Special Observances Authorities
The Office of Diversity and Inclusion (ODI) has received numerous inquiries regarding
the legality of utilizing appropriated funds to purchase food, posters, and other
items in support of special observances.
The Special Emphasis Program (SEP) is an intricate part of the overall EEO Program.
As such, activities sponsored by the SEPs are sanctioned under the following authorities:
Executive Order 11478
Code of Federal Regulation, Part 1614.102(b)(4)
c. EEO Act of 1972
Civil Service Reform Act of 1978
The Comptroller General, in two landmark decisions (B-200017,
March 10, 1981, and B199387, March 23, 1982), allows expenditures at agency-sponsored
cultural awareness events, appropriate funds for guest speakers, artistic and/or
cultural activities, food exhibits or samples (not intended for meals or refreshments),
or publications, when the intent is to promote cross-cultural harmony and awareness.
Where applicable, the International Merchant Purchase Authorization Card (IMPAC)
or IMPAC convenience checks may be used for the limited scope of purchasing food
items for sampling or exhibits at the agency-sponsored cultural awareness events.
EEO Directors and Managers should take the appropriate steps to ensure compliance
with 29 Code of Federal Regulation, Part 1614.102(b)(4). Special Emphasis Program
Managers and committee members should not be expected to finance EEO Program activities
with personal funds or via bake sales.
If you have any questions or concerns, please contact