
and included no employee training as defined in the Training Act.
Therefore, the cost of meals could not be paid. See also 72 Comp. Gen. 178
(1993); 68 Comp. Gen. 606 (1989); B-247563, Dec. 11, 1996; B-208527,
Sept. 20, 1983; B-187150, Oct. 14, 1976; B-140912, Nov. 24, 1959.
In 65 Comp. Gen. 143 (1985), GAO held that a Social Security
Administration employee who had been invited as a guest speaker at the
opening day luncheon of a legitimate agency training conference in the
vicinity of her duty station could be reimbursed for the cost of the meal.
The decision unfortunately confuses 5 U.S.C. §§ 4109 and 4110 by analyzing
the case under section 4110 yet concluding that reimbursement is
authorized “as a necessary training expense,” which is the standard under
section 4109.
(3) Award ceremonies
General operating appropriations may be used to provide refreshments at
award ceremonies under the Government Employees’ Incentive Awards
Act, 5 U.S.C. §§ 4501–4506. 65 Comp. Gen. 738 (1986); B-271551, Mar. 4,
1997. This Act authorizes an agency to use its operating appropriations to
cover the “necessary expense for the honorary recognition of” the
employee or employees receiving the awards. 5 U.S.C. § 4503. The Act also
directs the Office of Personnel Management to prescribe regulations and
instructions to govern agency awards programs. 5 U.S.C. § 4506.
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