a

GAO

United States General Accounting Office

Report to Congressional Requesters

March 2004 DOD TRAVEL CARDS

Control Weaknesses 

Led to Millions of 

Dollars Wasted on 

Unused Airline Tickets

GAO-04-398
www.gao.gov/cgi-bin/getrpt?GAO-04-398.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Gregory D. Kutz 

at (202) 512-9505 or kutzg@gao.gov. 

Highlights of -GAO-04-398, a report to 

congressional requesters 

March 2004

DOD TRAVEL CARDS

Control Weaknesses Led to Millions of 

Dollars Wasted on Unused Airline Tickets 

Control breakdowns over the centrally billed accounts resulted in DOD 

paying for airline tickets that were not used and not processed for refund. 

DOD was not aware of this problem before our audit and did not maintain 

data on unused tickets. We determined, based on airline data, that DOD had 

purchased—primarily in fiscal years 2001 and 2002—about 58,000 tickets 

with a residual (unused) value of more than $21 million that remained 

unused and not refunded as of October 2003. We also identified more than 

81,000 partially unused airline tickets with a purchase price of about 

$62 million that will require additional analysis to determine the residual 

value. Based on further analysis of the limited data, it is possible that DOD 

purchased at least $100 million in airline tickets that it did not use and for 

which it did not claim refunds from fiscal years 1997 through 2003. 

Fully Unused and Partially Unused Airline Tickets 

Airline Number of tickets Residual value (dollars in millions)

American 15,877 $4.1

Delta 15,588 6.4

Northwest 3,479 2.3

United 16,283 6.0

US Airways 6,719 2.3

Total known unused tickets 57,946 $21.1

Potential unused tickets At least $100

Source: GAO analysis of airline and Bank of America data. 

Although GAO asked DOD’s five most frequently used airlines for fiscal year 

2001 and 2002 unused ticket data, the airlines did not provide uniform, 

complete, or consistent responses. For example, one airline did not provide 

partially unused ticket data, another airline’s fiscal year 2001 data covered 

only September 2001, while yet another airline provided data on electronic 

tickets dating back to November 1998. Although additional data on unused 

tickets may be available from the airlines’ archives, our attempts to obtain 

additional information were unsuccessful. 

DOD’s unused ticket problems were caused by a flawed process that relied 

extensively on DOD personnel to report unused tickets to the travel offices. 

Although it appears that many unused tickets were processed for a refund, 

the internal controls DOD had in place did not detect millions of dollars of 

unused airline tickets. Specifically, DOD did not systematically implement 

compensating procedures to identify instances in which DOD personnel did 

not report unused tickets, or reconcile the centrally billed accounts to travel 

claims to determine whether airline tickets were used. Although some units 

had instituted a process by fiscal year 2002 to more systematically identify 

instances of unused tickets, the process was not implemented DOD-wide, 

DOD did not verify that units were consistently implementing the process, 

and the process could only identify unused electronic—not paper—tickets. 

Ineffective oversight and 

management of the Department of 

Defense’s (DOD) travel card 

program, which GAO previously 

reported on, have led to concerns 

about airline tickets DOD 

purchased but did not use and for 

which it did not claim refunds. 

GAO was asked to (1) determine 

whether, and to what extent, airline 

tickets purchased through the 

centrally billed accounts were 

unused and not refunded and 

(2) determine whether DOD’s 

internal controls provided 

reasonable assurance that all 

unused tickets were identified and 

submitted for refunds. 

GAO makes 20 recommendations 

to DOD, including the following: 

• evaluate the feasibility of 

requiring DOD personnel to 

purchase airline tickets with their 

individually billed travel cards, 

which would eliminate DOD’s 

risk of paying for unused tickets; 

• implement procedures to 

systematically provide 

reasonable assurance that all 

unused tickets purchased with 

the centrally billed accounts are 

refunded; and 

• submit claims to the airlines to 

recover the $21 million in known 

unused tickets—DOD might be 

able to recover more than 

$100 million for unused tickets. 

DOD concurred with all 20 of our 

recommendations and stated that it 

had taken or will take actions to 

address these recommendations. 
Page i GAO-04-398 DOD Travel Cards

Contents

Letter 1

Results in Brief 3

Background 5

Millions of Dollars of Airline Tickets Were Unused and

Not Refunded 7

DOD Did Not Implement Effective Controls over Unused

Tickets 12

Conclusion 20

Recommendations for Executive Action 21

Agency Comments and Our Evaluation 23

Appendixes

Appendix I: Objectives, Scope, and Methodology 25

Appendix II: Known Value of Fully and Partially Unused Tickets and 

Potential Magnitude of Control Weaknesses 28

Types of Data Provided Differed Substantially between Airlines 28

Known Unused Value of Fully and Partially Unused Tickets 30

Possible Magnitude of Unused Tickets Purchased with Centrally 

Billed Accounts 33

Appendix III: Comments from the Department of Defense 36

Appendix IV: GAO Contacts and Staff Acknowledgments 44

GAO Contacts 44

Acknowledgments 44

Tables Table 1: Known Residual Value of Fully and Partially Unused 

Airline Tickets, November 1998 through December 2002 8

Table 2: Known Residual Value of Fully Unused Airline Tickets, 

November 1998 through December 2002 9

Table 3: Known Partially Unused Airline Tickets, November 1998 

through December 2002 10

Table 4: Type of Data Provided by the Airlines 29

Table 5: Known Value of Unused Tickets by Airline 31

Table 6: Partially Unused Ticket Number and Value 32

Table 7: Fiscal Year 2002 Fully Unused Ticket Ratios 33

Table 8: Analysis of Fiscal Year 2002 Partially Unused 

Ticket Ratios 35
Contents

Page ii GAO-04-398 DOD Travel Cards

Figures Figure 1: Value of Tickets Charged to DOD’s Centrally Billed 

Accounts by Airline, Fiscal Years 2001 and 2002 6

Figure 2: Possible Control Breakdowns in the Unused Ticket 

Process 14

Abbreviations

CTO Commercial Travel Office

DOD Department of Defense

DTS Defense Travel System

GTO Government Travel Office

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Page 1 GAO-04-398 DOD Travel Cards

United States General Accounting Office

Washington, D.C. 20548

A

March 31, 2004 Letr

The Honorable Norm Coleman

Chairman

The Honorable Carl Levin 

Ranking Minority Member

Permanent Subcommittee on Investigations

Committee on Governmental Affairs

United States Senate

The Honorable Charles E. Grassley

Chairman 

Committee on Finance

United States Senate 

The Honorable Janice Schakowsky

House of Representatives

This report is a continuation of our series of reports on the Department of 

Defense’s (DOD) management of its travel card programs. In fiscal years 

2002 and 2003, we issued a series of testimonies1

 and reports2 addressing 

problems that the Army, Navy, and Air Force had in managing individually 

billed travel card accounts. These testimonies and reports showed high 

delinquency rates and significant potential fraud and abuse related to 

DOD’s travel card programs. Due to these concerns, you asked us to audit 

controls over the other major form of payment used by DOD for travel 

expenses—centrally billed accounts. In response to your request, we

1

U.S. General Accounting Office, Travel Cards: Control Weaknesses Leave Army Vulnerable 

to Potential Fraud and Abuse, GAO-02-863T (Washington, D.C.: July 17, 2002), and Travel 

Cards: Control Weaknesses Leave Navy Vulnerable to Fraud and Abuse, GAO-03-148T

(Washington, D.C.: Oct. 8, 2002).

2

U.S. General Accounting Office, Travel Cards: Control Weaknesses Leave Army Vulnerable 

to Potential Fraud and Abuse, GAO-03-169 (Washington, D.C.: Oct. 11, 2002); Travel Cards: 

Control Weaknesses Leave Navy Vulnerable to Fraud and Abuse, GAO-03-147 (Washington, 

D.C.: Dec. 23, 2002); and Travel Cards: Air Force Management Focus Has Reduced 

Delinquencies, but Improvements in Controls Are Needed, GAO-03-298 (Washington, D.C.: 

Dec. 20, 2002).
Page 2 GAO-04-398 DOD Travel Cards

reported3 in October 2003 that internal control weaknesses over DOD’s 

centrally billed accounts led to millions of dollars of improper premium 

class travel and increased costs to taxpayers. These weaknesses provide 

further examples of DOD’s long-standing financial management problems, 

which are pervasive, complex, and deeply rooted in virtually all business 

operations throughout the department. Such problems led us in 1995 to put 

DOD financial management on our list of high-risk areas, that is, areas that 

are highly vulnerable to fraud, waste, and abuse, a designation that 

continues today.4

 In light of the internal control problems with DOD’s travel 

card programs, you asked us to expand our work in the area of centrally 

billed accounts to determine (1) whether, and to what extent, airline tickets 

purchased through the centrally billed accounts were still unused and not 

refunded and (2) whether DOD’s internal controls provided reasonable 

assurance that all unused tickets were identified and submitted for refunds. 

