BNUMBER:  B-260771
DATE:  October 11, 1995
TITLE:  Bureau of Land Management - Availability of
Appropriations to Pay Expenses for Employees to Obtain a
Certified Government Financial Manager Designation

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Matter of: Bureau of Land Management - Availability of Appropriations 
          to Pay Expenses for Employees to Obtain a Certified 
          Government Financial Manager Designation 

File:     B-260771

Date:     October 11, 1995

DIGEST

The Bureau of Land Management may not use its appropriation to 
reimburse employees for the cost of obtaining a Certified Government 
Financial Manager designation.  A Certified Government Financial 
Manager designation recognizes the credentials and proficiencies of 
government financial managers meeting specified educational, 
experience and ethics requirements.  Just as appropriated funds may 
not be used to cover the costs of obtaining professional licenses 
necessary to qualify a government employee to do his or her job, 
appropriated funds may not be used to cover the costs of obtaining 
professional recognition of an employee's credentials.

DECISION

The Bureau of Land Management (BLM) asks whether it may use 
appropriated funds to reimburse employees for the fees charged by the 
Association of Government Accountants (AGA) to receive a Certified 
Government Financial Manager (CGFM) designation.  As explained below, 
we conclude that BLM's appropriation is not available for this 
purpose.

On July 1, 1994 the AGA began to accept applications for the CGFM 
designation.  The program brochure explains that the program "is 
specially designed to help meet the critical need for greatly 
increased emphasis on the professional qualifications and stature of 
government financial managers."  The brochure goes on to explain that 
the purpose of the CGFM designation is to recognize an applicant's 
existing qualifications:  "AGA urges you to further enhance your 
credentials as a government financial manager by choosing to have your 
proficiency recognized through professional certification . . . ."  
The AGA advises prospective applicants that the CGFM designation 
"offer[s] considerable benefits to you personally" as well as the 
agencies served.

To obtain a CGFM designation, the applicant must satisfy the CGFM 
initial education, experience, continuing professional education, and 
ethics requirements and pay the requisite fee.  The fee does not cover 
the cost of any training.  Membership in the AGA is not required to 
obtain the CGFM certificate, and no AGA membership results from 
receipt of a CGFM designation.[1]  Further, as BLM points out, the 
CGFM designation is not a state license (such as a Certified Public 
Accountant designation) for an individual to engage in a state 
regulated professional activity.  

The BLM submission states that the need for qualified financial 
management personnel is well-established and that the primary 
beneficiary of the increased skills demonstrated by obtaining a CGFM 
certificate is the federal government.  BLM also states that the CGFM 
designation is not a benefit transferable to the private sector.  
Accordingly, BLM advocates allowing appropriated funds to be used to 
reimburse government employees for the cost of obtaining a CGFM 
certificate, even absent appropriation language specifically 
authorizing such expenditures.

BLM has not identified any law that specifically authorizes the use of 
appropriated funds for the expense in question.  In such cases, the 
question is whether BLM can treat the reimbursement of employees for 
the expense of the CGFM designation as a "necessary expense" of its 
operating appropriation.  While we afford deference to an agency's 
determination that an expense is necessary to accomplish the purpose 
of its appropriation, such deference is not unlimited.  The agency 
must be able to articulate a reasonable nexus between the expenditure 
and the official purpose served by the appropriation, consistent with 
any statutes imposing restrictions on the use of appropriated funds 
and informed by applicable decisions and principles of the accounting 
officers of the Government.

It is a long-standing rule that individuals generally must bear the 
cost of obtaining professional licenses as a personal expense.  22 
Comp. Gen. 460 (1922); 46 Comp. Gen. 695 (1967); 61 Comp. Gen. 357 
(1982); B-218964, Nov. 26, 1985; B-235727,    Feb. 28, 1990 and cases 
cited therein.  We have consistently applied this rule to a variety of 
professional occupations, even when the agency supports the employee's 
efforts and the license is required for a position in the federal 
service.  E.g.,         B-248955, July 24, 1992 (agency may not pay 
cost of attaining professional engineer certification); B-204215, Dec. 
28, 1981 (agency may not reimburse employee for annual bar membership 
fee).  We have allowed an agency to reimburse an employee for the cost 
of a license necessary to perform environmentally sensitive tasks such 
as pesticide application or asbestos removal when Federal law 
expressly requires the agency to comply with applicable state and 
local environmental requirements.  B-252467, June 3, 1994, 73 Comp. 
Gen        .  However, that decision made clear that appropriated 
funds are not available to cover licensing requirements of 
professional personnel such as teachers, accountants, engineers, 
lawyers, doctors, and nurses.  Id.

The CGFM is not a professional license, as BLM points out, but a 
professional recognition of a government employee's credentials and 
experience as a financial manager.  BLM states without explanation 
that the differences between a CGFM and a professional license provide 
an adequate basis to reimburse employees for the cost of a 
designation.  It is true that expenses to obtain the CGFM designation 
do not fall within the literal reach of the rule prohibiting the use 
of appropriated funds to pay the expense of obtaining a professional 
license.  However, BLM has not suggested how reimbursement of the 
expense of obtaining recognition of an employee's educational and on 
the job experience from a private professional association furthers an 
official purpose.  We view the CGFM designation as recognition of the 
credentials and experience already possessed by the government 
employee that benefits the employee by distinguishing the employee 
from his peers and enhancing his reputation publicly.  These benefits 
are personal in nature.  In the absence of an explanation of how the 
use of its appropriations to cover this expense primarily benefits the 
agency, we have no basis to conclude that this reimbursement of the 
employee's expense of obtaining the CGFM designation is reasonably 
necessary to carry out its mission.

Accordingly, BLM's appropriation is not available to reimburse 
employees for the certification fees required by the AGA for the CGFM 
designation.

/s/James F. Hinchman
for Comptroller General 
of the United States

1. Appropriated funds are not available to pay membership fees in 
societies or associations.  5 U.S.C.  5946.