Travel Cards
Control Weaknesses Leave Army Vulnerable to Potential Fraud and Abuse Gao ID: GAO-03-169 October 11, 2002The Army's individually billed travel card program is different from the purchase card program in that the cardholder is directly responsible for all charges incurred on his or her travel card account, and the monthly bill is sent to the cardholder for payment. The cardholder is responsible for submitting a properly documented voucher and is reimbursed by the Army for all valid expenses related to official government travel. The intent of the travel card program was to improve convenience for the traveler and to reduced the government's costs of administering travel. GAO found substantial delinquencies and charge-offs of Army travel-card accounts during fiscal year 2001, and delinquencies continued into the first half of fiscal year 2002. GAO's analysis shows a correlation between delinquency problems and the travel cardholder's age and pay grade. GAO found that the Army's delinquency and charge-off problems are primarily associated with young, low- to mid-level enlisted military personnel. In addition, a weak internal control environment compounded by instances of delays in processing travel reimbursements to Army military and civilian personnel contributed to the high delinquency rates. The Army and the Department of Defense have taken action to address and focus command- and installation-level attention on management of delinquent travel card accounts. However, these actions are primarily focused on treating the symptoms or "back-end" problems rather than the "front-end" or preventive controls. GAO's work identified numerous instances of potentially fraudulent and abusive activity related to the travel card. During fiscal year 2001, 1,200 of the over 4,200 Army account holders who had written at least one nonsufficient funds (NSF) check to pay their travel card bill had their accounts charged off. In the same period, more than 200 cardholders whose accounts were eventually charged off may have also committed bank fraud by writing three or more NSF checks to the Bank of America. GAO's audit found that weaknesses in the Army's overall control environment, including a number of specific controls that were either flawed in their design or in their implementation, are the root source of the Army's inability to prevent or effectively detect the numerous instances of potentially fraudulent and abusive travel card related activity previously detected.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-03-169, Travel Cards: Control Weaknesses Leave Army Vulnerable to Potential Fraud and Abuse
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United States General Accounting Office:
GAO:
Report to Congressional Requesters:
October 2002:
Travel Cards:
Control Weaknesses Leave Army Vulnerable to Potential Fraud and Abuse:
GAO-03-169:
Contents:
Letter:
Results in Brief:
Army Has Highest Delinquency and Charge-off Rates but Recent Actions
Have Resulted in Some Improvements:
Potentially Fraudulent and Abusive Travel Card Activity:
Weak Overall Control Environment and Ineffective Travel Card Program
Controls:
Statistical Tests of Key Control Activities:
Conclusions:
Matter for Congressional Consideration:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Background:
Appendix II: Objectives, Scope, and Methodology:
Appendix III: Army Major Command Delinquency Rates:
Appendix IV: Army Personnel Grade, Rank, and Associated Basic Pay
Rates:
Appendix V: Comments from the Department of Defense:
Tables Table 1: Cumulative Charge-offs and Delinquencies by Military
Service as of March 31, 2002:
Table 2: Examples of NSF Checks Written on Charged-off Accounts:
Table 3: Examples of Abusive Activity Where the Account Was Charged
Off:
Table 4: Examples of Abusive Activity Where the Cardholders Paid the
Bill:
Table 5: Average Ratio of Cardholders to APCs at Army Sites Audited:
Table 6: Results of Testing of Key Internal Controls:
Table 7: Comparison of Number of Individually Billed Travel Cardholders
and Related Charges for DOD Versus Total Federal Government for Fiscal
Year 2001:
Table 8: Population of Fiscal Year 2001 Travel Transactions at Army
Units Tested:
Table 9: Estimate of Fiscal Year 2001 Transactions That Failed Control
Tests for Approved Travel:
Table 10: Estimate of Fiscal Year 2001 Transactions That Failed Control
Tests for Accurate Travel Voucher Payments:
Table 11: Estimate of Fiscal Year 2001 Transactions That Failed Control
Tests for Timely Submission and Processing of Travel Vouchers:
Table 12: Army Major Command Delinquency Rates (by Quarter) for the 2
Years Ending March 31, 2002:
Table 13: Army Military Grades, Ranks, and Associated Basic Pay Rates
for Fiscal Year 2001:
Table 14: Army Civilian Grades and Associated Basic Pay Rates for
Calendar Year 2001:
Figures Figure 1: Army, Non-Army DOD, and Civilian Agency Travel Card
Delinquency Rates for the 2-Year Period Ending March 31, 2002:
Figure 2: Army Delinquent and Total Outstanding Travel Card Balances by
Military Grade and Total Civilian Populations as of September 30, 2001:
Figure 3: Fiscal Year 2001 Army Charge-offs by Military Grades and
Total Civilian Populations:
Figure 4: Army Travel Card Charge-off and Recovery History from October
1, 2000, to March 31, 2002:
Figure 5: The Army Travel Process:
Figure 6: Travel Card Application:
Figure 7: Required Army and Bank of America Delinquency Process
Management Actions:
[End of section]
United States General Accounting Office:
Washington, D.C. 20548:
October 11, 2002:
The Honorable Charles E. Grassley:
Ranking Minority Member:
Committee on Finance:
United States Senate:
The Honorable Stephen Horn:
Chairman:
The Honorable Janice D. Schakowsky:
Ranking Minority Member:
Subcommittee on Government Efficiency, Financial Management and
Intergovernmental Relations:
Committee on Government Reform:
House of Representatives:
On July 17, 2002, we testified [Footnote 1] before the Subcommittee on
Government Efficiency, Financial Management, and Intergovernmental
Relations, House Committee on Government Reform, on the results of our
audit of internal controls over travel activity associated with about
430,000 individually billed Army travel card accounts, and $619 million
in related travel card charges for fiscal year 2001. The individually
billed travel card program is significantly different from the purchase
card program in that the cardholder is directly responsible for all
charges incurred on his or her travel card account and the monthly bill
is sent to the cardholder for payment. The cardholder is responsible
for submitting a properly documented voucher and is reimbursed by the
Army for all valid expenses related to official government travel. In
contrast, all purchase card charges are billed directly to the
government for monthly payment. The intent of the travel card program
was to improve convenience for the traveler and to reduce the
government‘s costs of administering travel. Appendix I provides
additional background information on the Army‘s travel card program.
This work was performed in response to your request for a comprehensive
examination of the Department of Defense‘s (DOD) and the military
services‘ purchase and travel card programs. This report provides
details and results of our Army travel card audit, which was summarized
in our recent testimony.
The objectives of our audit of the Army‘s travel card program were to
determine (1) the reported magnitude and impact of delinquent and
charged-off Army travel card accounts for fiscal year 2001 and the
first 6 months of fiscal year 2002, along with an analysis of related
causes and DOD and Army corrective actions, (2) whether indications
existed of potentially fraudulent and abusive activity [Footnote 2]
related to the Army travel card during fiscal year 2001, and (3) the
effectiveness of the overall control environment and key internal
controls for the Army‘s travel program. We analyzed the Army‘s account
delinquency and charge-off information and compared it to non-Army DOD
components and other federal agencies. In addition, we evaluated the
adequacy of selected, specific internal control policies, procedures,
and activities at four Army installations, representing 3 of the Army‘s
13 major commands.
We selected the four installations we audited based on the relative
amount of travel card activity, the number and percentage of accounts
past due, and the number and percentage of accounts charged off. For
these installations, we tested a statistical sample of travel card
transactions and conducted other audit work to evaluate the design and
implementation of key internal control procedures and activities. Our
statistical sample test results can be projected only to the individual
installations where we performed the testing and cannot be projected to
the command level or to the Army as a whole. Through auditing travel
card transactions at the four installations and data mining of fiscal
year 2001 transactions incurred by units throughout the Army, we
identified numerous examples of potentially fraudulent and abusive
travel card activity. However, our work was not designed to identify,
and we cannot determine, the extent of potentially fraudulent and
abusive activity.
We conducted our audit work from December 2001 through July 2002 in
accordance with U.S. generally accepted government auditing standards,
and we performed our investigative work in accordance with standards
prescribed by the President‘s Council on Integrity and Efficiency. We
received comments on a draft of this report from the Under Secretary of
Defense (Comptroller) dated September 30, 2002. We addressed DOD‘s
comments in the ’Agency Comments and Our Evaluation“ section and
reprinted them in appendix V. See appendix II for details on our scope
and methodology.
Results in Brief:
For fiscal year 2001, the Army had significant breakdowns in key
internal controls over individually billed travel cards. These
breakdowns contributed to the significant delinquencies and charge-offs
of Army employee account balances and potentially fraudulent and
abusive activity related to the travel card. The breakdowns resulted
primarily from a weak overall control environment, flawed policies and
procedures, and a lack of adherence to valid policies and procedures.
We found substantial delinquencies and charge-offs of Army travel card
accounts during fiscal year 2001, and delinquencies continued into the
first half of fiscal year 2002. Upon receipt of their travel cards, all
cardholders are required to sign a statement of understanding that the
card is to be used only for authorized official government travel
expenses. Most Army cardholders properly used their travel cards and
paid amounts owed to Bank of America timely. However, we found that the
Army‘s delinquency rate is higher than that of any other DOD component
or executive branch agency in the federal government. For the eight
quarters ending March 31, 2002, the Army‘s delinquency rate fluctuated
between 10 and 18 percent, and on average was about 5 percent higher
than the rest of DOD and 7 percent higher than federal civilian
agencies.
In addition, from November 1998 through March 2002, over 23,000 Army
travel card accounts totaling about $34 million were charged off by
Bank of America. Our analysis of available data shows a correlation
between delinquency problems and the travel cardholder‘s age and pay
grade. We found that the Army‘s delinquency and charge-off problems are
primarily associated with young, low- to midlevel enlisted military
personnel. In addition, a weak control environment compounded by
instances of delays in processing travel reimbursements to Army
military and civilian personnel contributed to the high delinquency
rates. These delinquencies and charge-offs have cost the Army millions
of dollars in lost rebates, higher fees, and substantial resources
spent pursuing and collecting past due accounts.
The Army and DOD have taken action to address and focus command- and
installation-level attention on management of delinquent travel card
accounts. Beginning in November 2001, the Army began offsetting wages
of certain military and civilian employees and the retirement benefits
of military retirees who had either delinquent or charged-off accounts.
These and other actions have begun to significantly reduce the number
and dollar value of charge-offs during fiscal year 2002. However, these
actions are primarily focused on treating the symptoms or ’back-end“
problems, such as delinquencies and charge-offs, rather than the ’front-
end“ or preventative controls, such as the weak overall internal control
environment and specific travel program control weaknesses.
Our work identified numerous instances of potentially fraudulent and
abusive activity related to the travel card. During fiscal year 2001,
about 1,200 of the over 4,200 Army account holders who had written at
least one nonsufficient funds (NSF) check to pay their travel card bill
had their accounts charged off. In the same period, more than 200
cardholders whose accounts were eventually charged off may have also
committed bank fraud by writing three or more NSF checks to Bank of
America. In one case, an Army employee, who had been convicted for
writing NSF checks prior to receiving the government travel card, wrote
over 86 NSF checks to Bank of America. Further, as part of our
statistical sampling results at the four sites we audited, we estimated
that personal use of the travel card ranged from 15 percent of fiscal
year 2001 transactions at one site to 45 percent at another site.
Cardholders used their travel cards for a wide variety of personal
goods or services. For example, government travel cards were used for
adult entertainment; dating and escort services; casino and Internet
gambling; cruises; tickets to musical and sporting events; personal
clothing; closing costs on a home purchase; and, in one case, the
purchase of a used automobile. We found that charged-off accounts
included those of both (1) cardholders who were reimbursed by the Army
for official travel expenses but failed to pay Bank of America for the
related charges, and thus pocketed the reimbursement, and (2) those who
used their travel cards for personal purchases for which they did not
pay Bank of America.
We also found several instances of abusive travel card activity where
Army cardholders used their cards at establishments, such as
gentlemen‘s clubs, which provide adult entertainment. Further, in some
cases, these clubs were used to convert the travel card to cash by
supplying cardholders with actual cash or ’club cash“ for a 10 percent
fee. To illustrate, a cardholder who charged $330 to the government
travel card at one of these clubs would receive $300 in cash.
Subsequently, the club receives a reimbursement from Bank of America
for a $330 restaurant charge. For fiscal year 2001, we identified about
200 individuals who charged almost $38,000 at these establishments. For
example, we found that one cardholder obtained more than $5,000 in cash
from these establishments.
We found little evidence of documented disciplinary action against Army
personnel who misused the card. Further, in many cases, evidence was
lacking that Army travel program managers or supervisors were even
aware that Army personnel were using their travel cards for personal
use. For example, a civilian employee working at the Pentagon on a
classified program used her travel card for personal purchases of
$3,600 and subsequently wrote two NSF checks for over $7,700 to Bank of
America. The cardholder‘s account was subsequently charged off when the
cardholder failed to pay the bill. The employee‘s supervisor was not
aware of any potentially fraudulent and abusive activity related to the
travel card. In another example, a California National Guard employee
with a $5,400 charge-off associated with authorized travel, for which
the Army reimbursed the cardholder, was subsequently promoted from
Major to Lieutenant Colonel.
In addition, we found that 38 of 105 travel cardholders we reviewed who
had their accounts charged-off still had active secret or top-secret
clearances as of June 2002. Some of the Army personnel holding security
clearances who have had difficulty paying their travel card bills may
present security risks to the Army. Army regulations provide that an
individual‘s finances are one of the key factors to be considered in
determining whether an individual should continue to be entrusted with a
secret or top-secret clearance. However, we found that Army security
officials were unaware of these financial issues and consequently could
not consider their potential effect on whether these individuals should
continue to have security clearances.
Our audit found that weaknesses in the Army‘s overall control
environment, including a number of specific controls that were either
flawed in their design or in their implementation, are the root causes
of the Army‘s inability to prevent and/or effectively detect the
numerous instances of potentially fraudulent and abusive travel card
related activity previously discussed. Our work demonstrated that the
Army has not provided for an adequate control infrastructure”primarily
human capital related”to effectively manage its travel card program. At
the four units we audited, we found that management was focused
primarily on delinquencies and often only after severe problems were
discovered and major commands began demanding improved performance in
reducing such delinquencies. There were few indications that management
emphasized controls designed to prevent or provide for early detection
of travel card misuse.
Our audit of seven controls relied on to manage the Army‘s travel card
program revealed critical weaknesses. For example, many problems we
identified were the result of ineffective controls over issuance of
travel cards. Although DOD‘s policy allows exemptions from the use of
travel cards for certain groups or individuals, we found that without
exception the Army issued travel cards to all personnel who requested
cards regardless of their travel or credit history. We found a
significant correlation between travel card fraud, abuse, and
delinquencies and individuals with substantial credit history problems.
The prior and current credit problems we identified for Army travel
cardholders included charged-off credit card and automobile loans,
defaulted and foreclosed home mortgages, bankruptcies, and convictions
for writing NSF checks.
Also, agency program coordinators (APC), who have the key
responsibility for managing and overseeing travel cardholders‘
activities, are essentially set up to fail in their duties because they
are given substantial responsibility for a large number of
cardholders”for example up to 1,000 cardholders per APC”and little time
to do this collateral duty. Military personnel who are responsible for
and rated on other job responsibilities”such as airport security”are
given the APC role as ’other duty as assigned.“ With a high level of
APC turnover (particularly military APCs, which at the locations we
audited were reassigned about every 6 months), and only minimal time
allotted to perform this collateral duty, we found that APCs generally
were ineffective in carrying out their key travel card program
management and oversight responsibilities.
Further, our statistical tests of key internal controls and processes
in place at four Army locations showed errors in travel voucher
processing that resulted in both overpayment and underpayment of the
amounts that travelers should have received for their official travel
expenses. In addition, substantial delays in travel reimbursements
contributed to the high delinquency rates for at least one of these
locations. Delays in reimbursement were often due to the traveler not
submitting a travel voucher within the required 5 days of completion of
travel, and/or the paying office not making payment within the required
30 days. We also found a substantial number of California National
Guard employees and several employees at other units audited who should
have been paid late fees for late reimbursements. However, the Defense
Finance and Accounting Service (DFAS) does not have the systems in
place to identify late payments and thus reported that it made no late
fee payments for fiscal year 2001.
This report includes a matter for congressional consideration that would
provide DOD the ability to require the split disbursement payment
process for all of its employees. We also provide recommendations to
the Army to strengthen the overall control environment for the Army‘s
travel card program and improve internal controls. Our recommended
actions are in the areas of travel card issuance; monitoring, review,
and disciplinary actions; and travel voucher and payment processes.
In written comments on a draft of this report, DOD concurred with 23 of
our recommendations and partially concurred with the remaining 3
recommendations and described actions completed, under way, or planned
to implement them. DOD partially concurred with our recommendations
regarding (1) training APCs to refer cardholders who write NSF checks
for disciplinary actions, (2) establishing an Army-wide disciplinary
action policy for abusive travel card activity, and (3) developing a
process to identify travel reimbursements that exceed the 30-day
requirement so that individuals not paid within the statutory period
are paid late fees in accordance with the law. With regard to the first
two issues, DOD‘s response indicated that they have taken or plan to
take actions that we believe will address the intent of our
recommendations. With regard to the third issue, DOD agreed that the
current systems for processing and computing travel vouchers for the
Army do not provide for automated means of calculating interest due on
voucher payments exceeding the 30-day requirement. DOD also stated that
the Defense Travel System (DTS) currently being deployed automates the
voucher submission process and should reduce the instances where
reimbursements extend beyond 30 days. However, according to the DOD
Office of Inspector General, DTS remains at high risk of not being an
effective solution in streamlining the DOD travel management process
and is not expected to be deployed until fiscal year 2006. Based on
this evaluation, we do not consider DTS to be a timely or viable
solution for identifying those reimbursements outside of the 30-day
requirement. We continue to recommend that, until DTS is fully
implemented and operational, DOD develop an interim process to identify
late reimbursements and pay cardholders the appropriate fees in
accordance with the law.
In addition, in one area, although DOD concurred with our
recommendation, we do not believe that its response indicates full
agreement or understanding of the intent of the recommendation.
Specifically, with regard to our recommendation that credit check
results be used to make decisions on travel card applicants, DOD
responded that those with prior credit problems are issued a restricted
card and that mandatory use of the government travel card is required
by TTRA. This is not correct. Both the DOD FMR and TTRA provide for
exemptions from the mandatory use requirements under certain
conditions, including evidence of financial irresponsibility. We
continue to believe that until the Army takes action to consider past
credit problems in determining whether to issue government travel
cards, it will continue to increase the risk that individuals will
repeat a pattern of fraud, abuse, and delinquency or nonpayment.
Finally, in concurring with our recommendations regarding the lack of
segregation of duties and other voucher processing problems at the
California Army National Guard, DOD indicated that it had a number of
detective and compensating controls in place. While these appear
responsive to our recommendations, we have not evaluated the
effectiveness of their implementation and therefore cannot determine
whether these measures will resolve the problems we identified.
Army Has Highest Delinquency and Charge-off Rates but Recent Actions
Have Resulted in Some Improvements:
The Army‘s travel card delinquency rate and amounts charged-off are
substantially higher than non-Army DOD components and civilian agencies
in the federal government. Cumulative Army charge-offs since the
inception of the travel card program with Bank of America in November
1998 are nearly $34 million. Our analysis of available data shows the
travel cardholder‘s age and pay rate are strong predictors of
delinquency problems. We found that the Army‘s delinquency and charge-
off problems are primarily related to young, low- and midlevel enlisted
military employees. Further, as discussed in the following sections of
this report, weaknesses in the Army‘s overall control environment and
delays and errors in processing and paying valid travel vouchers
exacerbate the Army‘s delinquency problems. The Army‘s high delinquency
and default rates have also resulted in contentious relations with Bank
of America. The bank threatened to end its participation in the
program, but eventually agreed to contract modifications that included
increased fees. The delinquencies and charge-offs have cost the Army,
the federal government, and the taxpayers millions of dollars in lost
rebates, higher fees, and substantial resources spent pursuing and
collecting on past due accounts.
The Army has taken a number of positive actions to address its high
delinquency and charge-off rates, and results from the first half of
fiscal year 2002 show a significant drop in charged-off accounts. Most
of this reduction is attributable to a salary and military retirement
offset program”similar to garnishment. These offsets began in November
2001. Other Army actions included encouraging the use of a split
disbursement payment process, in which DFAS sends a portion of the
traveler‘s reimbursement directly to the bank rather than the
cardholder, and increased management attention and focus on the
delinquency issue. The Army‘s actions, however, primarily address the
symptoms or ’back-end“ result of delinquency and charge-offs after they
have already occurred. As noted in the remaining sections of this
report, the Army‘s control weaknesses that are the root cause of the
problem are generally related to the ’front-end“ management of the
travel card program, such as issuing the cards and overseeing the
proper use of the cards.
The Army‘s Delinquencies and Charge-offs:
Since the inception of the travel charge card task order between DOD and
Bank of America on November 30, 1998, Bank of America has charged off
over 23,000 Army travel card accounts with nearly $34 million of bad
debt. As of March 31, 2002, over 11,000 Army cardholders had $8.4
million in delinquent debt. The amount of delinquencies and charge-offs
at the Army is the highest in DOD. Table 1 provides a comparison of
cumulative charge-offs and delinquencies by military service as of
March 31, 2002.
Table 1: Cumulative Charge-offs and Delinquencies by Military Service
as of March 31, 2002 (Dollars in millions):
DOD service: Army;
Total cumulative charge-offs[A]: $33.5;
Cumulative recoveries[A,B]: $12.9;
Net cumulative charge-offs[A]: $20.6;
Delinquencies as of March 31, 2002[C]: $8.4.
DOD service: Air Force;
Total cumulative charge-offs[A]: $11.6;
Cumulative recoveries[A,B]: $4.7;
Net cumulative charge-offs[A]: $6.9;
Delinquencies as of March 31, 2002[C]: $5.0.
DOD service: Navy[D];
Total cumulative charge-offs[A]: $16.6;
Cumulative recoveries[A,B]: $6.2;
Net cumulative charge-offs[A]: $10.4;
Delinquencies as of March 31, 2002[C]: $6.0.
[A] Cumulative charge-offs and recoveries are from November 1998
through March 2002.
[B] Recoveries represent amounts recovered through collection actions
on accounts that have been charged off by Bank of America.
[C] Delinquencies represent amounts not paid within 60 days of the
travel card monthly statement closing date, which is the cutoff date
for charges to be included in the monthly statement. Under the terms of
the travel cardholder‘s agreement with Bank of America, payment of the
travel card statement is due to Bank of America within 25 to 30 days of
the statement closing date.
[D] Includes Marine Corps.
Source: GAO analysis of Bank of America and General Services
Administration data.
[End of table]
Figure 1 compares delinquency rates [Footnote 3] among the Army, non-
Army DOD components including the other military services, and the 23
largest civilian agencies. [Footnote 4]
Figure 1: Army, Non-Army DOD, and Civilian Agency Travel Card
Delinquency Rates for the 2-Year Period Ending March 31, 2002:
[See PDF for image]
This figure is a multiple line graph. The vertical axis of the graph
represents percentage from 0 to 20. The horizontal axis of the graph
represents fiscal year quarters from 2000, third quarter through 2002
second quarter. The following approximated data is depicted on the
graph:
Army, Non-Army DOD, and Civilian Agency Travel Card Delinquency Rates
for the 2-Year Period Ending March 31, 2002:
Fiscal year: 2000, third quarter;
Governmentwide delinquency rate excluding DOD: 8.5%;
DOD delinquency rate excluding Army: 5.5%;
Army delinquency rate: 11%.
Fiscal year: 2000, fourth quarter;
Governmentwide delinquency rate excluding DOD: 7%;
DOD delinquency rate excluding Army: 9%;
Army delinquency rate: 15%.
Fiscal year: 2001, first quarter;
Governmentwide delinquency rate excluding DOD: 9.5%;
DOD delinquency rate excluding Army: 12%;
Army delinquency rate: 18%.
Fiscal year: 2001, second quarter;
Governmentwide delinquency rate excluding DOD: 5%;
DOD delinquency rate excluding Army: 6.5%;
Army delinquency rate: 13%.
Fiscal year: 2001, third quarter;
Governmentwide delinquency rate excluding DOD: 4%;
DOD delinquency rate excluding Army: 6.5%;
Army delinquency rate: 10%.
Fiscal year: 2001, fourth quarter;
Governmentwide delinquency rate excluding DOD: 4.5%;
DOD delinquency rate excluding Army: 8%;
Army delinquency rate: 11%.
Fiscal year: 2002, first quarter;
Governmentwide delinquency rate excluding DOD: 6%;
DOD delinquency rate excluding Army: 9%;
Army delinquency rate: 16%.
Fiscal year: 2002, second quarter;
Governmentwide delinquency rate excluding DOD: 3.5%;
DOD delinquency rate excluding Army: 7%;
Army delinquency rate: 13%.
Source: GAO analysis of General Services Administration data.
[End of figure]
As of March 31, 2002, the Army had the highest delinquency rate in the
federal government. Army‘s delinquency rate over the last 2 years
fluctuated between 10 and 18 percent, and on average was about 5 percent
higher than the other non-Army DOD components and about 7 percent
higher than the federal civilian agencies. [Footnote 5] According to
Army officials, the nature of the Army‘s mission, which includes
extensive travel for extended periods in remote, often hostile
locations around the world, contributes, at least in part, to the
Army‘s high delinquency rate. Appendix III provides a breakdown of the
Army‘s delinquency rates by major command.
