Travel Leadership Coalition Meeting Updates
The Program Support Center hosted the U.S. Department of Health and Human Services (HHS) Travel Leadership Coalition (TLC) March 12.
The coalition is the Department's functional community forum for all matters pertaining to travel. Each operating division has designated representation for matters requiring a vote; in addition, each OpDiv has a community, or "Associates," who provide their expertise on topics of discussion.
Because travel touches on many different areas of the Department, there is an open invitation for experts to participate.
The March agenda topics included:
- The PSC-hosted annual planning and information exchange meeting
- Progress of the TLC Centrally Billed Account working group
- Updates regarding the PSC-led Travel Credit Card Program, including the status of delivery of centrally billed accounts (CBA) reconciliation files having SmartPay 3 bank Citibank's new data, travel credit card lateness, and the pending Travel Credit Card Management Plan
- Updates on the HHS Common Configuration & Instance Consolidation Project
- Transportation policies that are being updated.
The TLC is also an advisory group to the HHS Travel Governance Council, the Department's Executive leader forum. It serves as a forum where every program area and interest has a voice as it pertains to travel. HHS travel activities are associated with many program areas, including information technology security and development, human resources, financial operations, program management, credit cards, policy, and more.
The coalition meets the second Tuesday of each month. To participate, contact your operating division Lead Federal Agency Travel Administrator or Senior Travel Official.
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Notice of ETS Non-Availability
The Department's E-Gov Travel System (ETS), titled "ConcurGov," will experience a brief period of non-availability starting at approximately 4:30 p.m., Eastern Time, Friday May 31, 2019 and ending at approximately 6 a.m. Eastern Time, Monday June 3, 2019.
This planned outage will mean that no one will be able to access the ETS during this period, including for the purpose of creating new travel authorizations and vouchers, approving travel authorizations and vouchers, or any other such user activities.
This will be an across-the-board outage scheduled for a period in which there are few system users performing activities within the ETS. As such, the period of unavailability is anticipated to have little impact upon the Department's personnel and no impact upon the Department's mission capability. The planned outage will impact all HHS Operating Divisions and Staff Divisions.
This planned outage is necessary for the SAP Concur to consolidate 11 of the Department's separate instances of the ETS under a single instance aligned to the Unified Financial Management System, while ensuring the National Institutes of Health (NIH) and Centers for Medicare and Medicare Services (CMS) instances remain aligned to the National Business System and the Healthcare Integrated General Ledger Accounting System, respectively. Because the ETS is "software as a service," SAP Concur will need to pause the Department's global access to move documents, routing lists and such to the new unified instance. The June 3 deployment will also see the implementation of the new HHS Common Configuration.
The deployment is the result of nearly two years of partnership and collaboration between the Program Support Center, the Operational Divisions and SAP Concur, and the consolidating of the instances will improve the overall support efficiency rate by more than 70 percent.
We recommend the following in preparing for the outage:
- Have all employees submit travel authorization requests as soon as possible and no later than May 20, 2019.
- Approve or decline all employee requests to travel by 4:30 p.m. ET, May 24, 2019.
- Supervisors should approve undisputed travel voucher amounts on employees' signed and submitted vouchers by 4:30 p.m. ET, May 24, 2019.
- Use internal communication channels to notify employees of the planned ETS period of unavailability.
- Travel authorizations that have requests for travel advances on them must be approved and fully processed by the financial systems no later than 4:30 p.m. ET, May 24, 2019
- Encourage employees to save the contact information of their supporting Travel Management Center in a manner of their preference so that it is accessible in case they need travel support during the planned outage period.
- This information is posted on the main splash page of the ETS and is also available from the various staff who support travel.
The ETS will return to the service on June 3, 2019. All users will have access to perform travel system-based activities as usual once the ETS returns to the service as scheduled.
The Program Support Center will have its full complement of systems technicians and travel account managers actively monitoring the resumption of services to resolve any technical issues.
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Instance Consolidation Project on Track for June 3 Deployment
The Program Support Center is leading an effort with its Operational Division partners to consolidate 11 of the 14 configured instances of the E-Gov Travel Management (ETS), titled "ConcurGov."
