### White House Communications Agency Expenses Incurred

on Political or Personal Travel by the President

W h e n th e W h ite H o u se C o m m u n icatio n s A gency acco m p a n ie s the P resid e n t on trav el, it m ay(a n d sh o u ld ) use appropriated fu n d s to pay fo r a n y expense incurred fo r activ itie s in fu rth e ra n c e o f its o fficial m ission to p ro v id e a contin u o u s c o m m unications cap a b ility to the P resid e n t a n d h is a d v iso rs, regardless o f w h eth er the travel is for official, political, o r personal purposes.

T h e W h ite H o u se C o m m u n icatio n s A gency m ay u se ap p ro p ria te d funds to pay fo r e x p en se s in c u rre d in c o n n e c tio n with th e p ro v isio n o f c o m m u n ic a tio n s facilities a n d serv ices fo r the o ffic ia l u se o f th e President a n d his staff d u rin g P resid e n tia l travel.

A p p ro p ria te d fu n d s m ay be e x p en d e d to facilitate official, b u t not p o litic a l, co m m u n ic atio n b e tw e e n th e P re s id e n t and the p ress.

October 22, 1990

M e m o r a n d u m O p i n i o n f o r t h e C o u n s e l t o t h e P r e s i d e n t

This memorandum responds to your request for our opinion on which expenses of the White House Communications Agency (“WHCA”), if any, may be paid from appropriated funds when the President travels for political or other non-official purposes. We conclude for the reasons set forth below that virtually all of the activities which you have informed us that WHCA undertakes in connection with travel by the President are in furtherance of WHCA’s official mission, and thus may be - indeed, should be — paid for out of appropriated monies, whether the President’s trip is official, political, or personal in nature.1

I.

WHCA is a component of the White House Military Office, responsiblefor providing continuous communications services to the President, his senior staff, and the Secret Service, both at the White House and during presidential travel, domestic or international. Your memorandum of March

1 We addressed in tw o prior opinions the general question of the allocation o f expenses for political trips taken by the President. See Payment o f Expenses Associated with Travel by the President and Vice President, 6 Op. O .L C . 214 (1982) (“ O lson M em orandum ”); M em orandum for R obert J. Lipshutz, C ounsel to the President, from John M . Harm on, A cting A ssistant A ttorney G eneral, O ffice o f Legal C ounsel (M ar. 15, 1977) (“ Harmon M em orandum ").


### 14428, 1990, details the principal functions performed by WHCA in connectionwith a routine presidential trip.2 Approximately one week prior to a presidential visit, WHCA travels to the site, establishes staff offices, and installstelephone lines, satellite terminals, and other equipment necessary for continuous communications capability. These facilities and equipment are then used during the President’s trip for communications between the President, his senior advisers, and the Secret Service, and the other departments andagencies of government and the general public. Staff telephones are generally provided “to permit staff and trip coordination.” Nelson Memorandum at 2. The White House staff has been advised repeatedly, however, that itmay not use WHCA communications equipment “for direct political purposes such as campaign fundraising and crowd-building.” Id. WHCA, as one of its communications functions, also arranges for the President’s access to and communication with the press. One or two WHCA officers “provide services used in routine press advance work” for each site.
Id. WHCA establishes an emergency press briefing center at each site for use if required.For official presidential events, WHCA provides lighting and sound equipment. At political events, these services are procured from private sources, with WHCA merely providing technical advice. At all events, “WHCAcontrols the ‘feed’ to the sound system and shuts down power to the microphones at the appropriate conclusion of remarks.” Id. WHCA furnishes a teleprompter whenever required, regardless of the nature of the event. Certain WHCA communications functions also serve a security purpose. For instance, WHCA provies a bullet-proof podium for presidential events. WHCA also “sets up emergency public address system speakers at each site, primarily for purposes of crowd control in case of an emergency.” M 3



### II.

The legal principles governing payment of WHCA expenses are set forth in the Olson Memorandum. In that memorandum, we identified two “major principles” of appropriations law applicable in this and similar contexts. First, “appropriated funds may be spent only for the purposes for which they have been appropriated.” Olson Memorandum at 215. Second, “in general, official activities should be paid for only from funds appropriated for such

2 See M em orandum for M ike L uttig, Deputy A ssistant A ttorney General, O ffice o f Legal C ounsel, from Frederick D. Nelson, A ssociate C ounsel to the President (Mar. 28, 1990) (“N elson M em orandum ”). J W e understand that the W HCA functions detailed in this m em orandum m ay not be exhaustive and that you m ay need to return to this O ffice for advice on the proper treatm ent o f expenses incurred in
connection w ith functions not identified herein.