To determine the magnitude of tickets purchased through the centrally 

billed accounts during fiscal years 2001 and 2002 that were unused and not 

refunded, we compared data on unused tickets provided by airlines (refer 

to app. II for information on data provided by airlines) to data provided by 

the Bank of America—DOD’s credit card bank. The unused ticket data 

came from the five U.S. airlines that provided about 82 percent of the value 

of all airline tickets DOD purchased during this period. Although we were 

able to validate that the tickets the airlines had on record as being unused 

were tickets that DOD had purchased with its centrally billed accounts, we 

were unable to confirm the completeness of the population of unused 

tickets we received from four of the five airlines. Despite the possibility of 

understating the extent of the problem, we used the airline data to 

determine the possible magnitude of DOD’s unused tickets from fiscal 

years 1997 through 2003. Further, we reviewed the unused ticket process to 

evaluate whether internal controls over the centrally billed accounts were 

properly designed to identify unused tickets, submit these tickets for 

refunds, and verify that refunds had been received. Appendixes I and II 

provide details on our scope and methodology.

3

U.S. General Accounting Office, Travel Cards: Internal Control Weaknesses at DOD Led to 

Improper Use of First and Business Class Travel, GAO-04-88 (Washington, D.C.: Oct. 24, 

2003), and Travel Cards: Internal Control Weaknesses at DOD Led to Improper Use of First 

and Business Class Travel, GAO-04-229T (Washington, D.C.: Nov. 6, 2003).

4

U.S. General Accounting Office, High-Risk Series: An Overview, GAO/HR-95-1

(Washington, D.C.: February 1995), and High-Risk Series: An Update, GAO-03-119

(Washington, D.C.: January 2003).
Page 3 GAO-04-398 DOD Travel Cards

We performed our work from March 2003 through January 2004 in 

accordance with generally accepted government auditing standards. We 

requested comments on a draft of this report from the Secretary of Defense 

or his designee. We received written comments, which are reprinted in 

appendix III of this report. 

Results in Brief A lack of departmentwide controls over the centrally billed accounts 

resulted in DOD paying for millions of dollars of airline tickets that were 

not used and not processed for refund. DOD was not aware of this problem 

before our review because it did not maintain data on unused tickets. Our 

analysis of the limited data provided by DOD’s five most frequently used 

airlines found that DOD had purchased—primarily in fiscal years 2001 and 

2002—about 58,000 tickets with a residual (unused) value of $21.1 million 

that remained unused and not refunded as of October 2003. In addition, 

three airlines had not determined the residual value of more than 81,000 

partially unused tickets, that is, at least one leg had not been used, with a 

total purchase price of more than $62 million. These amounts likely 

understate the value of fully and partially unused tickets because only two 

of the five airlines were able to provide us complete data on unused fiscal 

years 2001 and 2002 tickets as requested, and one airline did not provide 

any data for partially unused tickets. Based on further assessment of the 

limited data, we determined that it is possible that since 1997, DOD 

purchased more than $100 million in airline tickets with its centrally billed 

accounts that it did not use and did not process for refunds. Airline 

representatives informed us that limitations with the way their data are 

maintained prevented them from providing us with complete and 

consistent data, and our attempts to obtain additional information were 

unsuccessful. Federal agencies are authorized to recover payments made 

to airlines for tickets that agencies ordered but did not use. While generally 

a 6-year statute of limitations applies to the government’s ability to file an 

action for money damages based on a contractual right, the government 

also has up to 10 years to offset future payments for amounts it is owed. 

Millions of dollars in unused tickets have been wasted because DOD did 

not have a systematic process to identify and process unused tickets. 

DOD’s flawed process relied extensively on DOD personnel to report 

unused tickets to the travel offices. DOD did not systematically implement 

compensating procedures to identify instances in which DOD personnel 

did not report unused tickets, or reconcile the centrally billed accounts to 

travel claims to determine whether airline tickets were used. This failure to 

reconcile tickets that were centrally acquired to travel claims filed by 
Page 4 GAO-04-398 DOD Travel Cards

travelers resulted in DOD not being able to determine whether the airline 

tickets it purchased were used. Although bank data indicated that DOD 

received many credits to centrally billed accounts, the number and value of 

tickets the airlines reported as unused and not refunded demonstrated that 

the lack of effective internal control procedures led to a waste of scarce 

resources. We identified some improvements during fiscal year 2002, when 

a number of DOD commercial travel offices attempted to implement 

procedures to systematically identify unused electronic tickets within their 

computer reservation systems. However, this process had not been 

implemented DOD-wide and does not address paper airline tickets. 

Further, at locations where this technique was implemented, DOD’s 

government travel offices did not have systematic procedures to verify that 

the commercial travel offices consistently identified all unused electronic 

tickets, and that all tickets that had been identified as unused resulted in a 

credit to the centrally billed account. 

While we identified significant weaknesses in the controls over DOD’s 

centrally billed accounts, improved controls and management of 

individually billed accounts may provide DOD with options to reduce the 

financial exposure resulting from unused tickets that are not properly 

refunded. Specifically, using a well-controlled individually billed account 

program to pay for airline tickets would transfer responsibility for all 

charges to the individual cardholder, thus limiting the government’s 

financial exposure and providing an incentive to DOD cardholders to 

properly identify and claim refunds for unused tickets. However, DOD 

would still need to improve controls over its centrally billed account 

structure as not all DOD travelers would have access to an individually 

billed account, such as new employees and infrequent travelers.

This report contains 20 recommendations for DOD to reduce the risks 

associated with using the centrally billed accounts to purchase airline 

tickets by considering the feasibility of establishing the individually billed 

account travel card as the primary procurement method for transportation. 

We also recommend that DOD take a series of immediate steps to improve 

controls over the centrally billed account so that in the future, it can readily 

identify and request timely refunds on all unused tickets. Finally, we 

recommend that DOD attempt to recover all tickets that are unused and not 

refunded. To assist DOD in claiming refunds or converting the unused 

tickets to future use, in December 2003, we provided DOD a list of the 

unused ticket information we received from the airlines. DOD has told us 

that it is working to recover the value of those unused and partially used 

tickets. In written comments on a draft of this report, DOD concurred with 
Page 5 GAO-04-398 DOD Travel Cards

all 20 of our recommendations and stated that it had taken actions or will 

take actions to address these recommendations. 

Background The DOD centrally billed travel card program is part of a governmentwide 

travel card program started in 1983 with the express purpose of increasing 

convenience to the traveler and lowering (1) the government’s cost of 

travel by reducing the need for cash advances to the traveler and (2) the 

associated administrative costs. The travel card program includes both the 

individually billed accounts—accounts held and paid by the individual 

cardholders—and the centrally billed accounts. In general, individual 

cardholders use the individually billed accounts to charge nontransportation-related expenses, while most DOD services and units used 

the centrally billed accounts to purchase transportation services such as 

airline and train tickets and to facilitate expenses incurred for group 

travel.5

According to Bank of America data, the net value of airline tickets charged 

during fiscal years 2001 and 2002 to DOD’s centrally billed accounts totaled 

over $2.4 billion. As shown in figure 1, five U.S. airlines—American, Delta, 

Northwest, United, and US Airways—together accounted for more than 

82 percent of the dollar value of airline tickets purchased by DOD during 

fiscal years 2001 and 2002. More than 85 other airlines—both U.S. and 

foreign carriers—accounted for the remaining 18 percent of the value of 

total airline tickets DOD purchased in fiscal years 2001 and 2002. The 

$2.4 billion is made up of more than $2.6 billion in gross airline purchases 

net of credits totaling $233 million, or about 9 percent of gross airline 

purchases. Credits related to tickets that were unused, tickets issued 

erroneously, and charges identified as fraudulent.

5

The Air Force is an exception to this general rule. The Air Force uses both centrally billed 

and individually billed accounts for purchasing airline transportation.
Page 6 GAO-04-398 DOD Travel Cards

Figure 1: Value of Tickets Charged to DOD’s Centrally Billed Accounts by Airline, 

Fiscal Years 2001 and 2002 

The airline tickets DOD purchased through the centrally billed accounts 

are generally acquired under the terms of the air transportation services 

contract that the General Services Administration (GSA) negotiates with 

U.S. airlines. Airline tickets purchased under this contract have no advance 

purchase requirements, have no minimum or maximum stay requirements, 

are fully refundable, and do not incur penalties for changes or cancellation. 

The revenue recognition policy for the airlines industry is to recognize 

ticket sales as a liability until the transportation is provided, that is, when 

the ticket is used. The terms of the air transportation services contract also 

provide that contract carriers are to fully refund all unused portions of any 

government contract fare ticket to the activity paying for the ticket, the 

travel management center issuing the ticket, or the individual traveler, as 

appropriate. Because DOD travel regulations require that federal and 

military travelers on official business use a contract carrier for official 

airline travel unless a specific exception applies, airline tickets purchased 

by DOD are typically fully refundable. 