HHS originally had 14 configured ETS instances: Thirteen that were aligned to the three respective financial systems that comprise the HHS core financial system, and one that was configured and maintained but not used.
Consolidating the instances will reduce the total number of instances that must be operated and maintained, which will advance standardization of travel systems and system policies across the Department.
The overall objective of travel standardization is driven by the Federal Integrated Business Framework (FIBF), and the General Services Administration leads the innovation and refinement of the Travel Line of Business. For nearly 16 years, the FIBF approach has been transitioning government from the legacy approach to travel that saw agencies build and manage their own travel systems while publishing travel policies that did not effectively control travel costs. The FIBF approach is driving a government-wide transition to a travel model that features commercial-type practices and travel products while maintaining proper internal (management) control over the public's funds.
Once deployed on June 3, there will only be three configured instances that align to the Department's core financial system comprised of the Unified Financial Management System (UFMS), the National Business System (NBS), and the Healthcare Integrated General Ledger Accounting System (HIGLAS). The current project largely affects those instances that align to UFMS.
It's projected that the instance consolidation will net a support process efficiency improvement of more than 70 percent. For instance, when SAP Concur releases its update each month or when a defect must be researched and fixed, 11 fewer instances will need to be attended to.
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Discount Airline WOW AIR Ceases Operations
Iceland-based WOW AIR, known for its aircrafts' purple paint schemes, ceased operations suddenly March 28, canceling all flights that day.
SAP Concur, the Department's partner in providing travel management services, notified HHS that day and reported that no Department employees were traveling on the airline when it discontinued services.
Employees who might be slated to travel on the airline will have their travel re-booked to a comparable in-service airline by the servicing Travel Management Center, and then they will be notified of the new travel itinerary.
Headquartered in Reykjavik, WOW AIR operated passenger flights between Iceland, Europe, Asia, and North America.
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First HHS ETS "Common Configuration" to Be Deployed June 3
The Program Support Center (PSC) will deploy the first HHS "Common Configuration" June 3 as part of the Instance Consolidation project.
Since April 2017, the respective Operating Divisions (OpDivs) worked with the Program Support Center and E-Gov Travel Management 2 (ETS2) partner SAP Concur to establish the HHS Common Configuration, and the result will be a standardized travel system policy settings applied across the entire Department.
The ETS was originally configured according to OpDiv preferences. Under a standardized, common construct, the Department's travel system will now be configured according to uniformity across all of the OpDivs. This ensures consistent application of the Federal Travel Regulation (FTR) and the HHS travel policy while extending consistent common travel options to employee travelers that enable the various missions of the Department to be accomplished.
Once deployed, the Common Configuration will be stewarded and managed by PSC, and a configuration management process will be applied that will have change requests implemented only after approval by the HHS Travel Leadership Coalition, by direction of the HHS Travel Governance Council or because of an exigent need.
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TLC Charters Working Group to Recommend Future State of CBA Reconciliation Data Files
The HHS Travel Governance Council (TGC) recently asked the HHS Travel Leadership Coalition (TLC) to charter a working group to develop and recommend an alternative to obtaining custom Centrally Billed Account (CBA) data files.
Presently, all but one HHS Operational Division receives custom files through a contracted source. The files are used by CBA card holders to reconcile travel-related purchases applied to CBA travel credit cards that are uploaded to the E-Gov Travel System (ETS).
Standardization of the CBA file was an unrealized objective of the ETS2 implementation initiative because a government-wide standard had not been developed when HHS deployed the final instance of the ETS. In May 2018, the General Services Administration established a government-wide standardized file format and data elements, and directed SAP Concur to ensure the ETS is capable of producing the standardized file.
The working group will recommend options to the TLC, and the TLC chair will present a recommendation to the Department's TGC members at the council's May 19 meeting. If the recommendation is adopted, then an implementation plan, including a timeline, will be developed by the Program Support Center.
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Over-Use of ATM Withdrawals, Need For Travel Cash Advances Indicate High-Risk
Over-use or reliance on automatic-teller machine (ATM) withdrawals while traveling and requests for travel cash advances are indicators of high risk that might reflect that an employee's enduring a latent or emerging personal financial crisis.
