I can find nothing in AR 623-3 or DA PAM 623-3 that prevents the rater from mentioning this achievement. I could not find any policy that prevented it either. It is my opinion that such comments are authorized.
The reason many people believe that this such achievements cannot be mentioned or are unauthorized on the evaluation report is because they misread or misunderstand the requirements for a Soldier’s OMPF. The Order of St. Barbara, Samuel Sharpe, Horatio Gates, Audie Murphy Club and Sergeant Morales Club documents are not allowed in a Soldier’s Official Military Record but this does not prevent them from being mentioned in the evaluation report. In fact the only way a Soldier can be recognized for these types of achievement is by placing the comment in the evaluation report and/or receiving an award for it.