Age and Pay Grade Are Correlated to Delinquency and Charge-off
Problems:
A number of factors contributed to the Army‘s high delinquency rates.
Many of the problems related directly to the control environment at the
Army and at the sites we visited. Other problems related to the
implementation of the travel card program and a lack of controls over
travel card use and travel processing. A detailed discussion of the
control environment and specific internal control issues is provided in
the following sections of this report. Without proper management
control, demographics such as the age and pay rates of Army personnel
also contributed to delinquencies and charge-offs.
Our analysis of available data showed that there was a correlation
between certain demographic factors and high delinquency and charge-off
rates. According to Army representatives, and based on our analysis,
most Army travel cardholders responsible for delinquencies and charge-
offs were young (generally married), low- and midlevel enlisted
military personnel (E-1-privates to E-6-staff sergeants), [Footnote 6]
with relatively low incomes and little experience in handling personal
finances. If these individuals get into financial difficulty, they have
fewer resources at their disposal to pay their travel card balances in
full every month.
Figure 2: Army Delinquent and Total Outstanding Travel Card Balances by
Military Grade and Total Civilian Populations as of September 30, 2001:
[See PDF for image]
This figure is a multiple vertical bar graph depicting the following
data:
Grade/classification: E1-E3;
Delinquent: approximately $1 million;
Total outstanding balance: approximately $2 million.
Grade/classification: E4-E6;
Delinquent: approximately $5 million;
Total outstanding balance: approximately $21 million.
Grade/classification: E7-E9;
Delinquent: approximately $2 million;
Total outstanding balance: approximately $11 million.
Grade/classification: O1-O3;
Delinquent: approximately $1 million;
Total outstanding balance: approximately $7 million.
Grade/classification: O4-O6;
Delinquent: approximately $0.5 million;
Total outstanding balance: approximately $7 million.
Grade/classification: O7-O10;
Delinquent: approximately $0 million;
Total outstanding balance: approximately $0.5 million.
Grade/classification: WO1-WO5;
Delinquent: approximately $0 million;
Total outstanding balance: approximately $3 million.
Grade/classification: Civilian;
Delinquent: approximately $2 million;
Total outstanding balance: approximately $22 million.
Source: GAO analysis of Bank of America data.
[End of figure]
In the Army, grades E-1 through E-6 account for about 73 percent of all
military personnel. Consequently, it is not surprising that they have
the highest outstanding travel card balance. As shown in figure 2, the
travel cardholder‘s grade (and associated pay) is a strong predictor of
delinquency problems. We found that the Army‘s delinquency and chargeoff
problems are primarily associated with young, low- and midlevel
enlisted military personnel with basic pay levels ranging from $11,000
to $26,000. Delinquency rates were as high as 40 percent and 25 percent
for E-1 to E-3 and E-4 to E-6, respectively, compared to Army civilians
whose delinquency rate is consistent with rates for federal civilian
agencies, as shown in figure 1.
As shown in figure 3, personnel in grades E-1 through E-6 account for
about $8 million of the $10 million in total Army charge-offs for
fiscal year 2001.
Figure 3: Fiscal Year 2001 Army Charge-offs by Military Grades and
Total Civilian Populations:
[See PDF for image]
This figure is a vertical bar graph depicting the following data:
Grade/classification: E2-E3;
Charge-off amount: approximately $1 million.
Grade/classification: E4-E-6;
Charge-off amount: approximately $7 million.
Grade/classification: E7-E9;
Charge-off amount: approximately $1 million.
Grade/classification: O1-O3;
Charge-off amount: approximately $0.5 million.
Grade/classification: O4-O6;
Charge-off amount: approximately $0.25 million.
Grade/classification: O7-O10;
Charge-off amount: approximately $0 million.
Grade/classification: WO1-WO5;
Charge-off amount: approximately $0.25 million.
Grade/classification: Civilian;
Charge-off amount: approximately $1 million.
Source: GAO analysis of Bank of America data.
[End of figure]
Enlisted personnel in the E-1 to E-6 grade level range in rank from
privates to staff sergeants, respectively, and receive basic pay
ranging from $11,033 to $26,253. Although these basic pay rates are
supplemented with amounts such as housing and food allowances, these
salaries may not permit payment of excessive personal charges on travel
cards. Also, if cardholders in these lower grade levels do not receive
their travel card reimbursements promptly because of either delays in
filing their vouchers or in voucher processing, they may lack the
financial resources to make timely required payments on their travel
card accounts. Further, as discussed later, because of the Army‘s
failure to take any action to exempt personnel with poor credit
histories from required use of travel cards, these low- and midlevel
enlisted military personnel are often issued travel cards even though
they may already be in serious financial trouble and, therefore, may
not have been appropriate credit risks. The failure to provide proper
training and monitoring of travel card use, as well as maintain firm
credit limits, may also have exacerbated the delinquency rates for these
individuals.
High Delinquency and Charge-off Rates Have Resulted in Increased Costs
to the Government:
Although the bank generally absorbs the losses associated with
delinquencies and charge-offs, this problem has significant consequences
to the Army. The high delinquency and charge-off rates resulted in
increased costs in terms of increased fees imposed by Bank of America
following a contract dispute with DOD and the loss of potential refunds
associated with the program. Other costs are real but not easily
measurable, such as the increased administrative burden to the Army
associated with additional resources required to address delinquent and
charged-off accounts. For example, to effectively manage the travel card
program, employees with delinquent accounts must be identified,
counseled, disciplined, and closely monitored. In addition, employees
with financial problems who also have access to sensitive data may pose
a security risk, as discussed later in this report. While most employees
properly manage their travel card accounts and pay their bills on time,
the high delinquency and charge-off rates may undermine the professional
image of the Army and its personnel.
Dispute between Contractor and DOD:
Unexpectedly high defaults by DOD‘s travel cardholders, including the
Army‘s, resulted in a 5-month legal dispute with DOD‘s contractor, Bank
of America, over the continuation of the travel card contract. In 1998,
under the provisions of the General Services Administration‘s (GSA)
master contract with Bank of America, DOD entered into a tailored task
order for Bank of America to provide travel card services for a period
of 2 years, ending November 29, 2000. Under the terms of the task
order, DOD had three 1-year options to unilaterally renew the Bank of
America contract. On September 29, 2000, prior to the expiration of the
initial task order, DOD gave notice to Bank of America that it intended
to exercise its option to extend the task order for an additional year.
In November 2000, Bank of America contested the provisions of the DOD
task order with the GSA contracting officer. Bank of America claimed
that the task order was unprofitable because of required ’contract and
program management policies and procedures“ associated with higher-than-
anticipated credit losses. Bank of America officials estimated that
43,000 DOD employees defaulted on more than $59 million in debts. Bank
of America only agreed to drop its legal dispute with DOD after GSA
renegotiated the terms of the master contract and DOD renegotiated the
related tailored task order for travel card services in April 2001.
Specifically, under the renegotiated master contract and related task
order Bank of America was able to reduce its financial risk by
instituting additional fees, such as higher cash advance and late
payment fees; offsetting credit losses against rebates; facilitating
the collection of delinquent and charged-off amounts through salary and
military retirement pay offset; and participating in the split
disbursement payment process, in which the government pays the bank
directly.
Effect of Increased Fees:
One of the terms of the renegotiation of the task order between Bank of
America and DOD was an increase in travel card cash advance fees from
1.9 percent to 3 percent, or $2, whichever would be the higher fee
amount, effective August 10, 2001. The Army reimburses cash advance
fees [Footnote 7] incurred by a traveler while on authorized travel. We
estimate that this contract modification will result in approximately
$1.4 million of increased costs to the Army each year for the
reimbursement of cash advance fees. Our estimate was made by applying
the increase in the advance fees to cash advances made during fiscal
year 2001. Other fee increases agreed to in the renegotiation increased
the cost to the Army, such as the fee for expedited travel card
issuance, and to delinquent cardholders, such as the increase in late
fees from $20 to $29.
Delinquent Account Payment Affects Rebates to the Army:
The GSA master contract modification also changed the rebate
calculation, making it imperative that the Army improve its payment
rates to receive the full benefits of the program. Under the GSA master
contract, credit card companies are required to pay a quarterly rebate,
also known as a refund, to agencies and GSA as a result of a
combination of both individually billed and centrally billed card
usage. The rebate to the agency is reduced, or eliminated, if
significant numbers of an agency‘s individual cardholders do not pay
their accounts timely. Specifically, credit losses or balances that
reach 180 calendar days past the closing date on the statement of
account reduce the rebate amounts. Effective January 2001, one of the
terms of the contract modification changed the way that rebates are
calculated and how credit losses are handled. If the credit loss of an
agency‘s individually billed travel card accounts exceeds 30 basis
points”or 30 one-hundredths of a percent (.003)”of net sales [Footnote
8] on the card, the agency is assessed a credit loss fee, or rebate
offset, against the rebate associated with both individually billed and
centrally billed travel card accounts.
This credit loss fee, or rebate offset, which resulted solely from
individually billed account credit losses, significantly affected the
amount of rebate that the Army received as a result of combined
individually and centrally billed net sales in fiscal year 2001. The
Army collected approximately $635,000 of the $3 million in rebates for
fiscal year 2001 that we estimated that the Army would have received,
based on fiscal year 2001 dollar volume, had individually billed
account payments been timely. Prior to the change in the way the
rebates were calculated, in fiscal year 2000, the Army received
approximately $2.7 million in rebates from the travel card program, net
of $450,000 that was paid to GSA for an industrial funding fee (contract
administration fee).
GSA receives a contract administration fee of four basis points or four
one-hundredths of a percent (.0004)”of net sales on both the
individually and centrally billed accounts. For fiscal year 2001, GSA
received approximately $485,000 for the Army‘s net sales. Bank of
America pays this fee to GSA regardless of whether the agency or
service receives any rebates. For example, for the last three quarters
of fiscal year 2001, the Army had negative rebates after the credit
loss fees were deducted and GSA received approximately $386,000 from
Bank of America for those three quarters.
The negative net rebates are carried over to subsequent quarters until
they can be offset by positive net rebates that the agency earns.
Army and DOD Have Taken Some Steps to Reduce Delinquencies and
Chargeoffs, but Additional Actions Are Needed:
The Army has taken a number of positive actions to address its high
delinquency and charge-off rates, and results from the first half of
fiscal year 2002 show a significant drop in charged-off accounts. Most
of this reduction may be attributed to a salary and military retirement
payment offset program”similar to garnishment. This program began to
offset amounts from delinquent cardholders‘ salaries and military
retirement benefit payments in November 2001. Other Army actions
include a limited split disbursement payment plan, in which DFAS
disburses a portion of a travel reimbursement directly to the bank
(instead of disbursing the entire amount of the reimbursement to the
cardholder), and increased management attention and focus on the
delinquency issue. The Army‘s actions, however, primarily address the
symptoms or ’back-end“ result of delinquency and charge-offs after they
have already occurred. As noted in the remaining sections of this
report, the Army has significant control weaknesses, particularly with
respect to the front-end management of the travel card program, such as
issuing the cards and overseeing the proper use of the cards, which it
has not yet effectively addressed.
Charge-offs Have Decreased:
As shown in figure 4, the Army‘s charge-offs have decreased
substantially.
Figure 4: Army Travel Card Charge-off and Recovery History from October
1, 2000, to March 31, 2002:
Fiscal year: 2001, first quarter;
Charge-off: approximately $2.75 million;
Charge-off recoveries: approximately $1.0 million.
Fiscal year: 2001, second quarter;
Charge-off: approximately $3.6 million;
Charge-off recoveries: approximately $1.75 million.
Fiscal year: 2001, third quarter;
Charge-off: approximately $2.25 million;
Charge-off recoveries: approximately $1.5 million.
Fiscal year: 2001, fourth quarter;
Charge-off: approximately $1.6 million;
Charge-off recoveries: approximately $1.0 million.
Fiscal year: 2002, first quarter;
Charge-off: approximately $0.5 million;
Charge-off recoveries: approximately $0.8 million.
Fiscal year: 2002, second quarter;
Charge-off: approximately $0.2 million;
Charge-off recoveries: approximately $1.6 million.
Source: GAO analysis of Bank of America data.
[End of figure]
Specifically, although Army delinquency rates have not changed
substantially in the last 2 years, the total dollars charged off by
Bank of America have decreased for each of the last four quarters.
Figure 4 also shows that recoveries of charge-offs increased markedly
in the second quarter of fiscal year 2002. The primary causes of the
decrease in chargeoffs and recent increase in recoveries are DOD‘s new
salary and military retirement benefit offset program as well as other
positive steps, including encouraging the use of split disbursements
and increased management focus and attention.
Salary and Military Retirement Offset Program:
Starting in fiscal year 2002, DOD began to offset the salary of certain
civilian and military employees and retired military members for all
services, including the Army, for the amounts delinquent or charged off
on travel card accounts. The DOD salary offset program [Footnote 9]
implements a provision of the Travel and Transportation Reform Act of
1998 (TTRA) [Footnote 10] that allows any federal agency, upon written
request from the travel card contractor, to collect by deduction from
the amount of pay owed to an employee (or military member) any amount
of funds the employee or military member owes to the contractor, as a
result of delinquencies not disputed by the employee, on his or her
travel card. [Footnote 11]
With the task order modification, DOD agreed with Bank of America to
implement an offset program. From April 2001 through August 2001, DOD
worked with the Bank of America to establish protocols and to set up the
program. In August 2001, Bank of America sent demand letters to
cardholders with accounts over 90 days delinquent. DFAS processed the
initial offsets of delinquent accounts in October 2001 in the various
DOD pay systems. The first deduction was made from the November pay
period. Collections were paid to Bank of America starting in early
December 2001. Bank of America can also use the offset program to
recover amounts that were previously charged off. January 2002 was the
first month in which Bank of America requested offsets for charged-off
accounts.
The process takes approximately 2 months from initiating the offset
through payment to the bank. Specifically, after 90 days delinquency,
Bank of America sends a demand letter to the individual cardholder that
requests payment in full within 30 days. The demand letter provides for
initiating offset if payment is not made in full within 30 days. The
cardholder may negotiate an installment agreement or may dispute the
charges with the bank. The cardholder has a right to review all
records, such as invoices, and to request a hearing if he or she is not
satisfied with the bank‘s disposition of the dispute.
After the 30 days have passed, if payment is not made and the cardholder
does not dispute the debt, the bank includes the account in the list of
accounts requested for offset. Individuals in the following categories
cannot be accepted for offset.
* Civilian employees in bargaining units that have not agreed to offset
cannot be accepted. According to a DFAS official, as of the end of April
2002, 789 of 1,227 DOD bargaining units have agreed.
* Individuals with debts to the federal government or other garnishments
already being offset at 15 percent of disposable pay are considered to
be in protected status and are not eligible for the offset program.
* Individuals who cannot be located in the various payroll and military
retirement (active, reserve, retired military, or civilian) systems
cannot be accepted for offset.
* Civilian retirees are not currently subject to offset. The authorizing
statutes for both the Civil Service Retirement System [Footnote 12] and
the Federal Employee‘s Retirement System [Footnote 13] specify that
retirement benefits may be offset only to the extent expressly
authorized by federal statutes. TTRA, Section 2, provides authority to
offset salaries of ’employees“ of agencies but does not provide such
authority for civilian employee retiree annuitants.
Once an individual is accepted for offset, the related debt is
established in the respective pay system and DFAS can deduct up to 15
percent of disposable pay. Disposable pay is defined in GSA‘s Federal
Travel Regulation [Footnote 14] as an employee‘s compensation remaining
after the deduction from an employee‘s earnings of any amounts required
by law to be withheld (e.g., tax withholdings and garnishments). The
amounts collected are paid to the bank monthly for military personnel
and retirees and biweekly for civilian personnel.
According to DFAS, from October 2001 through April 2002, Bank of
America referred 49,014 DOD-wide cases with debt of $72.4 million to
DOD for offset. DOD accepted and started offset for 73 percent of the
cases and 68 percent of the debt amounts referred. The number and debt
amount of Army cases forwarded by Bank of America were not available.
From November 2001 through April 2002, DFAS collected $6.3 million from
Army military and retired military members through the offset program.
DFAS was unable to provide the amount of collections for civilian
employees by military service. However, the amount of total collections
from November 2001 through April 2002 for civilian employees of DOD
services and agencies was about $702,000.
Split Disbursement Payment Process:
DOD has recently encouraged cardholders to make greater use of the split
disbursement payment process. This payment method, by which cardholders
elect to have all or part of their reimbursement sent directly to Bank
of America, has the potential to significantly reduce delinquencies.
Split disbursements are a standard practice of many private sector
companies. DOD reported that for about 27 percent of the travel vouchers
paid in April 2002 at one of its major disbursing centers, cardholders
elected this payment option.
However, the use of the split disbursement payment process by employees
is currently voluntary, as shown by DOD‘s low participation rate. The
defense authorization bill for fiscal year 2003 passed by the Senate
would change this by authorizing the Secretary of Defense to require
that any part of an employee‘s travel allowance be disbursed directly
to the employee‘s travel card issuer for payment of official travel
expenses. The defense authorization bill for fiscal year 2003 passed by
the House does not contain comparable authority. As of early October
2002, the bill (H.R. 4546) was in conference.
Management Focus and Attention:
In response to the excessive delinquency rate, in October 2000, the Vice
Chief of Staff of the Army issued a directive to cut the Army‘s
delinquencies by 50 percent by the end of March 2001. Further, the Vice
Chief of Staff established a goal of a delinquency rate of no more than
4 percent of active cardholders as soon as possible and ordered
commanders throughout the Army to provide additional attention to the
government travel card program. [Footnote 15] Army officials emphasized
setting goals, monitoring results, providing feedback, providing
training, and coordinating efforts with DOD and Bank of America. We
have also seen increased management attention and focus on reducing
delinquencies at the Army command level. For example, commanders at
both Ft. Bragg locations we audited told us they hold monthly meetings
to discuss the status of any outstanding delinquencies and related
corrective actions.
Further, the DOD Under Secretary of Defense (Comptroller) created a
DOD-wide Charge Card Task Force in March 2002 to address management
issues related to DOD‘s purchase and travel card programs. The task
force issued its final report on June 27, 2002. We have reviewed the
report and believe that many of the actions proposed by the task force
will improve the controls over the travel card program. For example, as
previously discussed, we support the provision of the fiscal year 2003
defense authorization bill that would authorize DOD to require the use
of the split disbursement payment process. If enacted and required DOD-
wide, this authority has the potential to significantly reduce DOD‘s
and the Army‘s delinquency rates. Other important task force
recommendations include canceling inactive accounts and expanding the
salary offset program. However, actions to implement additional ’front-
end“ or preventive controls, such as strengthening the critical role of
the APCs and denying cards to individuals with prior credit problems,
were not addressed in the report. We believe that strong preventive
controls will be critical if DOD is to effectively address the high
delinquency rates and charge-offs, as well as the potentially
fraudulent and abusive activity discussed in this report.
Potentially Fraudulent and Abusive Travel Card Activity:
Our review identified numerous instances of potentially fraudulent and
abusive activity associated with the Army‘s travel card program during
fiscal year 2001. Failure to implement controls to reasonably prevent
such transactions can increase the Army‘s vulnerability to additional
delinquencies and charge-offs. As discussed previously, about $34
million associated with over 23,000 Army accounts was charged off since
the inception of the travel card program with Bank of America.
We considered any scheme or pattern of activity related to the use of
the travel card, in apparent violation of federal or state criminal
code, as a potentially fraudulent activity. For purposes of this
report, the only cases we characterized as potentially fraudulent were
those where cardholders wrote three or more NSF checks or wrote checks
on closed accounts to pay their Bank of America bills. These cases are
potentially fraudulent because they indicate a pattern of activity in
violation of one or more elements of federal or state criminal codes.
In addition, some of the travel card activity that we categorized as
abusive may be fraudulent if it can be established that the cardholder
violated any element of federal or state criminal codes.
For purposes of this report, we considered abusive travel card activity
to include (1) personal use of the cards”any use other than for official
government travel”regardless of whether the cardholders paid the bills
and (2) cases in which cardholders were reimbursed for official travel
and then did not pay Bank of America and thus benefited personally.
Potentially Fraudulent Transactions:
Our review identified numerous examples of potentially fraudulent
activity where the cardholders wrote checks against closed checking
accounts or repeatedly wrote NSF, or ’bounced,“ checks as payment for
their travel card accounts. Knowingly writing checks against closed
accounts or writing three or more NSF checks may be bank fraud under 18
U.S.C. 1344. [Footnote 16] Further, it is a violation of the Uniform
Code of Military Justice (UCMJ) [Footnote 17] article 123a when a
soldier makes, draws, or utters (verbally authorizes) a check, draft,
or order without sufficient funds and does so with intent to defraud.
During fiscal year 2001, of the over 4,200 account holders who wrote
NSF checks, close to 1,200 Army personnel had their accounts charged
off. In the same period, more than 200 personnel whose accounts were
eventually charged off may have committed bank fraud by writing three
or more NSF checks to Bank of America. Table 2 shows the 10 cases we
selected for review where the cardholders wrote three or more NSF
checks to Bank of America, and whose accounts were charged off due in
part to repeated use of NSF checks.
Table 2: Examples of NSF Checks Written on Charged-off Accounts:
Cardholder: 1;
Total amount (number) of NSF checks in FY 2001: $269,301 (86);
Total amount charged off: $35,883;
Grade: E-6;
Unit: Ft. Jackson
Credit history/problems: Criminal conviction for writing NSF checks and
serious credit card delinquency[A] prior to card issuance.
Documented follow-up/disciplinary action: Undergoing court-martial.
Cardholder: 2;
Total amount (number) of NSF checks in FY 2001: $12,327 (8);
Total amount charged off: $7,942;
Grade: O-3;
Unit: Ft. Hood;
Credit history/problems: None;
Documented follow-up/disciplinary action: None.
Cardholder: 3;
Total amount (number) of NSF checks in FY 2001: $7,737 (4);
Total amount charged off: $3,257;
Grade: GS-13;
Unit: Pentagon;
Credit history/problems: Charge-offs and referrals to collection
agencies[B] and serious credit card delinquencies prior to card
issuance.
Documented follow-up/disciplinary action: None. Bank of America account
paid in full after we identified it as a charge-off.
Cardholder: 4;
Total amount (number) of NSF checks in FY 2001: $6,099 (3);
Total amount charged off: $7,373;
Grade: GS-12;
Unit: Ft. McPherson;
Credit history/problems: Serious credit card delinquencies prior to card
issuance. Mortgage foreclosure and other charge-offs and referrals to
collection agencies since card issuance;
Documented follow-up/disciplinary action: Counseled. Salary offset
program.
Cardholder: 5;
Total amount (number) of NSF checks in FY 2001: $3,995 (3);
Total amount charged off: $5,259;
Grade: E-7;
Unit: West Virginia ROTC;
Credit history/problems: Bankruptcy judgment, automobile repossession,
and serious delinquencies prior to card issuance;
Documented follow-up/disciplinary action: Letter of reprimand. Salary
offset program.
Cardholder: 6;
Total amount (number) of NSF checks in FY 2001: $4,845 (11);
Total amount charged off: $3,380;
Grade: E-6;
Unit: Ft. Hood;
Credit history/problems: Referrals to collection agencies prior to card
issuance;
Documented follow-up/disciplinary action: None.
Cardholder: 7;
Total amount (number) of NSF checks in FY 2001: $2,709 (3);
Total amount charged off: $7,846;
Grade: E-4;
Unit: Ft. Drum/Ft. Lewis;
Credit history/problems: Prior charge-off and referral to collection
agency;
Documented follow-up/disciplinary action: Administrative discharge for
misconduct directly related to misuse of the travel card.
Cardholder: 8;
Total amount (number) of NSF checks in FY 2001: $900 (5);
Total amount charged off: $3,104;
Grade: E-3;
Unit: Ft. Drum;
Credit history/problems: None prior to travel card issuance. Automobile
repossession and delinquencies since 2000;
Documented follow-up/disciplinary action: None. Honorable discharge.
Cardholder: 9;
Total amount (number) of NSF checks in FY 2001: $840 (3);
Total amount charged off: $2,137;
Grade: E-7;
Unit: Army National Guard Utah;
Credit history/problems: Serious delinquencies prior to card issuance;
Documented follow-up/disciplinary action: None. Salary offset program.
Cardholder: 10;
Total amount (number) of NSF checks in FY 2001: $263 (3);
Total amount charged off: $2,763;
Grade: GS-5;
Unit: U.S. Army Europe;
Credit history/problems: Referral to collection agency and serious
delinquency before card issuance;
Documented follow-up/disciplinary action: Counseled. Salary offset
program.
[A] Serious delinquency is defined as 90 or more days past due on
payment submission.
[B] These included referrals to collection agencies for unpaid bills
from utility companies, cable companies, and department stores.
Source: GAO analysis.
[End of table]
Eight of the 10 cardholders included in table 2 had significant credit
problems prior to card issuance, such as charged-off credit card
accounts and automobile loans; mortgage foreclosures; bankruptcies;
serious delinquencies; referrals to collection agencies for unpaid
utility bills, medical fees, and department store accounts; and, in one
case, prior criminal convictions for writing NSF checks. The remaining
two had similar credit problems subsequent to issuance of Bank of
America travel cards. These examples are illustrative of many of the
breakdowns in the management and oversight over the Army travel card
program, as discussed in the following sections of this report. The
following provides detailed information on some of these cases.
