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 Department of Health and Human Services
OFFICE OF 
 
INSPECTOR GENERAL 
 
 
 
 
 
 
 
 
DEPAR TMENT OF HEALTH AND 
 
H S E
UMAN  ERVICES  MPLOYEE 
 
 
T C : U
RAVEL  ARDS    SAGE AND 
 
I   C  
NTERNAL  ONTROLS
 
 
 
 
Daniel R. Levinson  
Inspector General 
 
April 2009 
OEI-07-07-00480  Report Template Update:  04-03-08  
 
 
Office of Inspector General 
http://oig.hhs.gov 
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as 
amended, is to protect the integrity of the Department of Health and Human Services 
(HHS) programs, as well as the health and welfare of beneficiaries served by those 
programs.  This statutory mission is carried out through a nationwide network of audits, 
investigations, and inspections conducted by the following operating components: 
Office of Audit Services 
The Office of Audit Services (OAS) provides auditing services for HHS, either by conducting 
audits with its own audit resources or by overseeing audit work done by others.  Audits 
examine the performance of HHS programs and/or its grantees and contractors in carrying 
out their respective responsibilities and are intended to provide independent assessments of 
HHS programs and operations.  These assessments help reduce waste, abuse, and 
mismanagement and promote economy and efficiency throughout HHS. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide 
HHS, Congress, and the public with timely, useful, and reliable information on significant 
issues.  These evaluations focus on preventing fraud, waste, or abuse and promoting 
economy, efficiency, and effectiveness of departmental programs.  To promote impact, OEI 
reports also present practical recommendations for improving program operations.  
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations 
of fraud and misconduct related to HHS programs, operations, and beneficiaries.  With 
investigators working in all 50 States and the District of Columbia, OI utilizes its resources 
by actively coordinating with the Department of Justice and other Federal, State, and local 
law enforcement authorities.  The investigative efforts of OI often lead to criminal 
convictions, administrative sanctions, and/or civil monetary penalties. 
Office of Counsel to the Inspector General 
The Office of Counsel to the Inspector General (OCIG) provides general legal services to 
OIG, rendering advice and opinions on HHS programs and operations and providing all 
legal support for OIGs internal operations.  OCIG represents OIG in all civil and 
administrative fraud and abuse cases involving HHS programs, including False Claims Act, 
program exclusion, and civil monetary penalty cases.  In connection with these cases, OCIG 
also negotiates and monitors corporate integrity agreements.  OCIG renders advisory 
opinions, issues compliance program guidance, publishes fraud alerts, and provides other 
guidance to the health care industry concerning the anti-kickback statute and other OIG 
enforcement authorities.  Report Template Update:  04-03-08 
  
   
 E X E C U T I V E   S U M M A R Y  
OBJECTIVES
 
To determine (1) the extent to which the travel card transactions that 
Department of Health and Human Services (HHS) employees made in 
2007 constitute misuse and (2) whether travel card internal controls, 
such as guidance, training, transaction reviews, and follow-up actions, 
work as intended to prevent or address misuse. 
BACKGROUND 
Federal regulations require an employee who travels more than five 
times per year to obtain a Government travel card.  Pursuant to the 
Federal Travel Regulation and the HHS Travel Manual, official travel 
expenses include transportation, lodging, meals, and incidentals 
associated with official temporary duty travel.  Misuse is defined, in 
part, as the use of a Federal charge card for other than the official 
Government purpose for which it is intended.  Travel card program 
administrators, including Agency/Organization Program Coordinators 
(A/OPC) and cardholder supervisors, are responsible for reviewing 
reports to monitor cardholder activities, including misuse.  Travel 
cardholders are personally liable for transactions made with their travel 
cards.   
During 2007, HHS employees used travel cards to make approximately 
346,000 transactions totaling $68 million, excluding negative 
transactions, transactions of less than $5, and transactions that 
represent fees charged by the HHS-contracted travel agent.  From the 
universe of 2007 transactions, we selected a simple random sample of 
220 transactions to produce an overall estimate of misuse.  We also 
selected a stratified random sample of 213 transactions from the 
subpopulation of transactions that did not match electronic voucher 
data.  For both samples, we contacted the A/OPC for each transaction to 
obtain information to determine whether misuse occurred.  We 
conducted interviews with A/OPCs, cardholder supervisors, and 
employee and labor relations staff regarding the administration of the 
travel card program. 
FINDINGS 
Six percent of 2007 travel card transactions constituted misuse.  
Four percent of the 2007 transactions were for personal purchases while 
cardholders were not on official travel, 1 percent were for personal 
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EEE XXX EEE CCC UUU TTT III VVV EEE     SSS UUU MMM MMM AAA RRR YYY    
purchases while the cardholders were on official travel, and 1 percent 
were for local travel expenses. 
Twenty-seven percent of transactions that did not match electronic 
voucher data constituted misuse.  Twenty-one percent of the 2007 
transactions that did not match electronic voucher data were for 
personal purchases, 2 percent for local travel expenses, 2 percent for 
conference registration, and 1 percent for travel-related expenses of 
persons other than cardholders.  (Because of rounding, the percentages 
do not add to 27.) 
Program guidance is lacking in some areas, and training does not 
meet requirements.  Current travel card guidance lacks specificity on 
allowable purchases and follow-up actions for misuse, and training does 
not meet Office of Management and Budget (OMB) requirements. 
Program administrators may not identify all misuse.  Less than half 
of the A/OPCs that we interviewed matched transactions with travel 
dates to identify potential misuse.  Focusing only on atypical merchants 
would not identify lodging and airline tickets for personal travel.  
Cardholder supervisors reported limited roles in the travel card 
program. 
Less than one-third of sampled transactions that constituted misuse 
were associated with follow-up actions.  This can be explained in part 
by deficiencies in the travel card program, including a lack of specific 
guidance, training that does not meet OMB requirements or users 
needs, and review techniques that may not identify all misuse.   
RECOMMENDATIONS 
OIG recommends that the Assistant Secretary for Administration and 
Management: 
Improve travel card program guidance.  Topics could include:  
(1) specific examples of unallowable purchases with the travel card,  
(2) a departmental Table of Penalties that sets minimum and maximum 
guidelines on the actions to take for specific types of travel card misuse, 
and (3) instructions for reporting travel card misuse to employee and 
labor relations offices. 
Improve travel card program training.  At a minimum, the frequency 
and documentation of the training must meet the requirements in 
Appendix B of OMB Circular A-123, and the training content should 
meet users needs.  Training topics could include:  (1) specific examples 
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E X E C U T I V E   S U M M A R Y  
of unallowable purchases with the travel card for cardholders and 
(2) procedures and communication strategies for A/OPCs and cardholder 
supervisors to identify and respond to misuse. 
Improve methods to identify misuse.  These methods could include:  
(1) providing an automated data-matching program to compare dates of 
authorized travel to transaction dates and (2) communicating to A/OPCs 
and cardholder supervisors the availability of online access to 
transaction information. 
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
In its written comments to the report, the Assistant Secretary for 
Administration and Management (ASAM) accepted each of the three 
recommendations.  For each recommendation, ASAM described actions 
it has taken or will take to address it.  For example, ASAM updated the 
HHS Travel Manual in May 2008, coordinated with the Office of the 
Secretary and the General Services Administration to secure travel card 
training compliant with Appendix B of OMB Circular A-123, and plans 
to develop an internal data mining tool for all agencies to identify 
potential travel card misuse.  We did not make any changes to the 
report based on ASAMs comments.
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 T A B L E   O F   C O N T E N T S  
EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
 
