Reimbursed Travel: Commerce and FTC Generally Met Requirements but Some
Improvements Needed (Letter Report, 01/26/95, GAO/GGD-95-32).

Under federal regulations, government employees can accept payment of
travel costs by nonfederal sources, such as private companies and
universities, if the purpose of the travel is related to the employees'
official duties and the acceptance of such travel does not present a
conflict of interest. Federal agencies are required to establish
procedures to ensure that these conditions are met before travel
reimbursements are accepted. This report determines (1) how adequately
the Commerce Department and the Federal Trade Commission controlled
their employees' acceptance and reporting of travel funds paid by
nonfederal organizations and (2) the implication of Commerce's denying
the Office of Government Ethics access to its records of reimbursed
travel in 1992.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-95-32
     TITLE:  Reimbursed Travel: Commerce and FTC Generally Met 
             Requirements but Some Improvements Needed
      DATE:  01/26/95
   SUBJECT:  Air travel allowances
             Documentation
             Federal employees
             Transportation expense claims
             Travel costs
             Cost accounting
             Reporting requirements
             Claims settlement
             Compliance
             Fare discounts

             
******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO report.  Delineations within the text indicating chapter **
** titles, headings, and bullets are preserved.  Major          **
** divisions and subdivisions of the text, such as Chapters,    **
** Sections, and Appendixes, are identified by double and       **
** single lines.  The numbers on the right end of these lines   **
** indicate the position of each of the subsections in the      **
** document outline.  These numbers do NOT correspond with the  **
** page numbers of the printed product.                         **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
** A printed copy of this report may be obtained from the GAO   **
** Document Distribution Center.  For further details, please   **
** send an e-mail message to:                                   **
**                                                              **
**                                            **
**                                                              **
** with the message 'info' in the body.                         **
******************************************************************


Cover
================================================================ COVER


Report to the Honorable
John M.  Spratt, Jr., House of Representatives

January 1995

REIMBURSED TRAVEL - COMMERCE AND
FTC GENERALLY MET REQUIREMENTS BUT
SOME IMPROVEMENTS NEEDED

GAO/GGD-95-32

Reimbursed Travel

(966611)


Abbreviations
=============================================================== ABBREV

  FTC - Federal Trade Commission
  GSA - General Services Administration
  ITA - International Trade Administration
  NIST - National Institute of Standards and Technology
  NOAA - National Oceanic and Atmospheric Administration
  OGE - Office of Government Ethics

Letter
=============================================================== LETTER


B-258383

January 26, 1995

The Honorable John M.  Spratt, Jr.
House of Representatives

Dear Mr.  Spratt: 

This report presents the results of our review of the programs
administered by the Department of Commerce and Federal Trade
Commission (FTC) for controlling the acceptance and reporting of
travel expenses incurred by their employees and paid by nonfederal
organizations.  Under regulations promulgated by the General Services
Administration (GSA), federal employees can accept payment of travel
costs by nonfederal sources, such as private companies and
universities, if the purpose of the travel is related to the
employees' official duties and responsibilities and the acceptance of
such travel does not present the appearance of a conflict of
interest.  Federal agencies are required to establish procedures to
ensure that these conditions are met before travel reimbursements are
accepted. 

The Commerce, Consumer, and Monetary Affairs Subcommittee asked us on
November 9, 1993, to determine (1) the adequacy of Commerce's
administration of its employees' acceptance and reporting of travel
funds from nonfederal sources and (2) the implications, if any, of
Commerce's denying the Office of Government Ethics (OGE) access to
its records of reimbursed travel in 1992.  On June 6, 1994, the
Subcommittee also asked that we include FTC in our review. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Our overall assessment of Commerce's administration of reimbursed
travel expenses found that Commerce generally met applicable
requirements for accepting and reporting travel reimbursements. 
However, some instances of noncompliance were found and certain
procedural improvements could be made in the receipt and reporting of
these funds.  Specifically, Commerce did not ensure for all trips
that (1) travel requests containing all of the required information
were prepared and reviewed before trips were approved; (2) travel
reports that were required to be submitted to OGE accurately
disclosed the circumstances of each trip, including the nature,
dates, and itemized costs of the trips; or (3) trips were adequately
documented with receipts and vouchers from reimbursing organizations
listing the actual expenses reimbursed. 

