An agency recently asked the General Accountability Office (Comptroller General) if it could use agency funds to buy refreshments for an employee CFC rally designed to boost contributions. While GAO used the occasion to spell out the basic rule and its exceptions, it unknowingly shined a bright light on an opportunity for unions. GAO’s decision said,

Agencies may use appropriated funds for certain CFC-related expenses but the provision of food is a personal expense. It is well established that an agency may not use appropriated funds to purchase items considered personal expenses, such as food, without specific authority to do so. We have found exceptions, however, where an agency has specific statutory authority to provide food, or where it can demonstrate that such expenditures are an essential constituent part of accomplishing a statutory responsibility of the agency. (See GAO, B-325023 (7/11/14))

Since OSHRC, the agency seeking approval, did not cite any specific statutory authority allowing the use of its appropriated funds to purchase food for the proposed CFC event, GAO focused on whether the use of funds for food at the CFC kick-off event is an essential constituent part of accomplishing a statutory function. GAO denied OSHRC the ability to spend appropriated money on food saying that, “Without compelling empirical evidence demonstrating that serving food would generate increased CFC donations, or legislation permitting agencies to use appropriations to supply food at CFC events, we are unwilling to extend the availability of appropriations to cover food at CFC fundraising exceptions….Here, neither OSHRC, CFC nor anyone else has presented comparable sociological research establishing that serving food at a CFC fundraiser is an effective incentive to generate or increase contributions.

Empirical! Sociological! Evidence!

So, if an agency wants to provide snacks at a CFC fundraiser or similar event, such as a Bond drive or annual employee engagement survey rally, it has to come from something other than appropriated funds. Executives can chip in to pay the tab, but the GAO ruling creates a wonderful opportunity for the union to build its image, relationships and membership. Funding refreshments at a charity event is bound to boost the union’s image unless it represents a particularly cold-hearted unit.  Offering the funds to management for refreshments should boost an existing relationship or be the first step to a new one.  It is totally voluntary on the union’s part. Finally, if the union can trade its payment of refreshments for an information table about the union or access to employees during their break to get refreshments membership should also show some immediate improvements.

About AdminUN

FEDSMILL staff has over 40 years of federal sector labor relations experience on the union as well as management side of the table and even some time as a neutral.
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