AUDIT REPORT 

Audit of NRC’s Premium Class Travel 

OIG-08-A-16 September 12, 2008 

All publicly available OIG reports (including this report) are accessible through 

NRC’s Web site at: 

http:/www.nrc.gov/reading-rm/doc-collections/insp-gen/ 


Audit of NRC”s Premium Class Travel 

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EXECUTIVE SUMMARY 

BACKGROUND

The Nuclear Regulatory Commission (NRC) is required to follow the 

Federal Travel Regulations (FTR) for all travel taken for Government 

business. The FTR, issued by the General Services Administration, 

implements statutory and Office of Management and Budget (OMB) 

requirements and policies for most Federal civilian employees and others 

authorized to travel at the Government’s expense. OMB’s policy related to 

travel is that taxpayers should not pay more than necessary to transport 

Government officials. Consistent with this principle, the FTR states that, 

with limited exceptions, travelers must use coach class accommodations 

for both domestic and international travel. 

PURPOSE

The audit objectives were to determine if: 

• Travel costs associated with premium air travel (i.e., per diem) are 

properly authorized, justified, and documented. 

• Premium air travel is properly authorized, justified, and 

documented. As part of this objective, the Office of the Inspector 

General specifically assessed compliance with requirements in 

OMB Memorandum M-08-07, “Use of Premium Class Travel.” 

RESULTS IN BRIEF

With respect to per diem associated with premium travel, NRC’s travel 

program is well managed. However, NRC needs to improve controls over 

the premium air travel process to prevent excess spending on travel and 

to properly justify the money used for premium air transportation. 

RECOMMENDATIONS

This report makes recommendations to improve controls over the use of 

premium travel. A consolidated list of these recommendations appears at 

the end of Section III of this report.

AGENCY COMMENTS

At a September 3, 2008, exit conference, agency senior executives 

provided suggested revisions to the discussion draft report. This final 

report incorporates revisions made, where appropriate, as a result of the 

agency’s suggestions. 
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ABBREVIATIONS AND ACRONYMS 

DOI/NBC Department of the Interior/National Business Center 

FTR Federal Travel Regulations 

GAO Government Accountability Office 

MD Management Directive 

NRC Nuclear Regulatory Commission 

OCFO Office of the Chief Financial Officer 

OIG Office of the Inspector General 

OMB Office of Management and Budget 
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TABLE OF CONTENTS 

EXECUTIVE SUMMARY................................................................................... i 

ABBREVIATIONS AND ACRONYMS ..............................................................iii 

I. BACKGROUND........................................................................................1 

II. PURPOSE................................................................................................3 

III. FINDINGS ................................................................................................4 

 A. TRAVEL COSTS ASSOCIATED WITH PREMIUM TRAVEL ............................4 

 B. PREMIUM AIR TRAVEL .........................................................................6 

IV. AGENCY COMMENTS...........................................................................14 

APPENDICES 

A. SCOPE AND METHODOLOGY ..........................................................16 

B. FEDERAL TRAVEL REGULATIONS...................................................18 

C. OMB MEMORANDUM M-08-07 ..........................................................20 

D. NRC’S DEFINITION OF REST PERIOD .............................................22 

E. SPECIFIC AUTHORIZATION FORM...................................................24 
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I. BACKGROUND 

Federal Travel Regulations

The Nuclear Regulatory Commission (NRC) is required to follow the 

Federal Travel Regulations (FTR) for all travel taken for Government 

business. The FTR, issued by the General Services Administration, 

implements statutory and Office of Management and Budget (OMB) 

requirements and policies for most Federal civilian employees and others 

authorized to travel at the Government’s expense. OMB’s policy related to 

travel is that taxpayers should not pay more than necessary to transport 

Government officials. Consistent with this principle, the FTR states that, 

with limited exceptions, travelers must use coach class accommodations 

for both domestic and international travel. 

The FTR outlines when greater than coach class accommodations 

(i.e., premium travel1

) can be used. Premium travel has two main 

categories: first class travel and other greater than coach travel 

(e.g., business class, economy plus). There are four approved reasons 

for employees to use first class travel and nine reasons for use of other 

types of premium travel (see Appendix B for a listing of these reasons). 