* Cardholder #1 was a staff sergeant who wrote 86 NSF checks totaling
almost $270,000 for payment on his Bank of America travel card account
for charges incurred when the cardholder was not on official government
travel. This cardholder had a previous criminal record for writing NSF
checks. The cardholder also had numerous other financial problems,
including mortgage foreclosure and claims discharged in December 2001
for Chapter 7 bankruptcy. Among the claims discharged in bankruptcy was
a $2,199 claim on the cardholder‘s previous government travel card
issued by American Express and a $114,750 real estate loan. This
cardholder applied for and received a new Social Security number when
he legally changed his name in 1998, and since then has had two Social
Security numbers”one under each name. The individual authorized a
credit check at the time of his application for a government travel
card from Bank of America. However, it appeared that the credit check
was not performed and the individual was issued a standard card with a
$10,000 limit in April 1999, instead of a restricted card with a $2,500
credit limit.
From July 1999 through November 2000, the cardholder wrote
approximately 86 NSF checks”some on closed or invalid accounts”to Bank
of America. Industry regulations require that an account be credited
immediately upon receipt of a check. Consequently, when Bank of America
posted the NSF checks, the account appeared to have been paid, which
provided credit to the cardholder to make additional purchases. Thus,
by writing successively larger NSF checks, which Bank of America
credited to his travel card account, the staff sergeant was able to, in
effect, successively increase his credit limit to over $35,000”a
practice known as ’boosting.“ He used each of these successive
increases in his effective credit limit to charge additional items on
his travel card. Despite the 86 NSF checks and associated increases in
the cumulative unpaid balance on the cardholder‘s government travel
card account, records we obtained indicate that Bank of America did not
close this individual‘s account until February 2001, when the account
was charged off. The cardholder was undergoing court-martial in late
May 2002 for NSF checks related to his Bank of America account as well
as to the Army and Air Force Exchange Services. Bank of America
acknowledged that it erred in not closing this account sooner. This has
resulted in the bank changing its policy to require accounts to be
closed when a cardholder has written three NSF checks.
* Cardholder #3 currently works at the Pentagon as a GS-13 employee on
a classified program. Because of her position, the cardholder has a top-
secret clearance. Prior to applying for the Bank of America travel card,
the employee had credit problems, including several charged-off
accounts. Because the employee did not authorize a credit check on her
travel card application, she was given a restricted card with a credit
limit of $2,500, which should have been issued in ’inactive“ status and
only activated when needed for travel. However, Bank of America records
showed that in July 2000, immediately after receiving the travel card,
the employee used the card to pay for a personal move and other charges
totaling more than $3,600”more than $1,000 in excess of the credit
limit on restricted travel cards. The cognizant APC told us that while
a credit check authorization should have been done for the cardholder
to exceed the $2,500 credit limit, she could not confirm that one was
done in this case.
In addition, from October 2000 through September 2001, the employee
wrote four NSF checks totaling more than $7,700 to Bank of America.
The cardholder‘s account had an unpaid balance of $3,257 at the time it
was charged off in September 2001. Although the cardholder had a
restricted card that should have been activated only for the first
official travel, the fact that she was able to use the card immediately
upon issuance while not on travel indicated that Bank of America issued
the card in an ’active“ status. Shortly after our investigators
contacted this cardholder, she paid her account balance in full.
We also found that no disciplinary action had been taken against this
individual. The two APCs were not aware that the employee had problems
with her account, much less that the account was charged off, until
contacted by our investigators. The APCs told us they had little time
to devote to reviewing the over 500 individual accounts for which they
had oversight responsibilities assigned as a collateral duty. In
addition, while, according to a Bank of America official, APCs have had
access to NSF check information in its database since 2000, one of the
APCs told us she only recently received training on how to identify
delinquent accounts in Bank of America‘s database.
* Cardholder #6 exhibited a pattern of writing NSF checks about once a
month. During fiscal year 2001, the cardholder wrote 11 NSF checks to
Bank of America that ranged from $250 to $630. Some checks were written
to pay charges that appeared to be for personal travel. The
cardholder‘s account balance of $3,380 was charged off in February
2002. Further, when the cardholder was assigned from Ft. Hood, Texas,
to the U.S. Army Recruiting Command in Tampa, Florida, her travel card
account was not transferred and assigned to the APC responsible for
travel card oversight in her new unit. Consequently, the APC in Florida
was not aware of the cardholder‘s problems because the cardholder did
not appear in any of the Recruiting Command‘s delinquency reports.
Abusive Travel Card Activity:
We found instances of abusive travel card activity by Army cardholders
that covered charges for a wide variety of personal goods and services,
including cruises; sports and music event tickets; personal clothing
items; casino and Internet gambling; transactions to obtain cash at
adult entertainment establishments; and, in one case, the purchase of a
used automobile. There should be no misunderstanding by Army personnel
that personal use of the card is not permitted. The standard government
travel card used by most Army personnel is clearly marked, ’For Official
Government Travel Only“ on the face of the card.
In addition, all Army travel card applicants sign a statement that
provides, in part, that ’I also understand that I am authorized to use
the card only for those necessary and reasonable expenses incurred by
me for official travel.“ As part of our statistical sampling tests of
travel card activity at four Army locations, we estimated that 15
percent to 45 percent of the fiscal year 2001 travel card transactions
at those locations appeared to be for charges not related to official
travel and, therefore, were abusive. Further, abusive use of the card
related to failure to pay Bank of America was the result of (1)
cardholders who were reimbursed for official travel and then did not
pay Bank of America and (2) cardholders who used the card for personal
charges and failed to pay Bank of America.
Travel Card Abuse due to Failure to Pay Bank of America Charges:
Our work at four case study sites and our Army-wide data mining
identified numerous examples of abusive travel card use where
cardholders failed to pay their travel card bills. This abusive
activity included (1) authorized transactions incurred in conjunction
with approved travel orders where the cardholders received
reimbursement but did not pay the bills, leading to charge off of the
cardholders‘ accounts, or (2) transactions incurred by cardholders that
were not associated with approved travel orders where unpaid accounts
were also charged off. In all cases, we found that ineffective
monitoring contributed to charge-offs. Specifically, many APCs,
commanders, and supervisors did not effectively monitor travel card
usage or address delinquencies timely. We found little documentation
indicating that the APCs, commanders, and supervisors were aware of the
problems with individual cardholders, conducted follow-up, and took
appropriate disciplinary actions. Table 3 provides examples of the two
types of abusive transactions related to nonpayment and the related
follow-up and disciplinary actions.
Table 3: Examples of Abusive Activity Where the Account Was Charged
Off:
Cardholder: 1[A];
Grade: GS-12;
Unit: Ft. McPherson;
Total charged-off amount: $7,373;
Transactions contributing to charge-off: Used reimbursed travel money
for closing costs on a house. Wrote NSF checks;
Credit history/problems: Serious credit card delinquencies prior to
travel card issuance; mortgage foreclosure and other charge-offs and
referrals to collection agencies since 2000;
Documented follow-up/disciplinary action: Counseled; salary offset.
Cardholder: 2[B];
Grade: E-7;
Unit: ROTC;
Total charged-off amount: $5,259;
Transactions contributing to charge-off: $4,100 to Budget-Rent-
A-Car for purchase of a used automobile;
Credit history/problems: Bankruptcy judgment, automobile repossession,
and serious delinquencies prior to travel card issuance;
Documented follow-up/disciplinary action: Letter of reprimand. Salary
offset.
Cardholder: 3;
Grade: E-6;
Unit: Army Forces Command;
Total charged-off amount: $2,278;
Transactions contributing to charge-off: $110 in ’club“ cash from
Spearmint Rhino Adult Cabaret;
Credit history/problems: Serious credit card and other delinquencies
prior to travel card issuance;
Documented follow-up/disciplinary action: None.
Cardholder: 4;
Grade: E-4;
Unit: Army Reserve Command;
Total charged-off amount: $1,253;
Transactions contributing to charge-off: $500 to Cryptologic, Inc. by
spouse for Internet gambling;
Credit history/problems: Numerous referrals to collection agencies
prior to travel card issuance;
Documented follow-up/disciplinary action: None.
Cardholder: 5;
Grade: O-5;
Unit: California National Guard[C];
Total charged-off amount: $5,419;
Transactions contributing to charge-off: Did not use reimbursement to
pay travel card charges;
Credit history/problems: Serious delinquencies, including delinquency
on the American Express government travel card, prior to travel card
issuance;
Documented follow-up/disciplinary action: Salary offset.[C]
Cardholder: 6;
Grade: E-8;
Unit: Ft. Bragg, Special Operations;
Total charged-off amount: $4,704;
Transactions contributing to charge-off: ATM withdrawals in hometown
area without travel order;
Credit history/problems: Serious delinquency prior to travel card
issuance;
Documented follow-up/disciplinary action: Verbal counseling.
Cardholder: 7;
Grade: E-4;
Unit: Ft. Bragg, Forces Command;
Total charged-off amount: $8,709;
Transactions contributing to charge-off: Numerous charges at Wal-Mart
Supercenter;
Credit history/problems: Serious delinquency prior to travel card
issuance;
Documented follow-up/disciplinary action: None.
Cardholder: 8;
Grade: E-3;
Unit: Ft. Drum, Forces Command;
Total charged-off amount: $1,058;
Transactions contributing to charge-off: Cash from Dream Girls Escort
Service;
Credit history/problems: None prior. Serious credit card delinquencies
in 2002;
Documented follow-up/disciplinary action: None.
Cardholder: 9;
Grade: E-4;
Unit: Ft. Drum, Forces Command;
Total charged-off amount: $10,029;
Transactions contributing to charge-off: Numerous personal charges,
including casino gambling;
Credit history/problems: Referral to collection agency prior to travel
card issuance;
Documented follow-up/disciplinary action: None.
Cardholder: 10;
Grade: E-4;
Unit: Ft. Drum, Forces Command;
Total charged-off amount: $7,643;
Transactions contributing to charge-off: Numerous charges at local
restaurants, gas stations, grocery stores, and hotels in vicinity of
Ft. Drum;
Credit history/problems: Referrals to collection agencies prior to
travel card issuance;
Documented follow-up/disciplinary action: None.
[A] Same as NSF case #4.
[B] Same as NSF case #5.
[C] See disciplinary action section for a discussion of this
cardholder.
Source: GAO analysis.
[End of table]
Similar to individuals who wrote NSF checks, many of the 105 cardholders
that we reviewed whose accounts were charged off had significant prior
credit problems, such as charged-off credit card account balances and
automobile loan defaults, and referrals to collection agencies. Many of
these individuals experienced further credit problems, including
mortgage foreclosure, after issuance of the government travel card. As
shown in table 4, some charged-off accounts resulted from the use of
the card for transactions that were not proper travel expenses covered
by valid travel orders, while others resulted from official travel
expenses that were reimbursed but the cardholders failed to pay the
bills. The magnitude and range of abusive transactions reflect the poor
control environment and other internal control weaknesses discussed
later in this report. The following include details of some of these.
* Cardholder #1 was a GS-12 employee in Army Forces Command at Ft.
McPherson, Georgia. In August 2000, the cardholder used the card to pay
for authorized charges associated with a permanent change of station
move from Qatar to Ft. McPherson. The cardholder did not elect split
disbursement of his travel reimbursement between himself and Bank of
America when filing travel vouchers. Thus, the entire reimbursement for
travel expenses was electronically deposited in the cardholder‘s
checking account. The cardholder did not pay his travel card bill, but
instead used the reimbursement to, among other things, pay the closing
costs on the purchase of a home. The cardholder was counseled by the
APC and his supervisors after his travel card account became
delinquent, but no disciplinary action was taken. The cardholder is now
in the salary offset program. The cardholder informed us that he was
briefed, at the time of card issuance, of his responsibility to make
timely payments to Bank of America in payment of expenses claimed on
approved travel vouchers.
* Cardholder #2 was a sergeant first class (E-7) with an Army Reserve
Officers‘ Training Corps unit. Army investigative records showed that in
January 2001, the cardholder‘s spouse used his government travel card
to make two payments of $2,050 each to Budget Rent-A-Car for the
purchase of a used automobile. The spouse was able to use the travel
card because of the general military power of attorney provided to her
by the sergeant. In addition, several automated teller machine (ATM)
withdrawals were made using the card at times when the sergeant was not
on official travel status. The cardholder received a letter of
reprimand and subsequently retired. In February 2002, after his account
was charged off, the cardholder‘s account was put into the offset
program and a portion of his annuity automatically withheld for
repayment to Bank of America.
* Cardholder #9 was an Army specialist (E-4) at Ft. Drum and received a
total of three travel card accounts. Shortly after receiving his first
card he incurred over $5,000 in personal charges, including casino
gambling. He then notified Bank of America that his wallet, which
contained his government travel card and driver‘s license, had been
stolen and that the charges on the card were not made by him and
therefore were fraudulent charges. Bank of America closed this account,
charged off the amount as a fraud loss, and issued the soldier a second
account. The soldier then incurred over $8,000 in personal charges for
casino gambling and notified Bank of America that this card was lost.
Bank of America again closed this account and issued a third account to
the soldier. The soldier incurred approximately $5,000 in personal
charges on this account, including casino gambling. Bank of America
personnel began to question the soldier regarding the transactions made
on both the first and second accounts because both accounts showed
transactions at the same casino and the signatures on the charge
receipts were similar to the soldier‘s signature. As of April 17, 2002,
the soldier‘s travel card account was in charge-off status, with an
unpaid balance of $10,029. The soldier told us that he falsified the
report to Bank of America that his first card was stolen and that the
charges were fraudulent because he could not pay the bill. He also told
us that he falsely reported his second card lost again because he could
not pay the bill. In addition, the soldier stated that he made personal
charges on the third card, including casino gambling, in hopes of
winning enough to pay the bill. In October 2000, the soldier received
an Article 15 for misuse of his travel cards. He received a reduction
in grade from an E-4 to an E-1, forfeited a half-month‘s pay, and was
to serve 45 days of extra duty beyond his November 30, 2000, discharge
date. The soldier informed us that the Commander waived the 45 days and
he received an honorable discharge as an E-4. In February 2002, the
Army enrolled this soldier in the offset program. The soldier is
currently an E-5 with the Pennsylvania National Guard. According to the
National Guard, the Army‘ official personnel file for this soldier
contains no information concerning any adverse action.
* Cardholder #10, another Army specialist (E-4) at Ft. Drum used his
government travel card to make numerous purchases of personal items
totaling $2,841 over a 3-month period from May through July 2000. The
personal items included 38 restaurant charges, 37 charges at gas
stations, 14 charges at grocery stores, and 5 hotel charges in the
vicinity of Ft. Drum. The specialist, who had received a $10,000 credit
limit on his government travel card, had an unpaid balance of $7,643 as
of December 11, 2000. As of April 17, 2002, the travel card was in
chargeoff status and the specialist no longer worked for the Army. Our
review of the soldier‘s credit report showed that he received his
government travel card from Bank of America in May 1999. Since that
time, the soldier opened numerous credit card and other consumer
accounts with other vendors, almost all of which had unpaid balances
and were in collection status or had been charged off. We found no
evidence that the APC detected the soldier‘s personal use of the
government travel card. As a result, the Army could not take timely
action to cancel or suspend the soldier‘s travel card account. We also
found no evidence that disciplinary action was taken to address
personal use of the travel card or the unpaid debt once the Army became
aware of the problem.
In contrast to the charged-off accounts discussed above, we found some
instances where the failure to pay the travel card bill was
attributable to the delays and errors in processing vouchers and
reimbursing the travelers.
This issue is discussed in more detail in a later section on testing of
key internal controls.
Travel Card Abuse Where Cardholder Paid Bank of America:
We also found instances in which cardholders used their travel cards for
personal purposes, but paid their travel card bills when they became
due. These cardholders benefited by, in effect, getting interest-free
loans. Personal use of the card increases the risk of charge-offs
related to abusive purchases, which are costly to the government and
the taxpayer. In addition, the high rate of abuse with respect to
travel card activity is indicative of the weak internal control
environment and the failure of the APCs to monitor credit card
activities, as discussed later in this report.
Table 4 provides examples of the types of abusive charges we found
during our review.
Table 4: Examples of Abusive Activity Where the Cardholders Paid the
Bill:
Cardholder: 1;
Unit: U.S. Army Europe Allied Command;
Grade: E-5;
Vendor: Celebrity Cruises;
Amount: $5,192;
Nature of transaction: Reservations for 4 on the Millennium cruise
ship, which sails to the Bahamas and Caribbean;
Documented disciplinary action: None.
Cardholder: 2;
Unit: U.S. Army Reserve Command'
Grade: O-5;
Vendor: Purdue University Rose Bowl Tour;
Amount: $3,998;
Nature of transaction: Accommodations for two for 4 nights during the
Rose Bowl. Package includes pep rally, New Year‘s Eve event, and premium
seats to the parade;
Documented disciplinary action: None.
Cardholder: 3;
Unit: U.S. Army Reserve Command;
Grade: O-2;
Vendor: Louisiana Superdome;
Amount: $1,395;
Nature of transaction: 45 tickets to the Essence Music festival on July
5, 2001;
Documented disciplinary action: None.
Cardholder: 4;
Unit: Army Corps of Engineers
Grade: GM-15[A];
Vendor: Georgetown Prep Tennis Club;
Amount: $826;
Nature of transaction: Tennis club membership;
Documented disciplinary action: None.
Cardholder: 5;
Unit: California National Guard;
Grade: E-4;
Vendor: GEICO;
Amount: $491;
Nature of transaction: Automobile insurance;
Documented disciplinary action: None.
Cardholder: 6;
Unit: Ft. Bragg, Special Operations;
Grade: E-7;
Vendor: Russell‘s For Men;
Amount: $191;
Nature of transaction: Purchases made through a toll-free number for
’fine gifts for men;“
Documented disciplinary action: None.
Cardholder: 7;
Unit: Ft. Bragg, Forces Command;
Grade: E-5;
Vendor: Victoria‘s Secret;
Amount: $172;
Nature of transaction: Women‘s lingerie;
Documented disciplinary action: None.
Cardholder: 8;
Unit: Ft. Bragg, Forces Command;
Grade: E-4;
Vendor: 1-800-Contacts;
Amount: $80;
Nature of transaction: Contacts and contact solutions;
Documented disciplinary action: None.
Cardholder: 9;
Unit: Ft. Drum, Forces Command;
Grade: E-5;
Vendor: Gateway Direct;
Amount: $392;
Nature of transaction: Computer equipment;
Documented disciplinary action: None.
Cardholder: 10;
Unit: Ft. Drum, Forces Command;
Grade: E-6;
Vendor: Sunshine Entertainment;
Amount: $275;
Nature of transaction: Personal escort service;
Documented disciplinary action: None.
[A] Equivalent to GS-15.
Source: GAO analysis.
[End of table]
As shown in table 4, cardholders used their travel cards for a wide
variety of personal goods or services, including cruises, sporting and
music event tickets, membership dues, and personal clothing items. For
example, we were able to determine that, during fiscal year 2001,
approximately $45,000 was spent Army-wide to purchase cruise packages
or to pay for a variety of activities or services on cruise ships.
Some individuals who abused their travel card privileges held positions
where they may have been responsible for taking appropriate disciplinary
action with respect to travel card abuse by personnel within their
commands. For example, a Lieutenant Colonel used his travel card to
purchase accommodations and tickets to attend the Tournament of Roses
in Pasadena, California, as shown in example 2 in table 4.
Abusive Travel Card Use at Adult Entertainment Establishments:
We also found instances of abusive travel card activity in which Army
personnel used travel cards to obtain cash at establishments, such as
’gentlemen‘s clubs,“ instead of following prescribed ATM procedures.
Specifically, we found cases in which these clubs provided adult
entertainment services and helped the cardholders circumvent travel card
ATM cash withdrawal limits, by supplying cardholders with actual cash or
’club cash“ for a 10 percent fee. We were able to identify about 200
Army travel cardholders who during fiscal year 2001 charged almost
$38,000 on their government travel cards at these establishments. Some
of these individuals also did not pay their related travel card bills,
and their travel card accounts were charged off.
DOD‘s travel card policy sets limits on the amount of cash a cardholder
can withdraw using ATMs. Typically, the ATM limit is set at $500 for a
standard card and $200 for a restricted card, meaning that in any 1-
month cycle, Army cardholders could only obtain cash up to the limit
specified on their cards. However, Army cardholders circumvented these
policies by obtaining cash or club cash at a substantial fee from such
clubs.
The gentlemen‘s clubs typically sell adult entertainment, many sell
alcohol, and some sell food. DOD and other federal agencies use
merchant category codes (MCC) [Footnote 18] to identify and block
merchants in certain categories from accepting travel cards as payment
for goods and services at those establishments. However, some merchants
with blocked codes circumvented this control by using an allowable MCC
to submit cash transactions at their establishments. For instance,
Crazy Horse Too is an entertainment establishment that provides topless
dancing and sells alcohol, but not food. This establishment allows
customers to use their travel cards to obtain club cash from the bar
for a 10 percent fee. Club cash can only be used to tip dancers,
waitresses, and bartenders, but cannot be exchanged for currency and
cannot be used to purchase alcohol. Crazy Horse Too codes the club cash
that it provides to customers as a ’bar charge“ in the name of its
operating company, the Power Company. This coding allows these charges
to bypass the MCC blocking control. Other clubs, such as Cheetahs
Lounge Club, provide actual cash instead of club cash, and also code
the transactions as ’bar charges.“
For example, one cardholder used his restricted travel card to obtain
more than $5,000 in cash. As discussed previously, a restricted card
has a maximum credit limit of $2,500 and an ATM cash withdrawal limit
of $200 per monthly statement cycle. In this instance, the cardholder‘s
restricted travel card was activated about 20 days prior to his
official travel. The cardholder used the card to make numerous ATM cash
withdrawals and pay for large restaurant and grocery store charges
prior to departure for government travel. After arrival at his
temporary assignment location, the cardholder requested that his APC
raise his credit limit from $2,500 to $10,000 based on his ’mission-
critical status.“ [Footnote 19] The APC took the requested action,
without reviewing the cardholder‘s account history. The cardholder
then frequented gentlemen‘s clubs near his temporary assignment
location, where he obtained more than $5,000 in cash. The cardholder
told our investigators that he sent approximately $2,000 to his spouse,
leaving him with about $3,000 for personal use and entertainment. The
cardholder also told us the ability to obtain cash from these clubs was
common knowledge among military personnel at his temporary assignment
location. In this case, the APC subsequently discovered the abuse of
the travel card and took steps that resulted in closing the
cardholder‘s account, and the cardholder received an administrative
reprimand for unacceptable behavior.
Few Documented Disciplinary Actions Taken against Cardholders Who
Misused the Travel Card:
We found that disciplinary actions were taken against the cardholders in
less than half of the cases of cardholder abuse that we reviewed. It is
critical that cardholders who misuse their travel cards are identified
and held accountable for their actions. Lacking such an environment,
the Army is likely to continue to experience the types of potentially
fraudulent and abusive activity identified in our work. The DOD
Financial Management Regulation (FMR) states that ’commanders or
supervisors shall not tolerate misuse of the DOD travel cards and
cardholders who do misuse their cards shall be subject to appropriate
disciplinary action.“ However, DOD and Army policies and procedures do
not define appropriate disciplinary action to help ensure that
consistent punitive actions are taken against cardholders who abuse
their travel cards. Available documentation indicates that commanders
or supervisors did not take any disciplinary actions against the
majority of individuals who abused or misused their cards during fiscal
year 2001. We found little documentation demonstrating that APCs
forwarded cardholder delinquency information to appropriate commanders
and supervisors to consider in determining whether disciplinary actions
were warranted.
For the cardholders we inquired about, the primary action taken when
Army officials identified misuse or abuse of the travel card was to
counsel cardholders on proper use of the card and responsibility for
timely payment of travel card bills. In some cases, APCs took actions
to cancel the cardholder‘s travel card account. To the extent that more
severe disciplinary actions were taken, they were often in response to
travel card abuse in conjunction with other more serious offenses”such
as failing to obey orders or drug abuse. In these instances, documented
disciplinary actions included dismissal from the Army and criminal
prosecutions resulting in prison sentences.
At the sites we audited, we were not provided any documentation of
disciplinary actions taken against cardholders in 65 of 105 charge-off
cases we reviewed. For example, we found one instance in which a
cardholder (whose account was charged off for more than $5,000) was not
subject to any disciplinary action, and was subsequently promoted from
Major to Lieutenant Colonel. As shown in table 3 (cardholder #5), this
individual had a history of substantial credit problems, including
writing three NSF checks. In this instance, records indicated that the
cardholder was reimbursed for official travel, but did not pay the
travel card bill. The individual was subsequently placed in the salary
offset program.
Also, we found little evidence that cardholders faced adverse
consequences for personal use of the card as long as they paid the bills
received from Bank of America. For example, we identified cardholder
transactions of $5,192 for a Celebrity Cruise Line vacation for four
people, $2,195 for a stock market investing course, and $1,395 in
tickets to a musical event. In these instances, the cardholders
essentially obtained interest-free loans with no adverse consequences.