When an employee continually makes ATM withdrawals, the questions beg: "What is the cash being used for? Why isn't the travel expense being put on the individually billed account (IBA) credit card?"
In general, HHS employees who have IBA travel credit cards should not be allowed to obtain cash advances, and the use of cash advances should be reserved for situations when there is a bona fide need that cannot be overcome by obtaining of a card or training/re-training.
When an employee requests a cash advance to travel, the supervisor must first check to see if the employee has an IBA and question the need. If it is because the employee doesn't have an IBA travel credit card, then the employee should apply for the IBA and obtain it before traveling.
Supervisors and travel card agency/organization program coordinators (A/OPCs) should monitor employee travel, requests to travel, travel vouchers, and credit card reports to look for these indicators, and then take action to mitigate or avoid risks.
Risk avoidance might include declining requests for cash advances, training or re-training employees, and counseling and coaching to facilitate employee understanding, and verifying that all employees have IBA travel credit cards in hand before authorizing travel to be performed. Risk mitigation might include declining employee requests to travel when an employee has demonstrated an inability to travel compliantly, re-training employees, or initiating salary offsets to settle delinquent IBA card amounts.
And, employees who have credit challenges and are ineligible to bear an IBA travel credit card should be brought into eligibility through training or re-training and allowed to apply for a limited credit line travel IBA.
Only if an employee is formally denied an IBA travel credit card by Citibank should they be allowed to apply to the Secretary of the U.S. Department of Health and Human Services (HHS) for an exception from using the IBA travel credit card. The Federal Travel Regulation delegates to the agency head (the HHS Secretary) only the authority to waive the requirement for an employee to use IBA travel credit card when traveling on official government business.
Requests to be exempt from using the IBA travel credit card must be submitted through Operational Senior Travel Officials to the Program Support Center. Applications must be submitted in writing from the requesting employee and must fully articulate why an exception is needed, if the employee has a personal financial instrument to pay for the travel, or if travel advances would be needed. Supervisors must also certify the need and state what managerial actions are being taken to enable the employee to be made eligible for an IBA travel credit card. A copy of the formal declination by the bank to issue the employee an IBA card must also be submitted with the application.
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Supervision Is Key to Assuring Department Readiness Not Adversely Impacted by IBA Credit Card Payment Lateness
The public here and abroad often looks to the women and men of the U.S. Department of Health and Human Services to respond when a crisis happens. There is an expectation that highly trained professionals and experts of every type will be available to perform the duties they took a solemn oath to perform.
Yet, when an employee's individually billed account (IBA) travel credit card is suspended or canceled due to non-payment, the Department's readiness is adversely impacted because that employee is no longer operationally effective.
Employees bearing IBA travel credit cards are required to pay all undisputed amounts due. When an employee fails to meet their obligation to pay, then supervisors are obligated to exercise leadership to resolve the indebtedness.
Employees are obligated to immediately pay any undisputed IBA travel credit amounts due even if they have not filed a travel voucher to obtain reimbursement for travel performed. This is required by the Federal Travel Regulation and set forth in 5 CFR 2635(d)(12).
Supervisors have a variety of tools and resources available to address IBA travel credit card lateness, which could be as simple as directing the employee to pay the bill in full by a date specified or as assertive as initiating a salary offset.
A model approach to addressing IBA travel credit card indebtedness is:
- Obtain the IBA delinquency report from operational division travel credit card agency/organization point of contact (A/OPC).
- Identify the employees who are delinquent in paying their IBA.
- Send the employee an email that directs them to pay the IBA in full immediately and provide proof that payment was made.
- Obtain a new IBA delinquency report. If the employee is still listed on the delinquency report, notify the A/OPC to initiate salary offset.
- The A/OPC will coordinate with the Program Support Center (PSC) to start the process.
The Treasury Offset Program is a program established in law that is targeted specifically at federal employees for the purpose of addressing indebtedness. Employees are afforded due process rights through a standardized notification process that also includes opportunity to provide information as to why salary offset should not be initiated. They are also given the opportunity to resolve the debt.
Amounts offset are remitted directly to the bank to settle the indebtedness.