Federal agencies are authorized to recover payments made to airlines for 

tickets that agencies acquired but did not use.6

 While generally there is a 

6

31 U.S.C. § 3726(h).

8% - Northwest Airlines

14% - U.S. Airways

13% - American Airlines

18% - Others

23% - Delta Airlines

24% - United Airlines

Source: GAO analysis of Bank of America data.
Page 7 GAO-04-398 DOD Travel Cards

6-year statute of limitations on the government’s ability to file an action for 

money damages based on a contractual right,7

 the government also has up 

to 10 years to offset future payments for amounts it is owed.8 Several 

airlines sued GSA after it offset payments due to the airlines for the value of 

airline tickets that GSA claimed were unused. The court upheld GSA’s 

authority to administratively offset the payments despite the airlines’ 

assertion that provisions printed on the tickets themselves specified a 

shorter time limit in which the government could request a refund.9

 The 

court further held that the government’s right to refunds could not be 

limited by terms unilaterally imposed by the airlines.10

Millions of Dollars of 

Airline Tickets Were 

Unused and Not 

Refunded

As shown in table 1, data provided by five airlines and verified against Bank 

of America’s data showed that about 58,000 tickets with a value of 

$21.1 million were purchased with DOD’s centrally billed accounts but 

were unused and not refunded. The $21.1 million included more than 

48,000 tickets valued at $19.2 million that were fully unused, and 

$1.9 million in the residual value of about 10,000 American Airlines partially 

used tickets,11 that is, at least one leg had not been used. Based on our 

assessment of the limited data provided by the airlines, it is possible that 

since fiscal year 1997, DOD purchased more than $100 million in airline 

tickets that were not used and not processed for refunds and for which 

DOD may be entitled to refunds or offsets against other payments to those 

airlines. 

7

28 U.S.C. § 2415(a).

8

31 U.S.C. § 3716(e).

9

American Airlines, Inc. v. Austin, 75 F.3d 1535 (Fed. Cir. 1996). This case was an appeal of 

a prior case, American Airlines, Inc. v. Austin, 826 F. Supp. 553 (D.D.C. 1993), in which, 

among other things, the court ruled that the government was not entitled to refunds for 

unused tickets that the government could not specifically identify.

10American Airlines, Inc. v. Austin, 1541.

11Only American Airlines provided us the residual value of partially unused tickets.
Page 8 GAO-04-398 DOD Travel Cards

Table 1: Known Residual Value of Fully and Partially Unused Airline Tickets, 

November 1998 through December 2002 

Source: GAO analysis of Bank of America and airline data.

a

In total, American Airlines reported 24,013 tickets with residual value of more than $6.2 million that 

were fully or partially unused. We excluded 8,136 American Airlines unused tickets totaling more than 

$2.1 million from our analysis because either (1) less than 6 months had passed between the time the 

tickets were purchased and when American Airlines provided the file or (2) Bank of America data did 

not confirm whether the tickets were fully or partially unused. 

b

Residual value of $2.3 million represents the amount DOD paid Bank of America for those tickets. 

This amount differs slightly from Northwest Airlines’ reported fare of $2.1 million. Our analysis 

indicates that Northwest Airlines excluded taxes and fees from its reported amount of $2.1 million. 

Amount of Fully Unused 

Tickets Is Significant

Table 2 provides further details on the $19.2 million identified as being fully 

unused. Fully unused tickets made up most of the known unused tickets 

value of $21.1 million, which also included the residual value of partially 

unused tickets. As shown in table 2, DOD spent $19.2 million on more than 

48,000 airline tickets that were fully unused and not refunded. 

Dollars in millions

Airline Number of tickets Residual value of tickets

American 15,877a $4.1a

Delta 15,588 6.4

Northwest 3,479 2.3b

United 16,283 6.0

US Airways 6,719 2.3

Total 57,946 $21.1
Page 9 GAO-04-398 DOD Travel Cards

Table 2: Known Residual Value of Fully Unused Airline Tickets, November 1998 

through December 2002

Source: GAO analysis of airline data.

a

Values represent tickets purchased primarily in fiscal years 2001 and 2002. Of the $19.2 million, 

$2.4 million represents tickets that were not purchased during those 2 fiscal years. 

Since DOD was not aware of these unused tickets, and consequently did 

not know their number or dollar value, we requested these data from 

DOD’s five most frequently used airlines—American, Delta, Northwest, 

United, and US Airways. Although we asked each airline for consistent data 

on tickets purchased in fiscal years 2001 and 2002 that were unused and not 

refunded, we did not receive uniform, complete, or consistent responses. 

For example, although American Airlines and US Airways provided us with 

data on fully unused tickets for fiscal year 2002—tickets that were issued to 

DOD travelers but never traded in at a counter—they provided only partial 

data for fiscal year 2001. Delta Airlines provided us information on the 

status of all tickets DOD purchased with its centrally billed accounts during 

fiscal years 2001 and 2002, and guidance on how to identify those tickets 

that were fully and partially unused. For more detailed information on the 

breakdown of fully unused tickets by year, and further discussion of the 

types of data we received from the airlines, see appendix II. 

Residual Value of Partially 

Unused Tickets Is 

Potentially Significant

In addition to the $19.2 million in fully unused tickets, DOD failed to claim 

refunds on millions of dollars in airline tickets purchased with centrally 

billed accounts that were partially unused. As in the case of fully unused 

tickets, DOD was not aware of, and therefore did not maintain data on, 

partially unused tickets. Consequently, we had to request these data from 

the airlines. 

Dollars in millions

Airline

Number of fully unused 

tickets 

Residual value of fully 

unuseda tickets 

American 6,151 $2.2

Delta 15,588 6.4

Northwest 3,479 2.3

United 16,283 6.0

US Airways 6,719 2.3

Total 48,220 $19.2
Page 10 GAO-04-398 DOD Travel Cards

Partially unused tickets are those tickets that, although used, still have 

residual value as only portions of those tickets were traded in for travel. A 

DOD ticket may be partially unused for several reasons. For instance, a 

ticket can be partially unused when a DOD traveler used the ticket for the 

outbound flight but decided to drive home with another DOD traveler. A 

ticket can also be partially unused if, for example, a DOD traveler who was 

originally scheduled to travel from Seattle to Miami and then to San Juan, 

Puerto Rico, was ordered to return home from Miami because of weather 

problems. In this case, the portion of the airline ticket from Miami to 

Puerto Rico was unused. While the portions that have been used represent 

services rendered by the airlines, the portions that are partially used have a 

residual value that can be claimed as a refund. Table 3 summarizes the 

number and purchase price of partially unused tickets, as well as the 

residual value of partially unused tickets where available. 

Table 3: Known Partially Unused Airline Tickets, November 1998 through December 2002

Source: GAO analysis of airline data.

a

Values represent tickets purchased primarily in fiscal years 2001 and 2002. Of the more than 90,000 

tickets totaling $67.9 million, about 8,500 tickets with total purchase price of $5.2 million were not 

purchased during those 2 fiscal years. 

b

Purchase price of $7.6 million represents Bank of America data on ticket price. This amount differs 

from Northwest Airlines’ reported fare of $7.2 million. Our analysis indicates that Northwest Airlines 

excluded taxes and fees from its reported amount of $7.2 million. 

Over the entire period for which four airlines provided data on partially 

unused tickets—American, Delta, Northwest, and United—we identified 

Dollars in millions

Airline

Number of tickets identified 

as partially unuseda

Purchase price of tickets identified as 

partially unuseda

Residual value of tickets identified 

as partially unused 

US Airways Data not provided

Partially unused tickets requiring additional analysis to determine residual value

Delta 51,294 $39.3 Not provided

Northwest 7,420 7.6b Not provided

United 22,823 15.2 Not provided

Subtotal 81,537 $62.1 Not provided

Known residual value of partially unused tickets not requiring additional analysis

American 9,726 $5.8 $1.9

Total 91,263 $67.9 $1.9
Page 11 GAO-04-398 DOD Travel Cards

that more than 91,000 tickets costing about $68 million were only partially 

used. Although Delta, Northwest, and United provided data that identified 

over 81,000 partially unused tickets with a purchase price of more than

$62 million, these three airlines informed us that their ticket data are not 

maintained in a format that would allow them to easily quantify the residual 

value of these partially unused tickets. To do so would require a complex 

process involving the repricing of each of the segments that made up the 

total purchase price—a process the airlines told us would be laborintensive and costly. American Airlines was able to provide the residual 

value of its partially unused tickets—$1.9 million. Further, US Airways did 

not provide us with any data on these types of tickets. As indicated by the 

airlines, substantial work remained to be done to derive an estimate of the 

residual value of partially unused tickets. For more detailed information on 

the breakdown of partially unused tickets by year, see appendix II. 