At FTC, we found that the agency consistently met the requirements
for controlling the acceptance and reporting of travel reimbursements
by its employees.  However, FTC could improve its reporting by more
completely describing the nature of events attended in its reports to
OGE. 

Commerce's decision in November 1992 to deny OGE access to records
for nonfederally reimbursed travel was largely based on its view that
GSA, not OGE, was responsible for the applicable travel regulations. 
However, in May 1994 Commerce changed its position and acknowledged
that OGE does have the authority to review such records.  The overall
effect of Commerce's temporary denial of access was minimal, in that
OGE eventually received access to Commerce records and OGE has not
been denied access to such records at any other agency. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Section 302 of the Ethics Reform Act of 1989 (31 U.S.C.  1353)
provides that the Administrator of GSA, in consultation with the
Director of OGE, prescribe by regulation the conditions under which
an agency or employee may accept payment from nonfederal sources for
travel, subsistence, and related expenses with respect to attendance
at any meeting or similar function relating to the official duties of
the employee.  In the request for comments on the implementing
regulations, GSA stated that it expected OGE to review agency
implementation of section 302 in connection with its ongoing reviews
of agency ethics programs. 

GSA promulgated interim regulations in 41 C.F.R.  304 to implement
section 302.  These regulations, which have been in effect from March
8, 1991, through the present, include a definition of what
constitutes conditions for accepting travel reimbursements, a
description of payment methods, and a requirement that all instances
of nonfederally reimbursed travel in excess of $250 be reported
semiannually to OGE.  Initially, these reports were to include the
name and position of the employee, nature of the event, dates of
travel, and amount of payment.  However, GSA amended its regulations
effective December 9, 1992, by adding a few additional requirements,
including a provision that reports to OGE should also contain the
dates of the events and itemized expenses.  Commerce and FTC have
established regulations that require adherence to GSA's regulations. 

Private companies, universities, and other organizations often want
federal employees with expertise in such areas as weather forecasting
and antitrust and trade regulations to participate in meetings and
other events.  When these employees receive offers of reimbursed
travel, subsistence, or related expenses for a trip to such an event,
the employees are supposed to prepare a travel order to obtain
approval for the trip and a form requesting approval to accept the
offer of reimbursement.  At Commerce and FTC, the forms requesting
approval for reimbursement, referred to as request forms, require the
inclusion of details concerning the trip.  These details include the
name of the source offering reimbursements, dates and nature of the
event, and types and amounts of expenses that will be reimbursed. 
This information is to be used by the employees' supervisors and
other higher level reviewing officials.  If a trip meets the
applicable GSA regulations for authorizing travel on a reimbursable
basis, a travel order can be approved.  At Commerce, all travel
reimbursement offers made to the Secretary of Commerce are reviewed
by the Department's Office of General Counsel, while reimbursement
offers made to other Commerce employees are reviewed in their
respective offices.  At FTC, travel reimbursement offers made to any
employee are reviewed by FTC's Office of General Counsel. 

During the period of March 8, 1991, when GSA's interim regulations
became effective, through September 30, 1993, Commerce had 3,104
nonfederally reimbursed trips, or an average of 1,242 trips per
fiscal year.  We sampled 160\1 of these trips and found that the
average amount of reimbursed expenses was $1,100 per trip. 
Reimbursements varied from covering all of the trip's expenses to
some portion, such as airfare or lodging.  During the period of
October 1, 1992, through September 30, 1993, FTC had 59 nonfederally
reimbursed trips.  The average amount of reimbursed expenses for FTC
employees was $677 per trip.  Additional details on our scope and
methodology follow. 