GAO Report

A September 2007 Government Accountability Office (GAO) audit report, 

“Internal Control Weaknesses Governmentwide Led to Improper and 

Abusive Use of Premium Class Travel,” cited numerous breakdowns in 

key internal controls, a weak control environment, and ineffective 

oversight Governmentwide that led to vast unauthorized and improper use 

of premium class travel. GAO initiated this Governmentwide audit 

because of a March 2006 audit of the Department of State’s travel 

program which noted that although premium class travel was used on only 

19 percent of trips, it accounted for nearly 49 percent of all travel costs. In 

the September 2007 audit report, GAO estimated that approximately 

67 percent of all premium class travel taken by Government employees 

was not properly authorized, justified, or both – costing taxpayers at least 

$146 million in excess travel expenses. 

OMB Memorandum

In response to the September 2007 GAO report, OMB issued 

Memorandum M-08-07, “Use of Premium Class Travel” (OMB M-08-07), 

to all department and agency heads as a reminder of the premium class 

travel requirements and to reinforce the importance of having clearly 

 

1

 For the remainder of this report, all greater than coach class travel will be referred to as premium travel. 
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defined internal controls for using such travel (see Appendix C for a copy 

of the memorandum). OMB required that all agency heads (1) implement 

six policies over the premium travel process and (2) respond in writing, no 

later than March 31, 2008, to illustrate that they had addressed the six 

policy areas. 

NRC Travel Program

The Office of the Chief Financial Officer (OCFO) manages NRC’s travel 

program, which entails authorizing funds to pay for all flights, approving 

expenses incurred on travel, and reimbursing employees for authorized 

travel expenses. In January 2008, OCFO outsourced the review, 

approval, and reimbursement of travel expenses to the Department of 

Interior, National Business Center (DOI/NBC). As part of this 

arrangement, DOI/NBC is responsible for checking travel vouchers for 

completeness and reimbursing employees for funds claimed on travel 

vouchers. 

As another recent initiative, NRC is implementing an electronic travel 

process known as eTravel.2 In March 2008, NRC began piloting the 

eTravel process for selected users to assess the system and ensure that 

the eTravel process will meet user needs. NRC anticipates fully 

implementing eTravel by January 2009. The eTravel program will allow 

the agency to process premium travel requests and premium travel 

reimbursements electronically; therefore, it is important that NRC address 

issues related to processing premium travel before full implementation of 

the eTravel program. 

Between October 1, 2006, and March 31, 2008, NRC officials reported 

spending approximately $7.76 million on all air travel expenses. Premium 

air travel composed 7 percent (approximately $550,000) of this total cost. 

During this period, NRC employees took 77 premium air travel trips. 

 

2

 E-Gov Travel (eTravel) is a Web-based Governmentwide service to manage Federal Government travel from 

beginning (authorization) to end (payment). 
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II. PURPOSE

The audit objectives were to determine if: 

• Travel costs associated with premium air travel (i.e., per diem) are 

properly authorized, justified, and documented. 

• Premium air travel is properly authorized, justified, and 

documented. As part of this objective, the Office of the Inspector 

General (OIG) specifically assessed compliance with requirements 

in OMB Memorandum M-08-07. 

Appendix A contains information on the audit scope and methodology. 
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III. FINDINGS

With respect to per diem associated with premium travel, NRC’s travel 

program is well managed. However, NRC needs to improve controls over 

the premium air travel process to prevent excess spending on travel and 

to properly justify the money used for premium air transportation. 

A. Travel Costs Associated with Premium Travel 

Travel costs associated with premium travel were generally authorized, 

justified, and documented in accordance with Federal requirements. 

Federal Travel Regulation Requirements

The FTR prescribes mandatory regulations and controls for travel by 

Federal civilian employees and others authorized to travel at Government 

expense. Specifically, employees must use established per diem rates for 

hotels unless they have prior approval from agency management to 

exceed them. For international travel, these per diem rates are set by the 

Department of State. Employees must follow these rates, unless 

authorized by agency officials to exceed them. A traveler may obtain 

actual expense reimbursement if a request for authorization is made and 

granted in advance of the travel. Additionally, approval of actual cost may 

be granted after the fact when properly supported in accordance with 

agency policy and authorized by a designated official. Regarding travel 

reimbursement, the FTR states that all travel claims must be reimbursed 

to the traveler within 30 calendar days after submission to the agency’s 

designated approving office. 

Further, NRC Management Directive (MD) 14.1, “Official Temporary Duty 

Travel,” provides NRC travelers with implementation guidance for official 

Government travel and the means to properly claim reimbursement for 

expenses. 

