Frequently Asked Questions Representation Allowances
QUESTIONS: 1. Q: Can the embassy use representation funds to pay membership fees or dues for an individual employee in any society, club or association?
5. Q: Can employees be reimbursed for expenses associated with printing or engraving invitations to official functions?
6. Q: Can post use representation funds to purchase bulk items needed for representational events?
9. Q: Can representation funds be used to hire extra waiters to serve at official representation events?
12. Q: If household staff of the official residence work overtime for an official function is the overtime reimbursed as official residence expenses (ORE)?
QUESTIONS:
1. Q: Can the embassy use representation funds to pay membership fees or dues for an individual employee in any society, club or association?
A: Membership fees or dues for an individual employee may not be paid under any circumstances. (See 5 U.S.C. 5946) However, in certain cases, an agency may purchase a membership in its own name, provided that the expense can be justified as a "necessary expense". The membership must meet the following criteria: the benefits of the membership accrue to the embassy, not just to the embassy's employees, the membership "substantially contributes" to the agency mission, the membership is not in the name of any individual employee, and the embassy pays for the membership. Agencies that fall under the authority of the Foreign Affairs Manual (FAM), such as the Department of State, may not charge memberships to the representation allowance. They should expend Diplomatic and Consular Program (D&CP) funds for any allowable costs. Furthermore, the FAM prohibits payment or reimbursement for membership in social or sporting organizations. Please see3 FAM 3246.2(6) for more details 2. Q: Can the embassy reimburse an employee for expenses incurred in attending the local American Chamber of Commerce meeting? A: Representation funds may be used to pay for attendance at professional meetings, including meal costs, which are considered reasonable and customary expenses of such meetings, when a determination is made by the Chief of Mission or designated representative that an association or professional meeting be attended for representational purposes. Funds may not be used to pay for meals at professional meetings (consular, commercial or other associations) when the primary benefit is to the employee. 3. Q: The ambassador recently hosted a reception for a visiting Congressional Delegation. The other invitees were American business persons based in the country. The financial management officer has questioned the validity of the reimbursement claim because host country nationals were not included on the invitation list. Can post reimburse the ambassador for this claim? A: Yes. Reimbursement of representational events for members of the legislative and/or judicial branches of the United States Government is allowable. Employees can also be reimbursed for hosting representation events for other American citizens who are not employees of the Federal Government, including state and local officials and business persons. Note: Since representation relationships are established and maintained primarily with host country officials and private citizens, guest lists for representation events should reflect minimum guest ratio guidelines set by the chief of mission for each type of representation function (rarely more than fifty percent USG executive branch employees), to ensure representative cross sections are invited (see Foreign Affairs Agency Regulation Reference 3 FAH-1 H-3244.3). 4. Q: Can the embassy reimburse an employee for the printing and engraving costs of the Christmas/Holiday cards he mailed to his host country contacts?