 
I N T RO DUC T IO N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 
 
 
F I N D IN G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 
  Six percent of transactions constituted misuse . . . . . . . . . . . . . . . . 9 
  Twenty-seven percent of transactions that did not match  
electronic voucher data constituted misuse. . . . . . . . . . . . . . . . . . 10 
  Guidance is lacking; training does not meet requirements. . . . . . 12 
  Program administrators may not identify all misuse . . . . . . . . . . 15 
  Not all misuse led to follow-up actions. . . . . . . . . . . . . . . . . . . . . . 16 
 
 
R E C O MMEN D A T ION S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 
Agency Comments and Office of Inspector General Response . . . 19 
 
 
APPENDIXES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 
  A:  Sampled Transactions by Agency. . . . . . . . . . . . . . . . . . . . . . . 20 
  B:  Sampled Agency/Organization Program Coordinators 
   by Agency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 
  C:  Point Estimates and Confidence Intervals. . . . . . . . . . . . . . . . 22 
  D:  Agency Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 
   
A C K NO WL E D G M E N T S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25  Report Template Update:  04-03-08 
  
   
D E S I G N  
 I N T R O D U C T I O N  
OBJECTIVES 
To determine (1) the extent to which the travel card transactions that 
Department of Health and Human Services (HHS) employees made in 
2007 constitute misuse and (2) whether travel card internal controls, 
such as guidance, training, transaction reviews, and follow-up actions, 
work as intended to prevent or address misuse. 
BACKGROUND 
Federal regulations require employees who travel more than five times 
per year to obtain an Individually Billed Account travel charge card 
(hereinafter referred to as a travel card).  The regulations further 
require that travelers use the travel card for all official travel and 
travel-related transactions unless those transactions are specifically 
exempted.1  Federal employees enter into contractual agreements with 
the servicing bank (U.S. Bank for HHS in 2007) indicating that they 
will use the card only for official travel and travel-related transactions 
in accordance with agency policy and will pay all charges they incur.     
During 2007, HHS employees used travel cards to make 
346,441 transactions totaling $68,323,684, excluding negative 
transactions (i.e., credits to the travel card), transactions of less than 
$5, and transactions that represent fees charged by the HHS-contracted 
travel agent.  Table 1 shows the number and total dollar amount of 
transactions by category.   
 
 
1 The Travel and Transportation Reform Act of 1998, P.L. No. 105-264, 
5 U.S.C.  5701 note, required the promulgation of governmentwide regulations requiring 
Federal employees to use travel charge cards for all payments of expenses of official 
Government travel.  Subpart 301-51 of the Federal Travel Regulation (FTR) establishes the 
requirements for using the Government travel charge card (41 CFR  301-51).  Examples of 
exempt official travel transactions include parking and taxi services (41 CFR  301-51.2). 
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I N T R O D U C T I O N  
Table 1:  2007 Travel Card Transactions by Category 
Number of  Dollar amount of 
Category*
Transactions Transactions
Hotels 107,228 $37,877,956
Airline 33,801 $15,673,057
Money 36,906 $5,375,407
Rental Cars 15,752 $2,802,889
Eating/Drinking 73,130 $1,921,377
Vehicle Expense 48,895 $1,684,289
Other Travel 18,299 $1,482,368
Business Expense 2,690 $520,391
Other 3,822 $357,972
Office Services 1,431 $255,447
Wholesale Trade 2,875 $141,622
Maintenance, Repair, and Operating Supplies 336 $104,950
Medical 587 $39,405
Office Supplies 469 $30,586
Mail/Telephone 108 $30,166
Retail Services 39 $9,621
Automobile/Recreational Vehicle Dealers 57 $8,648
Building Services 13 $6,943
Retail Goods 3 $590
   Total 346,441 $68,323,684
Source:  Office of Inspector General (OIG) analysis of U.S. Bank database of 2007 HHS travel card 
transactions, 2008.
*U.S. Bank assigns each transaction to a predefined category.
 