We saw few indications that supervisors were aware that these abusive
transactions occurred. To the extent that we saw documentation that
APCs or supervisors were aware of such travel card abuse, we saw little
evidence of any disciplinary actions.
Credit Problems Generally Not Referred to Security Officials:
We also found many instances in which there was no evidence that Army
security officials were informed of travel card charge-offs for
consideration in reevaluating security clearances. Army regulations
provide that an individual‘s finances are one of the key factors to be
considered in whether an individual should continue to be entrusted
with a secret or top-secret clearance. However, we found that Army
security officials were unaware of travel card debt problems and,
consequently, did not consider this information in determining whether
these individuals should continue to receive their security clearances.
Our review of the 105 charge-off cases discussed previously showed that
of 43 cardholders who had secret or top secret clearances at the time
their accounts were charged off, 38 maintained the same level of
clearance as of June 2002. The clearances for the remaining 5
cardholders had expired. These financially troubled individuals may
present security risks to the Army.
The U.S. Army Central Personnel Security Clearance Facility (commonly
referred to as Army CAF) is responsible for issuing and updating
security clearances for Army personnel. Secret clearances are updated
every 10 years and top-secret clearances are updated every 5 years.
During the interim periods, Army regulations [Footnote 20] require
commanders of personnel with clearances, such as secret and top secret,
to submit to Army CAF any evidence of financial irresponsibility on the
part of the personnel that would affect their clearance. Such evidence
would include information on financial impropriety by the security
clearance holder, such as excessive indebtedness. Army CAF is to
evaluate this information and determine whether to revoke the
clearance.
We found that commanders responsible for referring evidence of financial
irresponsibility information to Army CAF were, for the most part,
unaware of their subordinates‘ financial problems. We provided the
information we collected on individuals with charged-off accounts to
Army CAF for its consideration in determining whether to revoke,
change, or renew their security clearances.
Weak Overall Control Environment and Ineffective Travel Card Program
Controls:
A weak overall control environment and ineffective internal controls
over the travel card program contributed to the potentially fraudulent
and abusive activity related to the travel card and the Army‘s high
rates of delinquency and charge-offs. The foundation of all other
controls, a positive control environment provides discipline and
structure as well as the climate that influences the quality of
internal controls. Although we observed improvements in the first half
of fiscal year 2002, we identified several factors that contributed to
a weak overall control environment for fiscal year 2001, including, as
discussed previously, few documented disciplinary actions taken against
cardholders who abuse the card and a lack of management attention and
focus on establishing and maintaining the organizational structure and
human capital needed to support an effective Army travel card
management program. We found that this overall weak control environment
contributed to design flaws and weaknesses in seven management control
areas needed for an effective travel card program. Specifically, we
identified weaknesses in the Army travel program controls related to
(1) travel card issuance, (2) APCs‘ capacity to carry out assigned
duties, (3) limiting card activation to meet travel needs, (4) controls
over transferred and ’orphan“ accounts, (5) procedures for terminating
accounts when cardholders leave military service, (6) segregation of
duties to ensure that no one individual can control all aspects of a
travel transaction, and (7) access controls for Bank of America‘s
travel card database.
All seven of these areas related to two key overall management
weaknesses: (1) the lack of clear, sufficiently detailed policies and
procedures and (2) limited travel card audit and program oversight.
First, the units we audited used DOD‘s travel management regulations
(DOD FMR, Volume 9, Chapter 3) as the primary source of policy guidance
for management of Army‘s travel card program. However, in many areas,
the existing guidance was not sufficiently detailed to provide clear,
consistent travel management procedures to be followed across all Army
units. Second, as recognized in the DOD Inspector General‘s March 2002
summary report [Footnote 21] on the DOD travel card program, ’because
of its dollar magnitude and mandated use, the DOD travel card program
remains an area needing continued emphasis, oversight, and improvement.
Independent internal audits should continue to be an integral component
of management controls.“ However, the DOD Inspector General report noted
that only two internal review reports were issued from fiscal year 1999
through fiscal year 2001 concerning the Army‘s travel card program.
These reports, issued by the Army‘s Assistant Secretary for Financial
Management (and Comptroller)‘s Internal Review Office, covered
government travel card usage in the Army during fiscal year 2000. In
addition, each of the Army installations we audited had internal review
groups that did some level of review of the travel program and
identified deficiencies in the Army‘s travel program at their
installations.
To the extent that oversight reviews were conducted, we saw few
indications that management took action to address the deficiencies
auditors identified. For example, the Army‘s two fiscal year 2000
internal review reports disclosed that existing review procedures were
not effective in identifying card misuse and identified additional
actions needed to address travel card abuses, such as unauthorized
usage of the card and unauthorized cash withdrawals. We identified
these same issues in our fiscal year 2001 work.
Ineffective Controls over Issuance of Travel Cards:
The Army‘s ability to prevent potentially fraudulent and abusive
transactions that can eventually lead to additional delinquencies and
charge-offs is significantly weakened if individuals who had histories
of financial irresponsibility are permitted to receive travel cards.
The Army‘s practice is to facilitate Bank of America issuing travel
cards”with few credit restrictions”to all applicants regardless of
whether they have histories of credit problems. DOD guidance in FMR,
Volume 9, Chapter 3, provides that all DOD personnel are to use the
travel card to pay for official business travel. However, the policy
also provides that exemptions from using the travel card may be granted
under a number of circumstances, including for personnel who are denied
travel cards for financial irresponsibility. However, DOD‘s policy is
not clear as to what level of financial irresponsibility by a travel
card applicant would constitute a basis for such an exemption. In
addition, the DOD FMR provides that credit checks are to be performed
on all travel card applicants, unless an applicant declines a credit
check. We found no evidence that the Army exempted any individuals or
groups from required acceptance and use of travel cards, even those
with histories of previous credit problems.
In July 1999, Bank of America began obtaining credit checks on DOD
travel card applicants and used the credit history obtained through
these checks as a basis for determining the type of account”restricted
or standard”it would provide to new DOD travel applicants. An applicant
who did not authorize a credit check, or with either no credit history
or a history of credit problems, is issued a restricted travel card
with a $2,500 credit limit. All other applicants are issued standard
travel cards with a $10,000 credit limit. DOD policy also permits
commanders or supervisors to raise the credit limits and ATM limits of
restricted travel cardholders to whatever level they deem necessary to
meet mission requirements, except when the cardholder declined a credit
check. Our analysis of credit application scoring models and credit
risk scores used by major credit bureaus confirmed that applicants with
low credit scores due to histories of late payments are poor credit
risks. Credit bureau officials told us that if their credit rating
guidelines for decisions on commercial credit card application
approvals were used to make decisions on travel card applicants, a
significant number of low- and midlevel enlisted Army cardholders would
not have qualified for credit cards even with the restricted limits. A
credit history showing accounts with collection agency action or charge-
offs poses an even higher credit risk. Any of these problems can be a
reason for denying credit in the private sector.
Consequently, until the Army takes action to prevent applicants with
past credit problems from receiving government travel cards, it will
continue to unnecessarily increase the risk that individuals will
continue a pattern of fraud, abuse, and delinquency or nonpayment.
Credit industry research and the results of our work demonstrate that
individuals with previous late payments are much more likely to have
payment problems in the future. As discussed previously, many of the
Army travel cardholders that we audited who wrote numerous NSF checks,
were severely delinquent, or had their accounts charged off had
histories of delinquencies and charge-offs relating to other credit
cards; defaulted automobile loans that resulted in repossession of the
vehicles; defaulted mortgage payments and foreclosure proceedings on
homes; numerous bankruptcies; and, in several cases, prior arrests and
convictions for crimes such as writing bad checks.
Unrealistic APC Performance Expectations:
DOD policy provides that APCs are the primary focal points for day-to-
day management of the travel program. However, APC duties are generally
’other duties as assigned.“ As discussed in the following sections, the
sheer number of responsibilities assigned to APCs, coupled with issues
concerning APC span of control, selection, turnover, training, and
performance evaluation, result in unrealistic expectations for the
effectiveness of APCs in carrying out their critical duties.
Consequently, we found that APCs were generally ineffective in
performing their key travel program management oversight duties.
APC Responsibilities:
As prescribed by DOD‘s FMR guidance, APCs ’are responsible for the day-
to-day operations of the DOD Travel Card Program.“ DOD FMR Volume 9,
Chapter 3, provides that APCs are responsible for a variety of key
duties, including establishing and canceling cardholder accounts,
tracking cardholder transfers and terminations, monitoring and taking
appropriate actions with respect to any account delinquencies,
interacting with the bank, and fielding questions about the program
from both cardholders and supervisors. APCs are also required to
monitor delinquent cardholders and notify commanders/supervisors of
such delinquencies for appropriate action. Further, DOD‘s FMR also
provides that APCs are to receive reports from Bank of America showing
cardholder transaction activity during the most recent billing cycle.
However, DOD‘s guidance does not further specify APC responsibilities
for actions based on their review of Bank of America reports.
We were told that individuals were given APC responsibilities as a
collateral duty. APC estimates of the percentage of time spent on their
APC responsibilities ranged from 2 percent to as high as 80 percent,
with most indicating they spent about 5 to 20 percent of their time on
APC duties. Several of the APCs we interviewed indicated that keeping
up with their APC responsibilities was a challenge because they were
expected to perform many other duties as well. For example, at the
sites we audited, civilians with APC responsibilities were often
program or budget analysts who worked in the installations‘ resource
management offices.
While some of the military personnel assigned APC responsibilities at
the sites we audited had primary job responsibilities that were finance
related, such as budget and resource managers, others had more mission-
related duties. For example, one of the APCs at the sites we audited
was responsible for security at an airport, and another was a
transportation officer. At Ft. Bragg, Special Operations, entire units,
along with the APCs, were deployed at the time of our audit. Such
deployments make it increasingly difficult for military personnel
assigned APC duties to carry out their responsibilities.
Few of the APCs we interviewed performed any account transaction
reviews beyond those conducted in conjunction with delinquencies.
Consequently, instances of abuse of the travel cards were seldom
detected promptly. Some units‘ operating procedures specify that APCs
monitor credit card activities to identify misuse. For example, in its
operating procedures, the California National Guard requires that APCs
review credit card activity to identify misuse, that such misuse be
brought to the attention of the commanders/supervisors, and that the
commanders/supervisors take actions to address the problems. However,
one California National Guard APC told us that she does not have
sufficient time available to monitor the travel activity of all the
cardholders under her purview. Another California National Guard APC
told us that, as time permits, he monitors the travel card transaction
activity of the cardholders that are his responsibility on a weekly
basis.
APC Span of Control:
DOD‘s FMR guidance does not address the appropriate span of control for
an APC”the number of cardholders that an APC should be responsible for
managing and overseeing. A reasonable span of control is critical for
effective management and proper travel program oversight. Bank of
America guidance provides that an optimal span of control is 100
cardholders per APC. In addition, because APC duties are assigned as
collateral duties, the span of control should be commensurate with the
time available to carry out APC responsibilities effectively. As shown
in table 5, at the four sites we audited, the average ratio of
cardholders with open accounts to APCs ranged from 65 to 1 to 804 to 1.
Table 5: Average Ratio of Cardholders to APCs at Army Sites Audited:
Span of control: Number of cardholders with open travel card accounts;
Ft. Drum, Forces Command: 6,498;
California National Guard: 4,022;
Ft.Bragg, Forces Command: 11,424;
Ft. Bragg, Special Operations: 5,696.
Span of control: Number of APCs;
Ft. Drum, Forces Command: 39;
California National Guard: 5;
Ft.Bragg, Forces Command: 120;
Ft. Bragg, Special Operations: 88.
Span of control: Average ratio of cardholders to APCs;
Ft. Drum, Forces Command: 167:1;
California National Guard: 804:1;
Ft.Bragg, Forces Command: 95:1;
Ft. Bragg, Special Operations: 65:1.
Source: GAO analysis of Bank of America data.
[End of table]
The span of control responsibilities for the APCs at the four sites we
audited ranged from about 5 open accounts to over 1,000. Decisions on
the optimal span of control must take into account not only the number
of accounts for which the APC has direct responsibility, but also the
number of accounts for which another lower-level APC has direct
responsibility, but for which the higher-level APC has oversight
responsibility. [Footnote 22] For example, an APC at the California
National Guard site we audited who had direct responsibility for
managing the travel activities of over 1,000 cardholders also had
oversight monitoring responsibility for about another 400 cardholders.
An APC at Ft. Bragg, Forces Command, with direct responsibility for
managing 287 travel card accounts told us that he was in the process of
working with Bank of America to identify and deactivate the cards of
any infrequent travelers within his purview. He reported that he hoped
to reduce the number of accounts he was responsible for to about
100.
The sites we audited were consistent in that few of the APCs we
interviewed performed any account transaction reviews beyond those
conducted in conjunction with delinquencies. Several of the APCs told us
that they received detailed account transaction activity reports from
Bank of America. But, outside of reviews of account activity associated
with delinquencies, they told us that detailed transaction reviews were
too time-consuming to carry out for their other cardholders. Another
APC we talked to, who attempted to compare reports on travel card
transactions received from Bank of America with valid travel orders for
the cardholders within her purview, said this activity was time-
consuming and almost impossible to perform for all of the people under
her span of control.
Failure to review available cardholder transaction activity reports
available from Bank of America and take action to address any
inappropriate card usage can result in delinquencies and account charge-
offs. For example, one APC was not aware that a cardholder within his
sphere of responsibility made multiple personal use transactions,
including purchases at Wal-Mart, Vitamin World, General Nutrition
Center, and Hecht‘s, until 3 months after the cardholder‘s name
appeared in a delinquency report in January 2001. By that time, the
cardholder owed $5,655 and was from 30 to 59 days delinquent. The
cardholder‘s account was eventually charged-off on August 10, 2001,
with a balance of $6,997.
APC Selection, Turnover, Training, and Performance Evaluation:
Our internal control standards state that management‘s commitment to
competence and good human capital practices are critical factors in
establishing and maintaining a strong internal control environment.
Specifically, our standards provide that management needs to identify
appropriate knowledge and skills needed for various jobs and provide
needed training, as well as candid and constructive counseling, and
performance appraisals. They also state that establishing appropriate
human capital practices, including hiring, training, evaluating,
counseling, and disciplining personnel, is another critical
environmental factor.
APC selection and turnover. As discussed previously, the DOD FMR
assigns a number of key duties for government travel card management to
APCs. However, neither DOD nor the Army had procedures in place that
addressed the requisite knowledge and skills needed, or the expected
tenure, for those selected to carry out these key APC responsibilities.
We found that APC assignments were based on the commanding officer‘s
judgment as to who could best carry out assigned APC duties.
At three of the four sites we audited, the individuals assigned overall
APC duties for the sites were civilians, and the majority of the
individuals assigned as subordinate-level APCs were military personnel.
We did not identify any information indicating that individuals
appointed as APCs were expected to serve in this role for any specified
period. We found that civilians appointed as APCs generally served
longer terms than military APC appointees. For example, at the Ft.
Bragg Special Operations site we audited, we were told that the
civilian APC had served for over 2 years in this role, while most of
the military APCs turned over roughly every 6 months. At the Ft. Bragg,
Forces Command, site we audited, only 1 of the 11 APCs we attempted to
interview who had been in position during fiscal year 2001 remained in
that position.
APC training. DOD policy provides that travel card training materials
are to be distributed throughout the department and that APCs are to be
informed of policy and procedural changes to the travel card program.
There are no supporting DOD or Army-wide procedures detailing
requirements for the extent, timing, and documentation of travel program
training for APCs. APCs are not required to receive training on the
duties of the position or on how to use available Web-based tools and
reports from Bank of America before they assume their APC duties.
A number of the APCs we interviewed told us they relied heavily on on-
the-job learning and other program coordinators for advice on how to
carry out their duties when they assumed their APC responsibilities. At
the Ft. Bragg, Special Operations, site we audited, we were told that
the command-level APC provided training every 3 months and expected all
APCs to attend, unless they were deployed or on an assignment that would
not allow them to attend the training. APCs at Ft. Bragg, Special
Operations, also told us they received annual or semiannual briefings
from Bank of America on the electronic tools available in its Web-based
system containing travel card transaction data”EAGLS (Electronic Account
Government Ledger System). According to the APCs we interviewed, the
briefings they received on EAGLS included guidance on how to use the
system to establish a travel account, how to extract individual
cardholder delinquency and transaction activity reports, and how to
contact Bank of America for additional help with the Web-based tools.
Some of the APCs we talked with reported that they have become
proficient in, and routinely use, the tools available through EAGLS to
assist them in their APC duties with respect to delinquency monitoring.
Other APCs indicated that they either did not use the tools available
through EAGLS or were not proficient in using them to monitor
cardholders‘ travel activities. According to data provided by Bank of
America, about 23 percent of the Army‘s APCs have never logged into
EAGLS.
APC performance evaluation. Generally, APC responsibilities were
assigned as an ’other duty assignment.“ Individuals serving as APCs had,
and were rated on, other job duties and responsibilities. The extent to
which the performance of APCs was recognized as a major duty, and rated
as such, varied. At Ft. Bragg, Special Operations, none of the
individuals serving as APCs were rated on how well they performed those
duties. At the Ft. Drum location, one of the APCs had a position
description that included ’serves as travel card program manager“ as a
major duty (with the recognition that this duty, combined with duties
as the unit‘s program manager for cost accounting, should require about
30 percent of the employee‘s time).
Controls over Activating/Deactivating Travel Cards to Meet Travel
Needs:
Allowing Army travel cardholders to maintain accounts in an active
status when not needed for government travel unnecessarily exposes the
Army to an increased risk of misuse”through cardholders either
mistakenly or intentionally using the card for personal purposes. DOD‘s
FMR provides that restricted cards are issued to cardholders in an
’inactive“ status and initially activated only when the cardholders
have authorized government travel needs. By contrast, standard cards
are ’active“ when they are issued to cardholders. DOD policy guidance
does not address deactivating restricted and standard travel cards when
not needed for official purposes.
Lacking overall policy and procedural guidance in this area, we found
instances in which individual commands or sites established their own
practices for deactivating cards when cardholders were not on travel.
For example, the California National Guard‘s August 2001 guidance to
all of its APCs required them to deactivate all travel card accounts
for cardholders not on official travel. In addition, APCs at Ft. Bragg,
Special Operations, told us that, as a matter of practice, they
deactivate the cards of cardholders in military grades of E-5 or below
when they are not on official travel.
Accountability for Transferred and Orphaned Accounts:
We also found that the Army lacks clear, sufficiently detailed
procedures with respect to maintaining effective day-to-day
accountability for cardholders‘ travel card accounts. Until the Army
takes action to work with Bank of America to clearly establish
accountability for accounts that are not under the control of a
specific APC, it will continue to be vulnerable to undetected,
potentially fraudulent, or abusive use of these accounts.
In practice, the Army relies on cardholders to inform the transferring
location‘s APC that they will be moving to another Army unit. After a
cardholder notifies the transferring APC of his or her upcoming move,
the APC is to inform the cardholder that he or she is required to
report to the APC at the new location within 10 days of arrival. If the
cardholder does not check in with the APC at the gaining location at
the end of 10 days, the losing APC is to deactivate the cardholder‘s
account. However, transferring units‘ APCs told us that cardholders do
not always inform them of upcoming moves and, therefore, they do not
deactivate the cards when the cardholders fail to report to the new APC
within 10 days.
As a result, many accounts fell into ’limbo“ and are also referred to as
’orphan accounts.“ Accounts for transferred cardholders can remain in
this limbo status for lengthy periods. For example, 2 California
National Guard accounts out of the 166 that we examined for our
statistical tests belonged to cardholders who had transferred from
their units in 1998 and 2000, respectively. The responsible APC was not
aware that the transfers had taken place until we brought the matter to
her attention.
According to Army officials, this breakdown in accountability is one of
the primary causes for the Army‘s large number of orphaned accounts.
[Footnote 23] These are Army travel card accounts that are not under
the purview of any APC, according to Bank of America records. Bank of
America officials also told us that some of the accounts in this group
might not even be Army accounts. As shown in appendix III, Bank of
America data show that as of the end of fiscal year 2001, orphaned
accounts had about a 20 percent delinquency rate.
Without an APC assigned to oversee these accounts, orphan accounts pose
a higher risk of charge-offs. In fiscal year 2001, Bank of America
charged off 717 accounts of the approximately 7,479 active orphan Army
accounts, accounting for almost $1 million. In May 2002, Bank of
America issued letters to all cardholders in the orphan grouping
informing them that unless they took action to identify accountable
APCs, their accounts would be closed.
Exit Control Procedures for Separating Employees:
As with transferred employees, neither DOD nor Army procedures are
sufficiently detailed to ensure that APCs are notified and take prompt
action to terminate cardholders‘ accounts when cardholders leave the
Army. DOD‘s FMR provides that APCs are responsible for terminating
travel cards when cardholders are dismissed, retire, or are separated
from DOD. Operating procedures established by individual Army commands
and installations to notify APCs in the case of retirement, separation,
or death of employees were neither consistent nor effective.
In general, we found that APCs relied on cardholders to notify them that
they were leaving the Army. Some APCs informed us that their units‘ exit
procedures for separated, retired, or dismissed employees require that
individuals turn in their travel cards as part of the exit process
before leaving the organizations. For example, the National Guard‘s
standard operating procedures provide that ’All departing cardholders
that are terminating their federal employment status will turn in their
Travel Charge Card to their APC as a part of their out processing.“
However, we found instances in which these procedures were difficult to
implement. For example, a California National Guard official told us
that this procedure is difficult to implement because some guard
employees are hundreds of miles from the location of their cognizant
APC. The official told us that many of the separations from the guard
are handled through mail, e-mail, and fax, and not through face-to-face
contact with unit officials or the APC. One APC told us that she
sometimes becomes aware that cardholders are departing when she
receives their travel cards through the mail. If an APC does not
receive messages or paperwork to cancel the cards, or if there is a
delay in notifying the APC of the cardholders‘ departure, the
cardholders‘ accounts would remain active and the separated cardholders
may abuse the cards.
Due to the lack of procedures to effectively identify and terminate the
cards of individuals no longer in the Army, we found the following
examples of separated or retired individuals who abused the travel card.
These separated or retired Army employees benefited by using travel
cards to purchase a variety of goods and services and then not paying
their monthly bills, essentially obtaining the personal items for no
cost and possibly receiving discounted government rates by using their
government travel cards.
* A service member (E-4) assigned to Ft. Knox was released from active
duty on September 16, 2000, but his travel card was not deactivated at
that time as required. In May 2001, over 8 months after he separated,
charges started appearing on his travel card. Charges included ATM
withdrawals, restaurant charges, and monthly fees for a fraternal
organization. In addition, the cardholder spent more than $110 at
Platinum Plus, an adult entertainment establishment. The cardholder
continued to use the card through August 2001, almost 1 year after he
left the service. Although the cardholder charged more than $1,125 on
the card, he did not submit any payments on his Bank of America bills.
The account balance was charged off in January 2002.
* An air reservist (E-6) assigned to military postal service was
discharged on February 4, 2000, but did not turn in his card. The
individual continued to use his government-issued travel card for
personal use. In fiscal year 2001, the individual made charges totaling
approximately $5,800 on his travel card, including over $5,000 of cash
advances in the vicinity of his home in New York. The soldier‘s travel
card account was closed on March 11, 2002, and the unpaid balance of
$3,419 was charged off.
* A first sergeant (E-8) at Ft. Hood, Texas, repeatedly used his travel
card after his retirement on September 30, 2000. During fiscal year
2001, he used the travel card for personal goods and services totaling
more than $8,000. The charges consisted of almost $2,000 in car
rentals, another $2,000 in hotel charges, and approximately $2,951 in
restaurant charges”including a one-time catering charge of
$1,455”primarily in Hawaii and Texas. In addition, he spent $1,119 on
two cruises with Royal Caribbean cruise line. Because the Army does not
routinely monitor cardholders‘ transaction reports for abusive activity
and because this particular account was always paid in full, the abusive
activities were not detected for more than a year. In February 2002,
while scanning travel card activities of all cardholders under her
sphere of responsibility, the APC became aware that the cardholder had
retired. The APC deactivated the cardholder‘s account in March 2002.
* A sergeant first-class (E-7) retired from the active duty National
Guard in February 2000, but continued to use the government travel card
in fiscal year 2001. Subsequent to his retirement, the individual
became a state guard employee. State employees are not entitled to hold
federal government travel cards. Bank of America and National Guard
records indicated that the individual used the government travel card
for onbase lodging and rental car charges related to official travel
with the state guard. As of the time of our audit, more than 2 years
after the cardholder‘s retirement, the cardholder‘s account was still
open, although we noted that the account was not delinquent.
An APC told us that out processing procedures should include APC or
supervisor verification that the cardholder‘s account was closed. In
fact, her unit has established an informal procedure that has helped
ensure that APCs receive timely notification of a cardholder‘s
departure. The procedure involves the departing cardholder‘s supervisor
sending e-mails to the cognizant APC notifying him or her of the date
the service member is leaving and to close the cardholder‘s account as
of that date.
We also found that the Army did not have procedures requiring periodic
comparisons between active travel card accounts and employees to ensure
that accounts of separated or retired employees are closed. For example,
each Army unit we visited maintained records of retired, dismissed, and
separated employees and the respective dates of these actions. However,
none of the APCs we interviewed compared these records against the list
of active accounts to identify accounts that should have been closed
but were not. Periodic reconciliations of the two lists would have
enabled the Army to identify employees who had left and should no
longer have had travel cards.