145purposes, unless Congress has authorized the support of such activities by

other means.” Id. at 216.4 Over the years, this Office has considered against the backdrop of these twin principles a variety of issues arising out of presidential trips on which political business is conducted.5 We have consistently concluded with respect to these so-called “mixed” trips that while political activities must be paidfor by political organizations,6 appropriated funds must be used to pay expenses incurred in connection with the performance of official duties duringpresidential travel, regardless of the purpose of the travel. We have specifically noted that certain individuals are required in the performance of their official duties to accompany the President whenever he travels, and that expenses of such individuals should be paid from official sources:

[T]here are some persons whose official duties require them to be with the President, whether or not the President himself is on official business. . . . A similar group would exist for theVice President. Expenses incurred during travel with the President or Vice President by this group of individuals should be considered official regardless of the character of the event that may be involved in a given trip.

Id. at 217-18 (footnotes omitted); see also id. at 218, 221.

The President’s military aide and doctor, for example, accompany the President on all of his travel, but we have said that their expenses should be paid from appropriated monies. See id. at 217-18. The official nature of the responsibilities performed by these persons does not change depending upon whether the trip is official, political, or personal. All of these persons are, when performing the duties described, engaged in the official business of the United States, and thus their expenses must be paid from public funds. WHCA is an obvious example of a group that, like the military aide and the President’s doctor, performs official responsibilities for the President when he travels, regardless of whether the travel is official, personal, or political. We have never squarely addressed whether expenses incurred in the performance of these responsibilities may be paid from appropriated

4T h e first principle derives from the statutory requirem ents of 31 U .S.C . § 1301(a). The second principle, under w hich the executive branch may not augm ent its appropriations, is asserted by the C om ptroller G eneral to be a corollary of C ongress’ constitutional pow er to control the Treasury. See U .S. G eneral A ccounting O ffice, O ffice o f General C ounsel, Principles o f Federal Appropriations Law 5-62 to 5-63 (1st ed. 1982) (explaining the non-augm entation principle).
5 See, e.g.. M em orandum for Fred F. Fielding, C ounsel to the President, from T heodore B. O lson, A ssistant A ttorney G eneral, O ffice of Legal C ounsel (Apr. 21, 1982); M em orandum for the Hon. M yer Feldm an, S pecial C ounsel to the President, from N orbert A. Schlei, A ssistant Attorney G eneral, O ffice o f Legal C ounsel (A ug. 20, 1964). 6See, e.g., M em orandum for the H on. Lloyd N. C utler, Counsel to the President, from Leon U lm an, D eputy A ssistant A ttorney General, O ffice o f Legal C ounsel (Sept. 17, 1980).

146funds when the travel is for personal or political purposes, but we have always assumed that they should be. For example, we observed in 1977 that,

[n]o reimbursement to the Government should be required,even on non-official travel, for accompanying staff and support personnel required for the President and Vice President to perform their official duties. This would include the Secret Service, military aides and support personnel, communications personnel, and whatever other staff the President and Vice President require for advice and assistance in transacting the public business.

Harmon Memorandum at 9 (emphasis added).7 Now that we are directly confronted with the question, we conclude that WHCA may — and indeedshould — use appropriated funds to pay for any expense incurred for activities in furtherance of its official mission when it accompanies the President on travel for either personal or political purposes. Our conclusion that these expenses should be paid from appropriated funds is consistent with the treatment of such expenses under the Federal Election Campaign Act (“FECA”), 2 U.S.C. §§ 431-456 and the Presidential Election Campaign Fund Act (“PECFA”), 26 U.S.C. §§ 9001-9013.8 Generally,Secret Service, WHCA, or other official expenses are not campaign “expenditures” under the FECA or “qualified campaign expenses” under the PECFA.9 Under the regulations promulgated pursuant to the FECA, if a candidate for federal office, other than a candidate for President or Vice President who receives federal funds under the PECFA, “uses government conveyance or accommodations for travel which is campaign-related,” then the candidate must report as an “expenditure” under the FECA “the rate for comparable