Associated Travel Costs Generally in Compliance

NRC generally complied with FTR per diem requirements for trips 

involving premium travel during the time period reviewed. Additionally, 

during this time period, NRC made significant improvements in processing 

travel vouchers. Auditors reviewed each of the 77 premium travel trips, 

including associated travel costs, that NRC staff took between 

October 1, 2006, and March 31, 2008. Each of these trips included at 

least one segment (i.e., part of route) of premium travel at an additional 

cost to NRC. 
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Auditors noted that after OCFO outsourced travel voucher processing to 

DOI/NBC in January 2008, there were improvements in the process. 

Specifically, travel voucher processing time improved subsequent to the 

outsourcing. Prior to the change, OCFO averaged 15 days to reimburse 

employees for travel expenses. In a few instances, OCFO took longer 

than 30 days to reimburse employees. However, since DOI/NBC took 

over the processing and payment of travel vouchers, the average 

processing time has shortened to 7 days. 
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B. Premium Air Travel 

Despite Federal and agency policies requiring that premium air travel be 

used only when warranted, approximately 50 percent of the premium air 

travel taken by NRC employees, between October 1, 2006, and 

March 31, 2008, was inappropriately authorized, justified, and/or 

documented. Additionally, NRC did not fully comply with OMB M-08-07 

with regard to the definition of a rest period (see Appendix D for NRC’s 

definition of a rest period). Further, NRC’s premium travel approval 

process for the Chairman’s travel differs from other Federal commissions. 

These problems occurred because NRC premium air travel guidance is 

inconsistent, unclear, and misleading to employees. The absence of 

proper controls over the premium air travel program resulted in NRC 

overspending approximately $104,000 on unjustified premium travel 

during the 18-month period. 

Relevant Federal and Agency Requirements

OIG identified Federal and agency policies, described below, that address 

requirements for use of premium air travel and require the proper 

authorization, justification, and documentation of decisions to use this 

class of travel. 

Federal Travel Regulations

The FTR governs the use of premium travel. This guidance requires that 

travelers fly coach for official domestic and international air travel, except 

when a traveler meets one or more prescribed exceptions and the agency 

authorizes the use of premium travel. As noted in Appendix B, there are 

four exceptions when a traveler can use first class travel and nine 

exceptions for all other types of premium travel. OCFO officials stated 

that during the period reviewed, the only two reasons for using premium 

class travel were: (1) to accommodate a disability, in which case a medical 

waiver is obtained,3

 and (2) when a traveler journeys for at least 14 hours 

without a rest period upon arrival or en route. 

MD 14.1, “Official Temporary Duty Travel”

MD 14.1 contains NRC’s internal policies and procedures that clarify the 

premium class travel provisions of the FTR. NRC’s policy is to authorize 

premium class travel in very specific, limited circumstances. As a general 

rule, coach class accommodations shall be used for all modes of 

passenger travel. 

 

3

 NRC MD 14.1 requires that written statements for medical waivers be submitted each fiscal year. 
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NRC travelers must obtain written justification for premium class travel in 

advance of travel. Furthermore, MD 14.1, Exhibit 4.2, provides a required 

format to obtain approval for premium class transportation, known as 

“specific authorization” (see Appendix E for a copy of this form). In 

addition, only the Chairman, Executive Director for Operations, and 

Inspector General are authorized to approve the use of premium travel for 

employees that report to them. MD 14.1 also states that the Chairman 

may delegate his signature authority within the Office of the Chairman to 

authorize premium class transportation. Per MD 14.1, the Chairman may 

also authorize and approve requests for premium class travel for himself. 

GAO Standards for Internal Control

GAO’s publication, “Standards for Internal Control in the Federal 

Government,” states that internal controls and all transactions need to be 

clearly documented and the documentation should be readily available for 

examination. Additionally the GAO standards state that documentation 

should appear in management directives, and administrative policies and 

records should be properly managed and maintained. 

OIG notes appropriate documentation of transactions is useful in 

evaluating or analyzing operations. When documentation of transactions 

is complete and accurate, it facilitates the tracing of transactions from 

travel authorization, through the travel voucher process, to the completed 

reimbursement to the traveler. Therefore, travel vouchers should include 

enough information for a clear audit trail. 

