ECO Travel Letter Draft To: "File WRD Archive Reston, VA " Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Thu, 18 Jul 1996 07:36:57 -0400 From: "Isabelle Halley des Fontaines, Chief, Br. Admin. Mgmt. Sys., Reston, VA " To: "AO - All Administrative Officers" cc: "David C Madril, Admin Officer, Reston, VA" , ladabaie@operqvarsa.er.usgs.GOV Subject: ECO Travel Letter Draft Mime-Version: 1.0 Content-Type: text/enriched; charset="us-ascii" Date: Wed, 17 Jul 1996 14:57:07 -0400 From: ladabaie@operqvarsa.er.usgs.GOV -------- The attached memorandum from Tim Calkins addresses and answers our concerns related to ECO Intern travel issues. Current Federal Travel Regulations (FTR) do not authorize the use of unlimited or limited "open" (area) travel for ECO Interns or any other nongovernmental employee. This creates what we feel is an unreasonable labor intensive process on our field operations utilizing ECO Interns. We will continue our efforts to resolve this issue and(or) develop a workable solution. OFM does understand our problem and is aware that we are providing advance travel funds through the Imprest Fund where available. They have indicated that unless specifically directed from higher authority no attempt will be made by their office to change this policy. As previously stated, we will continue our efforts in resolving this issue. Any questions regarding this issue may be directed to me at (703)648-5028. In Reply Refer To Mail Stop 270 MEMORANDUM To: Alice Sabatini Administrative Officer, Water Resources Division From: Timothy E. Calkins Acting Chief, Office of Financial Management Subject: Travel Issues related to ECO Interns This memorandum is in response to your request for a review of options available to the U.S. Geological Survey (USGS) for dealing with travel authorizations and advances for Environmental Careers Opportunities (ECO) Interns working in support of USGS programs. The Water Resources Division in particular has been interested in expanding the range of authorizations to include Limited Open travel authorizations rather than trip by trip authorizations, and to have travel advance amounts expanded correspondingly. For the reasons outlined below, these do not appear to be feasible options at this time. The pertinent regulations regarding travel authorizations are summarized as follows: -- Federal Travel Regulations (FTR) 301.1.102 limits the authorization purpose and describes who may receive authorizations. 1) Unlimited Open (TDU) and Limited Open (TDL) authorizations both allow for an employee to travel. 2) Trip by Trip (TDT) authorizations allow for an individual to travel. -- Title 5 U.S.C. 5705 defines an employee as an individual employed in or under an agency (including an individual employed intermittently in the Government service as an expert or consultant and paid on a daily, when-actually-employed basis, and an individual serving without pay or at $1 a year.) ECO interns do not meet the definition of "employee," and for this reason under current regulations are eligible only for TDT travel authorizations. For this same reason, they are not eligible to receive the American Express Government Travel Charge Card, which might otherwise simplify the travel advance administrative burden. I would like to pass on that I have specifically raised this issue on several occasions with the Departmental Office of Financial Management, and the answer has consistently been that notwithstanding a recognition that this restriction is burdensome, current regulations do not allow for an exception. We therefore raised the issue through the Department's National Performance Review Travel Lab, to see if some procedural alternative could be obtained through that route. While the Travel Lab has discussed travel authorization changes, and has not issued its report yet, it is my understanding that they do not intend to propose changes which would permit non-governmental individuals to travel on other than a TDT authorization. Therefore, I regretfully conclude that the USGS Office of Financial Management does not have any basis in current (or anticipated) authority to permit ECO interns to have travel authorizations other than TDT's. The second area is the issuance of travel advances, the amounts of which are, of course, linked to the type of authorization. According to 5 USC 5705, "an agency may advance, through the proper disbursing official, to an employee entitled to per diem or mileage allowances under this subchapter, a sum considered advisable with regard to the character and probable duration of the travel to be performed." A common example is a travel advance, which is the amount made available to an employee prior to the beginning of a trip. Within the various travel regulations applicable to the Department of the Interior (DOI), there is no authorization for payment of advances to individuals under contract, such as the ECO interns. We have raised this issue as well with the Department, and have not succeeded in gaining an exemption for our circumstances. The rational for the DOI position is founded on the view that DOI should move instead to stronger support of government wide travel initiatives which are aimed at minimizing cash travel advance amounts for Federal employees, primarily by expanding use of the American Express card. Furthermore, there is fairly broad consensus that DOI should not then further increase cash outlay demands upon the Treasury by issuing advances to contractors. An alternative approach which you and I have discussed previously would be to fund reimbursement for travel as part of the ECO (or successor) contract. In that arrangement, the intern's employee would cover travel charges and bill USGS for them after the fact, as is typical for other USGS contracts. While there are significant disadvantages to this approach, particularly when dealing with non-profit service providers who also have cash-flow limitations, it remains the most feasible alternative barring further changes in the FTR. I regret that we have not found a more satisfactory solution that would reduce the burden upon both administrative and mission activities that results from the present limitations upon our authority. I would like to offer to continue working with you to develop other alternatives. We too would like to rectify what we recognize is an ongoing problem for mission support. I will be glad to discuss these issues with you further.