’ See also H arm on M em orandum at 15-16: The President and Vice President should be provided all staff and other assistance as required for support o f the official responsibilities of those officers regardless o f location. T his w ould ordinarily include . . . communications facilities fo r control and administration o f the armed forces and other agencies o f the Government[.] (E m phasis added). ’The H arm on M em orandum did not reference the Federal Election C om m ission (“FEC ” ) regulations in
force at the time. See H arm on M em orandum at 20-21. The O lson M em orandum explicitly declined to address FEC rules applicable during federal elections. O lson M em orandum at 214. ’ The treatm ent o f W H CA expenses under the FECA or the PECFA is not necessarily dispositive o f w hether such expenses may be paid from appropriations. W hile it likely will often be the case thatofficial expenses properly payable from appropriations would not be cam paign "expenditures” o r “q u a lified cam paign expenses” for the purposes o f these Acts, and conversely that expenses that are “ex p en ­ ditures” or “qualified cam paign expenses" w ithin the m eaning o f those A cts would not be payable from appropriations, this need not be true. See, e.g.. 11 C F.R. § 9004.6 (1981) (Secret Service transportation paid by an authorized com m ittee “shall be qualified cam paign expenses,” although to the extent that the governm ent reim burses such expenses, they are not “ expenditures" under the FE C A ), amended by 48 Fed. Reg. 31,822, 31,822 (1983) (deleting language referring to Secret Service expenses); see discussion infra p. 150.



### 147commercial conveyance or accommodation.” 11 C.F.R. § 106.3(e) (1981).10

The regulations make clear, however, that expenses associated with staff andequipment authorized by law or necessary for national security are not “expenditures” reportable under this section:

In the case of a candidate authorized by law or required by national security to be accompanied by staff and equipment, the allocable expenditures are the costs of facilities sufficient to accommodate the party, less authorized or required personnel and equipment.

Id. (emphasis added). Accordingly, the expenses associated with such authorized or required personnel are not included in calculating the amount that must be reported as an “expenditure” under this regulation. A similar rule applies to travel of the President when, as a participatingcandidate under the PECFA, he campaigns for his own renomination or reelection or when he is campaigning on behalf of other federal candidates. The regulation governing presidential campaign travel during the general presidential election campaign11 states that

[i]f any individual, including a candidate, uses governmentconveyance or accommodations paid for by a government entity fo r campaign related travel, the candidate’s authorized committee shall pay the appropriate government entity an amount [calculated according to a specified formula],

11 C.F.R. § 9004.7(b)(5) (1981) (emphasis added).12 Any such repayable expenses are defined as “qualified campaign expenses” under the PECFA and must be reported as “expenditures” under the FECA. Id. § 9004.7(a). However, an individual’s travel is a campaign expenditure only if that
individual’s travel is “campaign-related.”13 Because personnel, like Secret Service agents and WHCA employees, accompany the President for official,

l0B y its term s, this regulation only applies to the President w hen he is a candidate and is not participating in th e public financing system of th e PECFA. See 11 C .F R . § 106.3(a) (1981). 11 A n identical provision governs p residential travel during the prim aries. Id. § 9034.7(b)(5). 12 T h e reim bursem ent form ula specifies that the candidate m ust pay an am ount equal to: (i) T h e first class commercial a ir fare plus the cost o f other services, in the case o f travel to a city served by a regularly scheduled com m ercial service; or (ii) T he com m ercial charter rate plus the cost o f other services, in the case o f travel to a c ity not served by a regularly scheduled com m ercial service. 11 C .F.R . § 9034.7(b)(5) (1983). 13 T h e re g u la tio n recognizes that w h eth er or not an in d iv id u al’s travel with the P resident is “cam - p a ig n -re la te d " is not dependent upon th e purposes fo r w hich the P resident is traveling, but upon the p u rp o ses o f th e p artic u la r individual’s trav el. Subsection (b)(4) states thAt, “[f]or trips by governm ent c o n v ey a n c e o r by ch ap ter,” the candidate m ust m ake available to the FEC “a list o f all passengers on such trip, along with a designation o f which passengers are and which are not campaign related.” 11 C .F .R . § 9 0 0 4 .7 (b )(4 ) (1981) (emphasis added). See also id § 9034.7(b)(4) (1981) (identical provision fo r p rim ary c am p aig n travel).