OMB M-08-07

In January 2008, OMB issued Memorandum M-08-07, “Use of Premium 

Class Travel,” to department and agency heads both as a reminder of 

premium class travel requirements and to reinforce the importance of 

establishing clearly defined internal controls regarding the use of premium 

class accommodations. OMB required that agencies implement the 

following premium class travel policies immediately: 

• Require that premium class travel requests for all agency 

personnel, including senior-level executives, be approved by an 

individual at least at the same level as the traveler, or by an office 

designated to approve premium class travel. 

• Develop and issue internal guidance that explains when mission 

criteria and intent call for premium class accommodations. 

• Define what constitutes a rest period. 
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• Require annual certifications of a disability, unless such disability is 

lifelong. 

• Restrict premium class travel for both temporary duty and 

permanent change of station travel (relocations) when the 

employee is not required to report to duty the following day. 

• Prohibit blanket travel authorizations for premium class travel, 

unless the traveler has a certification of disability. 

Premium Travel Inappropriately Authorized, Justified, and/or 

Documented

Despite requirements, approximately one half of the premium air travel 

trips taken were inappropriately authorized, justified, and/or documented. 

OIG reviewed all travel packages associated with the 77 premium travel 

trips taken between October 1, 2006, and March 31, 2008. Travel 

packages – which included travel authorization request forms, hotel 

receipts, airline itineraries, and detailed lists of expenses – were reviewed 

to determine if: 

• Appropriate approval was granted. 

• Travel met FTR requirements. 

• Supporting documentation was included. 

OIG determined that at least one problem existed with authorization, 

justification, or documentation in approximately 50 percent of the 

77 premium travel trips reviewed. 

Authorization

OIG considered a premium travel request properly authorized if it included 

administrative approval by the Chairman4

 or the Executive Director for 

Operations, based on the traveler’s office reporting structure. Such 

approval is conveyed by signature on the travel authorization form or on 

an attached signed memorandum approving premium travel (i.e., specific 

authorization). OIG reviewed the 77 travel packages requiring Chairman 

or the Executive Director for Operations signature and determined that 

34 trips did not contain the appropriate signatures and therefore were not 

properly authorized. 

 

4

 MD 14.1 states that the Chairman can delegate, within his office, his authority to approve premium travel. The 

Chairman has delegated this authority to three members of his staff. OIG considered these signatures as properly 

authorized. 
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Justification

A premium travel trip was determined to be justified if all premium portions 

of the travel met FTR requirements. While the FTR describes 

13 exceptions allowing use of premium travel, NRC used only 2 types of 

exceptions during the period reviewed: a medical waiver and flights longer 

than 14 hours. 

As shown in Table 1, all 34 premium travel trips involving medical waivers 

were properly justified, while 29 of the 43 trips involving the 14-hour rule 

did not fully meet FTR requirements. 

Table 1. Breakdown of Premium Air Trips 

Medical Waiver 14-Hour Rule Total 

Justified 34 14 48 

Unjustified 0 29 29 

Total 34 43 77 

The FTR states that premium class travel can be used when: 

“...the origin and/or destination are outside the continental United 

States, and the scheduled flight time, including stopovers and 

change of planes, is in excess of 14 hours. (In this instance you 

will not be eligible for a rest stop en route or a rest period upon 

arrival at your duty site.)” (Emphasis added.) 

The FTR further states that a rest period should not exceed 24 hours. 

While all premium travel trips taken using the 14-hour rule met the travel 

length requirements, the 29 unjustified trips included adequate rest 

periods upon arrival; therefore, the employees were not justified in using 

premium travel. 

Documentation

OIG considered a premium travel request properly documented if it 

included a written explanation as to why the traveler requested premium 

travel. This explanation should be noted on the travel authorization form 

or on an attached specific authorization form. Of the 77 premium travel 

trips taken, 24 trips were not documented properly. Specifically, there was 

no stated reason for the use of premium travel. 
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Furthermore, OIG reviewed travel voucher packages for completeness of 

information. Of the 77 travel voucher packages reviewed, 28 were 

missing information. All but one of these travel voucher packages were 

missing itineraries. While OCFO was able to provide information on the 

flights taken on these premium trips, this information was not included in 

the travel package records. 