--------------------
\1 For 1 of the 160 trips, Commerce was unable to provide any
documents other than the report to OGE. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :3

To determine the adequacy of Commerce's administration of employees'
acceptance of travel funds from nonfederal sources, we reviewed two
random samples of nonfederally reimbursed trips at Commerce.  First,
because of the Subcommittee's interest in travel by high-level
officials, we reviewed available documentation for a sample of 60 of
the 112 trips reported during the period from March 8, 1991, through
September 30, 1993, by these officials.  We defined "high level" as
those officials in the Office of the Secretary or the highest level
official in all other Commerce offices.  We compared these documents,
including travel requests, orders, vouchers, and receipts, to the
regulations in effect at the time the trips were taken and reported. 
Second, we reviewed similar information for a sample of 100 of the
2,992 trips reported during the same period by Commerce employees who
were not high-level officials.  We limited our review to the travel
reimbursed on or after March 8, 1991, because the GSA interim
regulations implementing Section 302 of the Ethics Reform Act of 1989
took effect at that time.  We included travel reported through
September 30, 1993, since these were the latest trips identified in
OGE's reports when we began our review. 

As agreed with the Subcommittee, we also reviewed how the procedures
governing reimbursed travel were administered within Commerce's
Office of the Secretary and at the three offices with most of the
reimbursed travel during the period.  Collectively, the International
Trade Administration (ITA), National Oceanic and Atmospheric
Administration (NOAA), and National Institute of Standards and
Technology (NIST) accounted for about 79 percent of Commerce's trips. 
We did this work to better understand the procedures and policies in
place for administering reimbursed travel at individual offices. 

The Subcommittee selected FTC for review in part because it had a
centralized system for reviewing travel requests as compared to
Commerce's decentralized system.  Because the decision to include FTC
was made during the latter part of our review, we limited our review
to all FTC employee trips that were reimbursed during fiscal year
1993 to ensure records would be readily available. 

We performed this review at Commerce, ITA, and FTC headquarters in
Washington, D.C.; NOAA headquarters in Silver Spring, MD; and NIST
headquarters in Gaithersburg, MD. 

We obtained comments from Commerce and FTC that are discussed on page
11 and presented in appendixes II and III.  Our work was conducted
from December 1993 to September 1994 in accordance with generally
accepted government auditing standards. 


   COMMERCE GENERALLY COMPLIED
   WITH REQUIREMENTS FOR ACCEPTING
   TRAVEL REIMBURSEMENTS
------------------------------------------------------------ Letter :4

Although our review of Commerce's handling of reimbursed travel
showed that applicable requirements were generally complied with, we
found some instances of noncompliance.  The most common of these
instances was that Commerce sometimes approved employees' travel
orders without first reviewing travel requests to obtain all of the
necessary information about the trip to be taken.  Although less
frequent, we also identified certain deficiencies in how Commerce
reported these reimbursements to OGE and in how internal controls
governing reimbursed travel were applied.  While no individual
reporting deficiency occurred consistently, a number of the reports
had at least one type of deficiency.  The frequency and types of
these deficiencies are shown later in this section. 


      COMMERCE SOMETIMES APPROVED
      EMPLOYEES' TRAVEL WITHOUT
      REVIEWING ALL THE REQUIRED
      INFORMATION
---------------------------------------------------------- Letter :4.1

Under GSA regulations, authorization to accept payment from a
nonfederal source should be given in advance of the travel.  As GSA
states in its regulations, the requirement for advance approval is
consistent with the long-standing practice of approving an employee's
official travel plans in advance.  Moreover, there is less risk that
an employee will receive an improper payment on behalf of the agency
if advance approval is required. 

Our review showed that travel orders indicating the existence of
reimbursed travel were almost always approved before the beginning of
the trip.  However, our samples of 60 high-level officials and 100
other employees identified a total of 36 trips, 13 and 23,
respectively, where the travel order was approved without first
reviewing a travel request form.  Nine of these 36 trips in the
samples were in the National Weather Service in NOAA.  Weather
Service officials told us that they (1) require the employee to
include a statement identifying the expenses that will be reimbursed
by the nonfederal source on the travel order and (2) allow the
employee to complete the travel request form after the trip is
complete.  The problem with such an approach is that there is no
assurance that all of the information necessary to assess
conflict-of-interest situations is submitted with the travel order. 
It should be noted that three of the Weather Service's nine travel
orders did not contain such important information as the identity of
the reimbursing organization and/or the amount and type of expenses
to be paid.  Also, 17 of the other 27 trips had travel orders that
did not include some of this important information. 


