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B-280759 1 (1998-11-05)

handle is hein.gao/gaocrptahws0001 and id is 1 raw text is: G AO United States General Accounting Office Washington, D.C. 20548 Office of the General Counsel B-280759 November 5, 1998 Mr. Jerome J. Markiewicz Chief, Fiscal Management Division and Administrative Support 1206 Stanley Rd. Ft. Sam Houston, TX 78234-5037 Dear Mr Markiewicz: In your letter of August 5, 1998, you asked for informal advice concerning the use of Operation and Maintenance, Army, funds (O&M) to purchase business cards. Your need for advice stems from a request for business cards for civilian personnel specialists of the Civilian Personnel Advisory Center (CPAC or Center). CPAC is the Fort Sam Houston representative of the Department of the Army centralized Civilian Personnel Operating Center serving the southwestern United States. The primary responsibility of CPAC is to act as a liaison between Army employing units and their employees, to provide advice and assistance to employers and employees, and to forward personnel actions and related documents to the Army's centralized center. The civilian personnel specialists will use the business cards to provide the Center's customer an accurate reference to the specialist providing assistance and a precise electronic address for contacting the specialist--a critical element in electronic correspondence, since neither phones nor electronic mail (e-mail) can redirect inaccurate deliveries. As you point out, there has been a long history of Comptroller General decisions holding that appropriated funds may not be used to purchase business cards except in limited circumstances. See, e.g., 68 Comp. Gen. 467 (1989); 41 Comp. Gen. 529 (1962); 12 Comp. Gen. 565 (1933). These decisions have been grounded on a narrow, if not an incorrect, understanding of the function and use of business cards. Because of this, and notwithstanding the valuable information that business cards convey about an officer's or employee's office, these cards have been viewed as a personal, not an official expense. I believe, however, that if this matter is analyzed from a necessary expense perspective, a more logical and legally defensible conclusion results. The Office of Legal Counsel (OLC), Department of Justice (DOJ), recently advised the General Counsel of the General Services Administration (GSA) that GSA may

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