Data Indicate That DOD 

May Have Millions More in 

Tickets That Are Unused 

and Not Refunded 

In addition to the millions of dollars in known amounts of unused tickets or 

segments thereof that were not refunded, we used the limited airline data 

to assess that the possible magnitude of outstanding unused tickets 

purchased from 1997 through 2003 was at least $100 million. As stated 

previously, federal agencies are authorized to recover payments made to 

airlines for tickets that agencies ordered but did not use. Generally a 6-year 

statute of limitations applies to the government’s ability to file an action for 

money damages based on a contractual right, but the government also has 

up to 10 years to offset future payments for amounts it is owed. However, 

airline representatives told us that they were concerned about the 

feasibility and costs of retrieving DOD’s unused ticket data from their 

archives. 

As you requested, we used the data provided by the airlines to determine 

the possible magnitude of the tickets DOD purchased but did not use or 

claim as a refund since 1997. Using the data that the airlines provided for 

fiscal year 2002, we calculated the total value of fully unused tickets as a 

percentage of total tickets purchased using a centrally billed account. We 

also used the more limited data the airlines provided on partially unused 

tickets for fiscal year 2002 to gauge the residual value of partially used 

tickets as a percentage of the total purchase value of these tickets. We 

applied these combined results, which on a per airline basis ranged from 

1.44 percent to 3.26 percent, to the total purchase value of tickets 

purchased with centrally billed accounts since 1997 (about $8 billion) and 

found—using the lowest estimate of 1.44 percent—that it is possible DOD 

purchased at least $100 million in airline tickets that were unused and not 
Page 12 GAO-04-398 DOD Travel Cards

refunded during this period. (See app. II for further information on our 

calculations.)

As discussed previously, DOD was not aware of, and consequently did not 

maintain data on, unused tickets and would therefore have to rely on the 

airlines to provide the relevant data needed to claim refunds. The 

inconsistent and incomplete responses we received from the airlines point 

to the difficulties in determining the total value of unused tickets. While the 

airlines readily provided us with at least 1 year of the data we requested, 

some airline representatives informed us that data on tickets purchased 

prior to the last 18 months have been moved to electronic archives, and 

retrieving data from these archives is costly and time-consuming. The 

process involves restoring from archives millions of records of tickets the 

airlines have issued before they can identify tickets purchased with the 

DOD centrally billed accounts that are fully and partially unused. Further, 

additional work would be necessary to determine the value of the unused 

portions of partially unused airline tickets. Finally, the airlines stated that 

some ticket data were not maintained electronically and that generating 

information related to these tickets would involve manually sifting through 

the airlines’ ticket coupons. However, unused tickets from these 5 airlines 

and the more than 85 other airlines that DOD uses represent a potentially 

substantial government claim. 

DOD Did Not 

Implement Effective 

Controls over Unused 

Tickets 

Millions of dollars of unused tickets have not been refunded because DOD 

did not have a systematic process to identify and process unused tickets. 

Effective internal controls are the first line of defense in safeguarding 

assets and preventing and detecting fraud, and are an integral part of an 

entity’s accountability for government resources. However, we found that 

DOD’s flawed process relied extensively on DOD personnel to report 

unused tickets to the travel offices. DOD had not systematically 

implemented procedures to identify instances in which travelers failed to 

notify the commercial travel offices (CTO) and their commands of unused 

tickets, or to ensure that refunds were processed once the CTOs received 

notifications. Although some units had instituted a process by fiscal year 

2002 to more systematically identify instances of unused tickets, the 

process was not implemented DOD-wide and could only be used to identify 

unused electronic—not paper—tickets. Further, in locations where this 

process had been implemented, DOD did not have systematic procedures 

to verify that the CTOs identified all unused electronic tickets and 

processed these for refunds. Because our preliminary assessment 

determined that current operations used to identify and process unused 
Page 13 GAO-04-398 DOD Travel Cards

tickets were flawed, we did not statistically test current processes and 

controls. 

Inadequate Controls over 

Unused Ticket Reporting 

and Processing 

During fiscal years 2001 and 2002, DOD relied on travelers to report unused 

tickets to the CTOs. DOD travel regulations state that the traveler must 

notify the CTO when a ticket is not used, and DOD’s Financial 

Management Regulations further stipulates that it is the traveler’s 

responsibility to return unused transportation tickets to the CTO for a 

refund. At some CTOs, each trip itinerary generated at the time an airline 

ticket was issued also contained a reminder to the traveler to return all 

unused tickets to the CTO. Unused ticket notification initiates a process 

whereby requests for refunds can be submitted to the airlines. As 

mentioned above, contract tickets purchased by the government are fully 

refundable. Timely processing of refunds ensures that scarce resources are 

returned to the government. 

However, DOD did not implement control procedures to systematically 

determine the extent to which DOD travelers adhered to the unused ticket 

requirements, and to identify instances in which they did not. According to 

bank data, DOD received credits amounting to about 9 percent of the 

airline tickets purchased through the CTOs during fiscal years 2001 and 

2002. Although these data indicate that some DOD travelers followed the 

unused ticket requirements, DOD did not maintain data in such a manner 

as to allow the department to identify the extent of noncompliance. 

Figure 2 illustrates where control breakdowns can occur if travelers do not 

adhere to DOD requirements and report unused tickets to the CTOs. As 

shown in figure 2, once a ticket is charged to the centrally billed account 

and given to the traveler, DOD has no systematic controls to determine that 

the ticket was used—or remains unused—unless the traveler notifies the 

CTO that the ticket was not used. If the traveler does not notify the CTO of 

an unused ticket, the ticket would not be refunded unless the CTO 

monitored the status of airline tickets issued electronically and applied for 

refunds on all unused tickets. Figure 2 also shows that the failure to notify 

the CTO of an unused paper ticket would result in the ticket being unused 

and not refunded. In addition, if the CTO identifies or is notified of an 

unused ticket but fails to process a refund, the ticket will also be unused 

and not refunded. 
Page 14 GAO-04-398 DOD Travel Cards

Figure 2: Possible Control Breakdowns in the Unused Ticket Process

DOD services and agencies have sometimes identified unused tickets as an 

indirect result of the procedures they have put in place to monitor the 

status of their obligations. For example, budget officials at the Department 

of the Navy’s location in Keyport, Washington, informed us that their 

financial system is programmed to identify all travel orders for which 

corresponding travel vouchers had not been filed 5 days after travel was to 

have been completed. Upon identification of the missing travel vouchers, 

the system automatically produces a list of travelers who have not filed 

their travel claims. Once identified, the finance office sends an e-mail 

reminder to the traveler to file his or her travel voucher. According to these 

officials, the traveler responds by filing a voucher or notifying the finance 

office that the travel was canceled and, therefore, the ticket was not used. 

Rather than relying on the traveler to notify the CTO of the unused ticket, 

the finance office gives the notification so that a refund can be processed. 

Similarly, finance officials at Hickam Air Base regularly monitor the 

CTO issues airline 

tickets and charges 

DOD's centrally 

billed accounts

Ticket is used or 

refunded

Wasted resources, unused ticket not refunded

Did traveler notify 

CTO?

CTO

requests credit for

unused ticket?

Is ticket

electronic?

Does

CTO monitor

unused

tickets?

Are

unused tickets 

identified?

Was ticket fully 

used?

Yes

Yes

Yes Yes

No

No No No

Yes

Yes

No

No

Source: GAO analysis of the process of issuing tickets charged to DOD's centrally billed accounts.
Page 15 GAO-04-398 DOD Travel Cards

accounting system for open travel orders (unliquidated obligations) and 

notify the appropriate resource officers to work on these unliquidated 

obligations. These resource officers would in turn remind the travelers to 

file the requisite travel vouchers or notify the CTOs of unused tickets.

However, the monitoring of open travel orders is only partially effective in 

identifying unused tickets, as it still relies, to a large extent, on the traveler 

providing notification to the CTO of canceled travel. Further, in a report 

issued in January 2003,12 we noted that hundreds of millions of dollars in 

unliquidated obligations were not accounted for because Navy fund 

managers failed to follow DOD regulations that require the periodic review 

of unliquidated obligations exceeding $50,000. These Navy managers cited 

time constraints as one of the obstacles to reviewing these unliquidated 

obligations. In contrast to the unliquidated obligations exceeding $50,000 

referred to in that report, travel obligations are often valued in the 

thousands and sometimes only in the hundreds of dollars. Consequently, it 

is likely that many of these smaller obligations would be of an even lower 

priority and therefore not reviewed. 

Similarly, we found that the monitoring of open travel orders at the Air 

Force is not effective in identifying unused tickets. The Air Force records 

all travel expenses—regardless of whether they were incurred with the 

centrally billed accounts or by the travelers directly—as one lump sum 

obligation. Once a voucher is filed, or a centrally billed charge is paid, 

whichever is sooner, the obligation would be liquidated, and the travel 

order removed from the list of unliquidated travel orders. Thus, the 

liquidation of an obligation is dependent on either the filing of a voucher or 

the payment of a centrally billed account, not whether the ticket is used or 

unused. Consequently, like the Navy, it would be difficult for the Air Force 

to consistently identify unused tickets through the monitoring of open 

travel orders. 