      COMMERCE'S SEMIANNUAL
      REPORTS COULD BE IMPROVED
---------------------------------------------------------- Letter :4.2

GSA's regulation governing the semiannual reporting of nonfederally
reimbursed travel to OGE requires 18 specific items of information to
be reported for each trip.\2 These items include the name of the
nonfederal source, the nature of the event, the dates of the
employee's travel, an itemization of benefits received, and the
amount of each benefit.  The regulations also require that the
expenses reported must be the actual amount paid by check or the
value of in-kind services,\3

other than for meals. 

While Commerce's Office of General Counsel, which is responsible for
providing the semiannual reports of reimbursed travel to OGE, has
several procedures in place to ensure that all reimbursed travel is
reported to OGE, we identified some deficiencies in the reported
information.  Specifically, we found 27 deficiencies that were
contained in 23 of the 160 trips in our sample.  These deficiencies
are shown in table 1. 



                                Table 1
                
                  Frequency and Types of Deficiencies
                    Found in Reporting of Commerce's
                  Nonfederally Reimbursed Travel From
                  March 8, 1991, to September 30, 1993

                                                            High-level
                                       All employees         officials
                                         (frequency/       (frequency/
Type of deficiency                      sample size)      sample size)
----------------------------------  ----------------  ----------------
Nature of event not described in               4/100              0/60
 report to OGE
Dates of travel not reported to                1/100              4/60
 OGE
Benefit and/or cost figures not                7/100              0/60
 itemized in report to OGE
Actual expenses not accurately                9/35\a            2/15\a
 reported to OGE
----------------------------------------------------------------------
Note:  In addition to the deficiencies in this table, we identified a
few instances of noncompliance in other areas that were primarily
caused by the individual actions of two officials.  In both of these
instances, procedural improvements were subsequently implemented. 

\a Reduced sample size reflects the number of trips for which
receipts were provided.  As discussed later, receipts are not needed
for all types of reimbursements. 

Source:  GAO analysis of Commerce's travel records and reports to
OGE. 

An official in Commerce's Office of General Counsel said that many of
the deficiencies were due to the December 9, 1992, change in GSA's
regulations, which is discussed on pages 2 and 3 of this report.  In
corroboration of this point, we found that all 12 of the deficiencies
involving the dates of events and itemized expenses did occur shortly
after the regulations were changed.  However, the other deficiencies
did not appear to be related to the revised regulations. 

The individual Commerce offices are responsible for the accuracy of
expenses reported to the Office of General Counsel.  In 11 of the 160
trips (9 in the all-employee sample and 2 in the high-level
officials' sample) the reported amounts differed from the amounts
recorded in the receipts.  The reported amount was less than the
receipts in five instances, ranging in difference from $7 to $523. 
In the other six instances, the reported amount exceeded the receipts
by $12 to $350.  Four of the nine instances of differing amounts in
the all-employee sample occurred in ITA.  The ITA Director of the
Office of Organization and Management Support commented on these four
trips.  For the trip that resulted in the largest variance, she said
that it was possible the employee reported the government rate for
the airfare rather than the actual amount paid.  She also said that
the other three instances, none of which was greater than $15, could
have been attributed to math errors. 

It should be noted that we could not always determine whether the
actual costs of the trips were reported in Commerce's semiannual
reports because receipts are not required for expenses paid in-kind. 
About 71 percent of the 160 reports included in-kind reimbursements. 


--------------------
\2 As previously discussed in the background section, GSA's initial
regulations did not require the reporting of some information that
the current regulations require.  In assessing Commerce's travel
reports to OGE, we applied the regulations in effect at the time of
the report. 

\3 In-kind services are goods, services, or other benefits provided
by a nonfederal source for travel, subsistence, and related expenses
in lieu of funds paid to an agency by check or similar instrument. 


