European Stars and Stripes, Darmstadt, Germany
FRANKFURT – The 103rd Area Support Group diverted $2,000 from an MWR fund to buy flags for a change of command ceremony held Tuesday, despite concerns by a contracting official that it violated Army regulations.
Regulation 215-1 states that morale, welfare and recreation funds will not be used “to subsidize any expense involved in a change of command, retirement or other such ceremony.” The regulation also prohibits the use of MWR money to purchase “individual or organizational equipment.”
H.J. Moore, the area support group’s non-appropriated fund contracting officer who signed the purchase order, said Wednesday that his initial reservations about the expenditure were overruled by superiors whom he refused to identify.
Moore said that when the issue came up in the first week in May he believed it was not appropriate to use MWR funds for the flags. However, “management was looking for an angle in the regulations that would allow this,” he said.
“When your boss tells you to go to the corner and be quiet, well, you do it,” Moore said. He added, however, that in the end he felt that the purchase was appropriate, because “soldiers get a morale boost when they see those flags.”
Moore’s supervisor is Alan Smith, the support group’s director of personnel and community activities, who Moore said is often involved in decisions about the expenditure of community MWR funds.
Smith contacted Stickerei Funk, the company that made the flags, on at least two occasions after the order was placed, said company manager Gunter Hofmann.
Several attempts to reach Smith by phone Wednesday were unsuccessful.
Stickerei Funk made four flags for the support group at a cost of 3,100 marks, Hofmann said. The bill was paid from the 103rd Area Support Group’s MWR account, Moore said.
The flags were displayed Tuesday during ceremonies in which Col. Kenneth Hibl turned over command of the support group to Col. William Alexander. A spokesman for the support group said command officials could not respond until they had researched the issue.
MWR funds are generated by non-appropriated fund services such as AAFES, craft centers and bowling alleys. Army guidelines require that MWR funds he used to benefit soldiers, their families and civilian members of the military community generating the funds.
In addition, the purchase of the flags violates Army Regulation 840-10, which governs the design and purchase of military insignia, said Marjorie Seid, of the Defense Department’s Institute of Heraldry in Washington. The institute controls the making of all military insignia for the DOD, including flags, Seid said.
“All come flags displayed by Army units must come from the support activity in Philadelphia,” Seid said, referring to the U.S. Army Support Activity in Philadelphia. That agency makes flags and other military insignia, but only if authorized by the Institute of Heraldry, Seid said.
The insignia regulation states that “the commercial procurement of flags, guidons, streamers and components is prohibited…” except when the Institute of Heraldry grants an exception.
“We never received a request for the commercial procurement from the 103rd and have authorized nothing for them,” Seid said.
The 103rd ordered the flags from Seid’s office last fall, she said. But at that time the area support group was still in “provisional status” that proceeded its activation Oct.1. The request for the flags was denied, because only active units are authorized to have their insignia made by the government, Seid said.
Seid said she did not realize that by the time she responded to the request the support group had been activated.
In a letter dated Nov. 4, 1991, and addressed to the Frankfurt military community headquarters, Seid cited the insignia regulation and told Frankfurt officials that the government could only make the flags after the 103rd was activated.
“Had they asked to have the flags made after the activation — you know, resubmitted the request — it would have been no problem,” Seid said. The flags would have been provided at no cost, she said.
But Seid said that 103rd never responded to her letter. Instead, nine months later, Moore signed the order authorizing the use of MWR money for the purchase.
Moore said Wednesday that paragraph G, section 3-15 of the MWR regulation allows the purchase of insignia, such as flags, when appropriated funds are not available. However, that clause is limited to uniform insignia.
Stickerei Funk has been making insignia for military units in Germany for 40 years. But this purchase, he said, was unusual from the outset.
“Smith came in two times to check on the progress of the flags,” Hoffman said. “He was afraid the flags would not be ready in time for the ceremony.”
Hofmann said he almost rejected the order because Smith wanted the flags on very short notice. Designing and making organizational flags usually takes about five weeks, Hofmann said. Support group officials wanted them in 21 days.
“I would not have accepted such a fast order, but they promised I would be paid very quickly,” Hofmann said. “It usually takes two or three months for the Army to pay.”
This time, Hofmann said, he was paid in three days.