Segregation of Duties Controls Were Compromised at One Installation:
Adequate controls must be in place to ensure that no one individual can
control all key aspects of a travel transaction. Such controls are key
to effectively reducing the risk of error or fraud at the four sites we
audited. Our observations and walk-throughs showed that proper
segregation occurred because no one individual was responsible for the
major functions associated with the voucher approval and payment
process. Specifically, we found the traveler and person approving the
travel orders were generally located at the installation, whereas a
DFAS center prepared the final vouchers and entered the data into the
DOD travel payment system, the Integrated Automated Travel System
(IATS). For example, in the case of Ft. Drum, located in Watertown, New
York, its vouchers were processed and paid by the DFAS center in
Orlando, Florida. Further, we found that no one individual at the DFAS
centers was responsible for (1) entering payment information into IATS
and (2) auditing travel voucher summaries for accuracy and
completeness.
However, at the California National Guard, we did identify weaknesses
that compromised segregation of duties controls. Specifically, controls
were not in place to prevent California National Guard members, who also
served as voucher examiners, from validating, approving, and auditing
their own final travel vouchers and submitting them to DFAS for
payment.
In addition, weak controls over the California National Guard‘s
usernames and passwords for ’temporary“ voucher examiners further
increased the risk that voucher examiners could prepare, validate, and
receive payment for erroneous or fraudulent travel vouchers without
detection. Temporary voucher examiners”those California National Guard
members who are employed as voucher examiners on a part-time or
intermittent basis”were given generic usernames and passwords for
accessing IATS. However, according to the permanent travel voucher
examiners we talked to, these generic usernames and passwords for
temporary voucher examiners were well known to the permanent travel
voucher examiners as well.
Consequently, any of the California National Guard‘s permanent travel
voucher examiners could use one of these well-known generic usernames
and passwords to access IATS to enter, delete, or modify travel data in
the system”including data related to their own travel voucher
processing and payment”without detection.
Access Controls over Bank of America‘s Travel Card System:
Thousands of Bank of America and DOD employees had access to Bank of
America‘s travel card transaction data system, known as EAGLS. Computer
system access controls are intended to permit authorized users to
access a system to perform their assigned duties and preclude
unauthorized persons from gaining access to sensitive information.
Access to EAGLS is intended to be limited to authorized users to meet
their information needs and organizational responsibilities. Authorized
EAGLS user access levels include APC-level (APCs requiring access to
travel data for cardholders under their purview), individual-level
(individual travelers requiring access to their own travel transaction
histories), and bank employee-level access (Bank of America employees
may be granted one of five different levels of access depending on
their assigned duties). The highest level of Bank of America employee
access to EAGLS is the ’super user“ level. According to Bank of America
security officials, this level of access”which provides users the
ability to add, delete, or modify anything in the system, including
creating accounts and editing transaction data in the system”should be
granted to as few individuals as possible.
We found that 1,127 Bank of America employees had some level of access
to the EAGLS system, including 285 with super user level access. After
we brought this matter to the attention of Bank of America security
officials, they reviewed employee access and deactivated access for 655
employees that they determined should not have had any level of access.
Further, Bank of America has since initiated periodic reviews to ensure
that it maintains appropriate levels of employee access.
In addition, DOD employees retained APC access to EAGLS after
relinquishing APC duties or after they may have been terminated or
transferred. In a 2000 survey of 4,952 individuals with APC-level
access to EAGLS, DOD found that approximately 10 percent could not be
located and may have been terminated or transferred or no longer had APC
responsibilities. Over concern that many of these accounts should be
deactivated, Bank of America has begun a review to determine if DOD
employees with APC-level access no longer have APC responsibilities or
have left the service.
Statistical Tests of Key Control Activities:
With the weak control environment and related program control
weaknesses we identified, it is not surprising that, as shown in table
6, we found a significant percentage of failures in several of the key
control activities we statistically tested at the four Army locations
we audited. We selected four key control activities to test related to
basic travel transaction and voucher processing.
Specifically, we tested the implementation of the following internal
control activities for a statistically valid sample of travel card
transactions.
* Was there a travel order associated with the transaction that was
approved prior to the start of travel?
* Was there a travel voucher associated with the transaction that was
properly reviewed to ensure that payment was accurate and properly
supported?
* Did the traveler submit a travel voucher associated with the
transaction to the installation travel office for processing within 5
days of completion of travel as required by government travel
regulations?
* In accordance with TTRA and DOD FMR, was the traveler paid within 30
days of the date a properly approved travel voucher associated with the
transaction was submitted for payment?
Appendix II includes the specific criteria we used to conclude on the
effectiveness of these controls.
Table 6: Results of Testing of Key Internal Controls:
Army unit: Ft. Drum, Forces Command;
Percentage of failure, Travel orders are approved prior to travel: 0.0;
Percentage of failure, Travel voucher reimbursements are accurate:
10.4;
Percentage of failure, Travel vouchers are submitted within 5 days of
travel completion: 21.9;
Percentage of failure, Travel vouchers are paid within 30 days of
submission: 5.2.
Army unit: Ft. Bragg, Special Operations;
Percentage of failure, Travel orders are approved prior to travel: 3.1;
Percentage of failure, Travel voucher reimbursements are accurate: 7.3;
Percentage of failure, Travel vouchers are submitted within 5 days of
travel completion: 30.2;
Percentage of failure, Travel vouchers are paid within 30 days of
submission: 7.3.
Army unit: Ft. Bragg, Forces Command;
Percentage of failure, Travel orders are approved prior to travel: 6.2;
Percentage of failure, Travel voucher reimbursements are accurate:
18.8;
Percentage of failure, Travel vouchers are submitted within 5 days of
travel completion: 38.5;
Percentage of failure, Travel vouchers are paid within 30 days of
submission: 8.3.
Army unit: California National Guard; 1.0 41.9 27.9 60.5
Percentage of failure, Travel orders are approved prior to travel: 1.0;
Percentage of failure, Travel voucher reimbursements are accurate:
41.9;
Percentage of failure, Travel vouchers are submitted within 5 days of
travel completion: 27.9;
Percentage of failure, Travel vouchers are paid within 30 days of
submission: 60.5.
Note: The numbers in the table represent point estimate percentages for
the number of failures in the population based on our sampling tests.
The confidence intervals for our sampling estimates are presented in
app. II.
Source: GAO analysis.
[End of table]
The Army‘s inability to establish effective controls in several of
these key control areas, particularly relating to timeliness of
payment, contributed to its high delinquency rate. As discussed
previously, for the four locations, we estimate that the percentage of
transactions during fiscal year 2001 that represented personal use
varied from 15 percent at one location to 45 percent at another
location. [Footnote 24]
Controls over Travel Order Approval Were Generally Effective:
Timely approval of the travel orders is the first step in ensuring that
travel is authorized. At three of the four installations we audited,
the controls over travel order approval were effective. We estimate
that 0 to 3 percent of transactions at these installations did not have
documented evidence that travel orders were approved prior to the
beginning of travel. At Fort Bragg, Forces Command, travel order
controls had an estimated 6 percent failure rate associated with travel
orders that were not approved prior to travel. The control breakdown we
noted in our sample transactions occurred when the travel took place
prior to written approval of the travel order. For example, one
traveler had travel duty from April 8, 2001, to April 19, 2001, but did
not get his travel order approved until April 27, 2001. According to
Army officials, this often occurred because travelers neglected to
document the date of verbal travel authorization on their written
travel orders.
Controls over Travel Voucher Review and Accuracy Were Not Effective:
Once the travel is complete, the traveler is to submit a voucher for all
reimbursable expenses and must include receipts for certain claimed
amounts. The voucher review process is intended to ensure that only
authorized, properly supported travel charges are reimbursed and that
the amounts are accurate and properly calculated. At the four
installations audited, we estimate that about 7 percent to 42 percent
of transactions were associated with travel vouchers that were not
accurate or were not properly supported. The California National Guard
had an estimated failure rate for voucher review that was two to six
times higher than that of the other three installations. We found
undetected instances of travel voucher errors by travelers, voucher
reviewers (both installation-level and DFAS-level), and DFAS.
Travel voucher errors result in either over- or underpayments to the
traveler and create an additional administrative burden for Army and
DFAS when the traveler must file a supplemental voucher to claim
amounts that were not paid initially or when the initial travel
vouchers are incomplete or erroneous. For example, according to DFAS
Orlando officials, during fiscal year 2001 DFAS Orlando returned an
estimated 12,000 vouchers to Army installations because of errors or
omissions in the initial voucher packages submitted to DFAS. Further,
delays in paying valid amounts to travelers can result in delinquent
accounts when the cardholder has not been fully reimbursed by the time
the monthly travel card bill is received. In our samples, we found that
most errors were in the following categories.
* Missing receipts – We found instances in which voucher packages did
not include all required receipts to support claims based on DOD and
Army regulations. DFAS paid the vouchered amounts in these cases
despite the lack of receipts. For example, for a Ft. Drum cardholder,
DFAS paid hotel charges on a voucher for which the cardholder did not
attach the required receipt. At the California National Guard, we found
that a cardholder was paid for 4 nights of lodging when the receipt was
for 3 nights.
* Errors in amounts paid – We found instances in which DFAS used an
incorrect per diem rate [Footnote 25] for lodging and meals and
incidental expenses to calculate the reimbursement amount, resulting in
both over- and underpayments to the traveler. We also found that DFAS
made errors in calculating reimbursements for ATM fees and car mileage.
Most of these errors were relatively small in terms of dollar amounts.
In one instance, we found that DFAS underpaid a cardholder about $814.
In this case, the cardholder, an E-8, master sergeant at Ft. Bragg,
Special Operations, filed a voucher package with required supporting
documentation for lodging, transportation, and other expenses totaling
about $814 incurred while on extended travel. DFAS erroneously excluded
these expenses from its reimbursement calculation and consequently
understated the amount paid to the cardholder by this amount. While the
cardholder paid his bill from Bank of America that included these
expenses, it was not until we brought this matter to the attention of
Army and DFAS officials that the cardholder was reimbursed. In another
instance, we found that an E-5 cardholder at Ft. Drum filed a travel
voucher with DFAS Orlando claiming and receiving reimbursement for taxi
fares totaling $48.50. However, according to the related travel order,
a government vehicle was provided. After we brought this matter to its
attention, DFAS Orlando obtained a $48.50 reimbursement from the
cardholder. At the California National Guard, we found that a
cardholder‘s per diem reimbursement was less than the allowed amount,
and the traveler was paid $75 for parking expense when the receipt
showed $86.
The California National Guard‘s procedures for reviewing travel vouchers
differed from the other locations we audited in that the United States
Property and Fiscal Office (USPFO)”an organizational component of the
California National Guard”reviews all travel vouchers submitted by
California National Guard personnel for validity and accuracy before
submitting voucher payment requests to DFAS. California National Guard
officials attributed the high error rate to staff shortages in the
voucher examination branch and difficulty in retaining high-quality
personnel in these low-paying positions.
For the other Army units we audited, DFAS was responsible for reviewing
the vouchers for accuracy and proper support prior to payment. We
visited DFAS Orlando”the DFAS location responsible for processing travel
vouchers for two of our four test sites. We found that DFAS Orlando made
some voucher processing errors, which officials at that location
attributed, at least in part, to the large volume of vouchers processed
at that location, the number of vacant positions, and the significant
amount of overtime needed to process vouchers and disburse funds within
a 4- to 5-day time frame. For example, DFAS Orlando officials reported
processing over 115,000 travel vouchers during fiscal year 2001,
averaging approximately 11,000 vouchers per month, and had six
vacancies that they were unable to fill. Also, in May 2002, DFAS
Orlando reported 912 hours of overtime associated with processing
13,422 of the estimated 17,500 travel vouchers received during the
month.
Travel Processing Timeliness Was a Significant Problem Resulting in Late
Payments to Travelers:
We tested two key areas where prompt action is needed to ensure that
travelers are reimbursed for valid expenses within required time frames.
First, DOD policy requires the traveler to submit a travel voucher
within 5 days of return from travel. [Footnote 26] We estimated
significant failure rates for this requirement at all four
installations, ranging from 22 percent to 39 percent of fiscal year
2001 transactions. When this control failed in our sample transactions,
the delay in submitting a travel voucher ranged from 6 days to as long
as 228 days. Numerous travelers took up to 3 weeks to submit vouchers
upon return from travel. Installation officials told us that travelers
on extended travel for deployment to a war zone do not always have an
opportunity to file interim vouchers. Also, the officials stated that
many travelers return from travel, only to leave within a day or 2 for
annual leave or another business trip and, therefore, do not have an
opportunity to submit their travel vouchers promptly.
Delays in filing travel vouchers cause delays in travel reimbursements,
which can ultimately result in delinquent accounts. For example in one
of the sampled Ft. Bragg, Special Operations, transactions, the
cardholder was on extended travel and did not file an interim voucher.
This traveler‘s account became delinquent, but he paid the balance due
after being reimbursed. In another instance, a member of the California
National Guard who completed travel in February 2001 did not complete a
travel voucher until mid-April 2001. It took another 3 months for the
voucher to arrive at the USPFO facility responsible for processing it.
Although DFAS paid the voucher 2 days after receipt of the payment
request, the cardholder‘s account was delinquent for the 3 months.
Second, upon submission of a proper voucher by the employee, DOD has
30 days in which to make reimbursement without incurring late payment
fees and charges. Once the approving official receives a properly
documented travel voucher, the 30-day payment period begins. If payment
is not made in 30 days, the traveler is owed a late payment fee that is
to be calculated using, at a minimum, the Prompt Payment Act interest
rate, as required by TTRA [Footnote 27] and GSA regulations. [Footnote
28] GSA‘s regulations also require the cardholder to be paid an amount
equal to the amount Bank of America would have been entitled to charge
the cardholder had the cardholder not paid the bill by the due date.
Failure rates for this control activity ranged from about 5 percent to 8
percent for three of the four installations we tested, which we
considered to be partially effective. Delays in these cases were
generally attributed to the review process at the installation, while
DFAS generally made payments within 7 days of receipt of the approved
voucher package. However, the fourth installation, the California
National Guard, had an estimated 61 percent of transactions that were
associated with vouchers that were not paid within the 30-day time
frame. Given the delays in initial submission of the vouchers, as
discussed previously, these additional processing delays will result in
travelers receiving payment well after they receive their monthly
travel card bills. Unless travelers use personal funds to pay the
bills, many accounts will remain delinquent until payment is received.
For example, we found that one Ft. Drum travel voucher was submitted 34
days after travel ended and another Ft. Drum voucher was paid 131 days
after the travel ended. A California National Guard cardholder did not
receive payment for a $3,554 voucher until 36 days after he submitted
his voucher. While the cardholder paid Bank of America the full amount
due following receipt of his reimbursement, the cardholder‘s account
was initially delinquent because it was not paid within the required 30-
day time frame.
In another case we reviewed, an individual had planned to retire from
the Army and subsequently withdrew his retirement paperwork and was
reassigned to another location. DFAS rejected the employee‘s travel
vouchers for reimbursement of official travel expenses because its
records showed that he had retired. At the time of our audit,
approximately 9 months had elapsed since the cardholder first sought
reimbursement from DFAS, and he was still not paid. The individual‘s
account was seriously delinquent, his card was canceled, and he
subsequently paid off his account out of his own funds”since he had not
yet been reimbursed.
With respect to the California National Guard, in many instances, USPFO
took more than 30 days from the date of receipt of the travel voucher to
send a request for voucher payment to DFAS. USPFO officials attributed
these problems to the lack of qualified voucher examiners.
Contrary to TTRA and GSA regulations, DFAS did not pay cardholders the
required late payment fees and charges. According to the DOD FMR, the
fees and charges are only paid if the traveler claims reimbursement by
filing a separate voucher claiming the fees and charges. Currently, DFAS
does not have the systems and data needed to identify and pay applicable
fees and charges due to travelers who are not reimbursed within 30
days.
Conclusions:
The intent of the travel card program was to improve convenience for
the traveler and to reduce the government‘s costs of administering
travel. However, when the Army implemented the travel card as part of
its travel program, it did not provide the control infrastructure”
primarily human capital”necessary to manage and oversee the use of
government travel cards. Consequently, a weak internal control
environment in the travel program has resulted in a significant level
of delinquencies and charge-offs of bad debts, and potentially
fraudulent and abusive travel card activity. This has resulted in
millions of dollars of costs to the Army, including higher fees, lost
rebates, and substantial time pursuing and attempting to collect
delinquent travel card accounts.
DOD and the Army have taken positive steps to reduce the delinquencies
and charge-offs, including establishing a system of wage and retirement
payment offset for many employees, sending travel reimbursements
directly to the bank rather than the employee, and making management of
the travel program a priority for the Army commands. These actions have
resulted in significant collections of previously charged-off and
delinquent accounts and improved relations with Bank of America. DOD
and the Army have also proposed additional steps as reported in the
June 27, 2002, DOD Charge Card Task Force report to improve the
controls over the travel card program. However, these Army and DOD
actions have primarily addressed the symptoms rather than the
underlying causes of the problems with the program. Specifically,
actions to date have focused on dealing with accounts that are
seriously delinquent, which are ’back-end“ or detective controls rather
than ’front-end“ or preventive controls. To effectively reform the
travel program, DOD and the Army will need to work to prevent
potentially fraudulent and abusive activity and severe credit problems
with the travel card. Preventive solutions include requiring use of the
split disbursement payment process by all employees; providing a
sufficient control infrastructure to effectively manage the program;
exempting individuals with histories of financial problems from required
use of travel cards; deactivating cards when employees are not on
official travel; and providing appropriate, consistent disciplinary
action to employees who commit fraud or abuse the travel cards.
Matter for Congressional Consideration:
To reduce DOD‘s travel card delinquency and charge-off rates,
particularly the Army‘s, which are higher than those of any other
executive branch agency, the Congress should consider authorizing the
Secretary of Defense to require using employees‘ travel allowances to
pay the travel card issuer directly for charges incurred using the
travel card. We believe that this action would provide DOD the ability
to require use of the split disbursement payment process for all of its
employees.
Recommendations for Executive Action:
To strengthen the overall control environment and improve internal
controls for the Army‘s travel card program, we recommend that the
Secretary of the Army take the following actions. We also recommend that
the Under Secretary of Defense (Comptroller) assess the following
recommendations and, where applicable, incorporate them into or
supplement the DOD Charge Card Task Force recommendations to improve
travel card policies and procedures throughout DOD.
Travel Card Issuance:
We recommend that the Secretary of the Army establish specific policies
and procedures governing the issuance of individual travel cards to
military and civilian employees, including the following:
* Evaluate the feasibility of extended use of credit checks for all
travel card applicants.
* For credit check results currently obtained and additional future
credit checks, use the results to make decisions on travel card
applicants. Decisions on whether to issue a travel card should consider
prior credit problems (e.g., bankruptcy; convictions for writing bad
checks; and defaulted credit cards, home mortgages, and automobile
loans).
* Provide individuals with prior credit problems who are denied travel
cards with alternative means of travel funding.
* Provide individuals with no prior credit histories with ’restricted“
travel cards with low credit and ATM limits.
* Develop procedures to periodically evaluate card usage and close
accounts of infrequent travelers, which will minimize exposure to fraud
and abuse.
* Cancel accounts for current infrequent travelers as noted in the
Charge Card Task Force report.
* Evaluate the feasibility of establishing a policy to activate and
deactivate cards on predetermined start and end dates, which are tied to
the cardholders‘ authorized travel orders. At a minimum, this policy
should focus on controlling travel card use for the ’high-risk“ enlisted
military personnel in the E-1 to E-6 grades.
* Develop comprehensive, consistent Army-wide initial training and
periodic refresher training for travel cardholders, focused on the
purpose of the program and appropriate uses of the card. The training
should emphasize the prohibitions on personal use of the card, including
gambling, personal travel, and adult entertainment. Such training
should also address the policies and procedures of the travel order,
voucher, and payment processes. For entry-level personnel, the training
should also include information on basic personal financial management
techniques to help avoid financial problems that could affect an
individual‘s ability to pay his or her travel card bill.
Monitoring, Review, and Disciplinary Actions:
We recommend that the Secretary of the Army establish the following
specific policies and procedures to strengthen controls and disciplinary
actions for improper use of the travel card:
* Establish Army guidance on who should be given APC responsibilities
that considers (1) the knowledge, skills, and abilities required to
carry out these responsibilities effectively, (2) the time required to
carry out APC responsibilities on a day-to-day basis effectively, and
(3) the length of time an individual should be required to stay in the
APC position in light of time required to become proficient in the use
of the tools relied on to monitor card usage effectively. Army should
evaluate whether the APC position should be full-time.
* To avoid high APC turnover, evaluate the feasibility of maximizing the
use of civilian rather than military employees to serve in the role of
APC.
* Establish guidance on APC span of control responsibilities so that
such responsibilities are properly aligned with time available to ensure
effective performance.
* Establish procedures to provide assurance that APCs receive training
on their APC responsibilities, including how to use EAGLS transaction
reports and other available data to monitor cardholder use of the travel
card”for example, reviewing account transactional histories to
ascertain whether transactions are incurred during periods of
authorized travel and appear to be appropriate travel expenses and from
approved MCCs.
* Train APCs to review EAGLS reports to identify cardholders who have
written NSF checks for payment of their account balances, and refer the
employees for disciplinary action.
* Review, in conjunction with Bank of America, individuals with APC-
level access to EAGLS to limit such access to only those with current
APC duties.
* Establish Army procedures detailing how APCs should carry out their
responsibility to monitor card usage for all cardholders assigned to
them. Included in the procedures should be development of a data mining
program enabling APCs to scan a large number of transactions, and
target potentially inappropriate transactions for further review.
* Establish a requirement for assessing performance of travel monitoring
and other APC duties as a rating factor on all APCs‘ performance
evaluations.
* Establish an Army requirement for cognizant APCs to retain records
documenting any cardholder‘s fraudulent or abusive usage of the travel
card and require this information to be provided to the gaining APC
when the cardholder is transferred.
* Establish appropriate, consistent Army-wide policy as a guide for
taking disciplinary actions with respect to fraudulent and abusive
activity and delinquency related to the travel card.
* Refer any travel cardholders with secret or higher level security
clearances for whom financial problems related to the travel card are
detected to Army CAF for investigation as to whether the individuals
should continue to be entrusted with secret or higher clearances.
* Assign responsibility and accountability over cardholders transferring
between Army units or locations, including cardholders currently in
’orphan“ status. Any accounts not assigned to an APC should be
immediately canceled.
* Strengthen procedures for any employee discharging from service so
that all cards are obtained from the cardholders, accounts are closed,
and repayment of any outstanding debts is arranged.
* Develop procedures to identify active cards of departed cardholders,
including comparing cardholder and payroll data.
Voucher and Payment Processes:
We recommend that the Secretary of the Army, in partnership with the
Director, Defense Finance Accounting Service, revise the travel voucher
and payment process by developing a process to monitor and track travel
reimbursements that exceed the 30-day requirement so that individuals
not paid within the statutory period are paid late fees in accordance
with the law.
To resolve severe voucher process problems specific to one of the units
we audited, we recommend that the Commander of the California Army
National Guard take the following actions:
* Evaluate travel card procedures from writing travel orders through
documenting expenses on the voucher and completing the reimbursement
process with a goal of reengineering these processes to provide
reasonable assurance that cardholder reimbursement is made within the
30-day requirement.
* Strengthen segregation of duties controls so that voucher examiners
cannot prepare, validate, and receive payment for erroneous or
fraudulent travel vouchers without detection. Improved controls should
include eliminating the use of generic usernames and passwords for
accessing the travel system.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, which are reprinted in
appendix V, DOD concurred or partially concurred with all of our
recommendations. DOD partially concurred with our recommendations
regarding (1) training APCs to refer cardholders who write NSF checks
for disciplinary actions, (2) establishing an Army-wide disciplinary
action policy for abusive travel card activity, and (3) developing a
process to identify travel reimbursements that exceed the 30-day
requirement so that individuals not paid within the statutory period
are paid late fees in accordance with the law.
Concerning our recommendation that APCs should be trained to refer
cardholders who write NSF checks for disciplinary action, DOD responded
that commanders of military members, not APCs, determine the
appropriate action when a cardholder has written an NSF check, and not
every case should be a referral for disciplinary action. DOD also
stated the Army intends to publish guidance that will require the APCs
to notify supervisors/commanders of incidents of abuse, misuse,
delinquency, and other events, including NSF checks. This response
appears to address the intent of our recommendation. We agree that APCs
should be trained to identify NSF checks and to report cardholders who
write NSF checks to the appropriate level of command for review and
possible further action. The supervisors and commanders would still
maintain their discretion to select the specific disciplinary action,
if any, depending on the circumstances of individual cases.
Regarding establishing Army-wide disciplinary action policy for abusive
travel card activity, DOD stated that the Army already has a strong
policy in place against theft, fraud, and other intentionally dishonest
conduct on the part of civilian employees and that it would be
inconsistent with current law for the Army to establish further
mandatory requirements that impose specific disciplinary actions. With
regard to military personnel, DOD stated that disciplinary actions are
addressed as a matter of command discretion.
We never contemplated that the policy would prescribe mandatory actions.