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PSC Is Producing a 5-Year HHS Travel Credit Card Management Plan
The Program Support Center (PSC) will soon publish a five-year HHS Travel Credit Card Management Plan, the first of its kind for the U.S. Department of Health and Human Services (HHS).
The plan is required by the U.S. Office of Management and Budget (OMB) Circular A-123, Appendix B, and the PSC plan serves as the "playbook" for the operating divisions (OpDivs) travel credit card programs. The plan will address all 11 areas required by OMB A-123.
What makes this plan unique is that it will establish a strategic, long-term approach for managing travel credit cards at HHS. In this way, OpDivs will have the foundation needed to establish travel credit cards as a low-risk operational area.
Because the authority for travel credit cards are established in the Federal Travel Regulations (FTR), the five-year plan will be established as an annex of the HHS Transportation Policy and will integrate with the Department's travel policy, which executes the FTR.
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All Travel Expenses Must Be Put on the Government-Provided Travel Credit Card
Did you know that the Federal Travel Regulation (FTR) requires that all travel expenses be charged to the SmartPay travel credit card, including meals?
The individually billed account (IBA) travel credit card is the primary financial instrument for paying travel expenses here at the U.S. Department of Health and Human Services (HHS), and employees should use it to the greatest extent possible. This includes for meals, transportation fare, taxicabs, lodging, transportation network companies (Uber, Lyft, etc.), dry cleaning (when authorized), etc.
Personal cash and personal credit cards should not be used because the FTR tightly restricts the use of cash by employees traveling on official government business. The FTR even defines purchasing with employees' personal credit cards as cash.
Many HHS employees have traveled for years now without ever using cash for travel expenses. The need for cash to travel decreases worldwide every day. For example, there are now more than 30 different transportation network companies operating in Africa, South America, Asia, Europe, and North America, and there are countless taxicab companies that use chip-enabled secure payment terminals. In some countries, there are vendors who hawk foodstuff from roadway median strips using chip-enabled terminals. Even many of India's classic "tuk tuks" (auto rickshaws), are app-enabled or their drivers take chip-enabled cards.
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Credit Card Merchant Data Does Not Include Information About What's Purchased
Whether you like to eat salads, cheeseburgers, tofu, black coffee, yogurt, donuts, or whatever, be assured that when you use the government-provided individually billed account (IBA) travel credit card, what you eat stays with you.
Credit card transactional data is broken out by levels for credit card processing: 1, 2, and 3.
The levels associate the data to the type of processing needed. Less data requires more processing. That is, the transaction requires more examination. The level of processing determines the interchange rates. The more data, the easier it is for the transactions to clear and the lower the interchange rates (faster clearing of transactions equals lower costs). For example, Level-1 data —the lowest type of data — is needed for verification and authorization of purchases.
The data levels are established in the SmartPay 3 contract and are uniformly applied across the entire government. The SmartPay contract requires vendors to submit Level-3 data.
Level-1 credit card processing data is only the merchant name, the transaction amount, and the date the transaction occurred. It's what's used for personal credit cards. Employees are often surprised to learn that, comparatively, the IBA travel credit card is more secure than their personal credit card.
Level-2 credit card processing data is that which is needed for business-to-business payment processing, such as business-specific payment methods. For instance, a corporate fleet card that might only be usable at a particular vendor or for a particular product like aviation fuel, motor vehicle repairs, etc. Level-2 processing data gives companies and businesses, including the government, the ability to monitor and control employee spending. Level-2 data also provides greater accuracy of transactional reporting needed by cardholders to reconcile accounts.
Level-2 transaction data includes:
- Merchant name
- Transaction amount
- Tax amount
- Customer code
- Merchant postal code
- Tax identification
- Merchant category code
- Merchant state code
Level-3 credit card processing data is the most-detailed data available, and it's mostly associated with corporate and government purchase cards. Level-3 data provides the most control over purchases and enhanced reporting. Level-3 data is generally associated with retailer and wholesaler data, such as:
- Item product codes
- Item general description
- Item quantities
- Item tax rate
- Ship from postal code
- Freight cost
- Duty amount
- Destination postal code
- Destination country code
A common myth about the IBA credit cards is that it can be determined the actual meals that someone has purchased when the IBA is used at restaurants. That's simply not true. Note that Level-3 card processing data is specific to purchase cards, and not IBA travel credit cards. Information like the type of meal purchased is never captured or reported.