Travel Card Guidance 
Requirements for the use of travel cards are contained in the FTR, 
pt. 301-51; HHS-wide supplemental policy and guidance is contained in 
the HHS Travel Manual, Chapter 9-00.  According to the FTR and the 
HHS Travel Manual, official travel expenses include transportation, 
lodging, meals, and incidentals associated with official temporary duty 
travel.2  The travel card may not be used for personal expenses at any 
time.3  Misuse is defined as the use of a Federal charge card for other 
than the official Government purpose for which it is intended.4 
 
2 HHS Travel Manual, Chapter 9-00-10.I prohibits use of the travel card for expenses 
within the local travel area, with certain exceptions such as rental cars. 
3 41 CFR  301-51.6 and HHS Travel Manual, Chapter 9-00-10.H. 
4 Office of Management and Budget (OMB) Circular A-123, Appendix B, Attachment 1. 
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I N T R O D U C T I O N  
OMBs Circular A-123, Appendix B, requires Federal agencies to 
maintain internal controls that reduce the risk of fraud, waste, and 
delinquency (i.e., failure to pay travel card bills in a timely manner) in 
Government charge card programs.  A summary of the various 
requirements includes:   
  written policies and procedures for the appropriate use of travel 
cards; 
  training frequency and content for Agency/Organization Program 
Coordinators (A/OPC),5 approving officials (typically cardholder 
supervisors), and cardholders;  
  risk management controls ranging from general (e.g., ensuring that 
practices to mitigate risks associated with the charge card program 
are carried out) to specific (e.g., reviewing transactions to detect 
instances of misuse); and 
  administrative and disciplinary actions that may be imposed on 
cardholders to address misuse of their travel cards.   
In April 2005, the Assistant Secretary for Administration and 
Management (ASAM) issued memoranda to cardholders and cardholder 
supervisors.  The memorandum to cardholders reminded them that 
using the travel card for purchases unrelated to official travel or failing 
to pay travel card bills in a timely manner constitutes misuse.  
Cardholders signed the HHS Travelers Agreement for Government 
Contractor-Issued Travel Charge Card Users to document receipt of the 
memorandum.  The memorandum to supervisors stated that a 
supervisor has the responsibility to:  (1) ensure that a process is in place 
for reviewing reports to identify misuse, (2) ensure that inquiries are 
conducted to determine whether misuse occurred, (3) consult with his or 
her employee and labor relations office when deciding what action to 
take, and (4) properly address instances of a subordinates misuse of the 
travel card.  The memorandum included examples of misuse and related 
travel card misconduct (e.g., submitting a false travel voucher).  It also 
included possible actions that supervisors might take in instances of 
misuse or misconduct, such as counseling, official reprimand, 
 
5 An A/OPC serves as an intermediary between the cardholder, the card-issuing bank, 
and agency management.  An A/OPCs role includes account setup and maintenance, 
understanding and implementing the FTR and agency travel policies, and monitoring 
cardholder activity. 
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I N T R O D U C T I O N  
suspension from duty without pay, reassignment or downgrade to a 
position not involving travel, or removal from the position and Federal 
service.  However, the memorandum did not specify which particular 
action should be taken in response to various types of misuse or 
misconduct.   
Most, but not all, of the HHS agencies have issued their own travel card 
guidance manuals.  Generally, these manuals offer guidance to 
cardholders in greater specificity than that contained in the FTR or the 
HHS Travel Manual (e.g., the step-by-step mechanics of obtaining a 
cash advance at an automated teller machine (ATM)).  Agencies may be 
more, but not less, restrictive than the FTR and HHS travel card 
guidance. 
Travel Card Training 
OMB Circular A-123 requires that all A/OPCs, approving officials, and 
travel cardholders receive training before taking on such roles and 
refresher training at a minimum of every 3 years.  Copies of training 
certificates must be maintained.  For A/OPCs, approving officials, and 
cardholders, the training content must include the provisions of the 
FTR and proper card use.  The training for A/OPCs must further 
include oversight tools and techniques. 
Travel Card Oversight 
A/OPCs are responsible for reviewing monthly transaction reports from 
the card-issuing bank (which was U.S. Bank in 2007) to monitor 
cardholder activities, including misuse.6  Each of the 12 HHS agencies 
has one individual who serves as the principal A/OPC for that agency.7  
Under this individual, one or more primary and/or alternate A/OPCs 
work at the division or office level.  According to information U.S. Bank 
provided us in January 2008, HHS had 370 primary and 252 alternate 
A/OPCs to oversee the purchasing activities of approximately 
32,000 travel cardholders. 
Related Studies 
In 2003, the Government Accountability Office (GAO) released a report 
entitled Controls over Travel Program Are Generally Effective, but 
Some Improvements Are Needed regarding travel-card-monitoring 
processes and 2001 travel card transactions in five HHS 
 
6 HHS Travel Manual, Chapter 9-00-10.J. 
7 There are 11 principal A/OPCs in HHS.  Two agencies share the same principal A/OPC. 
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I N T R O D U C T I O N  
agencies (GAO-03-334).  This report found that controls over the travel 
program were generally effective but that monitoring of travel card use 
focused mainly on delinquencies.  GAO found that 71 of 430 sampled 
transactions were unauthorized, meaning that they were for personal 
use or the agency lacked documentation to support that the transactions 
were for official travel expenses.  The methods used in the GAO report 
do not allow for comparison to the results of this report.  In 2002, the 
Presidents Council on Integrity and Efficiency (PCIE) issued a report 
entitled Review of Common Problems and Best Practices in Federal 
Agencies Travel Card Programs.  This report synthesized OIG 
evaluations and audits of six Federal agencies travel card programs 
(HHS was not included). 
METHODOLOGY 
Transaction Data 
U.S. Bank provided us with the following data:  (1) a departmentwide 
database of 2007 HHS travel card transactions, including the account 
number, transaction date, merchant name and category, amount, and 
unique transaction identification number for each transaction, and  
(2) a listing of all HHS cardholders, including name and account 
number.   
The National Institutes of Health (NIH) Business System provided 
2007 electronic travel voucher data, including employee name, dates of 
departure and return, and location.  The HHS Program Support Center 
provided 2007 electronic travel voucher data for all other HHS agencies, 
including employee name, dates of departure and return, travel card 
account number, and location.  This information was combined to create 
a departmentwide electronic voucher dataset.   
Sample Selection of Transactions 
Overall sample 
From the 402,301 HHS cardholder transactions in 2007, we excluded 
11,306 negative transactions (i.e., credits to travel cards), 
10,158 transactions of less than $5, and 34,396 transactions 
representing fees charged by the HHS-contracted travel agents for 
airline reservations, leaving a universe of 346,441 transactions.  To 
produce an overall estimate of transactions that constituted misuse, we 
selected a simple random sample of 220 transactions.  
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Sample of transactions that did not match electronic voucher data 
To examine transactions with a higher likelihood of being unrelated to 
official travel, we looked at a subset of the universe of 
346,441 transactions.  We matched official travel dates from the 
electronic departmental travel voucher data against transaction dates 
from the U.S. Bank transaction data.  We allowed a 5-day window 
before the departure date for advance purchase of airline tickets, train 
tickets, and ATM withdrawals and up to 4 days after the return date for 
posting of hotel and rental car transactions.  We matched the 
transaction date of each transaction against the dates in the database of 
travel voucher dates by travel card account number or by cardholder 
name if an account number did not match or was not listed in the 
voucher data.8  Of the 346,441 unique transactions, 53,504 (15 percent) 
did not match electronic voucher data.   
To produce estimates of the proportion and dollar amount of 
transactions that constituted misuse for this subpopulation, we selected 
a stratified random sample by dollar amount as shown in Table 2. 
 