We also found that DOD did not have control procedures to provide 

assurance that tickets identified as unused were processed for refunds. At 

9 of the 10 locations we visited, neither the CTO nor the government travel 

office (GTO) maintained centralized records of unused tickets submitted 

by the travelers. Without a centralized record of unused tickets, an unused 

ticket that had been lost or never processed for refund would not be 

12U.S. General Accounting Office, Defense Budget: Improved Reviews Needed to Ensure 

Better Management of Obligated Funds, GAO-03-275 (Washington, D.C.: Jan. 30, 2003).
Page 16 GAO-04-398 DOD Travel Cards

detected. Therefore, neither the CTO nor the GTO could certify that all 

tickets turned in by the travelers were processed for refunds. We did note, 

however, that 6 of the 10 locations had implemented procedures to verify 

that unused tickets processed for refunds resulted in credits to the 

government. 

DOD Had Not Designed 

Procedures to Reconcile 

Centrally Billed Account 

Tickets to Travel Claims

Our internal control standards identify reconciliation as a control activity 

that helps enforce management’s directives and ensures that actions are 

taken to address risks. Reconciliation should be performed routinely so 

that problems are detected and corrected promptly and differences are not 

allowed to age, thereby becoming increasingly difficult to research. 

However, we found that DOD did not implement reconciliation procedures 

that link airline tickets purchased with the centrally billed account to travel 

claims submitted by travelers. Specifically, when DOD purchased an airline 

ticket with a centrally billed account, DOD did not implement procedures 

to identify whether the traveler has or has not submitted a travel voucher. A 

lack of a travel voucher could indicate that the ticket was unused. Without 

reconciling these two types of records, DOD could not obtain reasonable 

assurance that centrally billed account charges represent airline tickets 

that were eventually used. 

DOD regulations require that travelers file travel claims, in the form of a 

travel voucher, within 5 days of the end of travel. The filing of a travel claim 

provides positive confirmation that the travel took place. A travel claim 

also represents the traveler’s assertion that the transportation mode 

indicated on the travel order—be it air or land—was used in the 

performance of official duty. Only in exceptional circumstances would the 

filing of a travel voucher fail to provide the confirmation that an airline 

ticket provided to the traveler through the centrally billed account was not 

used. For example, mechanical problems at one airline could result in the 

traveler buying another ticket on a different airline with an individually 

billed travel card or a personal credit card. In these instances, the ticket 

acquired through the centrally billed account would not be used, and this 

could have been detected through a reconciliation process. 

In addition, the positive confirmation provided by the filing of a travel 

voucher indicates that a DOD-wide reconciliation between travel vouchers 

and centrally billed account charges would lead to the identification of 

instances in which travel claims have not been filed for travel involving the 

issuance of a centrally billed airline ticket. Such identification would allow 

DOD to follow up with the travelers to determine whether travel was taken, 
Page 17 GAO-04-398 DOD Travel Cards

and therefore whether the ticket was used. A failure to reconcile tickets 

that were centrally acquired to travel claims filed by travelers resulted in 

DOD not being able to determine whether the airline tickets it purchased 

were used.

Some DOD Units Have 

Implemented Procedures to 

Identify Unused Electronic 

Tickets 

In the period under audit, some DOD units have made improvements to its 

unused ticket process to compensate for the lack of internal controls over 

the centrally billed account program. By fiscal year 2002, some DOD units 

had established procedures intended to systematically identify unused 

electronic tickets, thus allowing DOD to obtain refunds on tickets it 

otherwise might have missed. At these locations, the computer systems 

used to reserve and purchase flights13 allow the CTOs to search the 

databases of each airline that participates in electronic ticketing. Each CTO 

can customize the searches to generate a list of unused electronic tickets 

directly from these computer reservation systems, or manually review data 

on the status of each electronic ticket to identify tickets that are unused. 

These procedures enable the CTOs to systematically identify unused etickets without having to receive notification from the travelers. CTOs can 

process requests for refunds directly in the computer reservation systems 

after unused tickets are identified. This on-line capacity allows DOD to 

obtain timely refunds and increases the organization’s ability to safeguard 

resources. An increasingly larger portion of all tickets issued are issued 

electronically—data from one large U.S. airline indicated that 69 percent of 

tickets issued during fiscal year 2002 and as much as 84 percent of tickets 

issued during fiscal year 2003 were electronic tickets. Consequently, these 

procedures increase DOD’s ability to capture refunds on a large portion of 

unused tickets. This ability to independently identify unused electronic 

tickets, if implemented across the services consistently and properly 

supervised, would allow DOD to partially compensate for the lack of 

controls in ensuring that travelers notify the appropriate office of canceled 

travel. 

13Systems from three domestic companies dominate the U.S. travel agent market: Sabre, 

Galileo, and Worldspan. Each computer system allows a travel agency to access 

participating airlines’ schedules, fares, and seat availability; to make airline reservations; 

and to issue airline tickets. Although each computer reservation system was developed at a 

different airline, carriers have had to participate in each system so that all travel agents have 

access to an airline’s flight information. These systems are required to be unbiased in 

providing flight listings so that some airlines are not favored over others. 
Page 18 GAO-04-398 DOD Travel Cards

However, our work found that not all locations implemented this capability 

during fiscal year 2002. This is partly because DOD did not incorporate a 

requirement for this capability into all the contracts it issued to the CTOs 

during fiscal year 2002. For example, the CTO at Hickam Air Base did not 

monitor unused tickets electronically because its contract did not require it 

to do so. In contrast, some locations that did not have this requirement in 

their contracts nevertheless implemented this capability through an 

agreement between the CTO and the GTO. High-level DOD officials to 

whom we reported the status of unused tickets informed us that they will 

require this capability to be a part of the new contracts issued under the 

Defense Travel System (DTS). The DTS is intended to be the DOD-wide 

travel system and replace the more than 30 travel systems currently 

operating within the department. However, according to a 2002 DOD Office 

of Inspector General report,14 “the DTS was being substantially developed 

without the requisite requirements, cost, performance, and schedule 

documents and analyses needed as the foundation for assessing the 

effectiveness of the system and its return on investment.” The report 

further noted that DOD estimated that deployment would not be completed 

until fiscal year 2006.

In general, we found that the GTOs at locations where the CTOs had put 

this process in place have not implemented control procedures to verify 

that the CTOs consistently identify and file for refunds on unused e-tickets. 

For instance, the CTOs at several locations we visited did not provide their 

respective GTOs with inventories of tickets they have identified as unused. 

Therefore, the transportation officers were unable to determine that all 

unused tickets were turned in for refunds. As noted above, we found that 

several transportation officers had procedures in place to confirm that the 

organization receives a credit for tickets that have been submitted for 

refunds. However, this process was not implemented at all locations we 

visited. Consequently, not all DOD units could provide assurance that all 

requests for refunds resulted in a credit to the government. 

Even if the CTOs can identify all e-tickets, they cannot independently 

identify nonelectronic tickets. Nonelectronic tickets are typically used for 

international travel because many non-U.S. carriers do not issue electronic 

tickets. International travel can sometimes make up as much as 25 percent 

14U.S. Department of Defense, Office of the Inspector General, Allegations to the Defense 

Hotline on the Management of the Defense Travel System, Report No. D-2002-124 

(Arlington, Va.: July 1, 2002).
Page 19 GAO-04-398 DOD Travel Cards

of the total dollar value of a unit’s travel. Given the inability to identify 

unused paper tickets, and weaknesses in the control procedures over the 

CTOs, the reconciliation procedures we discussed previously will still need 

to be established to match purchases made with centrally billed accounts 

to travel vouchers that have been filed. Unless DOD establishes a 

procedure to verify whether all airline tickets are used, it will not have 

reasonable assurance that airline tickets purchased through the centrally 

billed account are used or refunded.

Improvements in 

Management of the 

Individually Billed Accounts 

Provide DOD Options to 

Minimize Unused Ticket 

Risks

In a series of testimonies15 and reports16 issued in fiscal years 2002 and 

2003, we addressed problems that the Army, Navy, and Air Force had in 

managing the individually billed account travel cards. These testimonies 

and reports showed high delinquency rates and significant potential fraud 

and abuse related to DOD’s individually billed travel card program. 

However, recent improvements to the individually billed program point to 

the possibility of using this program as the principal means of acquiring 

tickets, thereby reducing the government’s risk of losses from unused 

tickets arising from the use of centrally billed accounts. 

In response to our testimonies and reports on the individually billed 

accounts, the Congress took actions in the fiscal year 2003 appropriations 

and authorization acts17 requiring (1) the establishment of guidelines and 

procedures for disciplinary actions to be taken against cardholders for 

improper, fraudulent, or abusive use of government travel cards; (2) the 

denial of government travel cards to individuals who are not creditworthy; 

(3) split disbursements18 for travel cardholders; and (4) offset of delinquent 

15GAO-02-863T and GAO-03-148T.

16GAO-03-169, GAO-03-147, and GAO-03-298.

17Department of Defense Appropriations Act, 2003, Pub. L. No. 107-248, 116 Stat. 1519 

(2002), and the Bob Stump National Defense Authorization Act for Fiscal Year 2003, Pub. L. 