      COMMERCE COULD STRENGTHEN
      INTERNAL CONTROLS
---------------------------------------------------------- Letter :4.3

Commerce could improve its controls over travel expenses paid, either
by check or in-kind, by ensuring that employees submit receipts and
travel vouchers for all reimbursed expenses.


         RECEIPTS WERE NOT ALWAYS
         OBTAINED AND TRAVEL
         VOUCHERS WERE NOT ALWAYS
         PREPARED
-------------------------------------------------------- Letter :4.3.1

The Federal Travel Regulations (Part 301-11) require employees to
provide receipts for allowable cash expenditures in excess of $25. 
Receipts are also required for certain expenditures regardless of
amount, including fees relating to travel outside of the United
States.  When receipts are not available, the only documentation for
expenditures is the travel voucher.  While the GSA regulations on
nonfederally reimbursed travel do not address the need for receipts,
both Commerce and FTC believe that the Federal Travel Regulations
apply to expenses initially incurred by the employee and the
government and later reimbursed by check from the nonfederal source. 

There were 16 and 36 trips in the high-level officials and
all-employee samples at Commerce, respectively, that included
expenses that were reimbursed either partially or fully by check.  Of
these 52 trips, files for 11 cases contained no evidence of receipts'
being obtained to support the expenses that were claimed.  According
to several Commerce officials, receipts are used to bill the sources
of the reimbursements and may have been sent to them. 

Also, for another 11 of the 160 trips in our sample, Commerce
indicated that travel vouchers had never been prepared by the
employees.  Commerce officials said that the vouchers were not
prepared in these 11 cases because all of the expenses were paid
in-kind and, thus, there was no cost to the government and no need to
account for the expenses incurred.  However, since receipts are
generally not obtained for in-kind expenses, the travel voucher
serves as the only source of information for identifying the actual
expenses incurred when reporting to OGE. 


         RECEIPTS ARE NOT REQUIRED
         FOR IN-KIND EXPENSES
-------------------------------------------------------- Letter :4.3.2

GSA regulations governing nonfederally reimbursed travel require the
actual amounts of expenses paid, in-kind and by check, to be reported
to OGE.  Of the 160 trips in our sample, 128 included in-kind
reimbursements.  Since GSA regulations do not require travelers to
obtain receipts for in-kind expenses, Commerce did not have receipts
for 99 of these trips and thus, there was no assurance that the
estimates of reimbursed travel coincided with the actual costs
incurred. 


   FTC COMPLIED WITH THE
   REQUIREMENTS FOR ACCEPTING AND
   REPORTING REIMBURSED TRAVEL
------------------------------------------------------------ Letter :5

We did not identify any deficiencies in FTC's acceptance of
reimbursed expenses for the 59 trips we reviewed.  FTC also generally
complied with all GSA requirements for reporting and documenting
reimbursed travel.  However, FTC could have improved its reporting by
more fully describing the nature of the event in 17 reports to OGE. 
FTC also had internal controls in place, including the use of letters
of commitment to monitor expenses.  As previously discussed in the
background section, GSA regulation 41 C.F.R.  304-1.9 governing
reports of nonfederally reimbursed travel to OGE requires specific
information in each report, including the nature of the event.  In
the 17 reports to OGE where FTC did not fully describe the nature of
the event, FTC only stated the name of the organization conducting
the event, followed by a term such as "meeting," "conference," or
"symposium." The FTC Deputy Ethics Official responsible for the
report said that he believes FTC's practice to be in compliance with
GSA regulations.  A GSA official in the division responsible for
administering the regulations said that providing a specific
description of the event's nature, such as an American Bar
Association meeting on foreign trade tariffs, allows OGE and the
public to better understand the employee's reason for attending the
meeting. 

As previously discussed above, the GSA travel regulations do not
require employees to obtain receipts for expenses reimbursed in-kind,
but do require the actual value of in-kind services be reported to
OGE.  FTC obtains letters of commitment before the trips that provide
estimates of the expenses to be paid and relies on the employees to
inform FTC if the actual value of expenses paid in-kind deviates from
the estimate. 