Table 2:  Transaction Population and Sample Size 
Population 
Strata Definition Sample Size
Size
1.  Transactions from $5.00 through $250.00 44,111 80
2.  Transactions from $250.01 through $4,000.00 9,340 80
3.  Transactions over $4,000.00 53 53
   Total 53,504 213
Source:  OIG analysis of U.S. Bank database of 2007 HHS travel card transactions, 2008.
 
Determinations of Misuse 
For the sampled transactions in both sampling frames, we contacted the 
principal A/OPC for each agency with a list of all transactions for that 
agency to determine which A/OPC would best be able to explain 
whether each transaction was related to authorized travel.  In some 
cases, the principal A/OPC at the agency indicated that he or she would 
be the appropriate person to explain each sampled transaction; in 
others, the principal A/OPC provided the contact information for 
division or office-level A/OPCs.   
 
8 Sometimes when a cardholders account number changed (e.g., because a card was lost 
or stolen), it was not updated promptly in the electronic voucher data. 
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We contacted the designated A/OPC for each transaction to obtain a 
description of what was purchased, an explanation as to whether the 
transaction was related to authorized travel, and a description of any 
followup (e.g., verbal counseling, disciplinary action) that had occurred 
with the cardholder related to the sampled transaction before our 
inquiry.  We also asked the A/OPC to indicate the sources of information 
(e.g., electronic records, cardholder, cardholders supervisor) that he or 
she accessed to respond to our inquiry.  In our cover letter to the 
A/OPCs, we asked the A/OPCs to diligently search all available 
documents and other sources of information.  Based on the information 
the A/OPCs supplied to us, we attempted to determine which sampled 
transactions constituted misuse according to the criteria in the 
departmental and agency guidance.  In cases where the guidance did 
not adequately address whether a transaction constituted misuse, we 
consulted with ASAM officials.  To ensure consistent determinations of 
misuse according to ASAM directives, we made independent 
determinations rather than relying on A/OPC interpretations and 
applications of travel card guidance.  
A/OPCs were unable to provide information for four sampled 
transactions (e.g., the cardholder had retired).  Two of these 
transactions were from the overall sample, and two were from the 
transactions that did not match electronic voucher data.  We did not 
count these transactions as misuse.  See Appendix A for the number of 
sampled transactions by agency. 
Structured Interviews of A/OPCs and Cardholder Supervisors 
We received a database of the names and contact information for all 
A/OPCs from U.S. Bank.  We interviewed each of the principal A/OPCs 
within each of the 12 agencies and a random sample of 50 primary 
A/OPCs at the division or office level.  The sampling scheme ensured 
that each agency that had A/OPCs at the division or office level was 
represented.  We selected A/OPCs at random from the total number of 
A/OPCs proportionate to the number of cardholders at each agency.  See 
Appendix B for the number of sampled A/OPCs by agency.  We also 
selected one cardholder supervisor who corresponded with each sampled 
A/OPC for an interview.  If a sampled A/OPC corresponded with more 
than one cardholder supervisor, we randomly selected one cardholder 
supervisor from the universe of supervisors corresponding with the 
sampled A/OPC.  Because of the small sample size, we did not project 
the results of the interviews.   
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I N T R O D U C T I O N  
During the interviews, we inquired about A/OPCs knowledge of and 
experiences with misuse of travel cards by departmental cardholders.  
We addressed issues such as the procedures that A/OPCs and 
cardholder supervisors used to identify misuse, corrective actions that 
A/OPCs and cardholder supervisors have employed or would employ if 
misuse was identified, when and how A/OPCs and cardholder 
supervisors reported misuse, and corresponding corrective actions.  We 
also interviewed these officials regarding training for A/OPCs, 
cardholder supervisors, and cardholders. 
Structured Interviews of Employee and Labor Relations Staff 
We interviewed employee and labor relations staff from each of the five 
HHS human resource centers:  Atlanta, Baltimore, the Indian Health 
Service, NIH, and Rockville.  During the interviews, we inquired about 
addressing travel card misuse, written criteria for addressing misuse, 
and agencies frequency of contact with the employee and labor relations 
staff regarding travel card misuse. 
Limitations 
Although ASAM has identified delinquency as a type of travel card 
misuse, this evaluation did not examine it.  We did not attempt to 
match transactions with hard copy vouchers if they did not match 
departmental electronic voucher data.  The sampling method does not 
allow a dollar projection of transactions that constituted misuse for the 
overall sample.  It also does not allow a comparison of transactions that 
constituted misuse between agencies within HHS.  Although it is 
possible that a single transaction could have been selected in both 
sampling frames, this did not occur. 
Standards 
This study was conducted in accordance with the Quality Standards for 
Inspections issued by PCIE and the Executive Council on Integrity and 
Efficiency.
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 F I N D I N G S  
Unlike other Government charge 
Six percent of 2007 travel card transactions 
card programs, the travel card 
constituted misuse 
program makes the travel 
cardholder responsible for all 
charges on his or her account and the bill is sent directly to the 
cardholder for payment.  There is no monetary loss to the Government if 
cardholders charge non-travel-related purchases on their travel cards 
and pay their bill in full upon receipt.  However, the travel card is not 
an employees personal credit card, and the FTR and HHS Travel 
Manual prohibit use of the card as a vehicle to finance personal 
purchases. 
Overall, 6 percent (14 of 220) of the 2007 travel card transactions 
constituted misuse, with 4 percent of the transactions made for personal 
purchases while the cardholder was not on official travel, 1 percent for 
personal purchases while the cardholder was on official travel, and 
1 percent for local travel expenses.  Confidence intervals for the 
projections can be found in Appendix C.  To develop our projections, we 
reviewed 220 sampled transactions totaling approximately $35,000.9  
The average amount of the sampled transactions that constituted 
misuse was $83.68, ranging in our sample from $8.00 to $489.30.  
Table 3 summarizes the number and amount of misuse transactions by 
merchant category.   
Table 3:  Misuse Transactions by Merchant Category 
Number of 
Category Amount
Transactions
Airline 2 $529.30
Hotels 2 $275.00
Vehicle Expense (e.g., gasoline, parking) 4 $147.45
Money 1 $102.00
Other (e.g., retail)  1 $24.99
Eating/Drinking 2 $44.27
Other Travel 1 $30.00
Wholesale Trade 1 $18.57
   Total 14 $1,171.58
Source:  OIG analysis of A/OPCs' responses to transaction inquiries, 2008.  
 