Rather, we intended the policy to be a guide of possible disciplinary
actions to be taken against cardholders. This guidance would also serve
as an important internal control feature that clearly identifies the
consequences associated with improper and abusive travel card use and
would serve as a deterrent to such abuse. Further, the policy could
include a range of actions that would be appropriate for various types
of travel card misuse. To eliminate any confusion concerning the intent
of our recommendation, we made a slight modification to the text of the
recommendation.
We also recommended developing a system to identify travel
reimbursements that exceed the 30-day requirement so that individuals
not paid within the statutory period are paid late fees in accordance
with the law. DOD agreed that the current systems for processing and
computing travel vouchers for the Army do not provide for automated
means of calculating interest due on vouchers exceeding the 30 days
from the proper submission date. DOD also stated that the Defense
Travel System (DTS) currently being deployed automates the voucher
submission process and should reduce the instances where reimbursements
extend beyond 30 days. However, the DOD Office of Inspector General
concluded in a recent report [Footnote 29] that DTS remains at high
risk of not being an effective solution in streamlining the DOD travel
management process and that it is not expected to be deployed until
fiscal year 2006. This system has been under development since 1998
with substantial schedule delays and cost overruns as well as
reductions in functionality. Based on this evaluation, we do not
consider DTS to be a timely or viable solution for identifying those
reimbursements outside of the 30-day requirement. TTRA and GSA
regulations require that late fees be paid to those persons reimbursed
outside of the 30-day requirement. TTRA imposes a duty on agencies to
pay the late fees and does not condition the payment of late fees on
travelers identifying late reimbursements and submitting claims for the
fees. Until DTS is fully implemented and operational, we continue to
believe that DOD needs to develop an interim process to identify late
reimbursements and pay cardholders the appropriate fees in accordance
with the law.
In addition, in one area, although DOD concurred with our
recommendation, we do not believe that its response indicates full
agreement or understanding of the intent of the recommendation.
Specifically, with regard to our recommendation that credit check
results be used to make decisions on travel card applicants, DOD
responded that those with prior credit problems are issued restricted
cards and that mandatory use of the government travel card is required
by TTRA. This is not correct. Both the DOD FMR and TTRA provide for
exemptions from the mandatory use requirements under certain
conditions, including evidence of financial irresponsibility. When an
exemption is granted from the mandatory use of the travel charge card,
the use of personal funds, including cash or personal charge card;
travel advances; or Government Travel Requests may be authorized for
payment of travel expenses. We continue to believe that until the Army
takes action to consider past credit problems in determining whether to
authorize issuing government travel cards, it will continue to increase
the risk that individuals will repeat a pattern of fraud, abuse, and
delinquency or nonpayment. Our report includes numerous examples of
such individuals, including those who were issued restricted cards.
Finally, in concurring with our recommendations regarding the lack of
segregation of duties and other voucher processing problems at the
California Army National Guard, DOD indicated that it had a number of
detective and compensating controls in place. While these appear
responsive to our recommendations, we have not evaluated the
effectiveness of their implementation and therefore cannot determine
whether these measures will resolve the problems we identified.
As agreed with your offices, unless you announce the contents of this
report earlier, we will not distribute it until 30 days from its date.
At that time, we will send copies to interested congressional
committees; the Secretary of Defense; the Under Secretary of Defense
for Acquisition, Technology, and Logistics; the Under Secretary of
Defense (Comptroller); the Secretary of the Army; the Director of the
Defense Finance and Accounting Service; the U.S. Property and Fiscal
Officer, California Army National Guard; and the Director of the Office
of Management and Budget. We will make copies available to others upon
request. In addition, the report will be available at no charge on the
GAO Web site at [hyperlink, http://www.gao.gov].
Please contact Gregory D. Kutz at (202) 512-9095 or kutzg@gao.gov, or
John J. Ryan at (202) 512-9587 or ryanj@gao.gov if you or your staffs
have any questions concerning this report.
Signed by:
Gregory D. Kutz:
Director:
Financial Management and Assurance:
Signed by:
Robert J. Cramer:
Managing Director:
Office of Special Investigations:
[End of section]
Appendix I: Background:
In 1983, the General Services Administration (GSA) awarded a
governmentwide master contract with a private company to provide
government-sponsored, contractor-issued travel cards to federal
employees to be used to pay for costs incurred on official business
travel. The intent of the travel card program was to provide increased
convenience to the traveler and to reduce the government‘s cost of
travel by reducing the need for cash advances to the traveler and the
administrative workload associated with processing and reconciling
travel advances. The travel card program includes both individually
billed accounts”accounts held and paid by individual cardholders”and
centrally billed accounts that are used to purchase transportation or
for the travel expenses of a unit and are paid directly by the
government. As of the end of fiscal year 2001, over 2.1 million
individually billed travel cards were issued to federal government
travelers. These travel cardholders charged $3.6 billion during the
fiscal year.
Under the current GSA master contract, the Department of Defense (DOD)
entered into a tailored task order with Bank of America [Footnote 30]
to provide travel card services to DOD and the military services,
including the Army. Table 7 provides the number of individually billed
travel cards outstanding and related dollar amount of travel card
charges by DOD and its components in relation to the total federal
government.
Table 7: Comparison of Number of Individually Billed Travel Cardholders
and Related Charges for DOD Versus Total Federal Government for Fiscal
Year 2001:
Entity: Army;
Number of individually billed travel cardholders as of September 30,
2001: 432,460;
Fiscal year 2001 individually billed travel card charges (dollars in
millions): $619.
Entity: Navy (includes Marine Corps);
Number of individually billed travel cardholders as of September 30,
2001: 394,952;
Fiscal year 2001 individually billed travel card charges (dollars in
millions): $510.
Entity: Air Force;
Number of individually billed travel cardholders as of September 30,
2001: 501,306;
Fiscal year 2001 individually billed travel card charges (dollars in
millions): $831.
Entity: Other DOD;
Number of individually billed travel cardholders as of September 30,
2001: 86,922;
Fiscal year 2001 individually billed travel card charges (dollars in
millions): $174.
Entity: Total DOD;
Number of individually billed travel cardholders as of September 30,
2001: 1,415,640;
Fiscal year 2001 individually billed travel card charges (dollars in
millions): $2,134.
Entity: Total federal government;
Number of individually billed travel cardholders as of September 30,
2001: 2,132,031;
Fiscal year 2001 individually billed travel card charges (dollars in
millions): $3,634.
Entity: DOD percentage of total government;
Number of individually billed travel cardholders as of September 30,
2001: 66%
Fiscal year 2001 individually billed travel card charges (dollars in
millions): 59%.
Source: Bank of America.
[End of table]
As shown in table 7, DOD accounts for about 1.4 million, or 66 percent,
of the total number of the individually billed travel cards issued by
the entire federal government, and DOD‘s cardholders charged about $2.1
billion, or about 59 percent, of the federal government‘s travel card
charges during fiscal year 2001. Table 7 also shows that the Army
provided 432,460 individually billed cards to its civilian and military
employees as of September 2001. These cardholders charged an estimated
$619 million to their travel cards during fiscal year 2001.
Travel Card Program Guidelines:
The Travel and Transportation Reform Act of 1998 (Public Law 105-264)
expanded the use of government travel cards by mandating the use of
cards for all official travel unless specifically exempted. The act is
intended to reduce the overall cost of travel to the federal government
through reduced administrative costs and by taking advantage of rebates
from the travel card contractor based on the volume of transactions
incurred using the card and on cardholders paying their monthly travel
card bills on time. To help cardholders pay their monthly bills on
time, the act also requires that agencies reimburse cardholders for
proper travel claims within 30 days of submission of approved travel
vouchers by the cardholders. [Footnote 31] Further, the act allows, but
does not require, agencies to offset a cardholder‘s pay for amounts the
cardholder owes to the travel card contractor as a result of travel
card delinquencies not disputed by the cardholder. The act calls for
GSA to issue regulations incorporating the requirements of the act.
GSA incorporated the act‘s requirements into the Federal Travel
Regulation. The Federal Travel Regulation governs travel and
transportation and relocation allowances for all federal government
employees, including overall policies and procedures governing the use
of government travel cards. Agencies are required to follow the
requirements of GSA‘s Federal Travel Regulation, but can augment these
with their own implementing regulations.
DOD issued its Financial Management Regulations (FMR), Volume 9,
Chapter 3, Travel Policies and Procedures, which supplements GSA‘s
travel regulations. DOD‘s Joint Travel Regulations, Volume 1 (for
Uniformed Service Members) and Volume 2 (for Civilian Personnel), refer
to the FMR as the controlling regulation for DOD‘s travel cards.
Further, the Army provided informational pamphlets intended to assist
its travelers: Pamphlet 55-16, Transportation and Travel: Civilian
Travel and Transportation Permanent Change of Station Travel; Pamphlet
55-20, Temporary Duty Travel: Uniformed Services Personnel Travel and
Transportation; and Pamphlet 55-22, Civilian Travel and Transportation:
Temporary Duty Travel. In addition, some of the Army‘s individual
commands and units have issued their own instructions supplementing GSA
and DOD guidelines.
The Army Travel Process:
As shown in figure 5, the Army‘s travel card management program for
individually billed travel card accounts encompasses card issuance,
travel authorization, cardholders charging goods and services on their
travel cards, travel voucher processing and payment, and managing
travel card usage and delinquencies.
Figure 5: The Army Travel Process:
[See PDF for image]
* Traveler requests travel card;
* APC processes travel card application approved by supervisor and
controls credit limits;
* B of A issues travel card;
* Official government travel authorized (travel order);
* Traveler charges goods and services on travel card;
* Traveler prepares voucher and provides to supervisor for review with
submission to DFAS;
* DFAS processes and pays[B] voucher;
* Merchant (e.g., rental car co.) provides goods/services and charges
travel card;
* Merchant bank accepts transaction deposit slips and transfers
payment;
* B of A processes card charges, pays merchant bank, and bills
traveler;
* B of A credit card data in EAGLS;
* APC monitors card usage and delinquencies[A] by accessing EAGLS;
* Traveler leaves service or moves;
* APC terminates or suspends card for traveler leaving Army or moving.
[A] See figure 7 for specific actions to be taken by the agency program
coordinator (APC).
[B] The Defense Finance and Accounting Service (DFAS) allows travelers
to direct a portion or all proceeds from the reimbursement of travel
vouchers to Bank of America. Army National Guard units process travel
vouchers at the units and then send electronic files to DFAS
authorizing payment.
[End of figure]
Travel Card Issuance and Termination:
When an Army civilian or military employee or the employee‘s supervisor
determines that he or she will need a travel card, the employee
contacts the unit‘s travel card agency program coordinator (APC) to
complete an individually billed card account application form. As shown
in figure 6, the application requires the applicant to provide
pertinent information, including full name and Social Security number,
and identify whether he or she is an active, reserve, or guard military
member or a civilian employee of the Army. The applicant is also
required to initial a statement on the application acknowledging that
he or she has read and understands the terms of the travel card
agreement and agrees to be bound by these terms, including a provision
acknowledging that the card will be used only for official travel. The
APC is required to complete the portion of the member‘s application
concerning who will be responsible for managing the use and
delinquencies related to the card. Bank of America is required to issue
travel cards to all applicants for whom it receives completed
applications signed by the applicants, the applicants‘ supervisors, and
the APCs.
Figure 6: Travel Card Application:
[See PDF for image]
This figure is a copy of the Individually Billed Card Account
Setup/Application Form (Department of Defense Travel Card Program),
issued by Bank of America.
[End of figure]
Bank of America issues travel cards with either a standard or restricted
credit limit. If an employee has little or no credit history or poor
credit based on a credit check performed by Bank of America, Bank of
America will suggest to the service that the applicant receive a
restricted card with a credit limit of $2,500 instead of the standard
card with a credit limit of $10,000. However, as shown in figure 6, the
application allows the employee to withhold permission for Bank of
America to obtain a credit report. If this option is selected, Bank of
America automatically issues a restricted card to the applicant.
When cardholders leave the Army, they are required to contact their APCs
and notify them of their planned departure. Based on this notification
from cardholders, the APCs are to terminate the cardholders‘ accounts.
Travel Authorization:
When a cardholder is required to travel for official government
purposes, he or she is issued a travel order authorizing travel. The
travel order is required to specify the timing and purpose of the
travel authorized. For example, the travel order is to authorize the
mode of transportation, the duration and points of the travel, and the
amount of per diem and any cash advances. Further, the Army can limit
the amount of authorized reimbursement to military members based on the
availability of lodging and dining facilities at military
installations.
Using the Travel Card for Official Travel Expenses:
For authorized travel, travelers must use their cards to pay for
allowable expenses, such as hotels and rental cars. The Army generally
uses a centrally billed transportation account to pay for air and rail
transportation. Also, some units utilize unit cards, a form of
centrally billed account, in lieu of individually billed travel charge
cards for meals and lodging for group trips.
When the travel card is submitted to a merchant, the merchant will
process the charge through its banking institution, which in turn
charges Bank of America. At the end of each banking cycle (once each
month) Bank of America prepares a billing statement that is mailed to
the cardholder for the amounts charged to the card. The statement also
reflects all payments and credits made to the cardholder‘s account.
Bank of America requires that the cardholder make payment on the
account in full within 25-30 days of the statement closing date. If the
cardholder does not pay his or her monthly billing statement in full,
and does not dispute the charges within 60 days of the statement
closing date, the account is considered delinquent.
Travel Voucher Submission and Processing:
Within 5 working days of return from travel, the cardholder is required
to submit a travel voucher claiming legitimate and allowable expenses
incurred while on travel. Further, the standard is for the cardholder to
submit an interim voucher every 30 days for extended travel of more than
45 days. The amount that cardholders are reimbursed for their meals and
incidental expenses and hotels is limited by geographical rates
established by GSA.
Upon submission of a proper voucher by the cardholder, the Army has 30
days in which to make reimbursement without incurring late payment fees.
Cardholders are required to submit their travel vouchers to their
supervisors or other designated approving officials who must review the
vouchers and approve them for payment. If a supervisor‘s review finds an
omission or error in a voucher or its required supporting documentation,
the approving official must inform the traveler of the error or
omission. If the payment of the approved voucher takes longer than 30
days, the Army is required to pay the cardholder a late payment fee
plus an amount equal to the amount Bank of America would have been
entitled to charge the cardholder had the cardholder not paid the bill
by the due date.
For all Army units other than those in the Army National Guard, after
the supervisor approves a cardholder‘s travel voucher package for
payment, it is sent to a DFAS location for processing and payment. In
the Army National Guard, guard units process, review, and approve all
vouchers at that level before they are sent to DFAS for payment. DFAS
(or the guard unit) enters travel information from the approved voucher
into DOD‘s Integrated Automated Travel System (IATS). IATS calculates
the amount of per diem authorized in the travel order and voucher and
the amount of mileage, if any, claimed by the cardholder. In addition,
any other expenses claimed and approved are entered into IATS. Once the
travel information from the voucher has been entered into IATS, the
voucher may be selected for further review or audit. DFAS travel
services supervisors audit 2 percent of vouchers under $2,500 and all
vouchers $2,500 and greater. In addition, vouchers for amounts $20,000
and over are audited again by DFAS Indianapolis travel services
technicians before payment is disbursed. If problems with a voucher are
found during the initial entry of the information into IATS or during
the audit of the information, the transaction can be rejected and
returned to the cardholder for correction. Once the item is
successfully processed through IATS, DFAS makes payment to the
cardholder or to Bank of America and the cardholder, if the cardholder
elected the split disbursement option whereby part of the reimbursement
is sent to Bank of America.
Monitoring Travel Card Transaction Activity:
In addition to controlling the issuance and credit limits related to
the travel card, APCs are also responsible for monitoring the use of and
delinquencies related to travel card accounts for which they have been
assigned management responsibility. Bank of America‘s Web-based
Electronic Account Government Ledger System (EAGLS) provides on-line
tools that are intended to assist APCs in monitoring travel card
activity and related delinquencies. Specifically, APCs can access EAGLS
to monitor and extract reports on their cardholders‘ travel card
transaction activity and related payment histories.
Managing Delinquent Cardholder Accounts:
Both the Army and Bank of America have a role in managing travel card
delinquencies under GSA‘s master contract. While APCs are responsible
for monitoring cardholders‘ accounts and for working with cardholders‘
supervisors to address any travel card payment delinquencies, Bank of
America is required to use EAGLS to notify the designated APCs if any of
their cardholders‘ accounts are in danger of suspension or cancellation.
When Bank of America has not received a required payment on any travel
cardholder‘s account within 60 days of the billing statement closing
date, the account is considered delinquent. As summarized in figure 7,
there are specific actions required by both the Army and Bank of
America based on the number of days a cardholder‘s account is past due.
Figure 7: Required Army and Bank of America Delinquency Process
Management Actions:
[See PDF for image]
This figure is an illustration of required Army and Bank of America
Delinquency Process Management Actions, as follows:
Statement date:
Bank of America action: Sends statement to cardholder;
DOD action: None.
45 days after statement date:
Bank of America action: Sends a delinquency reminder to cardholder;
DOD action: None.
55 days after statement date:
Bank of America action: Sends a pre-suspension letter to the
cardholder;
DOD action: None.
60 days after statement date:
Bank of America action: Suspends the account prohibiting purchases.
Mails suspension letter to cardholder;
DOD action: APC issues 60-day delinquency notification memorandum to
the cardholder and immediate supervisor. Supervisor investigates and
takes appropriate disciplinary action.
75 days after statement date:
Bank of America action: Assesses late fee every 30 days;
DOD action: None.
90 days after statement date:
Bank of America action: Sends 90-day letter to cardholder; Sends letter
to cardholder of intent to initiate salary offset;
DOD action: APC issues 90-day delinquency notification memorandum to
the cardholder, immediate supervisor, and the Company Commander who
investigates and takes appropriate disciplinary action.
120 days after statement date:
Bank of America action: Sends a pre-cancellation letter to the
cardholder; Requests DFAS to offset salary;
DOD action: APC issues a 120-day delinquency notification memorandum to
the Commander; The Commander investigates and takes appropriate
disciplinary action.
126 days after statement date:
Bank of America action: Closes account, mails notice of cancellation
letter to cardholder;
DOD action: None.
150 days after statement date:
Bank of America action: None.
DOD action: DFAS offsets salary.
180 days after statement date:
Bank of America action: Mails a pre-charge off letter to the
cardholder;
DOD action: None.
210 days after statement date:
Bank of America action: Charges off account;
DOD action: None.
Note: Starting in fiscal year 2002, DOD began to offset the salary of
certain civilian employees, military members, and retired military
members from all services, including the Army, for the amounts
delinquent or charged off on travel card accounts.
Source: GAO analysis.
[End of figure]
The following is a more detailed explanation of the required actions by
Army and/or Bank of America with respect to delinquent travel card
accounts.
* 45 days past due”Bank of America is to send a letter to the cardholder
requesting payment. Bank of America has the option to call the
cardholder with a reminder that payment is past due and to advise the
cardholder that the account will be suspended if it becomes 60 days past
due.
* 55 days past due”Bank of America is to send the cardholder a pre-
suspension letter warning that Bank of America will suspend the account
if it is not paid. If Bank of America suspends an account, the card
cannot be used until the account is paid.
* 60 days past due”The APC is to issue a 60-day delinquency notification
memorandum to the cardholder and to the cardholder‘s immediate
supervisor informing them that the cardholder‘s account has been
suspended by Bank of America due to nonpayment. The next day, a
suspension letter is to be sent by Bank of America to the cardholder
providing notice that the card has been suspended until payment is
received.
* 75 days past due”Bank of America is to assess the account a late fee.
The late fee charged by Bank of America was $20 through August 9, 2001.
Effective August 10, 2001, Bank of America increased the late fee to
$29 under the terms of the contract modification between Bank of
America and DOD. Bank of America is allowed to assess an additional
late fee every 30 days until the account is made current or charged
off.
* 90 days past due”The APC is to issue a 90-day delinquency notification
memorandum to the cardholder, the cardholder‘s immediate supervisor,
and the company commander (or unit director). The company commander is
to initiate an investigation into the delinquency and take appropriate
action, at his or her discretion. At the same time, Bank of America is
to send a ’due process letter“ to the cardholder providing notice that
the account will be canceled if payment is not received within 30 days
unless he or she enters into a payment plan, disputes charge(s) in
question, or declares bankruptcy.
* 120 days past due”The APC is to issue a 120-day delinquency
notification memorandum to the cardholder‘s commanding officer. At
the same time, Bank of America is to send a pre-cancellation letter to
the cardholder. At 126 days past due, the account is to be canceled by
Bank of America. Beginning in October 2001, once accounts were 120 days
past due, Bank of America began sending files to DFAS listing these
accounts for salary offset.
* 180 days past due”Bank of America is to send a ’pre-charge off“ or
last call letter to the cardholder informing him or her that Bank of
America will charge off the account and report the cardholder to a
credit bureau if payment is not received. A credit bureau is a service
that reports the credit history of an individual. Banks and other
businesses assess the credit-worthiness of an individual using credit
bureau reports.
* 210 days past due”Bank of America is to charge off the delinquent
account and, if the balance is $50 or greater, report it to a credit
bureau.
Some accounts are pursued for collection by Bank of America‘s recovery
department, others are sent to attorneys or collection agencies for
recovery. The delinquency management process can be suspended when a
cardholder‘s APC informs Bank of America that the cardholder is on
official travel, but is unable to submit vouchers and timely pay his or
her account, through no fault of his or her own. Under such
circumstances, the APC is to notify the Bank of America that the
cardholder is in mission-critical status. Activating this status
precludes Bank of America from identifying the cardholder‘s account as
delinquent until 45 days after such time as the APC determines the
cardholder is to be removed from mission-critical status. According to
Bank of America, approximately 800 to 1,000 cardholders throughout DOD
were in this status at any given time throughout fiscal year 2001.
[End of section]
Appendix II: Objectives, Scope, and Methodology:
Pursuant to a joint request by the Chairman and Ranking Minority Member
of the Subcommittee on Government Efficiency, Financial Management and
Intergovernmental Relations, House Committee on Government Reform, and
the Ranking Minority Member of the Senate Committee on Finance, we
audited the controls over the issuance, use, and monitoring of
individually billed travel cards and associated travel processing and
management for the Department of the Army. Our assessment covered:
* the reported magnitude and impact of delinquent and charged-off Army
travel card accounts for fiscal year 2001 and the first 6 months of
fiscal year 2002, along with an analysis of causes and related
corrective actions;
* an analysis of the universe of Army travel card transactions during
fiscal year 2001 to identify potentially fraudulent and abusive
activity related to the travel card;
* the Army‘s overall management control environment and the design of
selected Army travel program management controls, including controls
over (1) travel card issuance, (2) APCs‘ capacity to carry out assigned
duties, (3) limiting card activation to meet travel needs, (4)
transferred and orphan accounts, (5) procedures for terminating
accounts when cardholders leave military service, (6) segregation of
duties to ensure that no one individual can control all aspects of a
travel transaction, and (7) access to Bank of America‘s travel card
database; and;
* tests of statistical samples of transactions to assess the
implementation of key management controls and processes for four Army
units‘ travel activity, including (1) travel order approval, (2)
accuracy of travel voucher payments, (3) timely submission of travel
vouchers by travelers to the approving officials, and (4) timely
processing and reimbursement of travel vouchers by the Army and DOD.
We used as our primary criteria applicable laws and regulations,
including the Travel and Transportation Reform Act of 1998 (Public Law
105-264), [Footnote 32] the GSA‘s Federal Travel Regulation, [Footnote
33] and the DOD FMR, Volume 9, Travel Policies and Procedures. We also
used as criteria our Standards for Internal Control in Federal
Government [Footnote 34] and our Guide to Evaluating and Testing
Controls Over Sensitive Payments. [Footnote 35] To assess the
management control environment, we applied the fundamental concepts
and standards in our internal control standards to the practices
followed by management in the seven areas reviewed.
To assess the magnitude and impact of delinquent and charged-off
accounts, we compared the Army‘s delinquency and charge-off rates to
other DOD services and federal agencies. We also analyzed the trends in
the delinquency and charge-off data from fiscal year 2000 through the
first half of fiscal year 2002.
We also used data mining to identify Army individually billed travel
card transactions for audit. Our data mining procedures covered the
universe of individually billed Army travel card activity during fiscal
year 2001 and identified transactions that we believed were potentially
fraudulent or abusive. However, our work was not designed to identify,
and we did not determine, the extent of any potentially fraudulent or
abusive activity related to the travel card.
To assess the overall control environment for the travel card program
at the Department of the Army, we obtained an understanding of the
travel process, including travel card management and oversight, by
interviewing officials from the Office of the Under Secretary of
Defense (Comptroller); the Department of the Army; DFAS; Bank of
America; and GSA. We reviewed applicable policies and procedures and
program guidance they provided. We visited four Army units to gain an
understanding of the travel process, including the management of travel
card usage and delinquency. We visited the DFAS Orlando location to
gain an understanding of the voucher review and payment process used
for two of the four Army locations we tested. We also assessed actions
taken to reduce the severity of travel card delinquencies and charge-
offs. Further, we contacted one of the three largest U.S. credit
bureaus to obtain credit history data and information on how credit
scoring models are developed and used by the credit industry for credit
reporting.
