Promotional Items

TABLE OF CONTENTS

OVERVIEW

6.1 What is the purpose of this chapter? This chapter: 

A. Establishes U.S. Fish and Wildlife Service (Service) policy on purchasing and using promotional items, including publicity expert services, informational/educational materials, and gifts for foreign officials; and

B. Identifies who reviews and approves the purchase of promotional items.

6.2 What is the scope of this chapter? This chapter covers the purchase of promotional items. It does not apply to items we use as awards to recognize achievements of employees, volunteers, and other citizens. (See 224 FW 3, Awards and Recognition, and 150 FW 3, Volunteer Program Operations, for information on these topics.) 

6.3 What are the authorities for this chapter? See 301 FW 1 for information on the authorities and responsibilities for all of the chapters in Part 301. The following authorities are specific to promotional items:

A. Department of the Interior Acquisition, Arts, and Asset Policy (DOI-AAAP) 0038 (DOI-AAAP-0038), “Restriction on the Purchase of Promotional Items.”

B. Employment of Publicity Experts; Restrictions (5 U.S.C. 3107).

C. Executive Order 13589, Promoting Efficient Spending.

D. Memorandum from the Deputy Assistant Secretary – Budget, Finance, Performance, and Acquisition; March 29, 2012, "Restriction on the Purchase of Promotional Items."  

E. Money and Finance, The Budget Process, Appropriations, Application (31 U.S.C. 1301 ).

F. Principles of Federal Appropriations Law: Chapter 3, Availability of Appropriations: Purpose, Section B, The necessary expense rule and the three-step analysis.

6.4 What are promotional items? 

A. Promotional items typically have a logo (see 041 FW 2), design, slogan, or name on them to promote a place, program, event, or idea that is directly mission-related. They are usually inexpensive.

B. They include items for:

(1) Distribution at meetings and conferences,

(2) Recruitment activities such as job fairs,

(3) Information or educational purposes to promote an initiative or appropriated program,

(4) Information or educational purposes purchased for employees and volunteers, and

(5) Gifts to foreign officials in the interest of diplomacy and protocol.

C. Promotional item examples may include, but are not limited to:

(1) Conference materials such as agendas, lapel pins, name tags, notepads, pens, portfolios, and tent cards;

(2) Informational or educational items such as pamphlets, books and reports, posters, coloring books and games, teacher’s guides, and video programs (information about Service printing requirements, environmental education, and interpretation programs can be found at 121 FW 1, 605 FW 6, and 605 FW 7); and

(3) Other items such as plaques, clothing, hats, tote bags, pins, recognition coins, cups, water bottles, mouse pads, posters, stickers, commemorative items, key rings, ice scrapers, pencils, decals, lanyards, magnets, bookmarks, bumper stickers, calendars, balloons, and candy.

D. Promotional items do not include the routine publication of notices and advertisements for procurement and recruiting purposes.

PROCESS FOR APPROVAL

6.5 Who reviews promotional item acquisitions to approve the use of appropriated funds? 

A. Program managers and supervisors must ensure that all expenditures for promotional items, including those bought with a Government purchase card, are allowable and that their employees have completed the Justification for Purchase of Promotional Items, FWS Form 3-2486, and attached the form to the Acquisition Request (for purchases under the micro-purchase threshold) or Program Purchase Request (for purchases over the micro-purchase threshold). See FWS Form 3-2486 for justification requirements.  

B. The program/office must submit requests under the micro-purchase threshold to the Head of the Contracting Activity (HCA) via email for approval.

(1) Requests under the micro-purchase threshold must include an Acquisition Request and the completed FWS Form 3-2486.

(2) Justifications for requests under the micro-purchase threshold must be approved at a level no lower than the HCA (DOI-AAAP-0038).

C. The program/office must submit requests over the micro-purchase threshold to the HCA via email for approval after obtaining a review by a Contracting Officer (CO).

(1) Requests over the micro-purchase threshold must include a Program Purchase Request and the completed FWS Form 3-2486.

(2) COs must review requests over the micro-purchase threshold, prior to submission by the program/office to the HCA, to ensure that there is adequate signed documentation to support the specific acquisition requirements for promotional items (see DOI-AAAP-0038), gifts to foreign officials, and publicity expertise (the appropriation must be specifically for that purpose).

D.  Purchases of promotional items will be tracked and monitored. Contracting personnel and purchase card reviewers must note violations of this policy when performing reviews and audits.

E. Requests for recurring purchases that cover multiple years may be indicated on the justification form. Specific time frames must be documented. For example, if the Service hosts an annual event for which promotional items are used, a single justification form could be used, but it must set a limit on the number of years that the justification covers.

APPROPRIATED FUNDS FOR PROMOTIONAL ITEMS AND SERVICES

6.6 When can employees use appropriated funds to buy promotional items?

A. Employees must not spend appropriated funds for promotional items unless the acquisition:

(1) Is specifically authorized by statute, or

(2) Is integral to accomplishing a program or project.

B. To purchase promotional items using appropriated funds:

(1) You should be able to answer “yes” to the question, “Will this program suffer or fail if these promotional items are not purchased?” See DOI-AAAP-0038 for additional information.

(2) You must write a justification and have it approved at a level no lower than the HCA (see section 6.5).

(3) You must properly document the promotional item purchase by attaching the appropriately signed justification (see section 6.5) to the purchase card statement as supporting documentation or to the Program Purchase Request for purchases greater than the micro-purchase threshold.

C. See Principals of Federal Appropriations Law, 4^th Edition, Chapter 3, Section C.6.j., Gift Giving, for more information on when employees may use appropriated funds to buy promotional items.  

6.7 May employees use appropriated funds for promotional services?

A. Promotional services are services that we hire individuals or companies (including the mass media) to provide that publicize specific places, programs, people, events, or ideas. Promotional services include paid advertising and the use of advertising agencies. (For paid advertising, see 115 FW 1, Official Public Communications – General Policy and Procedures, and the Federal Acquisition Regulation (FAR) Subpart 5.5, Paid Advertisements.)

B. Appropriated funds may be used to purchase promotional services. Promotional services must be either explicitly authorized by law or necessary to accomplish a program or project (for example, promoting the purchase of stamps for the Federal Duck Stamp program).

C. Promotional services are not subject to the justification and approval process described in this chapter.