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Four Simple Best Practices Make Being a Card Holder Easier
Every card holder has a duty to correctly use their government travel charge card when traveling. There are four simple best practices that make being an individually billed account (IBA) travel credit card holder easier:
- Activate Your Card! Once you get your card, make sure to activate it!
- Create an Online Profile. Cardholders must create an online profile in CitiManager in order to set up alerts and receive statements.
- Pay on Time. Cardholders must submit travel vouchers in a timely manner (as prescribed by the Federal Travel Regulation) and pay the amount due on the card even if a travel voucher has not been submitted or reimbursed.
- Watch for Training Opportunities. Stay up to date on the latest training and read any supplemental information or published instructions.
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PSC Is Training More Than 400 ASPR Emergency Responders
The Program Support Center (PSC) is presently training more than 400 members of the HHS's Assistant Secretary for Preparedness and Response (ASPR) emergency responder cadre how to properly request travel and file travel vouchers.
The PSC is delivering the training through virtual instructor led training, and it's expected that all of the ASPR responders will be finished before the start of the 2019 hurricane season.
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PSC Developing Travel Training Targeted at HHS Supervisors
A recent U.S. Department of Health and Human Services travel program manager review of a sample population of travel authorizations and vouchers found that all — 100% — had issues, and, upon closer inspection, would likely have identified a greater number of issues. Interestingly, every one of the travel documents bore the approval of the Federal Travel Supervisory Approver.
The results of this review indicate a need for travel training focused at the federal supervisor community, so the Program Support Center (PSC) is developing training specifically for this purpose. The development of new training will be complete this summer.
Some of the issues identified during the review of the travel documents included:
- Taxes reimbursed for international lodging
- Gibberish entered into required fields
- Missing lodging receipts, but lodging expenses were reimbursed
- Overlapping trip dates
- Airport parking that exceeded the cost of cab fare to or from the airport
- Credit card on the lodging receipt did not match the individually billed account (IBA) card in the employee's E-Gov Travel System (ETS) profile
- Voucher filed more than 30 days after the travel ended
- Extended temporary duty (TDY) having more than one travel voucher approved every 30 days during the TDY
- Taxicab expenses reimbursed when places for meals were near lodging
- Failure to use tax exempt forms in tax exempt states
- Taxicab/transportation network companies (TNC) reimbursement when a rental car was authorized
- Use of privately owned vehicle (POV) when either rail or air common carrier transportation was most advantageous
- Excessive laundry expense reimbursement (hotel valet instead of dry cleaner within walking distance of hotel that had pickup service)
- Returning to the Official Station multiple times without prior pre-approval on approval
- Cash advances authorized when employees had IBA travel credit cards in the ETS profiles
- Adding travel expenses by amending the travel authorization after travel occurred
- ETS used to reimburse employees for transit benefits
- Travel authorization approved for travel at the Official Station
- Start and stop of official government travel at location other than Official Station without any evidence of official need or business
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PSC Offers ETS Role Training Through Virtual Instruction
The Program Support Center (PSC) is offering Virtual Instructor-Led Training (VILT) courses this year for travelers, travel arrangers, as well as for Federal Agency Travel Administrators (FATAs).
VILT is a virtual, interactive method of learning that is designed to engage students with practical exercises as well as group and one-to-one dialogues — as if the participant were in a classroom setting. Students benefit from having a live, online instructor teaching them the latest in computer technology, receiving a hands-on learning experience, and having the convenience to take training anyplace of their choosing. All that is required is the time to learn, a phone, and a computer with an internet connection.
VILT is also less expensive than traditional classroom training. The cost is only $150 per student for FATA training and $100 for the traveler/travel arranger training. Additionally, classes are modularly designed so that students can enroll in a single day's session for a cost of $50 to gain the latest knowledge about a specific topic without the need to sit through the entire course again.