We selected four Army locations for testing controls over travel card
activity based on the relative size of travel card activity at the 13
Army commands and of the units under these commands, the number and
percentage of delinquent accounts, and the number and percentage of
accounts written off. We selected two units from Army‘s Forces Command
because that command represented approximately 19 percent of travel
card activity, 22 percent of the delinquent accounts, and 28 percent of
accounts charged off during fiscal year 2001 across the Army. We also
selected an Army National Guard location because the Army National
Guard represented 13 percent of the total travel card activity, 22
percent of the delinquent accounts, and 15 percent of charge-offs for
fiscal year 2001. Special Operations Command represents about 6 percent
of Army‘s charge card activity, 5 percent of the delinquent accounts,
and 4 percent of Army travel card accounts charged off in fiscal year
2001. Each of the units within the commands was selected because of the
relative size of the unit within the respective command.
At each of the Army locations we audited we also used our review of
policies and procedures and the results of our understanding of travel
processes and other observations to assess the effectiveness of controls
over segregation of duties among persons responsible for preparing
travel vouchers, processing and approving travel vouchers, and
certifying travel voucher payments. In addition, to ensure that work
responsibilities were properly segregated at the California National
Guard so that no single individual can perform or control all key
aspects of computer-related operations, we performed a limited review
of security controls in place at that location over access to DOD‘s
Integrated Automated Travel System (IATS). California National Guard
personnel used this system to record and process travel vouchers. We
interviewed managers, users, and administrators of IATS at the
California National Guard and DFAS‘s Financial Services Office. We also
conducted limited observations of the IATS keying process at the
California National Guard.
We also reviewed computer system access controls for EAGLS”the system
used by Bank of America to maintain DOD travel card data. To determine
whether these controls over EAGLS were effective, we interviewed Bank
of America officials and observed EAGLS functions and capabilities.
To test the implementation of key controls over individually billed Army
travel card transactions processed through the travel system”including
the travel order, travel voucher, and payment processes”we obtained and
used the database of fiscal year 2001 Army travel card transactions.
Because our objective was to test controls over travel card expenses, we
excluded credits and miscellaneous debits (such as fees) from the
population of transactions used to select random samples of travel card
transactions to review at each of the four Army units we audited. Each
sampled transaction was subsequently weighted in the analysis to account
statistically for all charged transactions at each of the four units,
including those that were not selected. Table 8 presents the sites
selected and the number of fiscal year 2001 transactions at each
location. [Footnote 36]
Table 8: Population of Fiscal Year 2001 Travel Transactions at Army
Units Tested:
Army unit tested: Ft. Drum, Forces Command;
Number of fiscal year 2001 travel transactions[A]: 109,443;
Dollar value of fiscal year 2001 travel transactions[A]: $7,281,275.
Army unit tested: Ft. Bragg, Forces Command;
Number of fiscal year 2001 travel transactions[A]: 128,583;
Dollar value of fiscal year 2001 travel transactions[A]: $10,648,419.
Army unit tested: Ft. Bragg, Special Operations Command;
Number of fiscal year 2001 travel transactions[A]: 35,021;
Dollar value of fiscal year 2001 travel transactions[A]: $5,035,743.
Army unit tested: California National Guard;
Number of fiscal year 2001 travel transactions[A]: 58,797;
Dollar value of fiscal year 2001 travel transactions[A]: $5,035,457.
[A] Transactions represent charges for sales and cash advances and
exclude credits, fees, and other miscellaneous debits.
[End of table]
We performed tests on statistical samples of travel card transactions at
each of the four case study sites to assess whether the system of
internal control over the transactions was effective, as well as to
provide an estimate of the percentage of transactions by unit that were
not for official government travel. For each transaction in our
statistical sample, we assessed whether (1) there was an approved
travel order prior to the dates of travel, (2) the travel voucher
payment was accurate, (3) the travel voucher was submitted within 5
days of the completion of travel, and (4) the travel voucher was paid
within 30 days of the submission of an approved travel voucher. We
considered transactions not related to authorized travel to be abuse
and incurred for personal purposes. The results of the samples of these
control attributes, as well as the estimate for personal use”or
abuse”related to travel card activity, [Footnote 37] can be projected
to the population of transactions at the respective case study site
only, not to the population of travel card transactions for all Army
cardholders.
We concluded that a control was effective if both the projected point
estimate of the failure rate and the upper bound of a one-sided 95
percent confidence interval associated with the estimate were no more
than 5 percent. We concluded that a control was ineffective if both the
point estimate of the failure rate and the lower bound of a one-sided
95 percent confidence interval associated with the estimate were
greater than 10 percent. Any point estimate between 5 and 10 percent
would generate an assessment of partially effective. Tables 9 through
11 show (1) the results of our tests of key attributes, (2) the point
estimates of the failure rates for the attributes, and (3) the two-
sided 95 percent confidence intervals for the failure rates for each
attribute. Table 9 shows the results of our test of the key control
related to the authorization of travel (approved travel orders were
prepared prior to dates of travel).
Table 9: Estimate of Fiscal Year 2001 Transactions That Failed Control
Tests for Approved Travel:
Army unit tested: Ft. Bragg, Forces Command;
Number of failed transactions: 6 of 96;
Estimated failure rate (95% confidence interval): 6.2% (2.3%, 13.1%).
Army unit tested: Ft. Drum, Forces Command;
Number of failed transactions: 0 of 96;
Estimated failure rate (95% confidence interval): 0% (0%, 3.8%).
Army unit tested: Ft. Bragg, Special Operations Command;
Number of failed transactions: 3 of 96;
Estimated failure rate (95% confidence interval): 3.1% (.6%, 8.9%).
Army unit tested: California National Guard;
Number of failed transactions: 1 of 96;
Estimated failure rate (95% confidence interval): 1.04% (.03%, 5.7%).
[End of table]
Table 10 shows the results of our test for effectiveness of controls in
place over the accuracy of travel voucher payments.
Table 10: Estimate of Fiscal Year 2001 Transactions That Failed Control
Tests for Accurate Travel Voucher Payments:
Army unit tested: Ft. Bragg, Forces Command;
Number of failed transactions: 18 of 96;
Estimated failure rate (95% confidence interval): 18.8% (11.5%, 28.0%).
Army unit tested: Ft. Drum, Forces Command;
Number of failed transactions: 10 of 96;
Estimated failure rate (95% confidence interval): 10.4% (5.1%, 18.3%).
Army unit tested: Ft. Bragg, Special Operations Command;
Number of failed transactions: 7 of 96;
Estimated failure rate (95% confidence interval): 7.3% (3.0%, 14.4%).
Army unit tested: California National Guard;
Number of failed transactions: 18 of 43;
Estimated failure rate (95% confidence interval): 41.9% (27.0%, 57.9%).
[End of table]
Table 11 shows the results of our tests of two key controls related to
timely processing of claims for reimbursement of expenses related to
government travel”timely submission of the travel voucher by the
employee and timely approval and payment processing of the travel
voucher.
Table 11: Estimate of Fiscal Year 2001 Transactions That Failed Control
Tests for Timely Submission and Processing of Travel Vouchers:
Army unit tested: Ft. Bragg, Forces Command;
Timely voucher submission by employee (5-day rule), Number of failed
transactions: 37 of 96;
Timely voucher submission by employee (5-day rule), Estimated failure
rate (95% confidence interval): 38.5% (28.8%, 49.0%);
Timely reimbursement to the traveler (30-day rule), Number of failed
transactions: 8 of 96;
Timely reimbursement to the traveler (30-day rule), Estimated failure
rate (95% confidence interval): 8.3% (3.7%, 15.8%).
Army unit tested: Ft. Drum, Forces Command;
Timely voucher submission by employee (5-day rule), Number of failed
transactions: 21 of 96;
Timely voucher submission by employee (5-day rule), Estimated failure
rate (95% confidence interval): 21.9% (14.1%, 31.5%);
Timely reimbursement to the traveler (30-day rule), Number of failed
transactions: 5 of 96;
Timely reimbursement to the traveler (30-day rule), Estimated failure
rate (95% confidence interval): 5.2% (1.7%, 11.7%).
Army unit tested: Ft. Bragg, Special Operations Command;
Timely voucher submission by employee (5-day rule), Number of failed
transactions: 29 of 96;
Timely voucher submission by employee (5-day rule), Estimated failure
rate (95% confidence interval): 30.2% (21.2%, 40.4%);
Timely reimbursement to the traveler (30-day rule), Number of failed
transactions: 7 of 96;
Timely reimbursement to the traveler (30-day rule), Estimated failure
rate (95% confidence interval): 7.3% (3.0%, 14.4%).
Army unit tested: California National Guard;
Timely voucher submission by employee (5-day rule), Number of failed
transactions: 12 of 43;
Timely voucher submission by employee (5-day rule), Estimated failure
rate (95% confidence interval): 27.9% (15.3%, 43.7%);
Timely reimbursement to the traveler (30-day rule), Number of failed
transactions: 26 of 43;
Timely reimbursement to the traveler (30-day rule), Estimated failure
rate (95% confidence interval): 60.5% (44.4%, 75.0%).
[End of table]
To determine if cardholders were reimbursed within 30 days, we used
payment dates provided by DFAS. We did not independently validate the
accuracy of these reported payment dates.
We briefed the following officials on the details of our review,
including our objectives, scope, and methodology and our findings and
conclusions: DOD managers, including officials in DFAS; Army managers,
including Office of the Assistant Secretary of the Army (Financial
Management and Comptroller) officials; Army Forces Command and Special
Operations Command unit commanders; unit-level APCs; Army National
Guard Bureau management and the California National Guard Adjutant
General; and Bank of America officials. We incorporated their comments
where appropriate. With the exception of our limited review of access
controls at the California National Guard, we did not review the
general or application controls associated with the electronic data
processing of Army travel card transactions. We conducted our audit
work from December 2001 through July 2002 in accordance with U.S.
generally accepted government auditing standards, and we performed our
investigative work in accordance with standards prescribed by the
President‘s Council on Integrity and Efficiency. We received DOD
comments on a draft of this report from the Under Secretary of Defense
(Comptroller) dated September 30, 2002, and have reprinted those
comments in appendix V.
[End of section]
Appendix III: Army Major Command Delinquency Rates:
Table 12 shows the travel card delinquency rates for Army‘s major
commands (and other Army organizational units at a comparable level)
that had outstanding balances over $1 million during the 2-year period
ending March 31, 2002. The Army‘s commands and other units are listed in
descending order based on their respective delinquency rates as of
March 31, 2002. The delinquency rates shown represent the total amount
delinquent (amounts not paid within 61 days of the travel card monthly
statement closing date) as a percentage of total amounts owed by the
command‘s travel cardholders at a point in time.
Table 12: Army Major Command Delinquency Rates (by Quarter) for the 2
Years Ending March 31, 2002:
Command[A]: U.S. Army Forces Command;
June 2000: 22.2;
September 2000: 25.1;
December 2000: 28.7;
March 2001: 23.1;
June 2001: 18.6;
September 2001: 22.1;
December 2001: 30.5;
March 2002: 23.7.
Command[A]: U.S. Army Pacific Command;
June 2000: 19.5;
September 2000: 25.1;
December 2000: 28.2;
March 2001: 19.8;
June 2001: 15.0;
September 2001: 18.7;
December 2001: 22.5;
March 2002: 18.9.
Command[A]: U.S. Army National Guard;
June 2000: 16.9;
September 2000: 16.4;
December 2000: 22.9;
March 2001: 13.6;
June 2001: 13.4;
September 2001: 16.2;
December 2001: 20.9;
March 2002: 18.4.
Command[A]: U.S. Army Europe and 7th Army Command;
June 2000: 17.8;
September 2000: 20.4;
December 2000: 21.1;
March 2001: 15.8;
June 2001: 13.0;
September 2001: 17.1;
December 2001: 22.5;
March 2002: 16.9.
Command[A]: U.S. Army orphan[B];
June 2000: 16.2;
September 2000: 22.2;
December 2000: 40.1;
March 2001: 38.1;
June 2001: 23.1;
September 2001: 20.4;
December 2001: 24.4;
March 2002: 16.9;
Command[A]: U.S. Army Reserve;
June 2000: 14.3;
September 2000: 16.0;
December 2000: 20.9;
March 2001: 13.1;
June 2001: 11.6;
September 2001: 11.9;
December 2001: 21.4;
March 2002: 15.3.
Command[A]: U.S. Army Recruiting Command;
June 2000: 22.5;
September 2000: 19.2;
December 2000: 17.4;
March 2001: 20.4;
June 2001: 13.6;
September 2001: 13.7;
December 2001: 10.6;
March 2002: 13.1.
Command[A]: U.S. Army Special Operations Command;
June 2000: 16.9;
September 2000: 17.4;
December 2000: 17.9;
March 2001: 9.9;
June 2001: 10.1;
September 2001: 10.6;
December 2001: 16.6;
March 2002: 12.0.
Command[A]: U.S. Army Operating Agency 22[C]:
June 2000: 8.7;
September 2000: 11.1;
December 2000: 11.4;
March 2001: 7.4;
June 2001: 7.0;
September 2001: 8.7;
December 2001: 12.2;
March 2002: 9.0.
Command[A]: U.S. Army Training and Doctrine Command;
June 2000: 10.8;
September 2000: 11.7;
December 2000: 13.9;
March 2001: 8.8;
June 2001: 8.4;
September 2001: 10.2;
December 2001: 12.1;
March 2002: 8.2.
Command[A]: U.S. Army Medical Corps;
June 2000: 12.3;
September 2000: 13.9;
December 2000: 14.8;
March 2001: 9.9;
June 2001: 8.1;
September 2001: 8.0;
December 2001: 12.3;
March 2002: 7.7.
Command[A]: U.S. Army Intelligence and Security Command;
June 2000: 10.3;
September 2000: 12.1;
December 2000: 11.9;
March 2001: 5.9;
June 2001: 5.6;
September 2001: 6.0;
December 2001: 4.2;
March 2002: 5.8.
Command[A]: U.S. Army Corps of Engineers;
June 2000: 4.8;
September 2000: 5.6;
December 2000: 6.5;
March 2001: 4.5;
June 2001: 3.3;
September 2001: 3.9;
December 2001: 5.8;
March 2002: 3.6.
Command[A]: U.S. Army Material Command;
June 2000: 3.4;
September 2000: 3.6;
December 2000: 4.4;
March 2001: 2.1;
June 2001: 2.1;
September 2001: 2.3;
December 2001: 2.4;
March 2002: 1.5.
Command[A]: All other commands combined;
June 2000: 8.5;
September 2000: 9.7;
December 2000: 11.1;
March 2001: 8.4;
June 2001: 5.9;
September 2001: 6.8;
December 2001: 7.2;
March 2002: 6.9.
Command[A]: Army-wide;
June 2000: 13.9;
September 2000: 15.5;
December 2000: 18.5;
March 2001: 13.3;
June 2001: 10.7;
September 2001: 12.5;
December 2001: 16.6;
March 2002: 12.8.
[A] Commands are ranked by the largest percentage of dollars delinquent
as of March 31, 2002. Commands with a March 31, 2002, balance
outstanding under $1 million have been combined into ’All other
commands combined.“
[B] U.S. Army orphan accounts are (1) Army travel card accounts that
are not under the purview of any APC and (2) accounts Banks of America
inherited from the previous government travel card contractor that were
not linked to any Army command and accounts for which the accountable
APC left or was relocated without having a replacement designated.
[C] U.S. Army Operating Agency 22 consists of various Army headquarters
and administrative offices, such as the Secretary of the Army, the
Assistant Secretary of the Army for Financial Management and
Comptroller, the Army Audit Agency, and the Army Judge Advocate
General.
Source: GAO calculation based on information provided by Bank of
America.
[End of table]
[End of section]
Appendix IV: Army Personnel Grade, Rank, and Associated Basic Pay
Rates:
Tables 13 and 14 show the grade, rank (where relevant), and the
associated basic pay rates for 2001 for Army‘s military and civilian
personnel, respectively. The basic 2001 pay rates shown exclude other
considerations, such as locality pay and any allowances for housing or
cost of living.
Table 13: Army Military Grades, Ranks, and Associated Basic Pay Rates
for Fiscal Year 2001:
Military grade: Enlisted personnel: E-1 to E-3;
Military rank: Private;
2001 pay: $11,033 to $14,449.
Military grade: Enlisted personnel: E-4 to E-6;
Military rank: Corporal to Staff Sergeant;
2001 pay: $17,739 to $26,253.
Military grade: Enlisted personnel: E-7 to E-9;
Military rank: Platoon Sergeant to Sergeant Major;
2001 pay: $31,563 to $46,445,
Military grade: Officers[A]: WO-1 to WO-5;
Military rank: Warrant Officer;
2001 pay: $29,302 to $60,152.
Military grade: Officers[A]: O-1 to O-3;
Military rank: First Lieutenant, Second Lieutenant, Captain;
2001 pay: $26,731 to $45,339.
Military grade: Officers[A]: O-4 to O-6;
Military rank: Major, Lieutenant Colonel, Colonel;
2001 pay: $56,635 to $84,317.
Military grade: Officers[A]: O-4 to O-6;
Military rank: Major, Lieutenant Colonel, Colonel;
2001 pay: $56,635 to $84,317.
Military grade: Officers[A]: O-7 to O-10;
Military rank: General;
2001 pay: $98,960 to $132,826
[A] Officers‘ ranks includes warrant officers (denoted by WO) and
commissioned officers (denoted by O).
Source: U.S. Army.
[End of table]
Table 14: Army Civilian Grades and Associated Basic Pay Rates for
Calendar Year 2001:
Civilian grade: General schedule employees: GS-1 to GS-3;
2001 pay: $14,244 to $22,712.
Civilian grade: General schedule employees: GS-4 to GS-5;
2001 pay: $19,616 to $28,535.
Civilian grade: General schedule employees: GS-6 to GS-8;
2001 pay: $24,463 to $39,143.
Civilian grade: General schedule employees: GS-9 to GS-12;
2001 pay: $33,254 to $62,686.
Civilian grade: General schedule employees: GS-13 to GS-15;
2001 pay: $57,345 to $103,623.
Civilian grade: Senior Executive Service: ES-01 to ES-06;
2001 pay: $109,100 to $125,700
Source: Office of Personnel Management.
[End of table]
[End of section]
Appendix V: Comments from the Department of Defense:
Under Secretary Of Defense:
Comptroller:
1100 Defense Pentagon:
Washington, DC 20301-1100:
September 30, 2002:
Mr. Gregory D. Kutz:
Director:
Financial Management and Assurance:
U.S. General Accounting Office:
Washington, DC 20548:
Dear Mr. Kutz:
This is the Department of Defense (DoD) response to the General
Accounting Office (GAO) draft report, "GAO-02-986 "Travel Cards:
Control Weaknesses Leave Army Vulnerable to Fraud and Abuse," August 1,
2002 (GAO Code 192066)."
The Department reviewed the draft report and recognizes the intent of
the recommendations. The Department takes travel and purchase charge
card abuse and misuse very seriously. At the direction of Secretary
Rumsfeld, I established a DoD Charge Card Task Force on March 2002 to
review and analyze the problems with the DoD charge card programs. The
Task Force completed its review on June 27, 2002, and has developed a
full range of reforms. Many are well underway.
We are taking actions to strengthen and enforce internal controls and
increase the tools available to managers for enforcing those controls.
These include employing data mining technologies to detect fraudulent
or abusive charge card transactions. We are also increasing management
emphasis and personal accountability, enhancing the capability of the
workforce to accomplish assigned charge card responsibilities to
include training and recommending minimum skills required for
performing essential charge card management tools.
To date, I have directed the cancellation of approximately 400,000
inactive travel charge card accounts. Travel charge cards in the hands
of individuals without legitimate need are an unnecessary
administrative burden and could lead to potential abuse and misuse. We
have taken other actions including the involuntarily deduction of
delinquent balances from the pay of military members and civilian
employees who fail to pay their delinquent travel charge accounts. We
also are looking at alternatives to the travel charge card such as
debit and stored value cards.
Regarding this specific report on the Army's Travel Card program, the
Department concurs or partially concurs with the majority of the
recommendations. As mentioned above, many actions have already been
taken or will soon be taken to implement a number of the
recommendations. In its draft report, the GAO recommends that the
Secretary of the Army "establish appropriate, consistent Army-wide
policy on disciplinary actions that are to be taken with respect to
fraudulent and abusive activity and delinquency related to the travel
card." The Department would be inclined to concur with the GAO's
recommendation to establish, by policy, the nature of the disciplinary
action to be taken in cases involving either civilian employees or
military personnel. Nevertheless, in practice, the Department is
limited by current law as to what further actions it can take in this
regard.
Please note that the Army already has a strong Army-wide policy in
place against theft, fraud, and other intentionally dishonest conduct
on the part of civilian employees. This policy states that: "It is the
policy of the Army that any civilian employee found to have engaged in
theft, fraud, or other intentionally dishonest conduct against the Army
will be considered for removal from federal service. Any lesser penalty
will require justifiable mitigating circumstances. It is the duty of
all supervisors to ensure that this policy is implemented." It would be
inconsistent with current law for the Army to establish further
mandatory requirements that impose specific disciplinary actions on
individual employees.
With respect to military personnel, commanders at all levels are
required to exercise their individual discretion in determining the
appropriate discipline warranted. Orders, policies, or guides that
infringe upon a commander's discretion are prohibited under the Uniform
Code of Military Justice. The Manual for Courts-Martial establishes
those permissible policies and factors for commanders to consider when
determining appropriate dispositions and punishments for military
personnel. The Department's civilian leadership is prohibited from
implementing policies that serve to mandate or require certain
disciplinary actions or forms of punishment.
For these reasons, we suggest that the recommendation focus on policies
that establish when and how commanders are notified of suspected fraud
or abuse involving travel cards. The enclosure includes detailed
comments on the recommendations contained in the report.
The Department appreciates the opportunity to comment on the draft
report. My staff point of contact on this matter is Mr. Ron Massengill.
He may be contacted by e-mail: massengr@osd.pentagon.mil or by
telephone at (703) 697-1101.
Sincerely,
Dov S. Zakheim:
Enclosure:
GAO Draft Report, GAO-02-986/Code 192066:
"Travel Cards: Control Weaknesses Leave Army Vulnerable To Fraud And
Abuse," August 1, 2002:
Department Of Defense Comments To The GAO Recommendations:
Overall GAO Recommendation: To strengthen the overall control
environment and improve internal control for the Army's travel card
program, the GAO recommended that the Secretary of the Army take the
following actions. The GAO also recommended that the Under Secretary of
Defense (Comptroller) assess the following recommendations, and where
applicable incorporate them into or supplement the DoD Charge Card Task
Force recommendations to improve travel card policies and procedures
throughout DoD.
Recommendation 1: Travel Card Issuance:
The GAO recommended that the Secretary of the Army establish specific
policies and procedures governing the issuance of individual travel
cards to military and civilian employees, including the following:
* Evaluate the feasibility of extended use of credit checks for all
travel card applicants.
* For credit check results currently obtained and additional future
credit checks, to use the results to make decisions on travel card
applicants. Decisions on whether to issue a travel card should consider
prior credit problems (e.g., bankruptcy, convictions for writing bad
checks, and defaulted credit cards, home mortgages, and automobile
loans).
* Individuals with prior credit problems that are denied a travel card
should either be required to use their own credit card to travel or be
provided alternative means of travel funding, such as advances.
* Individuals with no prior credit history should be provided with a
"restricted" travel card with low credit and ATM limits.
* Develop procedures to periodically evaluate card usage and close
accounts of infrequent travelers, which will minimize exposure to fraud
and abuse.
* Cancel accounts for current infrequent travelers as noted in the
Charge Card Task Force report.
* Evaluate the feasibility of establishing a policy to activate and
deactivate cards on pre-determined start and end dates, which are tied
to the cardholders' authorized travel orders. At a minimum, this policy
should focus on controlling travel card use for the "high risk"
enlisted military personnel in the E-1 to E-6 grades.
* Develop comprehensive, consistent Army-wide initial training and
periodic refresher training for travel cardholders, focused on the
purpose of the program and appropriate uses of the card. The training
should emphasize the prohibitions on personal use of the card,
including for gambling, personal travel, and adult entertainment. Such
training should also address the policies and procedures of the travel
order, voucher, and payment processes. For entry-level personnel, the
training should also include information on basic personal financial
management techniques to help avoid financial problems that could
affect an individual's ability to pay his or her travel card bill. (GAO
Draft Report/pp. 66-68)
DOD Response: Concur. The Army has either implemented or will soon take
action to implement the recommended actions.
* The current process does consider the results of credit checks and
those with prior credit problems are issued a restricted travel card.
Commanders must have the flexibility to issue restricted travel cards
to key personnel on a case-by-case basis. Mandatory use of the
government travel card is required by the Travel and Transportation
Reform Act (TTRA) of 1998 (PL 105-264).
* The Department will evaluate the feasibility of extended use of
credit checks. There are issues arising from the Fair Credit Reporting
Act (15 U.S.C. 1681b) that must be addressed.
* Individuals who decline a credit check, or whose credit check reveals
a low credit score may still have travel requirements that meet the
mandatory use conditions of the TTRA. Those individuals are assigned a
restricted card with half of the spending limit of a standard card.
* The travel charge card contractor is prohibited from discussing
credit scores with the APC, but has in the past, recommended or
strongly recommended issuance of a restricted product based on the
results of the credit check. This recommendation has been accepted by
supervisors/commanders in over 99% of the cases.
