Principles of Federal Appropriations Law - US Government ...

Chapter 4
Availability of Appropriations: Purpose
In 1998, GAO re-examined the prohibition. In B-280759, Nov. 5, 1998, GAO
did not object to the use of Operation and Maintenance (O&M) funds for
the purchase of business cards for use by civilian personnel specialists of
the Army Civilian Personnel Advisory Center. The Advisory Center acts as a
liaison between Army employing units and their employees, and provides
advice and assistance to employers and employees. The specialists would
use the business cards to provide the Center’s customers with accurate
information on how to contact the specialist assigned to a customer’s case.
Applying a necessary expense analysis, we concluded that business cards
would advance the Center’s mission, and that use of the Army’s O&M
appropriation (which funds the Center’s activities) to purchase business
cards for the specialists was proper. See also Memorandum from Richard L.
Shiffrin, Deputy Assistant Attorney General, Office of Legal Counsel,
Department of Justice, to Emily C. Hewitt, General Counsel, General
Services Administration, Aug. 11, 1997.
We have considered the cost of business or calling cards for Members of
Congress and their staff who require them a necessary and justifiable
expense, given the nature of Members’ constituent responsibilities. See
B-198419, Nov. 25, 1980; B-198419, July 8, 1980.
Also, we have considered reception and representation (or comparable
forms of “entertainment”) appropriations to be available to purchase
business cards for employees whose jobs included representation.
B-223678, June 5, 1989 (noting that business cards are a “legitimate and
accepted” representation device, so the expenditure is subject to the
limitation of that appropriation). See also 72 Comp. Gen. 146 (1993);
68 Comp. Gen. 467, 468 n.1 (1989); B-246616, July 17, 1992).
We considered a variation on business cards in B-173239, June 15, 1978.
The Board for International Broadcasting wanted to use what it termed
“transmittal slips” to accompany the distribution of its annual report. The
transmittal slip resembled a business card and contained the words “With
the compliments of (name and title), Board for International Broadcasting.”
It was not necessary to decide whether the “slips” were business cards or
not, because 44 U.S.C. § 1106 expressly provides that documents
distributed by an executive department or independent establishment may
not contain or include a notice that they are being sent with “the
compliments” of a government official. Use of the transmittal slips was
therefore unauthorized.
Page 4-244 GAO-04-261SP Appropriations Law—Vol. I