   OGE'S ACCESS TO COMMERCE'S
   TRAVEL RECORDS HAS BEEN
   RESOLVED
------------------------------------------------------------ Letter :6

OGE is responsible for providing overall direction of executive
branch policies related to preventing conflicts of interest on the
part of officers and employees of any executive agency.  Specific
responsibilities include developing and reviewing statutes and
regulations pertaining to conflicts of interest and monitoring agency
ethics programs. 

During a review of Commerce's ethics program in 1992, Commerce
officials denied OGE access to records and supporting documents
relating to acceptances of travel, subsistence, and related expenses
from nonfederal sources under 31 U.S.C.  1353.  According to OGE
officials, OGE made two verbal requests for the records and sent a
letter with their final report on October 15, 1992.  OGE's letter
expressed the need for OGE to have access to such records and asked
Commerce to reconsider its decision. 

OGE's letter also argued that the law requires GSA to consult with
OGE in the development of the regulations and requires agencies to
submit semiannual reports of payments accepted under the authority to
OGE.  Given OGE's involvement in those areas, combined with its
overall oversight responsibilities regarding ethical standards and
conduct, OGE believed its authority encompassed reviewing agency
compliance with the regulation for nonfederally reimbursed travel. 

Commerce's General Counsel responded to OGE's letter with a letter
dated November 5, 1992.  The General Counsel's letter stated that
Commerce officials did not provide documents related to nonfederally
reimbursed travel because such information seemed to be outside the
scope of OGE's audit.  The letter further stated that regulations
governing such travel are not found in ethics regulations but in GSA
travel regulations.  Therefore, Commerce believed that oversight was
the responsibility of GSA rather than OGE. 

Since it is OGE's responsibility to monitor executive agency
compliance with the statutory and regulatory requirements governing
travel reimbursement from nonfederal sources, we believe that OGE is
entitled to access to all records related to such reimbursed travel
that an agency may possess.  Commerce now agrees with our position. 
In May 1994, in response to our inquiries, Commerce's Assistant
General Counsel for Administration sent us a letter stating that
Commerce's "position is that OGE has authority to review records
relating to travel expenses accepted under the authority of the
Ethics Reform Act, including supporting documents.  Any past
misunderstandings concerning this issue have been resolved." In
addition, OGE conducted a review of Commerce's Patent and Trademark
Office this year, and OGE was given access to the office's records of
nonfederally reimbursed travel. 

Commerce's denial did not adversely affect OGE's reviews of other
agencies' nonfederally reimbursed travel.  Other agencies did not
refuse OGE access in reviews of reimbursed travel conducted during or
after Commerce's denial. 


   CONCLUSIONS
------------------------------------------------------------ Letter :7

Although Commerce generally complied with the requirements for
nonfederally reimbursed travel, some of its procedures can be
strengthened to reduce the risk of conflict of interest and improve
internal controls.  Specifically, Commerce could better ensure that
(1) employees have approved travel requests containing all of the
necessary information before trips are taken; (2) travel reports to
OGE accurately disclose the circumstances of each travel incident,
including the nature, dates, and itemized costs of the trips; and (3)
trips are adequately documented with receipts and vouchers. 

FTC's procedures for accepting and reporting reimbursed travel were
basically sound.  However, FTC's semiannual reports sometimes could
have better described the nature of the event to be attended.  By
including a better description, FTC could enable OGE to better form
an opinion as to whether the employee's attendance may appear to
constitute a conflict of interest. 

The issue of OGE's access to records relating to reimbursed travel
expenses at Commerce has been resolved.  Commerce's letter stating
that OGE has authority to review these records and OGE's recently
completed audit of such records at Commerce's Office of Patent and
Trademark indicate that Commerce and OGE are in accord.  The overall
effect of Commerce's temporary denial of access was minimal in that
OGE eventually received access to Commerce records, and OGE has not
been denied access to such records at any other agency. 


   RECOMMENDATIONS
------------------------------------------------------------ Letter :8

We recommend that the Secretary of Commerce take actions to ensure
that

  -- all Commerce employees' travel requests containing all of the
     necessary information, such as the name of the payer and the
     amount and type of expenses to be paid, are reviewed and
     approved before a trip;

  -- the Office of General Counsel, as part of its responsibilities
     for submitting semiannual reports to OGE, ensure that these
     reports include the required information, including the dates
     and nature of events attended and expenses paid; and

  -- Commerce offices require (1) travel vouchers and (2) receipts
     for reimbursed expenses, except for meals since they are not
     required by Federal Travel Regulations to be supported in this
     manner. 

