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    Can I purchase coffee mugs (about $1,500) for our department that are custom printed in the USA to facilitate adoption of our official program (per our 2 star general) to give to federal employees to encourage adoption?


    Answer

    First, thank you for doing some research here at AAP, that is sincerely appreciated.

    Second, we're assuming you want to use appropriated funds.

    Unfortunately we can't provided a definitive answer. The purchase of mementos, trinkets, gifts, etc. has and will always be a gray area. This is especially so if they are not part of a formal, officially sanctioned awards program or a specific event (but even those can be tricky).

    We get asked this question alot here at AAP and the two previous answers you mentioned had really great references (the GAO Redbook Chapter 3 and FMR 7000.14-R Volume 2A). Another good reference is the Fiscal Law Deskbook published by the Contract and Fiscal Law Department, Judge Advocate General’s Legal Center and School, United States Army. Basically the question comes down to the "Necessary Expense Doctrine".

    The SHARP program was authorized via OMA Budget Activity 01: Operating Forces Activity Group 13: Land Forces Readiness Support Detail by Subactivity Group 131: Base Operations Support: Community Services.

    We recoomend you get with your fiscal law atttorney and comptroller to determine if you have authority to purchase these and if yes, what funds would be most appropriate. If your program is a named (i.e. MDAP) program, there is most likely language that Congress included in that appropriation that provides some guidance on if this type of expense is or is not authorized.

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