No. 107-314, 116 Stat. 2458 (2002).

18Split disbursement is a process in which DOD pays the travel-card-issuing bank directly for 

charges incurred on the travel card and claimed on the travel voucher. Additional money 

owed to the traveler is deposited directly into the traveler’s bank account. Split 

disbursements are required of all military and civilian personnel. See also the National 

Defense Authorization Act for Fiscal Year 2004, Pub. L. No. 108-136, § 1009, 117 Stat. 1392, 

1587 (2003), 10 U.S.C. § 2784a.
Page 20 GAO-04-398 DOD Travel Cards

travel card debt against the pay or retirement benefits of DOD civilian and 

military employees and retirees. 

In response, DOD has implemented many of the legislatively mandated 

improvements—most notably the implementation of split disbursements 

and salary offsets and the reduction in the numbers of individuals with 

access to the travel cards. According to Bank of America, the delinquency 

rates we noted in our prior reports at the Army, Navy, and Air Force have 

decreased. For example, the delinquency rate at the Navy had decreased 

from an average monthly delinquency rate of about 11 percent during fiscal 

year 2002 to an average monthly delinquency rate of less than 7 percent in 

fiscal year 2003. Similarly, during that same period the Army’s average 

monthly delinquency rate decreased from about 14 percent to an average 

monthly delinquency rate of about 9 percent.

The benefits of using a well-controlled individually billed account program 

as the principal mechanism for acquiring airline tickets are twofold. First, 

in the individually billed account program, the cardholder is directly 

responsible for all charges incurred on his or her travel card. In contrast, 

improper charges to centrally billed accounts that are not detected and 

disputed or authorized charges, such as airline tickets that are not used, 

result in direct financial losses to the government in the amount of the face 

value of the tickets. Second, with the use of individually billed accounts to 

purchase tickets, DOD travelers have greater incentive to turn in unused 

tickets because they are responsible for paying the ticket charges. The use 

of individually billed cards to acquire airline tickets would therefore help to 

limit the government’s financial exposure.

However, the use of the individually billed accounts to acquire airline 

tickets would only minimize, not eliminate, the necessity of implementing 

internal controls over the centrally billed account program. DOD would 

still need to maintain a centrally billed account structure to purchase 

airline tickets for travelers who have been denied individually billed 

accounts, infrequent travelers whose individually billed credit cards have 

been canceled, and new employees who have not yet acquired individually 

billed accounts.

Conclusion The millions of dollars wasted on unused airline tickets provides another 

example of why DOD financial management is one of our “high-risk” areas, 

with DOD highly vulnerable to fraud, waste, and abuse. In implementing 

the centrally billed component of the travel card program, DOD relied on a 
Page 21 GAO-04-398 DOD Travel Cards

weak process that depended on travelers reporting all unused tickets to 

CTOs. Although many DOD travelers informed the CTOs of unused tickets 

as required, the lack of specific internal control procedures to identify 

instances in which the travelers did not do so resulted in DOD paying for 

thousands of airline tickets that were not used and not processed for 

refunds. During fiscal year 2003, some DOD units began implementing 

procedures to more systematically identify unused airline tickets, and in 

fiscal year 2004, DOD started working to recover from the airlines the value 

of unused tickets we identified. DOD must build on these improvements 

and establish controls over unused tickets to improve its ability to control 

costs and ensure basic accountability over scarce resources. In addition, 

DOD should take immediate actions to recover the outstanding value of 

tickets that were fully or partially unused and not refunded.

Recommendations for 

Executive Action

To improve the management DOD’s travel resources, we are making the 

following 20 recommendations to DOD officials. 

To decrease the risks associated with the use of the centrally billed 

accounts, we recommend that the Secretary of Defense evaluate the 

feasibility of the following two actions: 

• establishing the individually billed account travel card as the primary 

payment mechanism for transportation expenses, and 

• limiting the use of the centrally billed account travel card to procuring 

transportation expenses for those employees without access to 

individually billed accounts, such as new employees who have not yet 

obtained individually billed account travel cards and employees who do 

not qualify for the use of individually billed account travel cards, and for 

other situations in which the use of an individually billed travel card is 

not practical.

To enable DOD to systematically identify future unused airline tickets 

purchased through the centrally billed accounts, and improve internal 

controls over the processing of unused airline tickets for refunds, we 

recommend that the Secretaries of the Army, Air Force, and Navy and the 

heads of DOD agencies direct the appropriate personnel within services 

and agencies to take the following nine actions:
Page 22 GAO-04-398 DOD Travel Cards

• evaluate the feasibility of implementing procedures to reconcile airline 

tickets acquired using the centrally billed accounts to travel vouchers in 

the current travel system;

• modify existing CTO contracts to include a requirement that the CTOs 

• establish a capability to systematically identify unused e-tickets in 

their computer reservation systems,

• identify all unused tickets based on specified criteria before the 

unused ticket data are removed from the computer reservation 

systems,

• maintain daily schedules that identify unused tickets and how long 

they have been unused, 

• routinely provide the GTOs with unused ticket reports, 

• routinely process refunds for tickets identified as unused, and

• submit to the GTOs all requests for refunds that have been 

processed;

• require the GTOs to routinely compare unused tickets processed by the 

CTOs to the credits on the Bank of America invoice; and 

• require either the GTOs or the units responsible for monitoring the 

CTOs’ activities to determine whether the CTOs are consistently 

implementing the procedures to identify unused tickets and process 

these tickets for refunds. 

To enable DOD to more effectively monitor unused tickets under the DTS, 

we recommend that the Secretary of Defense direct the appropriate 

personnel to take the following four actions:

• use the DTS to remind travelers to claim refunds on all unused tickets, 

• include in future contracts issued for the DTS, a requirement that the 

CTOs establish the capability to

• systematically identify unused tickets and 
Page 23 GAO-04-398 DOD Travel Cards

• process these tickets for refunds, and 

• establish, in the DTS, a capability to routinely match travel vouchers to 

tickets issued through the centrally billed accounts.

To recover outstanding claims on unused tickets, we recommend that the 

Under Secretary of Defense (Comptroller) initiate the following five 

actions: 

• immediately submit claims to the airlines to recover the $21 million in 

fully and partially unused tickets identified by the airlines and included 

in this report;

• calculate, with the assistance of the airlines, the residual value of the 

partially unused tickets identified by the airlines and included in this 

report; and 

• work with the five airlines identified in this report and other airlines 

from which DOD purchased tickets with centrally billed accounts to 

• identify the feasibility of determining the recoverability of other fully 

and partially unused tickets purchased with DOD centrally billed 

accounts,

• determine the value of the unused portions of those tickets, and 

• initiate actions to obtain refunds.

Agency Comments and 

Our Evaluation

In written comments on a draft of this report, which are reprinted in 

appendix III, DOD concurred with all 20 of our recommendations and 

stated that it had taken actions or will take actions to address these 

recommendations. For example, with respect to actions already taken, 

DOD stated that it has implemented, in the DTS, a capability to routinely 

match travel vouchers to tickets issued through the centrally billed 

accounts. This capability is currently being tested at certain pilot sites. 

With respect to actions under way, DOD had submitted claims to the 

airlines on February 26, 2004, to recover the $21 million in fully and 

partially unused paper and electronic tickets identified by the airlines, and 

stated that it will work with the airlines from which it purchased tickets 

through the centrally billed accounts to identify the feasibility of 

determining the recoverability of other fully and partially unused tickets. 
Page 24 GAO-04-398 DOD Travel Cards

As agreed with your offices, unless you announce the contents of this 

report earlier, we will not distribute it until 30 days from its date. At that 

time, we will send copies to interested congressional committees; the 

Secretary of Defense; the Under Secretary of Defense, Comptroller; the 

Secretary of the Army; the Secretary of the Navy; the Secretary of the Air 

Force; and the Director of the Defense Finance and Accounting Service. We 

will make copies available to others upon request. In addition, the report 

will be available at no charge on the GAO Web site at http://www.gao.gov.

Please contact Gregory D. Kutz at (202) 512-9505 or kutzg@gao.gov,

John J. Ryan at (202) 512-9587 or ryanj@gao.gov, or John V. Kelly at 

(202) 512-6926 or kellyj@gao.gov if you or your staffs have any questions 

concerning this report. Major contributors to this report are acknowledged 

in appendix IV.

Gregory D. Kutz

Director

Financial Management and Assurance

Robert J. Cramer

Managing Director

Office of Special Investigations
Page 25 GAO-04-398 DOD Travel Cards

Appendix I

Objectives, Scope, and Methodology ApApenednxidexiIs

Pursuant to a joint request by the Chairman and Ranking Minority Member 

of the Permanent Subcommittee on Investigations, Senate Committee on 

Governmental Affairs; the Chairman of the Senate Committee on Finance; 

and Representative Schakowsky, we audited the controls over unused 

airline tickets purchased through the Department of Defense’s (DOD) 

centrally billed accounts. Our assessment covered the following:

• the extent of tickets charged to the centrally billed accounts that are 

unused and not refunded and

• whether DOD’s internal controls provided reasonable assurance that all 

unused tickets were identified and submitted for refunds. 