 
9 The sampling scheme does not allow a projection of the dollar amount of transactions 
that constituted misuse for the overall sample. 
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Four percent of 2007 transactions were for personal purchases while the 
cardholder was not on official travel 
Personal purchases included airfare in the amount of $489.30 to attend 
a relatives funeral, $267.00 for lodging for a personal trip following 
official travel, a $102.00 cash advance, and $24.99 at a sporting goods 
store, as well as gasoline and food purchases.  For these transactions, 
A/OPCs reported that the cardholder was not on official travel at the 
time of the transactions.  For the cash advance transaction, the A/OPC 
indicated that the cardholder used the travel card accidentally while on 
personal travel. 
One percent of 2007 transactions were for personal purchases while the 
cardholder was on official travel 
Two purchases are included in this category:  $40.00 for an airline 
upgrade and $18.57 for tablecloths purchased while traveling 
internationally.  Cardholders made these purchases while on official 
travel; however, they were for items unrelated to official Government 
business. 
One percent of 2007 transactions were for local travel expenses 
The travel card may not be used for expenses within the local travel 
area, with the exception of expenses for authorized rental cars.10  Three 
purchases of parking and gasoline were made on travel cards for local 
travel expenses totaling $59.00. 
 
Twenty-seven percent of transactions that  Of the transactions that did not 
match electronic voucher data 
did not match electronic voucher data 
(53,504 of 346,441 transactions), 
constituted misuse 
27 percent constituted misuse, 
which projects to $1.4 million.  Twenty-one percent of the transactions 
that did not match electronic voucher data were for personal purchases, 
2 percent for local travel expenses, 2 percent for conference registration, 
and 1 percent for travel-related expenses of persons other than 
cardholders.11  However, the majority of the transactions were in 
support of official Government travel.  To develop our projections, we 
reviewed 213 sampled transactions totaling approximately $364,000.  
Thirty-four sampled transactions constituted misuse.  The projected 
 
10 HHS Travel Manual, Chapter 9-00-10. 
11 Because of rounding, the percentages do not add to 27. 
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average amount of the transactions constituting misuse was $97.30, 
ranging in the sample from $5.12 to $4,955.53.  Table 4 summarizes the 
number and amount of sampled transactions that constituted misuse by 
merchant category.  
 
Table 4:  Misuse Transactions That Did Not Match Electronic Voucher 
Data by Merchant Category 
Number of 
Category Amount
Transactions
Hotels 5 $5,742.19
Money 4 $1,346.50
Business Expense 4 $1,192.82
Maintenance, Repair, and Operating Supplies 1 $685.00
Office Services 1 $495.00
Other 2 $336.87
Airline 1 $299.40
Eating/Drinking 9 $297.09
Vehicle Expense (e.g., gasoline, parking) 6 $207.28
Wholesale Trade 1 $14.79
   Total 34 $10,616.94
Source:  OIG analysis of A/OPCs' responses to transaction inquiries, 2008.  
 
Twenty-one percent of transactions were for personal purchases 
Examples of these transactions include lodging at a Hawaii hotel for 
$4,955.53 during a deployed employees military leave; cash advances of 
$600.00, $502.50, $143.00, and $101.00; a purchase at a casual clothing 
store for $136.87; gasoline for a personal vehicle for $30.01; and 
restaurant charges ranging from $5.12 to $138.90. 
Two percent of transactions were for local travel expenses   
As stated previously, the travel card may not be used for local travel 
expenses.  Cardholders purchased lodging and meals totaling 
$237.81 while on local travel.  For example, one cardholder while on 
local travel charged one nights lodging on her travel card because of 
inclement weather.  She was not reimbursed for this charge. 
Two percent of transactions were for conference registration 
The FTR does not clearly prohibit the payment of conference 
registration fees with the travel card.  However, as a direct result of 
Congresss concern regarding conference expenses for Federal 
employees, HHS issued supplemental guidance in April 2007 stating 
that employees may not use a travel card to charge early-bird 
conference registration fees.  This guidance was later incorporated in 
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the HHS Travel Manual.  Although HHS guidelines do not explicitly 
state that cardholders may not use travel cards to pay normal 
conference registration fees, ASAM officials advised us that travel cards 
should never be used for conference registration fees.  Six cardholders 
charged conference registration fees totaling $2,510.00 on travel cards.  
Based on the merchant categories assigned to various organizations 
that offer conferences, the conference registration fees fall within the 
categories of Business Expense; Maintenance, Repair, and Operating 
Supplies; Office Services; and Other. 
One percent of transactions were for travel-related expenses of persons 
other than the cardholders 
The HHS Travelers Agreement stipulates that the travel card may be 
used only for the cardholders own authorized official business expenses, 
and use of the card for any other purpose is misuse.  One cardholder 
purchased a $299.40 airline ticket for a staff member who did not have 
a travel card, and another cardholder purchased dinner totaling $82.00 
for four individuals and received cash reimbursement from the three 
other travelers.  
The majority of transactions were in support of official Government travel 
Most transactions that did not match electronic voucher data were 
legitimate.  For example, travelers requested official flights to be 
ticketed more than 5 days before the departure date (e.g., to lock in an 
airfare when a noncontract flight was necessary).  In addition, when 
cardholders charged travel-related transactions on their travel cards 
but were reimbursed through a source other than one of HHSs 
electronic travel voucher systems (e.g., the travel was paid for by 
another agency, the employee was involved in a permanent change of 
station), the transactions did not match electronic voucher data.  Still, 
transactions that did not match produced a statistically significant 
higher rate of transactions constituting misuse when compared to 
transactions overall. 
 