Compliance with OMB Memorandum

NRC generally complied with OMB M-08-07 in that the agency responded 

to the March 31, 2008, deadline5

 and the response addressed all six 

policy areas. For many of the areas that OMB requested agencies to 

address, NRC already had existing guidance. However, OIG concluded 

that NRC’s definition of a rest period is not complete. Specifically, NRC 

needs to clearly define how a rest period impacts the use of premium 

travel. 

OIG also determined that NRC’s policy of permitting the Chairman to selfauthorize premium travel is at variance with OMB M-08-07’s direction that 

requests must be approved by someone at the same level or by an office 

designated to approve premium travel. OIG contacted five Government 

agencies with Commission structure similar to NRC’s to determine their 

processes for approving premium travel for their Chairmen. OIG found 

that none permitted Chairman self-approval, as allowed by NRC. 

Table 2. Premium Travel Approval for Chairmen of Commission-Based Agencies 

 

Federal 

Communications 

Commission

Securities 

and 

Exchange 

Commission

Federal 

Energy 

Regulatory 

Commission

Consumer 

Product 

Safety 

Commission

Federal 

Trade 

Commission

Approves 

Chairman 

Premium 

Travel

Managing Director 

(e.g., Executive 

Director) 

Executive 

Director 

Executive 

Director 

Acting 

Chairman in 

conjunction 

with the 

General 

Counsel 

Executive 

Director 

As noted in Table 2, all five agencies have a designated office that 

approves the Chairman’s premium travel. Four of the five agencies 

designate the Executive Director to approve the Chairman’s travel. For 

 

5

 NRC was granted a 1-week extension to the deadline and NRC submitted its response before this extension 

expired.
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the other agency, the Acting Chairman, in conjunction with the General 

Counsel, approves premium travel for the Chairman. OIG’s benchmarking 

review shows that agencies with a similar structure to NRC do not allow 

self-authorization. 

OIG met with the GAO auditors who conducted the audit that identified 

Governmentwide weaknesses in internal controls over the use of premium 

class travel. Based on this meeting, OIG learned that, as a general rule, 

GAO believes self-authorization is not a good practice and that senior 

executives should not approve their own travel. It is important that 

someone independent review travel requests for agency heads prior to the 

travel and, further, it is important that this process be documented in the 

agency policies. 

Guidance and Controls Lacking Over Premium Travel

NRC’s failure to comply with premium class travel restrictions occurred 

because of incorrect agency guidance and lack of controls in the travel 

approval process. 

Inappropriate authorizations of premium travel occurred because NRC 

guidance concerning authorizations is inconsistent, unclear, and 

misleading and because OCFO did not require the necessary signatures 

for some premium travel trips. MD 14.1 contains conflicting information 

regarding who can approve premium class travel. While one section 

states that the Chairman, Executive Director for Operations, and Inspector 

General are responsible for approving premium travel, another section 

states that Office Directors, Regional Administrators, and the Chief 

Financial Officer can approve premium class travel. OCFO officials 

clarified to OIG that only the Chairman, Executive Director for Operations, 

and Inspector General should approve requests for premium travel. 

An OCFO official stated the office is aware of these inconsistencies in 

MD 14.1 and is working to correct the language. OCFO also issued a 

yellow announcement on March 7, 2008, to all employees reminding them 

of the rules of premium travel and identifying the approving officials for 

premium travel. In addition, OCFO staff acknowledged that they did not 

require Chairman or Executive Director for Operations signatures for 

premium travel trips that met the 14-hour rule, which also contributed to 

the problems OIG identified. 

Improperly justified premium travel occurred because of a lack of sufficient 

internal controls over the premium travel process. According to OCFO 

management, the traveler’s supervisor is responsible for reviewing the 

travel request and determining if premium travel is justified. However, 

these first-line supervisors are not trained on FTR and NRC requirements 

for using premium travel. Additionally, OCFO staff who process premium 
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travel requests rely on first-line supervisors to determine whether a rest 

period was taken upon arrival at a travel destination or upon return. 

OCFO staff do not have access to traveler schedules and are unable to 

make these determinations; therefore, they do not provide a second level 

of scrutiny over appropriate use of premium travel, e.g., use of a rest 

period. However, OCFO staff are required to ensure that flights meet the 

14-hour requirement. OCFO management acknowledges that the use of a 

rest period was not factored into the decision to allow employees to take 

premium travel. 