To assess the magnitude of tickets charged to the centrally billed accounts 

that are unused and not refunded, we obtained from Bank of America 

databases for fiscal years 2001 and 2002 travel transactions charged to 

DOD’s centrally billed travel card accounts. The databases contained 

transaction-specific information, including ticket fare, ticket number, name 

of passenger, date and destination of travel, and number of segments in 

each ticket. We reconciled these data files to control totals provided by 

Bank of America and to data reported by the General Services 

Administration as DOD’s centrally billed account activities. We also 

requested that the five airlines that DOD used most frequently provide us 

with data relating to tickets DOD purchased during fiscal years 2001 and 

2002 that were unused and not refunded. These five airlines—American, 

Delta, Northwest, United, and US Airways—together accounted for more 

than 82 percent of the value of total airline tickets DOD purchased. To 

obtain assurance that the tickets the airlines reported as unused 

represented only airline tickets charged to DOD centrally billed accounts 

we compared data provided by the airlines to transaction data provided by 

Bank of America. Because DOD does not track whether tickets purchased 

with centrally billed accounts were used, we were unable to confirm that 

the population of unused tickets that the airlines provided was complete, 

that is, it included all DOD tickets that are unused and not refunded. 

While the five airlines provided data on unused tickets that allowed us to 

identify which tickets were unused and not refunded, they did not provide 

uniform or consistent data, and their data did not always cover the same 

periods. Specifically, all five airlines provided data that enabled us to 

determine the total purchase price of fully unused tickets, and four of the 

five airlines provided data that enabled us to determine the total purchase 

price of partially unused tickets. Only one airline provided us the unused 
Appendix I

Objectives, Scope, and Methodology

Page 26 GAO-04-398 DOD Travel Cards

value (residual value) of partially unused tickets. Further, while all five 

airlines provided us information on fiscal year 2002 fully unused tickets, 

the data they provided on fully unused tickets covered from 1 to over

4 years. In addition, only four airlines provided partially unused ticket data, 

and the data they provided similarly covered from 1 to over 4 years. For 

further details on the type of data received, and our calculations of the 

value of fully unused and partially unused tickets, see appendix II. We also 

reviewed relevant statutes and court decisions related to the period of time 

federal agencies are allowed to claim refunds and apply administrative 

offsets to goods and services they purchased but did not receive. 

To assess controls over unused tickets, we obtained an understanding of 

the travel process by reviewing DOD’s travel regulations and interviewing 

officials from the Departments of the Army, Navy, and Air Force. We visited 

two Army units, three Navy units, three Air Force units, and two Marine 

Corps units to confirm our understanding of the travel process. We also 

interviewed DOD officials at the government travel offices and 

representatives of the commercial travel offices to obtain an understanding 

of the process used to identify unused tickets and claim refunds on those 

tickets. To assess the internal controls over unused tickets, we applied the 

fundamental concepts and standards set forth in our Standards for 

Internal Control in the Federal Government1 to the practices followed by 

these units to manage unused tickets. Because we determined that controls 

over unused tickets were ineffective, we did not assess or design statistical 

sampling tests to test these controls.

We briefed DOD managers, including DOD officials in the Office of the 

Under Secretary of Defense (Comptroller), the Defense Finance and 

Accounting Service, and the Office of the Inspector General; Army officials 

in the Office of Deputy Chief of Staff for Logistics; Navy officials in the 

Office of the Assistant Secretary of the Navy for Financial Management and 

Comptroller; Air Force officials in the Office of the Deputy Chief of Staff 

for Installation and Logistics; and Marine Corps officials in the Office of 

Deputy Chief of Staff for Installations and Logistics concerning the results 

of our work. On December 19, 2003, we provided DOD officials with a 

partial list of fully and partially unused tickets we received as of that date. 

On February 10, 2004, we requested comments on a draft of this report 

from the Secretary of Defense or his designee. We conducted our audit 

1

U.S. General Accounting Office, Standards for Internal Control in the Federal 

Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).
Appendix I

Objectives, Scope, and Methodology

Page 27 GAO-04-398 DOD Travel Cards

work from March 2003 through January 2004, in accordance with U.S. 

generally accepted government auditing standards.
Page 28 GAO-04-398 DOD Travel Cards

Appendix II

Known Value of Fully and Partially Unused 

Tickets and Potential Magnitude of Control 

Weaknesses ApendxiI

To determine whether design flaws in controls over purchasing tickets 

using DOD centrally billed accounts resulted in a significant loss of federal 

tax dollars, we contacted DOD’s five most frequently used airlines and 

requested that they identify tickets DOD purchased with a centrally billed 

account that had not been used or refunded as of the date of our request. 

While those airlines did not provide consistent data concerning unused 

tickets, they did provide information sufficient to allow us to determine the 

unused value of some of their fully unused tickets and the original purchase 

price of some of the partially unused tickets. In addition, one airline 

provided information on the unused value of at least some of its partially 

unused tickets. Using the ratios of the known value of unused tickets to 

total tickets purchased, we were able to assess the potential magnitude of 

tickets purchased with DOD centrally billed accounts that were not used or 

refunded since 1997—the first year for which centrally billed account 

information is available from the General Services Administration. 

Types of Data Provided 

Differed Substantially 

between Airlines

We asked DOD’s five most frequently used airlines—American, Delta, 

Northwest, United, and US Airways—to provide information on tickets 

purchased by DOD with centrally billed accounts during fiscal years 2001 

and 2002 that had not been used or refunded. As shown in table 4, while all 

the airlines generally provided complete data on fiscal year 2002 fully 

unused tickets, the airlines did not provide uniform, complete, or 

consistent responses to our request for fiscal year 2002 partially unused 

tickets, or for fully or partially unused ticket data for fiscal year 2001. In 

addition, some airlines provided some information on fully and partially 

unused tickets that were purchased in fiscal years 2003, 2000, and 1999. 
Appendix II

Known Value of Fully and Partially Unused 

Tickets and Potential Magnitude of Control 

Weaknesses

Page 29 GAO-04-398 DOD Travel Cards

Table 4: Type of Data Provided by the Airlines

Source: GAO analysis of airline data.

a

American Airlines also provided data on tickets purchased from October through December 2002 that 

were still unused. We excluded 8,136 American Airlines unused tickets totaling $2.1 million from our 

analysis because either (1) less than 6 months had passed between the time the tickets were 

purchased and when American Airlines provided the file or (2) Bank of America data did not confirm 

whether the tickets were fully or partially unused. 

b

Northwest Airline’s file included 88 tickets that were issued in fiscal 2000 that were included in fiscal 

year 2001 Bank of America statements.

c

United Airlines provided information on 9,702 paper tickets; 413 of those paper tickets were 

purchased prior to April 2002.

While American, Delta, Northwest, and United provided some data on 

partially unused tickets, US Airways did not provide any. Further, as noted 

in table 4, while American, Delta, Northwest, and United provided data on 

the total purchase price of tickets that were partially unused, American 

Airlines was the only airline that also provided data on the unused value of 

its partially unused tickets. Table 4 also shows that there were 

inconsistencies among the airlines when it came to providing data on 

unused tickets purchased before, during, and after fiscal year 2002. The 

airlines cited difficulties with accessing their historical files as the reason 

for not being able to fully respond to our request. The airlines pointed out 

that to provide additional information, they would have had to access 

information that had been stored in archived computer files, and in some 

instances, the computer files had been eliminated and the only 

documentation that remained were paper records of the flights.