Using available guidance, we 
Program guidance is lacking in some areas, and 
could not determine without 
training does not meet requirements 
consulting ASAM whether 
six types of transactions in our samples constituted misuse.  Some 
A/OPCs and cardholder supervisors that we interviewed had questions 
regarding whether specific types of transactions are allowed with the 
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F I N D I N G S  
travel card.  Additionally, current training practices do not meet OMB 
requirements. 
Travel card guidance lacks specificity on allowable purchases 
After reviewing available guidance, we had to consult ASAM to 
determine whether the following types of transactions in our samples 
constituted misuse:   
(1)    a passport photo,  
(2)   meals on the first or last day of travel in the employees office 
location,  
(3)    paying for another travelers meals,  
(4)    gasoline for personal vehicles,  
(5)   costs for mailing materials to the employees office, and 
(6)   conference registration.   
In some cases, the guidance was silent on the type of purchase, and in 
other cases the guidance did not address the specifics of the purchase.  
For example, we did not find any guidance related to gasoline purchases 
for personal vehicles (e.g., for traveling to or from the airport).  We note 
that in our interviews, some A/OPC interpretations of these six types of 
transactions differed from the views of ASAM officials.  This lack of 
consistent understanding can lead to cardholders inadvertently 
misusing their travel cards because they have received inaccurate 
responses when seeking guidance. 
Division- and office-level A/OPCs are often sought for answers regarding 
the travel card program.  Forty-two of the fifty sampled A/OPCs said 
they received questions from cardholders, and 26 said they received 
questions from supervisors.  A/OPCs reported that questions they 
received included questions on allowable uses of the card.  For example, 
six A/OPCs volunteered that they had been asked whether conference 
registration is an allowable travel card charge.  Overall, 24 of 50 
A/OPCs and 18 of 50 cardholder supervisors indicated that they want to 
receive additional guidance on the travel card program. 
Guidance on follow-up actions and penalties is lacking 
Neither the HHS Travel Manual nor the 2005 memoranda from ASAM 
describe specific follow-up actions and penalties for travel card misuse.  
The 2002 PCIE report on travel card misuse stated that a lack of such 
guidance may result in employees being treated differently for the same 
type of misuse. 
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At the time of this evaluation, only NIH had published a Table of 
Penalties that outlines the actions supervisors must take in response to 
travel card misuse.  NIHs guidance states that at a minimum the 
supervisor must address the misuse by meeting with and counseling the 
employee.  In cases of repeated or serious travel card misuse, the NIH 
Table of Penalties describes a range of formal actions a supervisor may 
take. 
Training does not meet OMB requirements for frequency and documentation 
OMB Circular A-123 requires that all A/OPCs, approving officials 
(typically cardholder supervisors), and travel cardholders receive 
training before taking on those roles and refresher training at a 
minimum every 3 years.  Copies of training certificates must be 
maintained.  Principal agency-level A/OPCs reported that they did not 
maintain training records.  An ASAM official confirmed that no 
centralized database of training records existed at the time of our 
review.  This official reported, however, that an online training module 
that would maintain completion records was under development. 
Of the 50 division- and office-level A/OPCs we interviewed, 39 reported 
receiving initial training, but only 15 of the 39 reported that 
documentation was maintained (e.g., hard copy certificate in employees 
file).  Of those A/OPCs who reported receiving training, eight reported 
receiving it from a departing A/OPC rather than from a formal 
departmental or agency course, and two reported receiving it at a 
previous position.  Additionally, 32 of 50 cardholder supervisors 
reported receiving some type of travel card training (either initial or 
refresher), but only 12 had documentation.     
A/OPCs and cardholder supervisors agreed on the need for additional 
training.  Twenty-eight of fifty division- and office-level A/OPCs would 
like additional training and suggested the content be a general 
refresher, training in the use of the card-issuing banks online system, 
or program updates.  Thirty-four cardholder supervisors would like 
additional training and suggested that the content be a general 
refresher, program updates, or training on the supervisors role and 
responsibilities in the travel card program.  Thirty-two of fifty 
division- and office-level A/OPCs and 35 of 50 cardholder supervisors 
reported that more training is needed for cardholders.  The top two 
content areas suggested were general refresher and misuse (i.e., what 
may and may not be purchased with the travel card).  One cardholder 
supervisor explained that she maintains a log of examples of misuse 
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F I N D I N G S  
that have occurred in her office and uses these to conduct a one-on-one 
training with each new cardholder. 
 