148governmental purposes, their travel is not “campaign-related,” and therefore is not a reimbursable “expenditure” or “qualified campaign expense” under the regulation.14 Similarly, under the regulation applicable to individuals, including the President, who campaign on behalf of candidates for federal office, expenses for Secret Service protection and other such personnel who travel with that individual in the performance of their official duties would not be campaign “expenditures” under the FECA. The regulation states:

[w]here an individual, other than a candidate, conducts campaign-related activities on a trip, the portion of the trip attributed
to each candidate shall be allocated on a reasonable basis.

11 C.F.R. § 106.3(c)(1) (1981) (emphasis added). This regulation requires an individual campaigning on behalf of another “to allocate their mixed campaign/non-campaign travel expenses on a reasonable basis.” 1 Federal Election Campaign Financing Guide (CCH) f 807, at 1537-8 (1989) (reproducing FEC “Explanation and Justification of Part 106”); Federal Election Commission, Campaign Guide fo r Congressional Candidates and Committees 21 (1988) (same comment). Under this regulation, the expenses of Secret Service or other such personnel clearly would not be considered to bean allocable portion of the President’s total expenditures in making the campaign trip. Since expenses for Secret Service and other such personnel arenot campaign “expenditures” under the FECA when a federal candidate campaigns for himself or herself, considering such costs to be noncampaign expenses when such an individual campaigns for someone else certainlyallocates the campaign and noncampaign costs “on a reasonable basis.” Furthermore. applying the regulation directly to each individual member of the President’s support staff would also lead to the conclusion that no portion of

14 An earlier version o f this regulation included an explicit exem ption for personnel authorized by law or required by national security to accom pany the candidate. See 11 C .F.R . § 9 0 0 4 .7 (b )(3 )(iii)(1981) ("In the case o f candidates authorized by law or required by national security to be accom panied by staff, such staff shall not be considered to be travelling for cam paign purposes un less such staff engages in cam paign activ ity during a trip."). T here is no indication that, by deleting this sentence in the later regulation, the FEC intended for such expenses to be considered cam paign “exp en d itu res” under the FE C A . T he change, w hich w as m ade shortly after the FEC issued com parable regulations governing presidential prim ary cam paigns, was m ade prim arily to conform section 9004.7 to the new prim ary regulations. 48 Fed. Reg. 31,822, 31,822 (1983). As explained fu rth er below, see infra p. ISO, the prim ary cam paign regulations deleted references to Secret Service and other such personnel because the paym ent o f their expenses was generally addressed under the federal travel regulations. T hat the FE C did not intend deletion o f the reference to such personnel in section 9004.7 o r its prim ary election counterpart, section 9034.7, to affect the treatm ent o f Secret Service and other such expenses is evidenced by the fact that the FEC, in its explanatory com m ents, did not identify the change as significant; the FEC identified only “one significant change,” nam ely that candidates u sin g g o v ern ­ m ent conveyance w ere required to pay a higher rate than under the previous regulation. 48 Fed. R eg. 5224, 5229 (1983) (em phasis added) (discussing section 9034.7); see also 48 Fed. R eg. at 31,824 (identical com m ent on section 9004.7).