Inconsistencies in travel authorization requests and travel voucher 

packages occur because OCFO staff do not require consistent 

documentation. OCFO staff stated that the office did not require specific 

authorizations (i.e., an attached signed memorandum approving the use of 

premium travel, such as the one shown in Appendix E of this report) to be 

attached to the travel authorizations. 

OIG determined that during the 18-month review period, NRC spent 

approximately $550,000 on premium air travel, $104,000 of which was not 

justified. With improved controls over the process, NRC would have been 

able to put these funds to better use. Furthermore, without appropriate 

documentation for decisions regarding premium travel, NRC is unable, in 

many instances, to explain why premium travel was needed. As NRC 

transitions to eTravel, it is important that proper controls and guidance be 

implemented to prevent these errors in the future. 

Recommendations

The Office of the Inspector General recommends that the Chief Financial 

Officer: 

1. Update Management Directive 14.1 to: 

• Clearly identify premium travel authorizing officials. 

• Clarify “Delegation of Authority” and require this to be in 

written form. 

• Clarify the 14-hour rule, specifically the rest period. 

2. Issue interim guidance to accomplish the intent of 

Recommendation 1, pending revision of Management 

 Directive 14.1. 
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3. Provide annual training on premium travel requirements to 

travelers and supervisors involved in premium travel. This 

training should include: 

• Who can authorize. 

• What makes it justified. 

• What documentation is required. 

4. Develop and implement internal controls to ensure that proper 

authorization, justification, and documentation exist before 

issuing premium travel air tickets. 

5. Develop and implement internal controls to ensure that travel 

voucher packages include itineraries. 

6. As NRC transitions to eTravel, develop controls that: 

• Require premium travel to be authorized by the 

appropriate officials. 

• Ensure premium travel justification fully meets FTR 

criteria. 

• Require travel authorization forms to state reasons why 

premium travel is required. 

7. Designate the Executive Director for Operations as the 

approving official for all Chairman requests for premium travel. 
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IV. AGENCY COMMENTS 

At an exit conference on September 3, 2008, NRC officials agreed with 

the report contents and provided editorial suggestions, which OIG 

incorporated as appropriate. 
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Appendix A 

SCOPE AND METHODOLOGY 

Auditors evaluated NRC’s premium travel program to determine if travel 

packages contained proper authorization, justification, and supporting 

documentation to validate the use of premium travel. In addition, auditors 

reviewed the associated per diem of premium travel and related issues 

including timely payment upon completion of the travel voucher. 

The audit team reviewed NRC compliance with relevant criteria, including 

the FTR; NRC MD 14.1, “Official Temporary Duty Travel;” and OMB 

M-08-07, “Use of Premium Class Travel.” Other criteria reviewed related 

to the internal controls over premium travel include GAO Report 07-1268, 

“Internal Control Weaknesses Governmentwide Led to Improper and 

Abusive Use of Premium Class Travel,” dated September 2007; GAO 

Standards for Internal Control; Department of State prescribed per diem 

rate schedule; and NRC Yellow Announcement 08-033, “Reminder 

Regarding Use Of Premium Class Airline Travel.” 

At NRC Headquarters in Rockville, MD, auditors interviewed OCFO staff 

and management from Carlson Wagonlit Travel, the agency’s travel 

services contractor, to gain an understanding of their roles and 

responsibilities as they pertain to the issuance of premium class travel 

accommodations. Auditors also interviewed the project manager for 

NRC’s eTravel system to assess how internal controls have and could be 

incorporated into eTravel. Additionally, auditors traveled to Denver, CO, 

to interview DOI/NBC staff who process travel vouchers. 

OIG reviewed 100 percent of premium travel taken between 

October 1, 2006, and March 31, 2008, and identified all trips containing at 

least one segment of premium class travel. OIG excluded from the review 

premium class travel that represented no additional cost to the 

Government. Auditors analyzed the remaining trips and determined if: 

• Proper authorization existed. 

• The trip met the FTR criteria. 

• The travel package contained the proper documentation. 

Auditors then determined the excess cost borne by the Government for 

any travel found not justified in accordance with one of the 13 reasons 

stated in the FTR as justification for premium travel. 
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This work was conducted from March 2008 through August 2008 in 

accordance with generally accepted Government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. The work was conducted by 

Steven Zane, Team Leader; Kathleen Stetson, Audit Manager; 

Rebecca Underhill, Senior Auditor; Yvette Mabry, Senior Auditor; and 

Joseph Foster, Management Analyst Intern. 
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Appendix B 

FEDERAL TRAVEL REGULATIONS 

The following is taken directly from FTR, Part 301-10, “Transportation 

Expenses.” 

