[Decision Concerning HUD Use of Operating Appropriations to Pay Contractors for Food, Entertainment, and Gifts]

The Department of Housing and Urban Development (HUD) requested a decision regarding its authority to use research and technology or official reception appropriations to pay contractors for meals, entertainment, and gift items they provided during an international trade show. HUD noted that the behavior code for conducting international business required such expenditures as the extension of hospitality and the exchange of gifts. GAO held that HUD lacked authority to use its: (1) research and technology appropriations for those expenses, since it failed to show the actual necessity of the expenditures; and (2) official reception and representation appropriations, since the trade show was not an authorized HUD program goal. Accordingly, HUD could not use its appropriations to reimburse contractors' expenditures for gifts, entertainment, and meals associated with the international trade show.