149the cost of the travel of Secret Service or other such personnel need be

allocated to any candidate as an expenditure. Even though they may accompany the President on a campaign trip he makes on behalf of various federalcandidates, Secret Service and similar personnel do not “conduct[] camp aig n -related activities” when they m erely perform their official responsibilities.15 Secret Service and other such personnel expenses thus have consistently been considered not to be “expenditures” under the FECA, and generally have been considered not to be “qualified campaign expenses” under the PECFA. We are aware of only one regulation under which expenses for Secret Service agents and other such personnel would have been considered to be “qualified campaign expenses” under the PECFA. Under a previous version of 11 C.F.R. § 9004.6 (1981), expenses incurred by an authorized committee of a participating presidential candidate for transportation and ground services provided to “Secret Service or other staff authorized by law or required by national security” were considered to be “qualified campaign expenses.” See 11 C.F.R. § 9004.6(a) (1981). This regulation, however, simply allowed Secret Service travel and similar expenses, when incurred by the authorized committee, to be paid from federal funds received under the PECFA; it did not require committees to treat these expenses as campaign“expenditures” under the FECA. The regulation, which permitted an authorized committee to receive reimbursement for such expenses up to an established limit, id. required the committee to report such reimbursements only as “[o]ffsets to operating expenditures” under 11 C.F.R. § 104.3(a)(3)(ix) (1981). See id. § 9004.6(c). The FEC comments explaining this provision made clear that these offsets were not “expenditures” for purposes of the presidential spending limit in the FECA, 2 U.S.C. § 441a(b). See 45 Fed. Reg. 43,371, 43,376 (1980) (“Pursuant to Part 104, the reimbursements will be subtracted from the com m ittee’s total expenditures to produce the committee’s net expenditures. It is the net expenditures which will count against the candidate’s expenditure limit.”). The classification of such costs as “qualified campaign expenses” was of little practical significance. The regulation by its terms did not apply where the government provided the transportation for these individuals and where,under section 9004.7(b)(5), the committee incurred no costs for such transportation. It applied only when “an authorized committee incur[red] expenses for transportation made available [to such persons],” 11 C.F.R. § 9004.6(a) (1981) (emphasis added). However, when a committee had paid the travel expenses of Secret Service agents or other such personnel and the regulationtherefore applied, the committee’s expenses were generally reimbursable under regulations providing for government reimbursement of employees who
travel on official business. See 41 C.F.R. ch. 301 (1990). Accordingly, in

15 O f c ourse, w ere such personnel to perform any cam paign function distinct from their official functions, they w ould be required to allocate their m ixed cam paign/non-cam paign travel expenses on a
reasonable basis. 150most situations, the regulation was either inapplicable or irrelevant. It was apparently for this reason that the FEC deleted as superfluous the reference to such personnel when it revised this regulation.16 Because of this deletion, such expenses would not in any event be considered “qualified campaign expenses” under the current regulations. Furthermore, and more significant, nothing in the current or previous FEC regulations governing presidential campaign expenses would require that expenses for Secret Service and other such personnel be classified as “expenditures” under the FECA.In sum, we adhere to the conclusion of the Olson and Harmon Memoranda that expenses incurred for official purposes during travel with the President should be paid from appropriated funds, even if the purpose for the President’s trip is not official. Accordingly, expenses incurred by WHCAfor services in furtherance of its official mission that are performed in connection with presidential travel should be paid from appropriated funds.



### III.

We now turn to the question of whether the particular WHCA functions described in your memorandum further the agency’s official mission. The resolution of this question ultimately turns on whether the funds used to pay WHCA’s expenses are being used for the purposes for which they were provided by Congress. Congress has not detailed the purposes for which funds appropriated forWHCA may be used.17 WHCA officials therefore have a substantial measure of discretion in defining the precise scope of the agency’s official mission,and whether a given expenditure is an authorized use of the funds appropriated by Congress is in the first instance a question for those officials. An expenditure, however, of course must be reasonably related to the official mission of the agency. The primary responsibilities of WHCA during presidential travel are to install, maintain, and operate the communications facilities and equipmentthat permit the President and his entourage to have continuous communications capabilities, and the lion’s share of expenses incurred by WHCA during

16The reference was deleted from section 9004.6 in order to conform to the corresponding prim ary cam paign regulation, 11 C.F.R. § 9034 6. See 48 Fed Reg. 31,822 (1983). The FEC explained that it deleted the reference to travel expenses o f Secret Service and other such personnel from the prim ary cam paign regulation because "other governm ent regulations govern paym ent for those expenditures.” 48 Fed Reg. at 5229 (discussing section 9034.6); 48 Fed. Reg. at 3 1,824 (identical com m ent on section 9004.6). 17 You have inform ed us that W HCA’s expenses are paid from accounts o f the Defense C om m unicationsA gency (“DCA” ), one o f the “Defense A gencies" included in the annual D epartm ent o f D efense appropriations legislation. See generally N ational Defense A uthorization Act for Fiscal Years 1990 and 1991, Pub. L. No. 101-189, §§ 104, 201, 301, 2401-2422, 103 Stat. 1352, 1370, 1393, 1407, 1639-44 (1989) (the “A uthorization Act”); D epartm ent o f Defense A ppropriations Act, 1990, Pub. L. No. 101-165, 103Stat. 1112, 1116, 1124, 1126 (1989) (the “A ppropriations A ct”). The A uthorization Act and the A ppropriations A ct do not provide specific directions concerning the use o f appropriated funds for W H C A expenses, and we are aware o f no relevant lim itation on the use o f D efense A gencies appropriations.

