B-231830, Jun 5, 1989, 68 Comp.Gen. 467

B-231830, Jun 5, 1989, 68 Comp.Gen. 467

The Forest Service, United States Department of Agriculture, may not pay for "identification" cards used by its public affairs officers. The "identification" cards are no different from business or calling cards. The purchase of these cards has always been viewed as a personal expense which may not be paid for with appropriated funds, in the absence of specific statutory authority.

Forest Service-- Purchase of Information Cards:

An authorized certifying officer of the Forest Service, United States Department of Agriculture, has asked for our advance decision on whether he should certify a payment to reimburse a Forest Service employee for the purchase of 1,000 "information" cards "for use in performing his job as a Public Affairs Officer for the Public Affairs Office of the Rocky Mountain Office." He also asks whether he may certify a payment for "information" cards that identify the agency but do not indicate the name and title of any individual. For the reasons indicated below, we conclude that these cards may not be purchased using appropriated funds and that payment should not be certified.

BACKGROUND

Lynn Young, a public affairs officer for the Rocky Mountain Region of the Forest Service, purchased 1,000 "information" cards to be used in the course of his official business. He has requested reimbursement for the cost of these cards. As explained by Mr. Young, the exchange of information cards is essential to the conduct of public information business. He says that there is an unspoken rule that those who have frequent contact with the public and the media have these cards available for distribution.

The "information" cards purchased by Mr. Young have a gold colored shield of the U.S. Forest Service impressed in one corner, and include his name, title, Forest Service office, address, and both commercial and FTS phone numbers printed on the card.

Some units of the Forest Service have printed "information" cards that do not contain the name or title of any specific individual. Forest Service personnel distribute these cards in the course of their official duties. Many of these employees hand print or stamp their names and titles on the cards before using them. According to the certifying officer, the cards give the public ready access to Forest Service telephone numbers, and serve "as a reminder to the public of who we are and what they can do to assist the Forest Service."

The certifying officer submitted a sample of these cards. The card, printed on wood-grain paper, contains the shield of the Forest Service in one corner and the message "'We Care' Pike & San Isabel National Forests" printed across the top. Then, in large letters, is printed "SOUTH PLATTE Ranger District" and the address and phone number of the office.

DISCUSSION

We have long held that the costs of calling or business cards constitute personal rather than official expenses of the persons using them. Therefore these costs may not be paid with government funds in the absence of specific statutory authority to do so. /1/ See, e.g., B-131611, Feb. 15, 1968; 12 Comp.Gen. 565 (1933). We have continued to apply this rule even when it was clear that the cards were being used only for official purposes. See B-195036, July 11, 1979; 12 Comp.Gen 565, 566 (1933). /2/

We have frequently considered arguments similar to those presented by Mr. Young in this case, but have consistently ruled that appropriated funds are not available for these cards. E.g., B-195036, July 11, 1979 (agency employee had "extensive contact with public, government, and business officials who frequently asked him to leave business cards"); B-131611, Feb. 15, 1968 ("the use of business cards was necessary in conducting business in Europe for the National Park Service"); 41 Comp.Gen. 529, 530 (1962) ("it is a well-established practice to exchange business cards" and "initial contacts are unnecessarily marred if the ... customers are required to solicit information that the business card should provide"); B-131611, May 24, 1957 ("officer is required to make many official visits" to prospective customers and agency "wanted the agricultural officer to have items of this nature where they help him to do his job better"). our opinion the arguments made by Mr. Young are no more persuasive than the ones we have rejected in the past.

Mr. Young, who is familiar with our earlier decisions, asserts that unlike calling cards, which are primarily for private use and private benefit, his "information" cards are "strictly for official business." B-149151, July 20, 1962, we addressed a similar contention:

"The cards in question while denominated as "cards of introduction" ... are actually calling ... cards. The "cards of introduction" are calling cards issued to the foreign visiting student with his name added at the time of issuance of the card to him. The card serves the purpose of introducing the bearer to anyone to whom the card is presented. This is a primary function of a calling card."

Likewise, Mr. Young's "information" cards serve the purpose of introducing him to those to whom he gives them and are therefore no different than calling cards. Accordingly, he may not be reimbursed for the cost of purchasing the cards.

We reach the same result with respect to the "information" cards printed without names or titles. These cards are generally used for the same purpose as calling cards-- introducing the agency official to the person to whom he or she presents them. The fact that the individuals who use these cards generally add their names and titles clearly indicates that they are being used as calling cards. The purchase of these cards, therefore, constitutes a personal expense which may not be paid from government funds. Cf. 47 Comp.Gen. 314, 316 (1967) (the cost of seasonal greetings cards were a personal rather than an official expense even though "the names of the officers or employees sending the cards were not included and nothing attached to the cards to indicate the compliments of any individual"); accord 37 Comp.Gen. 360 (1957).

/1/ Such specific authority could be provided, for example, by a line- item agency appropriation for official reception and representation expenses. Calling or business cards are a legitimate means of "representation," and an agency head could determine that their use by certain officials or employees would be a necessary representation expense.

/2/ This rule is also recognized in the Joint Committee on Printing's Printing and Binding Regulations, which state: "Printing or engraving of calling or greeting cards is considered to be personal rather than official and shall not be done at Government expense." S. Pub. No. 5, 100th Cong., 1st Sess. 15 (1987)