Planned VILT dates are:
|April 23–25||FATA Training|
|May 21–22||Arranger Training|
|June 25–27||FATA Training|
|July 30–31||Arranger Training|
|August 27–29||FATA Training|
|September 24–25||Arranger Training|
PSC also accepts group and advanced reservations to support employees' annual individual development plans. PSC is updating its entire current training course offering to be delivered by VILT. The courses may be purchased using a purchase card.
Seats fill up fast! So, register today for VILT training by emailing firstname.lastname@example.org.
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Employees 25 Years Old and Younger Cannot Be Charged Extra to Rent Vehicles When Authorized for TDY
Employees who are 25 years or younger cannot be charged any additional fees for renting a car when authorized to do so for temporary duty (TDY).
The in-force Government Rental Card Agreement — Agreement Number Four — does not set any age restrictions or allow for any special fees to be charged if an employee is 25 years or younger.
If this issue is encountered, escalate the issue if necessary through the supporting operating division lead Federal Agency Travel Administrators (FATA).
Keep in mind that it is the obligation of the employee to read the rental car agreement before accepting it or accepting the keys to the vehicle. Extra fees for the driver being 25 years old or younger are not reimbursable travel expenses.
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Exchanging Tickets Is Not a Practice Endorsed, Supported or Enabled by the Department
The Program Support Center travel support team is often asked, "Can travelers exchange their government ticket for a commercial ticket?" The succinct answer is, "No."
Title 18 US Code §641 establishes that it's a felony to knowingly convert a thing of value of the United States — in this case the government issued tickets — for personal use. The law states, "Whoever receives, conceals, or retains the same with intent to convert it to his use or gain, knowing it to have been embezzled, stolen, purloined or converted... shall be fined under this title or imprisoned..."
It is also noted that General Services Administration's (GSA's) E-Gov Travel Services (ETS) Master Contract does not have any provisions for providing personal travel services to any employees, nor does the associated U.S. Department of Health and Human Services (HHS) Task Order. Such services are personal in nature and not allowable by the Federal Acquisition Regulations.
Further, there is no authority for the Department to use appropriated funds to provide personal services of this type to employees. For this reason, ETS2 contractor SAP Concur and its sub-contractor Travel Management Centers Duluth Travel, Inc., and Omega World Travel do not have any means established to accept personal funds or personal payment methods from HHS employees, nor are they allowed.
In summary, absent express authority to do so in law or regulation, the government's property cannot be converted by exchange.
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Travel Must Be in the Most-Direct Manner, by the Usually Travel Routes
Consider this scenario: a government employee has a family reunion that starts immediately after the end of her temporary duty (TDY) travel. She picks up the phone and asks the Program Support Center, "Can I fly directly to my family reunion instead of coming home and having to fly out? It would save me time!"
Every employee has the obligation to make their travel arrangements so that they conform to the law, regulations, and rulings by the Civilian Board of Contract Appeals. Historically, that has meant that the onus is always on the employee to travel in a lawful, conforming manner even if given bad advice or improper permission.
Federal Travel Regulation (FTR) §301-10.7 states, "How should I route my travel? You must travel to your destination by the usually traveled route unless your agency authorizes or approves a different route as officially necessary." The phrasing of this section is important. The question phrasing is "should," but the response was "you must," which is an imperative. And, it should be noted that anything different must be approved by the agency and it must be officially necessary.
And, although the employee has tools available to arrange their own travel, the FTR establishes that it is the agency that determines the method of travel, which includes any officially necessary routings.
The FTR states in §301-10.4, "How does my agency select the method of transportation to be used? Your agency must select the method most advantageous to the Government, when cost and other factors are considered. Under 5 U.S.C. 5733, travel must be by the most expeditious means of transportation practicable and commensurate with the nature and purpose of your duties. In addition, your agency must consider energy conservation, total cost to the Government (including costs of per diem, overtime, lost worktime, and actual transportation costs), total distance traveled, number of points visited, and number of travelers."
All of this is based on the official business need, not any employee's preferences or wishes. A Federal Travel Supervisory Approver is not granted the leeway to abdicate this responsibility to the employee who is requesting permission to travel, even if the E-Gov Travel System's (ETS's) online booking engine allows employees to make their own reservations.
