DONNA

/ Jan 27
/

Dear Marcerto,

The GTAC meeting was very interesting. It is always valuable to hear different perspectives and learn about other travel practices and procedures. My comments concerning the M&IE rates are attached.

Thank you for the opportunity to attend the Webinar!

Best Regards,

DonnaGraige

T & T Solutions

Thank you for the opportunity to attend the GTAC webinar and for allowing us to provide feedback.

T & T Solutions agrees that GSA’s methodology for reviewing and establishing per diem rates is sound and the per diem rates are equitable. However, we do have concerns about changing the flat rate per diem method to actual expenses and requiring receipts for each meal.

In our opinion, if the federal government returns to asking for receipts for all meal expenses, and requiring itemization for meals, etc., this is returning to a system that, according to prior GAO reports, was inefficient and not cost effective - and costs taxpayers money in high administrative travel claim review and processing costs.

Although the M&IE lump sum system was in effect many years before agencies began to migrate to electronic travel reimbursement systems, among others, one of the key factors that GAO supported was the current lodgings-plus M&IE system to reduce the administrative costs of processing travel claims.One of T & T Solutions subject matter experts recalls that GAO did an intense study of travel reimbursement systems in 5 major Fortunate 500 companies and reported that private sector companies were spending under $25 to process a simple travelclaim and the federal government was spending around $150 -$200. However, the federal government costs were probably higher because the federal agencies that GAO reviews, unlike the private sector companies, was able to provide GAO their bench line costs. Bench line costs covered the total costs including the administrative/human resources, etc.

The main justification for adopting electronic travel systems was to streamline processing by reducing paper work and redundant reviews, simplifying rules, and implementing lump sum payment policies like lump sum M&IE as well as raising expense amounts that require receipts up to $75+.Beforea decision is made to revise the FTR to require actual expense itemization and receipts for all meals, we think there should be a GAO study to compare current FTR policies and related electronic travel system travel audit and payment costs to projected costs. In sum, the goal of electronic business travel systems is to reduce paper and streamline travel/trip planning, creating travel orders, and auditing/paying travel claims.

In addition, changing the flat rate per diem method to an actual expense method will significantly affect both DOD and the State Department. Prior to considering a change it is imperative that GSA receive input from them.

A question was asked during the GTAC webinar concerning how long the per diem method has been in effect. The House of Representatives passes laws which are published in the Statutes at Large. Public Law 89-554 was passed in 1966 to establish the United States Code (U.S.C.) to categorize and organize the Statutes at Large. Per Diem is addressed in Title 5 U.S.C. § 5702. Following are excerpts concerning per diem from Public Law 89-554, September 1966 and the current 5 U.S.C. published in 2012.

PUBLIC LAW 89-554 - SEPT. 6, 1966

TITLE 5—GOVERNMENT ORGANIZATION AND EMPLOYEES

CHAPTER 57—TRAVEL, TRANSPORTATION, AND SUBSISTENCE

SUBCHAPTER I—TRAVEL AND SUBSISTENCE EXPENSES; MILEAGE ALLOWANCES

§ 5702. Per diem; employees traveling on official business

(a) An employee, while traveling on official business away from his designated post of duty, is entitled to a per diem allowance prescribed by the agency concerned. For travel inside the continental United States, the per diem allowance may not exceed the rate of $16. For travel outside the continental United States, the per diem allowance may not exceed the rate established by the President or his designee, who may be the Director of the Bureau of the Budget or another officer of the Government of the United States, for the locality where the travel is performed.

Title 5 - 2012 5 U.S.C. § 5702 - Per diem; employees traveling on official business

(A)a per diem allowance at a rate not to exceed that established by the Administrator of General Services for travel within the continental United States, and by the President or his designee for travel outside the continental United States;

(B)reimbursement for the actual and necessary expenses of official travel not to exceed an amount established by the Administrator for travel within the continental United States or an amount established by the President or his designee for travel outside the continental United States; or

(C)a combination of payments described in subparagraphs (A) and (B) of this paragraph.

(1)Any per diem allowance or maximum amount of reimbursement shall be established, to

the extent feasible, by locality.

(2)For travel consuming less than a full day, the payment prescribed by regulation shall be

allocated in such manner as the Administrator may prescribe.

Donna Graige

T & T Solutions Phone: 720.206.6299

Henry Maury

/ Jan 29
/

Craig,

I would like to strongly endorse Donna Graige's comments below. It would be crazy to go back to requiring that federal travelers itemize all M&IE, and I think GSA would be laughed and hounded out of its own Interagency Travel Management Committee if that proposal were floated there. There may be large companies that can handle itemization efficiently, but the federal government is much too large, and the agencies much to diverse, to make this work. The processing cost would far outweigh any possible benefit.

Thanks, Henry Maury

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