Also, we recommend that the Chairman, Federal Trade Commission

  -- require the Office of General Counsel to ensure that the
     agency's reports to OGE more completely describe the nature of
     the events attended. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :9

Commerce and FTC provided written comments on a draft of this report. 
These comments are summarized below and included in their entirety,
along with our specific responses, in appendixes II and III. 

Commerce agreed to implement our recommendations that the Department
ensure that (1) all Commerce employees' travel requests be reviewed
and approved before beginning a trip, (2) the Office of General
Counsel ensure that reports to OGE include the required information,
and (3) Commerce offices require receipts for those expenses
reimbursed by check.  Also, Commerce offered an alternative to our
recommendation that its offices require travel vouchers by proposing
that it require receipts and other evidence for all reimbursed
expenses regardless of whether they were paid in-kind or reimbursed
by check.  We consider Commerce's proposal to be an adequate response
to our concern that expenses reported to OGE are accurate.  However,
because a travel voucher is the established way for employees to
submit travel receipts and other related information to management,
we continue to believe that Commerce should require their use.  FTC
agreed to implement our recommendation that it ensure that reports to
OGE more completely describe the nature of the events attended. 


---------------------------------------------------------- Letter :9.1

We are sending copies of this report to the Secretary of Commerce,
the Chairman of FTC, and other interested parties and will also make
copies available to others upon request. 

The major contributors to this report are listed in appendix IV.  If
you have any questions about this report, please contact me on (202)
512-5074. 

Sincerely yours,

Timothy P.  Bowling
Associate Director, Federal Human
 Resource Management Issues


MISSIONS OF THE AGENCIES REVIEWED
=========================================================== Appendix I


      OFFICE OF THE SECRETARY
------------------------------------------------------- Appendix I:0.1

This office administers the operations of all the offices in the
Department of Commerce. 


      INTERNATIONAL TRADE
      ADMINISTRATION (ITA)
------------------------------------------------------- Appendix I:0.2

ITA is involved in issues concerning import administration,
international trade and commercial policy, and trade promotion. 
Specific operations include conducting a trade adjustment assistance
program that provides financial assistance in the form of grants to
selected firms and communities, developing and carrying out policies
and programs to promote world trade, and strengthening the
international trade and investment position of the United States. 


      NATIONAL OCEANIC AND
      ATMOSPHERIC ADMINISTRATION
      (NOAA)
------------------------------------------------------- Appendix I:0.3

NOAA has five major program areas, each with its own mission related
to some aspect of oceanic and atmospheric conditions.  Our review
focused on the two offices with the most employees, the National
Marine Fisheries Service and the National Weather Service.  The
Fisheries Service is responsible for promoting the conservation,
management, and development of living marine resources for commercial
and recreational use.  The program includes the management of a
nationwide financial assistance program in the form of loan
guaranties and a capital construction fund.  The Weather Service is
responsible for monitoring and predicting the state of the
atmospheric and hydrologic environment.  The Weather Service has
contracts for computers and other services with private entities. 


      NATIONAL INSTITUTE OF
      STANDARDS AND TECHNOLOGY
      (NIST)
------------------------------------------------------- Appendix I:0.4

NIST's primary mission is to promote economic growth in the United
States by working with industry to develop and apply technology,
measurements, and standards.  NIST programs include an advanced
technology effort that includes entering into contracts and
cooperative agreements with businesses.  NIST has eight laboratories
whose roles range from establishing standards for information
processing and various forms of radiation to analyzing the
performance of building and construction materials. 

NIST now works with industry and other federal agencies in four major
areas:  (1) transferring technology, (2) helping smaller
manufacturers tap into regional and national sources of information,
(3) recognizing U.S.  companies that have successful quality
management systems, and (4) assisting federal agencies and industry
with specific technically based trade issues related to standards and
conformity assessment. 