151and in connection with presidential travel are associated with the discharge

of these responsibilities. As Commander in Chief, as well as in his otherofficial roles, the President requires dependable means by which to communicate instantly with individuals anywhere in the world at any moment. Inan age when conflict may develop and escalate to crisis proportions in minutes, the President cannot be expected to rely on unpredictable and variable private communications facilities. Indeed, it was precisely to eliminate the need for reliance upon such non-governmental facilities that WHCA was created. The provision of these communications facilities and services for the
official use of the President and his staff is WHCA’s official mission. Therefore, provided that these facilities and services are used for official government purposes, WHCA may expend appropriated funds to pay for the expenses incurred in connection with the provision of such facilities and services, regardless where and for what reason the President travels.18 WHCA also provides facilities and services for communication with themedia. We believe that funds appropriated for WHCA’s use may also permissibly be expended to facilitate official, as distinguished from political,communication between the President and the press. The press is indispensable to the effective and proper functioning of the presidency — indeed to government as a whole. As Commander in Chief and in his other officialroles, the President must communicate with the public. Such communication may on occasion even be necessary for reasons of national defense. Direct communication with the public is, as a practical matter, only possible with the assistance of private news media. Facilitation of such contact thus furthers important governmental interests, regardless of the purpose for which the President may be traveling.19

" T he responsibilities and duties perform ed by the President and those serving the President cannot alw ays be satisfactorily characterized as w holly “official,” “political,” or “personal.” We noted, for ex am ple, in the O lson M emorandum : [I]t is sim ply not possible to divide many o f the actions o f the President and Vice President in to utterly official o r purely political categories. To attem pt to do so in m ost cases would ignore the nature o f o ur political system and the structure o f our governm ent. A ccordingly, efforts to establish such divisions m ust be approached w ith com m on sense and a good faith effort to apply the spirit of the principles we discuss in this m em orandum , and they m ust beju d g e d w ith considerable deference to the decisions o f the persons directly involved in m aking the determ inations.

O lson M em orandum at 215.T hus, there will alw ays be particular instances when it will not be evident (and certainly not in advance) w hether use o f a W HCA facility will be in furtherance of the P resident's official, as distinguished from his political, responsibilities. For exam ple, a presidential aide who returns a reporter’s telephone call w ill not know until the conversation is over w hether the reporter is interested in political o r official m atters, o r both. We believe that even w hen it eventuates that the reporter’s inquiry relates m ore to the P resid en t’s political than to his official responsibilities, W HCA may pay for such de minimis use o f its facilities, and that special logs need not be m aintained nor other m onitoring m ethods em ployed. W e have repeatedly em phasized that com m on sense m ust be the touchstone in m any o f the p artic u la r applications o f the broadly draw n rules in this area. 19 T h e re w ill no doubt be occasions w hen there are additional costs for press o r other third-party c o m ­ m unications beyond those ordinarily associated with the P resident’s travel. If the costs are incurred fo r item s or services that are attributable to the special needs and/or requests o f such third parties, W H C A should seek reim bursem ent from the third parties.

152The same governmental interests are served by the incidental security functions performed by WHCA, such as provision of a bullet-proof podium or anemergency sound system. Danger to the President’s life does not vary depending on the purpose of a public appearance.20 Appropriated monies therefore may be used to pay the expenses associated with these services as well.



### CONCLUSION

We conclude that virtually all of the functions that you have informed usare performed by WHCA in connection with presidential travel are in furtherance of WHCA’s official mission to provide a continuous communications capability to the President and his advisers. As a consequence, the expenses incurred for these activities may be paid with appropriated funds, regardless of whether the travel is for official, political, or personal purposes.



### J. MICHAEL LUTTIG Assistant Attorney General Office of Legal Counsel

“ The official purpose behind tw o other W HCA activities — controlling the “ feed” to the sound system (including turning o ff the m icrophones at the end of a speech) and furnishing a teleprom pter w henever required — is not as easily discernible. We sim ply have not been provided sufficient inform ation c o n ­ cerning the purposes for having W H CA perform these functions to enable us to conclude w hether they may be paid for w ith appropriated funds.

153