[Request for Advance Decision]

The Uniformed Services University of the Health Sciences requested an advance decision as to whether appropriated funds may be used for expenses related to the University's annual graduation ceremony. GAO determined that funds allotted to the University from its congressional appropriation are available for all of its functions, including its graduation ceremony. GAO concluded that expenditures for the rental of academic regalia for invited guests, military students, and faculty were necessary to carry out the objectives of the University's appropriation. GAO noted that military officers attending school for training purposes are performing required duty and cannot be expected to pay for equipment necessary to perform that duty. Similarly, invited guests should not reasonably be expected to bear the cost of their rental regalia. However, GAO held that the University should not use its appropriated funds for rental regalia worn by graduating civilian students and civilian faculty and determined that it was customary for students and faculty at private universities to bear the cost of renting graduation regalia. GAO also held that all expenses incident to the graduation ceremony, which include the costs of printing invitations and announcements, were valid expenditures.