      FEDERAL TRADE COMMISSION
      (FTC)
------------------------------------------------------- Appendix I:0.5

FTC is involved in investigation, rule making, and enforcement of
laws for organizations engaged in or whose businesses affect
commerce, except banks, savings and loans, federal credit unions, and
common carriers.  FTC utilizes its statutory powers to enforce both
consumer protection and antitrust laws.  For example, FTC is
responsible for keeping the marketplace free from unfair, deceptive,
or fraudulent practices by investigating alleged law violations and,
when appropriate, taking administrative enforcement action or seeking
judicial enforcement. 




(See figure in printed edition.)Appendix II
COMMENTS FROM THE DEPARTMENT OF
COMMERCE
=========================================================== Appendix I



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on Commerce's letter dated October
12, 1994. 

GAO COMMENTS

1.  Although it is true that our review did not identify any
conflicts of interest, it needs to be recognized that identifying
such situations was not the specific purpose of our review.  The
focus of our review was to determine how well these controls over
reimbursed travel were being implemented. 

2.  Commerce said that these issues arose with respect to only a few
of its operating units.  As stated in our scope and methodology
section, we reviewed the procedures governing reimbursed travel at
these offices because they accounted for 79 percent of the reimbursed
travel by Commerce employees. 

3.  We understand Commerce's reluctance to have the Office of General
Counsel audit all of the travel gift reports.  We believe that
obtaining receipts for all reimbursed expenses would improve the
accuracy of reported amounts and preclude the need for a General
Counsel audit. 

4.  We believe that the FTC's favorable experience with securing
letters from nonfederal sources listing the expenses to be paid prior
to the trip demonstrates that this suggestion is feasible.  However,
we withdrew this draft recommendation in deference to Commerce and
FTC views that the added administrative burden would outweigh the
benefits of better assuring that the actual amount of reimbursed
expenses was being reported to OGE. 




(See figure in printed edition.)Appendix III
COMMENTS FROM THE FEDERAL TRADE
COMMISSION
=========================================================== Appendix I



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on FTC's letter dated October 3,
1994. 

GAO COMMENTS

1.  With respect to FTC's concern that the draft report's title
appeared to focus on the few negative aspects of our review, we
modified the title to reflect that FTC and Commerce generally
complied with requirements but some improvements are needed. 

2.  We disagree with FTC's contention that the potential for "double
charging" does not exist.  FTC said that the traveling employee would
not receive a receipt for a travel-related expense paid in-kind by a
nonfederal source and would, therefore, not have the documentation
needed to charge the government for the same expense.  Our review of
FTC trips in 1993 found that employees had been able to obtain
receipts for in-kind expenses for three of the trips.  In addition,
Commerce proposed in its comments that employees obtain receipts for
in-kind expenses to better document travel expenses.  While it
appears that the employees can obtain receipts for some in-kind
expenses, we believe that FTC's practice of obtaining a letter from
the nonfederal source citing expenses to be paid is a sufficient
internal control against an employee's double charging the
government. 

3.  While it is true that there is no evidence that travelers
inaccurately report in-kind payments received from nonfederal
sources, there is also little evidence that they reported accurately. 
There were no receipts for 25 of the 28 trips by FTC employees in
fiscal year 1993 that involved in-kind expenses.  Nevertheless, we
withdrew our draft recommendation regarding the verification letter,
deferring to FTC's and Commerce's views that the added administrative
burden may outweigh the benefit of improved controls over accurately
reporting the receipt of in-kind expenses. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IV

GENERAL GOVERNMENT DIVISION,
WASHINGTON, D.C. 

Norman A.  Stubenhofer, Assistant Director
Thomas C Davies, Jr., Evaluator-in-Charge
Sandra S.  Silzer, Evaluator
Jeffrey W.  Dawson, Evaluator
Geraldine C.  Beard, Evaluator

OFFICE OF THE GENERAL COUNSEL,
WASHINGTON, D.C. 

Alan N.  Belkin, Assistant General Counsel
James M.  Rebbe, Attorney


*** End of document. ***