* The Department is taking additional measures to address delinquencies
and abuse, and is exploring alternatives to the charge card that may be
applicable in situations where there is a poor credit history or no
credit history. Until those measures are evaluated and available, the
Department must continue to meet its travel needs through the existing
charge card program in accordance with the TTRA.
* Army infrequent traveler accounts are among the 400,000 accounts that
the Under Secretary of Defense (Comptroller) has directed be canceled
by the travel charge card contractor in his memorandum dated July 19,
2002, in accordance with a recommendation of the Charge Card Task
Force.
* By September 30, 2002, the Army intends to instruct commanders/
supervisors to conduct semi-annual reviews of card usage and cancel
cards of infrequent travelers.
* The Army will evaluate the feasibility of requiring the activation/
deactivation of card inventories based on the issuance of travel
orders. In accordance with a recommendation of the Charge Card Task
Force, the Program Office of the Defense Travel System is evaluating
whether and how an activation/deactivation capability could be added to
the Defense Travel System. Currently, there is no automated way to
accomplish this.
* By September 30, 2002, the Army intends that the Army travel card
program manager, will survey major commands to find out which of them
have high incidents of junior enlisted travel. Based on data such as
frequency and duration of travel, grade and incidents of delinquency,
will recommend actions to effectively control this segment of the card
population.
* By September 30, 2002, the Army intends to direct commanders and
supervisors to ensure that cardholders receive training on the
authorized use of the travel card prior to issuance. In addition to the
current cardholder agreement, cardholder training available on the
EAGLS Help Desk website will be used to meet this requirement. This
training will be documented and, along with a statement of
understanding signed by the cardholder, will be kept on record for
future review. Also, in accordance with a recommendation of the Charge
Card Task Force, a training Compact Disk (CD) is being developed to
provide the results of the Task Force to travel charge card program
officials and cardholders DoD wide. The CD is intended to be used both
as training for new program officials/cardholders and as a quick
reference tool when questions on proper use and prohibitions arise.
Recommendation 2: Monitoring, Review, And Disciplinary Actions:
The GAO recommended that the Secretary of the Army establish the
following specific policies and procedures to strengthen controls and
disciplinary actions for improper use of the travel card:
* Establish Army guidance on who should be given APC responsibilities
that considers (1) the knowledge, skills, and abilities required to
effectively carry out these responsibilities, (2) the time required to
effectively carry out APC responsibilities on a day-to-day basis, (3)
the length of time an individual should be required to stay in the APC
position in light of time required to become proficient in the use of
the tools relied on to effectively monitor card usage. Army should
evaluate whether the APC position should be full time.
* To avoid high APC turnover, Army should evaluate the feasibility of
maximizing the use of civilian rather than military employees to serve
the role of APC.
* Establish guidance on APC span of control responsibilities so that
such responsibilities are properly aligned with time available to
ensure effective performance.
* Establish procedures to provide assurance that APCs receive training
on their APC responsibilities, including how to use EAGLS transaction
reports and other available data to monitor cardholder use of the
travel card--for example, reviewing account transactional histories to
ascertain whether transactions are incurred during periods of
authorized travel and appear to be appropriate travel expenses and from
approved merchant category codes.
* APCs should be trained to review EAGLS reports to identify
cardholders that have written NSF checks for payment of their account
balances, and refer the employee for disciplinary action.
* Review, in conjunction with the travel charge card contractor,
individuals with APC-level access to EAGLS to limit such access to only
those with current APC duties.
* Establish Army procedures detailing how APCs should carry out their
responsibility to monitor card usage for all cardholders assigned to
them. Included in the procedures should be development of a data-mining
program enabling APCs to scan a large number of transactions, and
target potentially inappropriate transactions for further review.
* Establish a requirement for assessing performance of travel
monitoring and other APC duties as a rating factor on all APCs'
performance evaluations.
* Establish an Army requirement for cognizant APCs to retain records
documenting any cardholder's fraudulent or abusive usage of the travel
card and require this information to be provided to the gaining APC
when the cardholder is transferred.
* Establish appropriate, consistent Army-wide policy on disciplinary
actions that are to be taken with respect to fraudulent and abusive
activity and delinquency related to the travel card.
* Refer any travel cardholders with secret or higher level of security
clearance for whom financial problems related to the travel card are
detected, to Army CAF for investigation as to whether the individual
should continue to be entrusted with a secret or higher clearance.
* Assign responsibility and accountability over cardholders
transferring between Army units or locations, including cardholders
currently in "orphan" status. Any accounts not assigned to an APC
should be immediately canceled.
* Strengthen procedures for any employee discharging from service so
that all cards are obtained from the holder, accounts are closed, and
repayment of any outstanding debts is arranged.
* Backup procedures should be developed to identify active cards of
departed cardholders, including comparing cardholder and payroll data.
(GAO Draft Report/pp.68-70).
DOD Response: Partially concur. The Army has either implemented or will
soon take action to implement most of these recommendations. The
Department has concerns, however, about the recommendations to: (1)
have APCs identify cardholders with NSF checks and refer them for
disciplinary action, and (2) establish an Army-wide disciplinary action
policy for abusive travel card activity.
* Not later than September 30, 2002, the Army intends to direct
commanders to ensure that individuals selected to be Agency Program
Coordinators (APC) possess the knowledge, skills, and abilities to
carry out the responsibilities of the position. As part of this
direction, the Army will require that APCs are fully trained prior to
assuming their duties and receive refresher training on an annual
basis. This training will be documented for future audit review.
Training will include a comprehensive block on EAGLS and, in
particular, the reporting tool as a means to identify abuse and misuse
and will be provided by the travel charge card contractor trainers or
qualified Army resources (e.g., HQ DA, MACOM).
* The Army will instruct commanders to determine the specific span of
control needed to provide effective account oversight to meet program
requirements and mission needs and to ensure that the APC function is
adequately staffed.
* The Army will evaluate the feasibility of using data from various
databases (e.g., personnel, pay systems) to verify status and location
of separating/departed cardholders. In a memorandum dated July 19,
2002, the Under Secretary of Defense (Comptroller) directed the
cancellation of existing "orphan" status accounts and established the
requirement to continually review and cancel these accounts on a semi-
annual basis. Army cardholder accounts currently in the "orphan
hierarchy" were deactivated on August 13, 2002, and, if the cardholder
does not respond with requested information, will be canceled on
October 11, 2002.
* The Vice Chief of Staff, Army wrote senior Army commanders on August
13, 2002, on the urgent need to reduce the Army's unacceptably high
rate of cardholder delinquency and to eliminate card misuse.
* In a memorandum dated August 9, 2002, the Under Secretary of Defense
(Comptroller) issued guidance to all Services and Agencies to validate
the need for APC access to EAGLS system and delete unneeded access. The
Army is currently working to eliminate ex-APCs from the active EAGLS
file. The estimated completion date for this effort is September 30,
2002.
* Partially concur with the recommendation that "APCs should be trained
to review EAGLS reports to identify cardholders that have written NSF
checks for payment of their account balances, and refer the employee
for disciplinary action."
- Not later than September 30, 2002, the Army intends to publish
guidance, outlining general to specific APC responsibilities. It will
allow commanders to add/delete specific actions to meet their unique
mission requirements. The guidance will stress that the APC duty should
be considered a principal duty and that consideration should be given
to maximizing the use of the civilian workforce, where available, to
serve as APC. The Army will require APCs to notify supervisors/
commanders of incidents of apparent abuse, misuse, delinquency, and
other events (e.g., NSF checks) that may indicate financial problems
and may require investigation to determine if the incidents jeopardize
maintaining a security clearance. In accordance with a recommendation
of the DoD Charge Card Task Force, the Office of the Inspector General,
DoD, and the Defense Finance and Accounting Service are working
cooperatively to determine whether or not data mining techniques can be
effectively applied to travel card program. Data has been requested
from the travel charge card contractor for use in developing initial
indicators.
- However, it should be understood that it is commanders of military
members, not APCs who make determinations as to what action is
appropriate based on all the facts. For example, every case involving a
"NSF" check has its own set of facts. Appropriate actions may include
oral counseling, written counseling, revocation of the travel card or
more permanent adverse administrative actions that impact the soldiers
official record. In serious abuse cases, criminal prosecution under the
UCMJ may be appropriate. Not every case, however, is a referral "for
disciplinary action."
* The Department would be inclined to concur with the GAO's
recommendation to establish, by policy, the nature of the disciplinary
action to be taken in cases involving either civilian employees or
military personnel. Nevertheless, in practice, the Department is
limited by current law as to what further actions it can take in this
regard.
- Please note that the Army already has a strong Army-wide policy in
place against theft, fraud, and other intentionally dishonest conduct
on the part of civilian employees. This policy states that: "It is the
policy of the Army that any civilian employee found to have engaged in
theft, fraud, or other intentionally dishonest conduct against the Army
will be considered for removal from federal service. Any lesser penalty
will require justifiable mitigating circumstances. It is the duty of
all supervisors to ensure that this policy is implemented." It would be
inconsistent with current law for the Army to establish further
mandatory requirements that impose specific disciplinary actions on
individual employees.
- With respect to military personnel, commanders at all levels are
required to exercise their individual discretion in determining the
appropriate discipline warranted. Orders, policies, or guides that
infringe upon a commander's discretion are prohibited under the Uniform
Code of Military Justice. The Manual for Courts-Martial establishes
those permissible policies and factors for commanders to consider when
determining appropriate dispositions and punishments for military
personnel. The Department's civilian leadership is prohibited from
implementing policies that serve to mandate or require certain
disciplinary actions or forms of punishment.
* Concur with the recommendation to establish a requirement for
assessing performance of travel monitoring and other APC duties as a
rating factor on all APC performance evaluations. The Department will
pursue the establishment of APC duties as a rating factor on APC
performance evaluations in all DoD Components.
* Concur with the recommendation to refer any travel cardholders with
secret or higher level of security clearance to Army CAF for
investigation as to whether the individual should continue to be
entrusted with a secret or higher clearance. In accordance with a
recommendation of the Charge Card Task Force, the Office of the Under
Secretary of Defense (Comptroller) is working with the Office of the
Assistant Secretary of Defense (Command, Control, Communications and
Intelligence) to provide guidance to the Components on the suspension
of access to classified information due to abuse or misuse of
government charge cards.
* Concur with the recommendation to strengthen procedures for any
employee discharging from Service so that all cards are obtained from
the holder, accounts closed, and repayment of any outstanding debts is
arranged.
- For military personnel outprocessing at the Government Travel Card
and Military Pay Stations, existing requirements are already identified
in AR 600-8-101, Personnel Processing (In- and Out- and Mobilization
Processing). All transitioning soldiers are required to complete these
stations. The travel card is to be destroyed, and any unpaid debts
processed. Government Travel Cards are also a part of the Installation
Clearance Record check (DA Form 137-2-R, Item 13, DoD Travel Charge
Card Program Coordinator, and Section C, Military Pay Processing, Item
17, Debt Processing). Provisions are in place.
- The Army has developed functional requirements for automated In and
Out Processing systems for civilian employees. At present these
functions are accomplished manually by staffs of local commanders who
have developed checklists and procedures tailored to the requirements
at each depot, arsenal or installation. The objective of developing a
centralized In and Out Processing system is to reengineer and
standardize the process and save workyears. This objective is part of
the Army's plan for using technology to improve efficiency. We will
review the military methodology for outprocessing and adjust our
requirements to ensure consistency in both military and civilian
processes when possible.
- In accordance with a recommendation of the Charge Card Task Force,
the Department is evaluating ways to ensure cards of those who separate
from the Department are closed. In addition to requiring turn in of
cards during routine checkout procedures, the Department is exploring
how to best develop and distribute lists of separated employees to APCs
to ensure cards are canceled.
Recommendation 3: Voucher And Payment Processes:
The GAO recommended that the Secretary of the Army, in partnership with
the Director, Defense Finance Accounting Service, revise the travel
voucher and payment process in the following areas by developing a
process to monitor and track travel reimbursements that exceed the 30-
day requirement so that individuals not paid within the statutory
period are paid late fees in accordance with the law. (GAO Draft
Report/p.70)
DOD Response: Partially concur. The current systems for processing and
computing travel vouchers for the Army do not provide for an automated
means of calculating interest due on vouchers where the reimbursement
exceeded 30 days from the proper submission date. Manually determining
and computing interest calculations would detract from the higher
priority of ensuring vouchers are initially reviewed and paid on time.
Individuals may submit supplemental vouchers for interest and late fees
resulting from government error in processing of their voucher. The
Defense Travel System currently being deployed automates the voucher
submission process and thus, should further reduce the instances where
reimbursements extend beyond 30 days.
* In addition, by September 30, 2002, the Army intends to direct
leaders at all levels, to ensure that: travelers are trained on the
proper preparation of settlement claims; travel claims are filed within
5 days of return from travel; approving officials expedite their review
of travel claims; and units expedite submission of travel claims to the
servicing DFAS site for payment.
Recommendation 4: To resolve severe voucher process problems specific
to one of the units audited, GAO recommended that the Commander of the
California Army National Guard take the following actions.
* Evaluate travel card procedures from writing travel orders through
documenting expenses on the voucher and completing the reimbursement
process with a goal of reengineering these processes to provide
reasonable assurance that cardholder reimbursement is made within the
30-day requirement.
* Strengthen segregation of duties controls so that voucher examiners
cannot prepare, validate, and receive payment for erroneous or
fraudulent travel vouchers without detection. Improved controls should
include eliminating the use of generic usernames and passwords for
accessing the travel system. (GAO Draft Report/p.71)
DOD Response: Concur.
* The California Army National Guard (ARNG) processing times were
unduly long but the situation have been corrected. The chart below
reflects the processing time at the United States Property and Fiscal
Office (USPFO) for California over the past year. The ARNG Operational
Review Program (ORP) is designed to audit financial and logistical
controls within State USPFOs. Travel is one of several areas examined.
A metric, determining whether or not a state is meeting the required 30-
day payment window from the submission of a proper travel claim through
review, processing and payment of the travel settlement, is being added
to the audit checklist. The California National Guard will be examined
under this program in fiscal year 2003.
* The Integrated Automated Travel System (IATS), which is used for
computation of travel payments, has systemic controls that segregate an
examiners ability to compute, audit, certify, authorize, maintain and
disburse. Automated segregation of duties is preferable, but sometimes
impractical. Many offices do not have enough personnel assigned to be
able to implement the automated feature as designed. Travel clerks must
have several authorities in order to cover for office vacancies,
illnesses and leave. However, although there may not be separation of
duties in those states with small staffs, this does not eliminate the
need for controls. The IATS generates management reports which aid in
the detection of fraud. Additionally, if disbursements are made without
travel orders being obligated, this would create unmatched
disbursements that would be researched and the improper disbursements
would be found. This control minimizes the opportunity for travel
office employees to commit fraud. The USPFO for California will also
periodically review the travel payment records of all voucher examiners
to ensure no abuses have occurred or could occur undetected. A metric
is being added to the ORP checklist to determine whether or not
adequate procedures are in place to minimize the opportunity for travel
clerks to commit fraud. The California Army National Guard has
eliminated the practice of issuing generic usernames and passwords. The
ORP checklist includes a metric evaluating a state's password control
and protection practices and procedures. The California National Guard
will be examined under this program in fiscal year 2003.
Figure: USPFO In-house Travel Voucher Processing Time:
(Measured from date of receipt to upload to DFAS Indianapolis):
Average 24 days over the last 18 months:
Average 4 days over the last 3 months (as of 9 Aug):
[See PDF for image]
This figure is a line chart depicting the following approximated data:
Date: July 2001;
Number of days: 18.
Date: August 2001;
Number of days: 33.
Date: September 2001;
Number of days: 36.
Date: October 2001;
Number of days: 30.
Date: November 2001;
Number of days: 34.
Date: December 2001;
Number of days: 54.
Date: January 2002;
Number of days: 52.
Date: February 2002;
Number of days: 41.
Date: March 2002;
Number of days: 25.
Date: April 2002;
Number of days: 4.
Date: May 2002;
Number of days: 3.
Date: June 2002;
Number of days: 5.
Date: July 2002;
Number of days: 1.
[End of figure]
[End of enclosure]
[End of section]
Footnotes:
[1] U.S. General Accounting Office, Travel Cards: Control Weaknesses
Leave Army Vulnerable to Potential Fraud and Abuse, GAO-02-863T
(Washington, D.C.: July 17, 2002).
[2] We defined potentially fraudulent activity as any scheme, or
pattern of activity, related to the use of a travel card in apparent
violation of federal or state criminal code. For purposes of this
report, the only cases we characterized as potentially fraudulent were
those where cardholders wrote three or more nonsufficient fund checks,
or wrote checks on closed accounts to pay their Bank of America bills.
These cases are potentially fraudulent because they indicate a pattern
of activity in apparent violation of one or more elements of federal or
state criminal code. In addition, for purposes of this report, we
considered abusive travel card activity to include (1) personal use of
the card”any use other than for official government travel”regardless
of whether the cardholder paid the bill and (2) cases in which
cardholders were reimbursed for official travel and then did not pay
Bank of America, and thus benefiting personally. Some of the travel
card activity that we categorized as abusive would be potentially
fraudulent if it can be established that the cardholder violated any
element of federal or state criminal code.
[3] Throughout this report, we calculated delinquency rates using the
proportion of dollars of accounts delinquent to the total dollars of
accounts outstanding according to industry standards set by the Federal
Financial Institutions Examination Council.
[4] The civilian agencies included in our analysis are the 23 executive
branch agencies covered under the Chief Financial Officers (CFO) Act,
as amended by the Government Management Reform Act.
[5] We did not analyze in detail the reason that the Army delinquency
rates are substantially higher than those of the non-Army DOD component
delinquencies. However, we will be issuing separate reports that
include analysis of delinquency rates for the departments of the Navy
and the Air Force.
[6] Appendix IV provides a description of each of these military grades
and their associated military rankings and pay, along with
corresponding civilian grade and pay data.
[7] Cash advance fees are also referred to as automated teller machine
(ATM) fees. ATMs allow cardholders to withdraw cash with a travel card.
For each cash advance withdrawal, cardholders are charged a fee of a
set amount or percentage of the amount of the withdrawal.
[8] Net sales consist of all purchases and other charges less any
credits, such as returns, other than payments to the accounts. Other
charges include ATM use, traveler‘s checks, and any other fees.
[9] DOD‘s salary offset program includes individuals‘ salaries paid by
DOD through its active duty, reserve, and civilian pay systems, and
retirement benefits paid through its military retirement pay system.
[10] Sec. 2(d), Public Law 105-264, 112 Stat. 2350 (5 U.S.C. 5701
note).
[11] Cardholder debts to Bank of America are not subject to the Debt
Collection Improvement Act of 1996, which is limited to the collection
of certain debts owed the federal government.
[12] 5 U.S.C. section 8346.
[13] 5 U.S.C. section 8470.
[14] 41 C.F.R. section 301-54.2.
[15] For performance measurement purposes, the Army is calculating
delinquency rates using the number of delinquent accounts compared to
the total number of active accounts. The dollar amount method we used
is the industry standard and is also used by the CFO Council and by the
DOD Charge Card Task Force.
[16] Bank fraud is defined by 18 U.S.C. 1344 as any execution of, or
attempt to execute, a scheme or artifice to defraud a financial
institution or to obtain any of the moneys, funds, credits, assets,
securities, or other assets owned by, or under the custody or control
of, a financial institution, by means of false or fraudulent pretenses,
representations, or promises.
[17] UCMJ is a federal law enacted by the Congress. UCMJ articles 77-
134 are known as ’punitive offenses,“ that is, specific offenses which,
if violated, can result in punishment by court-martial.
[18] MCCs are established by the banking industry for commercial and
consumer reporting purposes. Currently, about 800 category codes are
used to identify the nature of merchants‘ businesses or trades, such as
airlines, hotels, ATMs, jewelry stores, casinos, gentlemen‘s clubs, and
theaters.
[19] Mission-critical status is a determination made by the APC that
the cardholder‘s credit card limit needs to be increased or the
delinquency process needs to be suspended because the cardholder needs
the card to travel, but is unable to obtain reimbursement”and,
therefore, pay the bill”timely.
[20] U.S. Department of the Army, Regulation 380-67, Security,
Personnel Security Program, Chapter 8, ’Unfavorable Administrative
Actions“ (Sept. 9, 1988).
[21] U.S. Department of Defense Inspector General, Acquisition: Summary
of DOD Travel Card Program Audit Coverage, D-2002-065 (Washington,
D.C.: Mar. 18, 2002).
[22] APC responsibilities vary depending on the APC‘s level in the
Army‘s organizational hierarchy from headquarters down through the
Army‘s organizational chain of command to the individual Army unit
level. That is, individuals with APC responsibilities at the Army unit
level have direct responsibility for monitoring cardholder account
activity whereas individuals at higher levels in the Army‘s
organizational hierarchy may have responsibility for overseeing the
activities of one or more APCs as well as direct responsibility for
monitoring the account activity of a number of cardholders.
[23] Bank of America also includes in this grouping accounts inherited
from the previous government travel card contractor that were not
linked to any Army command and accounts for which the accountable APC
left or was relocated without having a replacement designated.
[24] Our estimates of the percentage of apparent personal use of the
travel card at the four sites we audited were: Ft. Bragg, Forces
Command (45.0 percent); Ft. Drum, Forces Command (14.8 percent); Ft.
Bragg, Special Operations (18.0 percent); and California Army National
Guard (29.5 percent).
[25] Per diem is a daily allowance paid to travelers in lieu of actual
subsistence expenses. Per diem rates for various geographic areas are
published by GSA.
[26] DOD‘s FMR provides that for long-term travel, cardholders are
expected to file interim vouchers every 30 days.
[27] Public Law. 105-264, Section 2 (g), 112 Stat. 2352 (Oct. 19,
1998).
[28] 41 C.F.R. Section 301-52.20.
[29] Department of Defense Office of the Inspector General, Acquistion:
Allegations to the Defense Hotline on the Management of the Defense
Travel System, Report No. D-2002-124 (Washington, D.C.: July 1, 2002).
[30] DOD contracted with NationsBank of Delaware, N.A., which
subsequently merged into the Bank of America, N.A., under a Tailored
Task Order under the GSA Master Contract Award for the travel card
program. The period of performance under the task order was November
30, 1998, through November 29, 2000, with three 1-year options to
renew. The task order also allowed for five additional 1-year options
under the GSA master contract renewal provisions.
[31] The act also requires agencies to pay cardholders a late payment
fee if they do not reimburse cardholders within the 30-day period
allowed. Specifically, Federal Travel Regulations prescribed by the
Administrator of General Services require agencies to either (1)
calculate late payment fees using the prevailing Prompt Payment
Interest Rate beginning the 31st day after submission of a proper
travel claim and ending on the date on which payment is made or (2)
reimburse the traveler a flat fee of not less than the prompt pay
amount, based on an agencywide average of travel claim payments. In
addition to the fee required in the items above, the agency must also
pay the traveler an amount equivalent to any late payment charge that
the card contractor would have been able to charge the traveler had the
traveler not paid the bill. 41 C.F.R. Section 301-52.20.
[32] The Travel and Transportation Reform Act of 1998 (Public Law 105-
264, Oct. 19, 1998) states that, unless specially exempted, federal
employees are required to use federal travel charge cards for all
payments of expenses of official government travel, requires the
government to reimburse employees who have submitted proper vouchers
within 30 days of submission of the vouchers, and allows for the offset
of pay for employees with undisputed travel card charge delinquencies
in an amount up to 15-percent of the amount of disposable pay of the
employee for a pay period.
[33] Federal Travel Regulation, 41 C.F.R., chapters 300-304, issued by
the Administrator of General Services, governs travel and
transportation allowances and relocation allowances for federal
civilian employees.
[34] U.S. General Accounting Office, Standards for Internal Control in
the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November
1999). This document was prepared to fulfill our statutory requirement
under the Federal Managers‘ Financial Integrity Act to issue standards
that provide the overall framework for establishing and maintaining
internal control and for identifying and addressing major performance
and management challenges and areas at greatest risk of fraud, waste,
abuse, and mismanagement.
[35] U.S. General Accounting Office, Guide to Evaluating and Testing
Controls Over Sensitive Payments, GAO/AFMD-8.1.2 (Washington, D.C.: May
1993). This document provides a framework for evaluating and testing
the effectiveness of internal controls that have been established in
various sensitive payment areas.
[36] The populations from which we selected our samples included some
transactions that were not supported by travel orders or vouchers, such
as personal charges made by a cardholder. We excluded such transactions
from our selections for travel order, voucher, and payment process
controls. However, we included such transactions in order to project
the percentage of personal use transactions.
[37] At Ft. Bragg, Forces Command, we found that 85 of 189 transactions
appeared to be personal (projecting to an estimated 45 percent with a
95 percent confidence interval from 37.8 percent to 52.4 percent). At
Ft. Drum, Forces Command, we found that 17 of 115 transactions appeared
to be personal (projecting to an estimated 14.8 percent with a 95
percent confidence interval from 8.9 percent to 22.6 percent). At Ft.
Bragg, Special Operations, we found that 21 of 117 transactions
appeared to be personal (projecting to an estimated 18 percent with a
95 percent confidence interval from 11.5 percent to 26.1 percent). At
the California National Guard we found that 49 of 166 transactions
appeared to be personal (projecting to an estimated 29.5 percent with a
95 percent confidence interval from 22.7 percent to 37.1 percent).
[End of section]
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