A: Printing, engraving or purchase of season greeting cards may be allowed if there exists agency authority (such as Department of State authority under 22 U.S.C. 2669(a) for doing so. Any messages or images on the cards should be secular in nature (such as "Season's Greetings" or pictures of wreaths, wintry scenes, or snowmen) and should not convey religious themes or messages. 5. Q: Can employees be reimbursed for expenses associated with printing or engraving invitations to official functions? A: Yes. Under 22 U.S.C. 2669(a), reimbursement can be made for printing or engraving costs for invitations to official functions. 6. Q: Can post use representation funds to purchase bulk items needed for representational events? A: At the discretion of the Chief of Mission or his/her designee, purchases of representation supplies in advance of a function are limited to the type and quantity necessary due to circumstances at post. Each post should develop written guidelines to cover the specific situations where advance purchases are authorized. For State Department, representation funds reimbursement or payment, except for invitation cards to official functions and American wine, is permitted only event-by-event on the basis of guest (recipient) lists. Bulk purchases to cover several future representation events, even though practical and economical, except for invitation cards and American wine, must be financed by the host or other officer and reimbursed only on an event-by-event basis. Reasonable amounts of invitation cards and American wine (not to exceed a year's supply -- prior year's usage should be used as a benchmark) may be procured and paid for or reimbursed as a bulk purchase in lieu of buying new cards or American wine for each event. American wine, if purchased in bulk from official funds, must be under inventory control of the accountable property officer, and must be accounted for (as a no-reimbursement item) on representation vouchers. In no case, however, is the post authorized to use excess year-end funds to purchase wine, invitations, or other representation supplies and materials which are not a bona fide need of that fiscal year. 7. Q: Can representation funds be used to reimburse employees who invite foreign guests to the Marine Ball? A: Expenditures for tickets or admission to unhosted events are a poor use of representation funds, and while not prohibited, are considered allowable only in those instances where the highest levels of host country officials are present and the attending employee has the necessity and opportunity to fulfill the purpose of the representation allowance. Attendance at a Marine ball, or other strictly social function normally does not permit an officer to meet the criterion for the representation allowance. However, at the discretion of the chief of mission or his/her designee, reimbursement can be made if it is determined that the invited guests' attendance will assist the embassy in promoting U.S. Foreign policy interests. 8. Q: While in the U.S. for consultations, the ambassador hosted a dinner for the Foreign Minister of Xanadu. Can the embassy use post's representation funds to reimburse her for the expense? A: Representation funds allotted to posts can only be used in foreign locations. Representation expenses incurred in the U.S. are reimbursed from the appropriation for emergencies in the diplomatic and consular service (K fund). Post officials should consult with the appropriate assistant secretary in their regional bureau before hosting events in the U.S. 9. Q: Can representation funds be used to hire extra waiters to serve at official representation events? A: Yes. The Comptroller General has ruled that the State Department's representation allowance appropriation can be used to fund this expense. 10. Q: Are receipts required for representation expenditures? A: Yes. Evidence of expenditure will be supplied for each expenditure of $75 or more for any single occasion. This should not be interpreted to mean that no receipts are necessary for expenditures for less than $75. Representation expenditures must be supported by receipt, copy of canceled check, credit card charges, admission ticket stub or other similar physical means. For each expenditure less than $75, the employee's certification will be sufficient when it is impracticable to obtain a receipt. 11. Q: I am a Consul General. One of my duties is to represent the United States Government at post. As the only USG official accredited here I am thus responsible for all political and judicial démarches with this country. I recently attended National Day ceremonies. A very protocol-conscious society, the host country makes it clear which type of formal wear is supposed to be worn at each event. I had to rent a morning coat with tails, top hat, gloves, etc, as I do not own these items. I have submitted a voucher to the Embassy with a request for reimbursement but the embassy's Budget and Fiscal (B&F) section states that in accordance with the regulations (DSSR 320g), reimbursement can be made only for "Ambassadors, Deputy Chiefs of Mission and officers serving as Charge d'Affaires." Am I entitled to reimbursement? A: No. Reimbursement is applicable for rental costs incurred for ceremonial dress required of staff accompanying an Ambassador in presenting his/her credentials to the head of state; rental costs incurred by Ambassadors, Deputy Chiefs of Mission and officers serving as Charge d'Affaires for formal morning dress required by host country protocol for official ceremonial occasions. Reimbursement for rental costs of formal wear for all other occasions is prohibited 12. Q: If household staff of the official residence work overtime for an official function is the overtime reimbursed as official residence expenses (ORE)? A: No. As noted in State Department telegram 188617 (para 2), dated October 1998, when extra waiters are hired to serve at representation functions, they are paid by the officer hosting the function and the reimbursement to the officer is charged to the representation funds which were appropriated for the purpose. When direct hire foreign service nationals perform as extra waiters, the pay they receive for serving is not charged as overtime to the appropriation for their salary and overtime, but to representation funds. When ORE residence household staff serve at representation functions, any extra pay over their regular salary is charged to representation not ORE.
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