Technical Questions

Technically, yes, although it is important to recognize the intersection of several administrative authorities in such a situation. The decision to reward an employee or group of employees with training or equipment may be very reasonable within a recognition program that contemplates such forms of recognition. In that instance, under the definition of "award" at section 451.102 of title 5, Code of Federal Regulations, the "award" would be considered an "action taken." The action itself would be the procurement of the training or equipment. As such, it would be subject to all relevant training and procurement regulations, limitations, and requirements. It would not be unreasonable to deduct the costs of such training or equipment from the relevant awards budget, although technically that is not required. Some agencies partition their funding very specifically across object classes such as awards, training, equipment, etc., and special funding arrangements and transfers may be required.