Further, the Civilian Board of Contract Appeals has stated:
Travel approving officials do not possess the authority to authorize reimbursement of travel that is not the direct, usually traveled route from the employee's PDS [permanent duty station] to the TDY location and back, regardless of how compelling the personal circumstances of the employee may be. See In the Matter of Robert O. Jacob, CBCA 471-TRAV (2007).
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The FTR Tightly Restricts the Use of Personal Cash or Credit Cards for Government Travel
The Federal Travel Regulation (FTR) establishes that the government contractor-provided travel credit card shall be used for all travel expenses. This includes meals, airfare, lodging, rental cars, taxicabs, transportation network companies (i.e., Lyft, Uber, etc.), fees, taxes, etc. No travel expense of any type is exempt.
The FTR reinforces this further in §301-51.100 by addressing common carrier transportation (air, rail, and bus tickets), by stating, "What method of payment must I use to procure common carrier transportation? You must use a Government contractor-issued individually billed travel card, centrally billed account, or GTR to procure contract passenger transportation services. For all other common carrier transportation, you must use one of the methods specified in the following table..."
Again, the imperative "must" is used.
The FTR's table goes on to establish tight parameters for use of cash, including dollar amount limits, that makes it nearly impossible for any employee to use cash for travel. This appears to be by design and with the intent of compelling use of the contractor-provided travel credit card.
Finally, the FTR tightly restricts the exemptions to using the government-provided travel credit card. In November 2017, the FTR reduced the total number of exemptions from four to three and specified that only the agency head as defined by 5 CFR has the authority to waive an employee from using the government travel credit card. To date, the Secretary of the U.S. Department of Health and Human Services (HHS) has not exempted any HHS employee from using the contractor-provided travel credit card. Even employees who have personal credit challenges have the means to obtain an individually billed account (IBA) travel credit card with a reduced credit limit sufficient to perform temporary duty, and they should not be extended travel advances until the current supporting SmartPay program bank officially declines to issue an IBA.
These regulatory provisions are specific for the purpose of preventing an employee's personal affairs from impinging upon the government's business.
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Use of E-Gov Travel Services Required for Government Business Travel
The Federal Travel Regulation (FTR) tightly restricts employees with regard to the ways they may purchase common carrier transportation (e.g., air, rail, and bus) tickets.
The FTR requires that the E-Gov Travel System (ETS) be used to arrange travel, whether that be through either the ETS (a.k.a. "ConcurGov") or by calling the servicing Travel Management Center to have a travel agent arrange travel.
The FTR makes limited provision for the rare exceptions that might occur and only for the very narrow purpose of ensuring the government's business can be accomplished. However, the vast majority of government travel is not unique or exceptional. It fits squarely into a standard construct.
While it might seem convenient to purchase tickets through other means, it is a violation to do so; it has "downstream" impacts, plus it introduces unacceptable risk. As just one example, this unacceptable practice undermines government-wide strategic sourcing and contributes to putting the government at a disadvantage in annual negotiations with airlines over ticket pricing and routes.
Using the system correctly also saves the user time and money! For example, the Civilian Board of Contract Appeals just published a decision regarding an employee who missed his flight because of traffic and used Siri on his phone to call the airlines. Unfortunately for him, Siri actually connected him to a third party resource which charged him a $232 change fee which the agency refused to reimburse.
The Civilian Board of Contract Appeals held that while it sympathized with Mr. Simpson's situation, the agency could not reimburse the $232 change fee because relief was not allowed under the FTR.
Specifically, Section 301-50.3 of the FTR provides that employees "must use [their] agency's existing Travel Management Service (TMS) to make [their] travel arrangements" when traveling on official business. If the employee does not use the required TMS, he or she is "responsible for any additional costs resulting from [that] failure . . . , including service fees, cancellation penalties, or other additional costs," unless the employee falls within "an approved exception under § 301-50.4 or § 301-73.104." See 301-50.5.
Because Mr. Simpson did not meet any of the exceptions, the Civilian Board of Contract Appeals held that "we have no authority to expand these exceptions. The FTR is a legislative rule that has the force and effect of law over government employee travel expense reimbursements." See In the Matter of Stewart Simpson CBCA 6271-TRAV (2019).
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