Program administrators may not  Although A/OPCs reported 
regularly conducting transaction 
identify all misuse 
reviews to identify misuse, some 
techniques may not identify all misuse.  Less than half of the A/OPCs 
that we interviewed matched transactions with travel dates to identify 
potential misuse.  Focusing only on atypical merchants may not identify 
lodging and airline tickets for personal travel.  Limited roles for 
cardholder supervisors may also contribute to undetected misuse. 
Only 24 of 50 A/OPCs match transactions with travel dates 
Although 47 of 50 division- or office-level A/OPCs reported having 
access to travel dates contained in their agencys travel management 
system, only 24 mentioned matching transactions to cardholders 
authorized travel dates to determine whether any purchases were made 
while the cardholders were not on official travel.  Additionally, although 
U.S. Bank offered real-time online access to transaction information to 
all A/OPCs, only 16 of 50 mentioned using it, with 7 indicating a need 
for additional online capabilities in the travel card program.  At the 
time of this evaluation, no automated approach existed for A/OPCs to 
accomplish a match of transactions to travel dates.  Automation is 
particularly important given that over half of the A/OPCs we 
interviewed reported responsibility for reviewing the transactions for 50 
or more cardholders.  In addition, all but one of the interviewed A/OPCs 
indicated that the travel card program was not their only job duty.  In 
fact, three-fourths of the responding A/OPCs indicated that they spent 
less than 10 percent of their time on the travel card program. 
Efforts to detect atypical purchases may not identify all misuse 
All 50 A/OPCs serving at the division or office level that we interviewed 
reported that transactions are reviewed on a monthly or more frequent 
basis.  Some A/OPCs noted that their reviews involve identifying 
unusual merchants that pop out, with 28 of 50 stating that they look 
for personal purchases and 19 stating that they look for anything 
suspicious or atypical.  Based on our results that found misuse at 
typical travel merchants, such as airlines and hotels, looking only for 
atypical merchants may not identify all misuse. 
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F I N D I N G S  
Cardholder supervisors reported limited roles in the travel card program 
When asked to describe their involvement with the travel card program, 
38 of 50 cardholder supervisors said that their role was minimal, limited 
to approving travel, or nothing.  In fact, 9 of 50 cardholder supervisors 
reported that they did not know whether transaction reviews were being 
conducted, and seven did not know what A/OPCs were looking for while 
conducting the reviews.  Finally, 18 cardholder supervisors reported 
that they rely on A/OPCs or administrative staff to consult various 
sources, including cardholders, to determine whether misuse occurred.  
This may not be the best approach given that five A/OPCs volunteered 
that questioning cardholders about potential misuse transactions can be 
difficult.  Its touchy to approach people on these matters, noted one 
A/OPC. 
However, the 2005 ASAM memorandum to cardholder supervisors 
states the supervisors roles and responsibilities for the travel card 
program.  The memorandum states that supervisors are responsible for 
consulting with employee and labor relations staff and taking 
appropriate action when misuse is identified.  Employee and labor 
relations office staff collectively estimated that they receive about 
150 notifications of travel card misuse each year.  This figure would 
equate to less than 1 percent of travel card transactions in 2007.  Only  
8 of 50 cardholder supervisors volunteered that they would seek advice 
from their employee and labor relations office if faced with travel card 
misuse. 
 
A/OPCs for only 14 of the 
Less than one-third of sampled transactions 
48 sampled transactions that 
that constituted misuse were associated with 
constituted misuse (5 of 
follow-up actions 
14 transactions from the overall 
sample and 9 of 34 from the sample of transactions that did not match 
electronic voucher data) reported that followup (e.g., verbal counseling, 
disciplinary action) occurred with the cardholder before we began 
fieldwork.  For example, cardholders received no verbal counseling or 
disciplinary action for a $283.65 hotel transaction for personal travel, a 
$489.30 airline ticket for personal travel, and a $502.50 cash advance 
not related to official travel.  The A/OPC for this last transaction 
indicated that the cardholders supervisor was not aware of this cash 
advance at the time of our inquiry.   
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F I N D I N G S  
We cannot definitively determine whether limited followup was due to 
the misuse not being identified (e.g., guidance did not clearly indicate 
that the transaction was misuse, review techniques failed to identify the 
misuse) or due to inaction on the part of the A/OPC or cardholders 
supervisor in response to identified misuse.  The fact that less than 
one-third of the sampled transactions that constituted misuse were 
associated with follow-up actions can be explained in part by 
deficiencies in the travel card program.  These deficiencies include a 
lack of specific guidance, training that does not meet OMB 
requirements or users needs, and review techniques that may not 
identify all misuse. 
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 R E C O M M E N D A T I O N S  
  
