Travel History Trivia Answers

Thank you to all those who participated in our Travel History Trivia, published in the spring edition of the Compass Newsletter! Now that the quiz is closed and we have selected the winner, it is time to share the answers. 


1.  May an employee be reimbursed for the costs incurred in washing a rental car before returning it to the car vendor?

Answer:  Yes, according to the GSA Civilian Board of Contract Appeals.  An employee of the Customs and Border Protection, Department of Homeland Security (agency), among other costs, requested reimbursement of $16.00 for the cost of washing his rental car before returning it to the car vendor.  The employee claimed that the rental car was so dirty from driving on dirt roads while conducting official business that he could not see through the windows. The agency denied reimbursement of the car washing cost stating it was not a travel expense, but rather, a matter of “personal taste or preference” citing a prior GSA BCA case (Lawrence F. Fragomeli, GSBCA 16086-RELO, 03-2 BCA ¶ 32,349) which denied an employee’s claim for the cost of washing a personally-owned vehicle during relocation to a new duty station.

The GSA Board of Contract Appeals ruled reimbursement of claimant’s cost for washing his rental car was allowable because the employee was restoring the car to its condition when he first rented it, and his action avoided additional charges from the rental car company.  See In the Matter of GLENN F., CBCA 7227-TRAV, November 24, 2021.


2.  May an employee who inadvertently used a third party website to change his scheduled return flight be reimbursed for the cost incurred in using the third party?

Answer:  No, according to the GSA Civilian Board of Contract Appeals.  An employee with the Environmental Protection Agency (EPA), was driving to the San Diego airport for a return trip when he hit unexpected traffic and needed to reschedule his return flight that had been booked by the EPA’s TMC.  The employee claimed that he did not have the number of the agency’s TMC and did not want to incur the TMC fee so he used the virtual voice assistant on his mobile phone for United Airlines Reservations to change to a later return flight. According to the employee, the voice assistant identified a phone number for “United Airlines San Diego,” and the employee, while still in hands-free mode, asked it to connect him. After the call was connected, United Airlines hold music played until a phone representative answered, confirmed that he was with United Airlines, and indicated that the flight change was subject to a $232 change fee, even though his original flight was on a GSA city pair fare. The employee provided his government credit card for the change fee. When the employee arrived at the United Airlines counter, he asked for a refund of the change fee. Upon investigation, the United Airlines representative found no change fee in its system and upon calling the number the employee used the person on the other end of the call refused to identify himself or the company and hung up.  The employee had been the victim of a phone scam. However the Board, while sympathizing with the employee denied reimbursement holding that “the applicable regulations required [him] to make flight changes in the circumstances here through the EPA’s existing travel management service, which, had he done so, would have avoided his involvement in the third party’s chicanery.” See In the Matter of STEWART SIMPSON, CBCA 6271-TRAV, February 19, 2019.


3.   Must an employee who used his personal credit card for travel expenses provide the agency with the personal credit card statement when requested by the agency?

Answer: Yes.   A Department of State employee used his personal credit card for TDY travel expenses to Guatemala City, Guatemala, for temporary duty (TDY).  He requested reimbursement of those expenses including lodging costs.  The charges on that receipt were in Guatemalan currency. The agency requested that the employee submit his personal credit card statement, with redactions for all charges unrelated to the lodging expenses, to verify the exact exchange rate used so that it could accurately determine lodging expense amounts and his reimbursement, in dollars.  The employee objected to providing his personal credit card statement.  The GSA Civilian Board of Contract Appeals held that the agency’s request for the personal credit card statement was reasonable and consistent with the Federal Travel Regulation. See In the Matter of MARCUS R. JACKSON, CBCA 5564-TRAV, May 31, 2017.


4.  May an employee be reimbursed for an upgrade on his car rental which he claims he did not request but which was reflected on the rental agreement?

Answer: No.   An employee of the Army Corps of Engineers was authorized a non-four-wheel drive rental vehicle during the TDY to Baltimore, MD.  The employee stated he requested a compact car and signed the rental agreement when he picked of the car. The rental agreement showed an “X” and the word “AGREED” in capital letters next to the phrase “agreed upon upgrade at $10.00 per day.”  After travel, the employee submitted a claim for reimbursement of the rental car charges, including the $30 total upgrade charges.  The Army initially paid the charges, but upon a subsequent audit, the Army concluded it overpaid claimant by $30 due to an unauthorized upgrade of the rental vehicle. The employee disputed that he should be responsible for the overcharge claiming that the vehicle upgrade was done without his knowledge or permission and that he did not sign or initial the line next to the upgrade charge.  The GSA Civilian Board of Contract Appeals held that the employee could not be reimbursed for the upgrade. It found that the terms of the rental agreement were clear, and none of those terms regarding additional charges were initialed or signed individually. Furthermore, the employee’s signature at the bottom of the agreement attests to the review of, and signifies concurrence with, the charges listed in the rental agreement. To the extent that claimant denies ever agreeing to the upgrade–despite the clear terms of the agreement and his signature on it–the employee’s dispute was with the rental company, not the Army. See In the Matter of THOMAS L. NORTH, CBCA 5442-TRAV, October 27, 2016.


5.  May an employee who was authorized TDY travel for training that took place within 50 miles of his permanent duty station be reimbursed his TDY expenses, including lodging?

Answer: No.  An employee of ICE whose permanent duty station (PDS) was at ICE’s Baltimore Field Office in Maryland was authorized TDY to attend a three-day training program at ICE’s headquarters building in Washington, D.C.  In connection with the training, the employee stayed at a hotel in Alexandria, VA.  The hotel in Alexandria at which the employee stayed and the training location in Washington are both located within a fifty-mile driving distance from his PDS.

After the travel, the employee sought reimbursement for his lodging costs which his agency subsequently denied because his temporary duty station was within fifty miles of his PDS.  The employee claimed that he was entitled to reimbursement because the travel for the mandatory training was authorized in advance and that the agency had impliedly waived the fifty-mile rule. The GSA Civilian Board of Contract Appeals held the employee was not entitled to reimbursement of his TDY costs despite the travel authorization as it “is well established that the Government may not authorize the payment of money if not in accordance with statute and regulation….Hence, any misinformation from an ICE employee that [the employee] detrimentally relied on cannot bind the agency when it conflicts with the FTR. The Board also held as an ICE employee he was subject to the ICE Travel Handbook, which does not provide for the waiver of the fifty-mile rule.  Although ineligible for reimbursement of TDY travel expenses, the employee was eligible for reimbursement of his local travel expenses. See In the Matter of BRANDON G. ZUMBANO CBCA 6302-TRAV May 16, 2019.


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