BNUMBER:  B-270432
DATE:  June 24, 1996
TITLE:  Senior Airman Calvin S. Watford, Jr.-Claim for Basic
Allowance for Quarters

**********************************************************************

Matter of:Senior Airman Calvin S. Watford, Jr.-Claim for Basic 
          Allowance for Quarters

File:     B-270432

Date:June 24, 1996

DIGEST

An Air Force member is married to another member, and they have a 
child.  The member's spouse receives Basic Allowance for Quarters 
(BAQ) at the with-dependent rate, and the member receives BAQ at the 
without-dependent rate.  The member has been awarded legal custody of 
his brother by a court, and the brother is therefore now his 
dependent.  The member's claim for BAQ at the with-dependent rate is 
denied because the brother joins the couple's child as a single class 
of dependents who live in the family household.  Only one of the 
members may receive BAQ at the with-dependent rate, but they may 
decide which one will do so.

DECISION

This is in response to a request for an advance decision regarding the 
claim of Senior Airman Calvin S. Watford, Jr., for Basic Allowance for 
Quarters (BAQ) pursuant to his guardianship of his brother, who is a 
minor.  His claim is denied.

Senior Airman Watford is married to another service member, and they 
have one child.  His spouse receives BAQ at the with-dependent rate on 
behalf of that child, and Senior Airman Watford receives BAQ at the 
without-dependent rate.  In February 1995 a Virginia state court made 
Senior Airman Watford the guardian of his 14-year old brother, who now 
lives with Senior Airman Watford and his family.[1]  Senior Airman 
Watford claims BAQ at the with-dependent rate on account of his 
brother.

The Defense Finance and Accounting Service (DFAS) submitted the claim 
to us as a doubtful claim.  Since Senior Airman Watford is married to 
another member who is receiving BAQ at the with-dependent rate because 
of their child, DFAS asks whether his brother joins the child in a 
common class of dependents, in which case Senior Airman Watford is not 
entitled to the with-dependent rate for his brother.[2]

Under 37 U.S.C.  sec.  403, a member who receives basic pay is generally 
entitled to BAQ, unless assigned to appropriate government quarters 
adequate for himself and his dependents.  BAQ is paid either at the 
with-dependent or without-dependent rate.  "Dependent" is defined in 
37 U.S.C.  sec.  401, and can include the member's spouse, child, parent, 
or ward (an unmarried person placed in the legal custody of the member 
by a court), if that person meets the requirements of the statute.  
Wards were included among dependents with the enactment of Pub. L. No. 
103-160,  sec.  631, 107 Stat. 1683-1684 (1993).

The primary purpose of Congress in enacting  sec.  631, was to provide 
medical care to minors who were in the care of members.  The 
legislative history of  sec.  631 reveals that in 1991 Congress recognized 
that members and retired members were taking legal custody of minors 
for humanitarian reasons and were unable to obtain military medical 
care for them because the minors did not meet the definition of 
"dependent" in 37 U.S.C.  sec.  401, as it existed at that time.  Congress 
ordered the Secretary of Defense to submit a report on the feasibility 
of providing military medical care to such minors, and  sec.  631 was 
enacted in response to the report.[3]  Wards apparently were not 
placed in the definitional category with children because some wards 
are not related to their guardians and because the definition of 
"children" is already complex, because it includes legitimate and 
illegitimate natural children, stepchildren, and adopted children.

A member who is not living in government quarters and who has one 
dependent (also not in government quarters) generally receives BAQ at 
the with-dependent rate.  Adding another dependent, even from another 
category of dependents, does not necessarily increase his 
entitlement-e.g., a member who has a wife (category 1 of dependents in 
37 U.S.C.  sec.  401) who is not a member and receives BAQ at the 
with-dependent rate does not gain entitlement to any more BAQ when he 
acquires one or more children (category 2 of dependents).

When two service members are married to each other and are not 
provided appropriate government quarters, each is entitled to BAQ at 
the without-dependent rate, unless one or both have dependents.  See 
generally the Department of Defense Military Pay and Allowances 
Entitlements Manual, part 3, chapter 2, section C.  If each of them 
has children from an earlier marriage who live elsewhere and the 
members live together as a family unit in non-government quarters, one 
of the members is entitled to BAQ at the with-dependent rate and one 
at the without-dependent rate.  Petty Officer First Class Earl Duffy, 
USNR, and Petty Officer Carole Duffy, USNR, B-217665, Aug. 23, 1985.  
Likewise, when one of the members has a child from an earlier marriage 
and they have a child of their marriage, one of them is entitled to 
BAQ at the with-dependent rate and one at the without-dependent rate.  
Warrant Officer Leola F. Cruise, B-180328, Oct. 21, 1974.  The common 
factor in these cases is that the dependent children all form one 
class of dependents, and all could reside with the members but for 
reasons of a personal nature.  Id.; and Pay Manual, paragraph 
30232(b).

The present situation is analogous to that in Warrant Officer Leola F. 
Cruise, supra.  The child of the Watfords' marriage and Senior Airman 
Watford's brother, who is now in effect his adopted son, form one 
class of dependent children who reside together.  The Watfords may 
choose which spouse is to receive BAQ at the with-dependent rate and 
which at the without-dependent rate.  Payment of BAQ at the 
with-dependent rate to both would constitute an unwarranted gratuity 
unrelated to their housing needs.  Petty Officer First Class Earl 
Duffy, USNR, and Petty Officer Carole Duffy, USNR, supra.[4]

Senior Airman Watford's claim for BAQ at the with-dependent rate is 
therefore denied.

/s/Seymour Efros
forRobert P. Murphy
General Counsel

1. The Secretary of the Air Force has apparently determined under 37 
U.S.C.  sec.  403(h) that Senior Airman Watford's brother is his dependent.  
That determination is final and not subject to review by any 
accounting officer.

2. DFAS has informally advised us that it is their view that the ward 
joins the Watfords' child in a common class of dependents and that 
Senior Airman Watford is therefore not entitled to BAQ at the 
with-dependent rate on account of his ward.  DFAS administers the 
relevant regulation, the Department of Defense Military Pay and 
Allowances Entitlements Manual; deference is generally accorded to the 
interpretation of a regulation made by the agency which administers 
it.

3. See Pub. L. No. 102-190,  sec.  732, 105 Stat. 1407-1408 (1991); and 
H.R. Rep. No. 200, 103d Cong. 1st Sess. 295 (1993) reprinted in 1993 
U.S.C.C.A.N. 2013, 2082.

4. If the Watfords had no children when Senior Airman Watford was 
granted custody of his brother, it would be appropriate for one of 
them to begin receiving BAQ at the with-dependent rate.  In the 
present situation Senior Airman Watford's spouse was already receiving 
BAQ at the with-dependent rate for their child.  Adding children to a  
military family does not increase BAQ at the with-dependent rate.  
Since Senior Airman Watford's brother is in effect an adopted child of 
the family, it is our view that additional BAQ is not payable in this 
situation.