  
In 2007, 6 percent of the transactions overall and 27 percent of the 
transactions that did not match electronic voucher data constituted 
misuse.  Travel card program guidance is lacking in some areas, and 
training does not meet OMB requirements.  Furthermore, program 
administrators may not identify all misuse.  Finally, less than one-third 
of the sampled transactions that constituted misuse were associated 
with follow-up actions.  We recognize the need for program 
improvements while still maintaining flexibility, which is imperative 
given the diverse size and function of agencies within HHS.  We also 
recognize that HHS transitioned to a new card-issuing bank in 
November 2008.  Even so, the information in this report may prove 
valuable to improve the administration of the travel card program with 
the new bank. 
Therefore, we recommend that ASAM: 
Improve travel card program guidance 
Topics could include:  (1) specific examples of unallowable purchases 
with the travel card, including the six types of transactions identified in 
this report; (2) a departmental Table of Penalties that sets minimum 
and maximum guidelines on the actions to take for specific travel card 
misuses; and (3) instructions for reporting travel card misuse to 
employee and labor relations offices.  In December 2008, after 
completion of our fieldwork, the Program Support Center sent an email 
directing travelers to the E-Gov Travel Web site.  This Web site contains 
a Travel Card Dos & Donts for Employees page addressing some 
aspects of guidance that this report identified as lacking. 
Improve travel card program training 
At a minimum, the frequency and documentation of the training must 
meet the requirements in Appendix B of OMB Circular A-123, and the 
training content should meet the users needs.  Training topics could 
include:  (1) specific examples of unallowable purchases with the travel 
card for cardholders and (2) procedures and communication strategies 
for A/OPCs and cardholder supervisors to identify and respond to 
misuse.  In August 2008, after completion of our fieldwork, ASAM 
issued a memorandum to heads of operating and staff divisions 
regarding sources of training and documentation requirements. 
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R E C O M M E N D A T I O N S  
Improve methods to identify misuse 
These methods could include:  (1) providing an automated 
data-matching program to compare dates of authorized travel to 
transaction dates and (2) communicating to A/OPCs and cardholder 
supervisors the availability of online access to transaction information. 
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
In its written comments to the report, ASAM accepted each of the three 
recommendations.   
In response to the first recommendation, ASAM stated that it updated 
the HHS Travel Manual in May 2008, published a pamphlet entitled 
Travel Card Dos & Donts for Employees in September 2008, and 
updated memoranda to cardholders and cardholder supervisors in 
February 2009.  Additional actions are planned with employee and labor 
relations staff. 
In response to the second recommendation, ASAM stated that it has 
coordinated with the Office of the Secretary and the General Services 
Administration to secure travel card training compliant with 
Appendix B of OMB Circular A-123 through HHS University.  In 
addition, ASAM is developing a training tool to enhance A/OPC and 
cardholder supervisors understanding of HHS travel policy to be 
available in May 2009. 
In response to the third recommendation, ASAM plans to develop an 
internal data mining tool in 2009 for all agencies to identify potential 
travel card misuse.  The tool will compare dates of authorized travel to 
transaction dates and identify excessive cash advances, large purchases, 
and inappropriate merchant category codes.  ASAM will oversee the use 
of the tool. 
We did not make any changes to the report based on ASAMs comments.  
The full text of ASAMs comments on the draft report can be found in 
Appendix D.
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 A P P E N D I X ~ A  
Table A-1:  Sampled Transactions by Agency 
Population of  Sampled 
Transactions That  Transactions That 
Sampled 
Agency Population Did Not Match  Did Not Match 
Transactions
Electronic Voucher  Electronic Voucher 
Data Data
Administration for Children & Families 18,458 16 1,608 3
Administration on Aging 1,422 0 156 0
Agency for Healthcare Research and 
1,079 1 239 1
Quality
Centers for Disease Control and 
82,333 40 14,912 60
Prevention
Centers for Medicare & Medicaid 
35,230 20 2,992 13
Services
Food and Drug Administration 49,188 29 6,089 49
Health Resources and Services 
12,038 9 1,919 7
Administration
Indian Health Service 55,768 38 11,525 20
National Institutes of Health 26,261 18 6,670 26
Office of the Secretary 56,383 46 6,230 30
Program Support Center 2,350 0 364 2
Substance Abuse & Mental Health 
5,931 3 800 2
Services Administration
   Total 346,441 220 53,504 213
Source:  Office of Inspector General analysis of U.S. Bank database of 2007 Department of Health and Human Services travel card 
transactions, 2008.
 
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 A P P E N D I X ~ B  
Table B-1:  Sampled Agency/Organization Program Coordinators by Agency 
Number of 
Number of 
Number of  Sampled 
Agency Primary 
Cardholders Primary 
A/OPCs
A/OPCs
Administration for Children & Families 958 23 2
Administration on Aging* 79 0 0
Agency for Healthcare Research and Quality* 154 0 0
Centers for Disease Control and Prevention 5,994 47 9
Centers for Medicare & Medicaid Services 2,596 4 3
Food and Drug Administration 6,757 50 10
Health Resources and Services Administration 1,055 20 2
Indian Health Service 3,111 76 5
National Institutes of Health 3,217 66 5
Office of the Secretary 8,333 78 12
Program Support Center 381 4 1
Substance Abuse & Mental Health Services 
335 2 1
Administration
   Total 32,970 370 50
Source:  Office of Inspector General analysis of U.S. Bank databases of Department of Health and 
Human Services cardholders and Agency/Organization Program Coordinators (A/OPC), 2008.
*The Administration on Aging and the Agency for Healthcare Research and Quality have principal 
A/OPCs at the agency level but do not have any A/OPCs at the division or office level.
 
 
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 A P P E N D I X ~ C  
Table C-1:  Point Estimates and Confidence Intervals  
Confidence Interval 
Finding Point Estimate
95 Percent
Overall Sample of 2007 Travel Card Transactions
Transactions that constituted misuse 6.4% 3.5%10.5%
Transactions that constituted misuse because they were for personal purchases 
4.1% 1.9%7.6%
while the cardholder was not on official travel
Transactions that constituted misuse because they were for personal purchases 
1.0% 0.1%3.3%
while the cardholder was on official travel
Transactions that constituted misuse because they were for local travel expenses 1.4% 0.3%3.9%
Sample of 2007 Travel Card Transactions That Did Not Match Electronic Voucher Data
Transactions that constituted misuse 26.7% 19.1%35.9%
Dollar amount of transactions that constituted misuse $1.4 million $0.8 million$1.9 million
Average dollar amount of transactions that constituted misuse $97.30 $66.31$128.30
Transactions that constituted misuse because they were for personal purchases 21.3% 14.4%30.3%
Transactions that constituted misuse because they were for local travel expenses 2.1% 0.5%8.0%
Transactions that constituted misuse because they were for conference registration 2.1% 0.1%6.0%
Transactions that constituted misuse because they were for travel-related expenses 
1.2% 0.2%6.4%
of persons other than the cardholders
Source:  Office of Inspector General analysis of agency/organization program coordinators responses to transaction inquiries, 2008.
 
 
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 A P P E N D I X ~ D  
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A P P E N D I X   ~   D  
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 A C K N O W L E D G M E N T S  
This report was prepared under the direction of Brian T. Pattison, 
Regional Inspector General for Evaluation and Inspections in the 
Kansas City regional office.   
Tricia Fields served as the team leader for this study.  Other principal 
Office of Evaluation and Inspections staff from the Kansas City regional 
office who contributed to the report include Rae Bozworth, Julie Dusold, 
Lt. Mike Garner, and Dennis Tharp; central office staff who contributed 
include Robert Gibbons and Scott Manley. 
 
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