[Use of Appropriated Funds To Purchase Membership in Chamber of Commerce]

The Director of the Federal Law Enforcement Training Center requested an advance decision as to whether he might be reimbursed a membership fee he paid to the local Chamber of Commerce for the benefit of the Center. He reasoned that such an expenditure would be proper because: (1) the information obtainable from the Chamber of Commerce would be useful to the trainees at the Center; and (2) the membership would facilitate the Center's public relations activities. Agencies may obtain memberships in private organizations where such membership would be of primary benefit to the agency and where the agency determines that such membership is necessary to carry out its statutory functions. However, membership fees may not be obtained in the name of employees unless authorized by a specific appropriation. GAO concluded that, upon determination that such membership is necessary to carry out the Center's mission, appropriated funds may be used to obtain a membership. However, membership may not be obtained in the name of the director. Moreover, he may not be reimbursed for the membership even if he converted the membership to the Center. No government employee can create a valid claim in his favor by paying obligations of the United States from his own funds. Accordingly, reimbursement to the director for the amount in question was not authorized.