First Class Travel

You may use first-class airline accommodations only when your agency 

specifically authorizes/approves your use of such accommodations, for the 

reasons given under paragraphs (a) through (d) of this section [of FTR]. 

(a) No coach or business-class accommodations are reasonably 

available. “Reasonably available” means available on an airline that 

is scheduled to leave within 24 hours of your proposed departure 

time, or scheduled to arrive within 24 hours of your proposed arrival 

time. 

(b) When use of first-class is necessary to accommodate a disability or 

other special need. A disability must be substantiated annually in a 

written statement by a competent medical authority. A special need 

must be substantiated in writing according to your agency’s 

procedures. If you are authorized under §301-13.3(a) of this chapter 

[of FTR] to have an attendant accompany you, your agency also 

may authorize the attendant to use first-class accommodations if you 

require the attendant’s services en route. 

(c) When exceptional security circumstances require first-class travel. 

Exceptional security circumstances are determined by your agency 

and include, but are not limited to: 

(1) Use of other than first-class accommodations would 

endanger your life or Government property; 

(2) You are an agent on protective detail and you are 

accompanying an individual authorized to use first-class 

accommodations; or 

(3) You are a courier or control officer accompanying controlled 

pouches or packages. 

(d) When required because of agency mission. 
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Other Premium Class Travel

[You may use business-class airline accommodations] only when your 

agency specifically authorizes/approves your use of such 

accommodations, for the reasons given under paragraphs (a) through (i) 

of this section [of FTR]. 

(a) Regularly scheduled flights between origin/destination points 

(including connecting points) provide only first-class and businessclass accommodations and you certify such on your voucher. 

(b) No space is available in coach-class accommodations in time to 

accomplish the mission, which is urgent and cannot be postponed. 

(c) When use of business-class accommodations is necessary to 

accommodate your disability or other special need. Disability must 

be substantiated in writing by a competent medical authority. 

Special need must be substantiated in writing according to your 

agency’s procedures. If you are authorized under §301-13.3(a) of 

this chapter [of FTR] to have an attendant accompany you, your 

agency also may authorize the attendant to use business-class 

accommodations if you require the attendant’s services en route. 

(d) Security purposes or exceptional circumstances as determined by 

your agency make the use of business-class accommodations 

essential to the successful performance of the agency’s mission. 

(e) Coach-class accommodations on an authorized/approved foreign air 

carrier do not provide adequate sanitation or health standards. 

(f) The use results in an overall cost savings to the Government by 

avoiding additional subsistence costs, overtime, or lost productive 

time while awaiting coach-class accommodations. 

(g) Your transportation costs are paid in full through agency acceptance 

of payment from a non-federal source in accordance with Chapter 

304 [of FTR]. 

(h) Where the origin and/or destination are outside the continental 

United States, and the scheduled flight time, including stopovers and 

change of planes, is in excess of 14 hours. (In this instance you will 

not be eligible for a rest stop en route or a rest period upon arrival at 

your duty site.). 

(i) When required because of agency mission. 
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Appendix C 

OMB MEMORANDUM M-08-07 
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Appendix D 

NRC’S DEFINITION OF REST PERIOD 

MD 14.1, Section 4.4.2, defines a rest period as follows: 

The NRC may authorize a rest period of up to 24 hours when the following 

four conditions are met: 

(1) Employees travel directly between authorized origin and destination 

points that are separated by several time zones 

(2) Either the origin or destination point is outside CONUS 

(3) Employees are traveling by less than premium class 

accommodations 

(4) The scheduled flight time, including stopovers, exceeds 14 hours 

The rest stop may be authorized for any intermediate point, including 

points within CONUS, provided the point is midway in the journey or as 

near to midway as requirements for use of U.S. flag air carriers and carrier 

scheduling permit. 

A rest stop will not be authorized when an employee, for personal 

convenience, elects to travel by an indirect route resulting in excess travel 

time. 

The per diem rate for the rest stop will be the rate applicable for the rest 

stop location. 

When a rest stop is not authorized or cannot be scheduled due to airline 

schedules, the traveler should plan his or her trip to allow sufficient time to 

rest before reporting to duty. 
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Appendix E 

SPECIFIC AUTHORIZATION FORM