Matter of: Gary Spangelo File: B-248955 Date: July 24, 1992
Highlights
It has long been held that the costs of qualifying for a federal position are personal to the employee. Spangelo's claim is not payable under previous decisions of this Office. It is a long-standing rule that individuals must bear the cost of qualifying themselves for positions in the federal service. These cases and others cited therein have consistently applied this rule to a variety of professional occupations. The matter was submitted to us by the Chief.
Matter of: Gary Spangelo File: B-248955 Date: July 24, 1992
APPROPRIATIONS/FINANCIAL MANAGEMENT Appropriation Availability Purpose availability Specific purpose restrictions Personnel expenses/furnishings Licenses An agency may not pay the costs associated with an employee's attainment of a professional engineering certificate which the agency required as a qualification for the employee's position. It has long been held that the costs of qualifying for a federal position are personal to the employee.
DECISION
The Bureau of Reclamation, Department of the Interior, as a condition of Mr. Gary Spangelo's employment in a Regional Engineer's position, required that he become a registered professional engineer. Mr. Spangelo took and passed the necessary state-administered examination and submitted a claim for the costs he incurred. [1] The agency acknowledges that Mr. Spangelo's claim is not payable under previous decisions of this Office, but, nonetheless, asks that those decisions be reconsidered so that his claim may be paid since he incurred the costs to meet a requirement imposed on him by the agency. [2]
As the agency notes, it is a long-standing rule that individuals must bear the cost of qualifying themselves for positions in the federal service, including the costs of obtaining personal licenses when necessary. 22 Comp.Gen. 460 (1922); 46 Comp.Gen. 695 (1967); 61 Comp.Gen. 357 (1982); Audrey Rose and Allen Bailey, B-218964, Nov. 26, 1985. These cases and others cited therein have consistently applied this rule to a variety of professional occupations, even when the agency supports the employee's efforts. We see no basis now to disturb such well-settled precedents. Accordingly, Mr. Spangelo's claim may not be paid.
1. These costs include the examination fee ($90), study materials ($234) and travel expenses ($225).
2. The matter was submitted to us by the Chief, Accounting Operations, Administrative Service Center, Denver, Colorado.