Airline Type of data Period covered

American • Value of fully unused tickets 

• Purchase price of partially unused tickets 

• Unused value of partially unused tickets

• Tickets purchased in the 13-month period from 

September 2001 through September 2002a

Delta • Status of all tickets issued to DOD • Tickets purchased during fiscal years 2001 and 2002

Northwest • Value of fully unused tickets 

• Purchase price of partially unused tickets

• Tickets purchased in fiscal years 2001 and 2002b

United • Value of fully unused tickets 

• Purchase price of partially unused tickets 

• Electronic tickets: tickets purchased from November 

1998 through December 2002

• Paper tickets: tickets purchased primarilyc from April 

2002 through December 2002

US Airways • Value of fully unused tickets • Tickets purchased in the 15-month period from July 

2001 through September 2002
Appendix II

Known Value of Fully and Partially Unused 

Tickets and Potential Magnitude of Control 

Weaknesses

Page 30 GAO-04-398 DOD Travel Cards

Known Unused Value 

of Fully and Partially 

Unused Tickets 

As shown in table 5, airline data showed that DOD used centrally billed 

accounts to purchase about 58,000 tickets with a value of $21.1 million that 

were unused and not refunded. The $21.1 million included more than 

48,000 tickets valued at $19.2 million that were fully unused and about 

10,000 partially unused tickets (i.e., at least one leg had never been used) 

that had an unused value of about $1.9 million. Due to differences in the 

data provided by the airlines, we used three primary methods to identify 

the number and value of tickets that are fully unused. Three airlines—

Northwest, United, and US Airways—provided us with data files that 

identified a ticket as being fully unused and its purchase price. For these 

airlines, we calculated the unused value of fully unused tickets by totaling 

the purchase price of each of the fully unused tickets. American Airlines 

provided us a file containing fully unused and partially unused tickets. To 

separate partially from fully unused, we used Bank of America data. Delta 

Airlines provided us with data on the status of each airline ticket DOD 

purchased using the centrally billed accounts during fiscal years 2001 and 

2002 and guidance on how to determine whether a ticket is fully used, 

partially unused, or fully unused. To identify fully unused Delta tickets from 

Delta databases, we first identified tickets reported by Delta that matched 

Bank of America data of how many ticket legs were purchased, then we 

used the guidance Delta provided to identify its fully unused tickets. Once 

we identified these tickets, we derived the unused value of fully unused 

Delta Airlines tickets by totaling the purchase price of each of the fully 

unused tickets, similar to the methodology we used for the other four 

airlines. 
Appendix II

Known Value of Fully and Partially Unused 

Tickets and Potential Magnitude of Control 

Weaknesses

Page 31 GAO-04-398 DOD Travel Cards

Table 5: Known Value of Unused Tickets by Airline

Source: GAO analysis of airline data.

a

Partial fiscal year 2001 data include September 2001 only. 

b

United Airlines did not provide data on the number and value of paper tickets purchased prior to April 

2002 that were unused and not refunded. 

c

Partial fiscal year 2001 data include data from July 2001 through September 2001.

d

Tickets purchased in fiscal year 2003 and prior to fiscal year 2001.

Partially Unused Tickets We could not determine the total unused value of partially unused tickets 

for the five airlines we reviewed. Only American Airlines calculated the 

unused value of the partially unused tickets it identified. Three airlines—

Delta, Northwest, and United—provide the original purchase price of the 

partially unused airlines tickets, and US Airways did not provide any 

information on partially unused tickets. To determine the number and total 

purchase price of partially used tickets purchased with DOD centrally 

billed accounts for which DOD did not claim a refund, we followed the 

same methodology used to derive the number and purchase price of fully 

unused tickets. For example, to derive the total purchase price of partially 

unused American, Northwest, and United tickets, we added the purchase

 Dollars in millions

Airline

Number of tickets identified as fully unused Unused value of fully unused tickets

Fiscal year

Total

Fiscal year

2002 2001 2002 2001 Total 

Known value of fully unused tickets

Americana 5,806 345 6,151 $2.1 $ 0.1 $2.2

Delta 8,441 7,147 15,588 3.3 3.1 6.4

Northwest 1,640 1,839 3,479 1.1 1.2 2.3

Unitedb 5,682 4,044 9,726 2.3 1.3 3.6

US Airwaysc 4,933 1,786 6,719 1.8 0.5 2.3

Total fiscal years 2001 and 2002 41,663 $16.8

Other time periodd -- -- 6,557 -- -- 2.4

Total value of fully unused tickets -- -- 48,220 -- -- $19.2

Known value of partially unused tickets

Americana 9,159 567 9,726 $1.9

Known value of fully and partially unused tickets

Total value of fully and partially 

unused tickets -- -- 57,946 -- -- $21.1
Appendix II

Known Value of Fully and Partially Unused 

Tickets and Potential Magnitude of Control 

Weaknesses

Page 32 GAO-04-398 DOD Travel Cards

price of each of the partially unused tickets.1 For Delta Airlines, we applied 

the guidance Delta representatives provided to identify partially unused 

tickets, then added the purchase price of each of these tickets to derive the 

total. As shown in table 6, our analysis of partially unused tickets indicated 

that DOD travelers did not use all of the segments on more than 91,000 

tickets DOD purchased with centrally billed accounts. 

Table 6: Partially Unused Ticket Number and Value

Source: GAO analysis of airline data.

a

Partial fiscal year 2001 data include September 2001 only.

b

Purchase price of $7.6 million represents Bank of America data on ticket price. This amount differs 

from Northwest Airlines’ reported fare of $7.2 million. Our analysis indicates that Northwest Airlines 

excluded taxes and fees from its reported amount of $7.2 million. 

c

United Airlines was not able to provide complete data on the number and value of paper tickets that 

were purchased prior to April 2002 but were not used or refunded. Consequently, the number and 

value of partially unused United tickets are understated by the number and value of paper tickets 

purchased prior to April 2002 that were partially unused, not refunded, and not provided. 

d

Data not provided.

e

Tickets purchased in fiscal year 2003 and prior to fiscal year 2001. 

1

As previously discussed, US Airways did not provide us data on partially unused tickets. 

Dollars in millions

Airline

Number of tickets identified as 

partially unused 

Purchase price of tickets identified as 

partially unused

Fiscal year

Total

Fiscal year

2002 2001 2002 2001 Total 

Americana 9,159 567 9,726 $5.5 $0.3 $5.8

Delta 29,483 21,811 51,294 22.9 16.4 39.3

Northwestb 3,283 4,137 7,420 3.2 4.4 7.6

Unitedc 10,319 3,962 14,281 8.2 1.8 10.0

US Airways d d d d d d

Total fiscal years 2001 and 2002 82,721 $39.8 $22.9 $62.7

Other time periode -- -- 8,542 -- -- 5.2

Total, partially unused 52,244 30,477 91,263 $39.8 $22.9 $67.9
Appendix II

Known Value of Fully and Partially Unused 

Tickets and Potential Magnitude of Control 

Weaknesses

Page 33 GAO-04-398 DOD Travel Cards

Possible Magnitude of 

Unused Tickets 

Purchased with 

Centrally Billed 

Accounts 

During the period from fiscal year 1997 through 2003, DOD spent about 

$8 billion on airline tickets purchased using centrally billed accounts. To 

assess the potential magnitude of fully and partially unused airline tickets 

purchased using centrally billed accounts since 1997—the first year that 

centrally billed account information is available from the General Services 

Administration—we used known information related to fiscal year 2002 

fully and partially unused tickets and applied that information to the tickets 

purchased from fiscal years 1997 through 2001 and in fiscal year 2003. We 

used fiscal year 2002 data because it was the only year for which the 

airlines provided us fairly complete data. This assessment indicates that 

the unused value of fully and partially unused tickets purchased from fiscal 

year 1997 to fiscal year 2003 with DOD centrally billed accounts could be at 

least $115 million. 

The magnitude of fully unused tickets could be at least $53 million. As 

shown in table 7, the percentage of fully unused tickets (unused ticket 

value as a percentage of total ticket sales) in fiscal year 2002 for DOD’s five 

most frequently used airlines ranged from 0.66 percent for United Airlines 

to 1.11 percent for American Airlines and US Airways. 

Table 7: Fiscal Year 2002 Fully Unused Ticket Ratios 

Source: GAO analysis of data provided by Bank of America and the airlines.

a

Differences due to rounding of the value of fully unused tickets and the total value of tickets purchased 

through DOD’s centrally billed accounts.

The substantially lower ratio for United Airlines is attributed to the fact 

that fully unused ticket data from United Airlines did not include complete 

data on paper tickets purchased during the first 6 months of fiscal year 

2002. If data on fully unused paper tickets were available, the ratio of fully 

Dollars in millions

Airline

Value of fully unused 

tickets 

Value of tickets purchased through 

DOD’s centrally billed accounts 

Value of fully unused tickets as a 

percentage of the value of all ticket 

purchasesa

American $2.1 $189.1 1.11

Delta 3.4 334.0 1.01

Northwest 1.1 104.8 1.01

United 2.3 344.8 0.66

US Airways 1.8 159.5 1.11

Total $10.7 $1,132.2 --
Appendix II

Known Value of Fully and Partially Unused 

Tickets and Potential Magnitude of Control 

Weaknesses

Page 34 GAO-04-398 DOD Travel Cards

unused tickets for United Airlines would be higher. To be conservative, we 

applied the lowest percentage of the value of fully unused tickets (United 

Airlines ratio of 0.66 percent) to the value of all airline tickets that DOD 

purchased from fiscal years 1997 through 2003 ($8 billion). If the ratio of 

the value of fully unused tickets to the total value of tickets purchased with 

a centrally billed account in fiscal year 2002 was consistent since 1997, the 

magnitude of value of fully unused tickets could be at least $53 million.

The potential magnitude of the unused value of partially unused tickets 

could increase the unused ticket value by at least $62 million. To arrive at 

this assessment, we used the data provided by the airlines on partially 

unused tickets for fiscal year 2002 to calculate the estimated unused value 

of partially unused tickets for each of the four airlines that provided 

partially unused ticket data. The first step was to estimate the unused value 

of partially unused tickets for each of the four airlines. We accomplished 

this by multiplying the total value of partially unused tickets by the fiscal 

year 2002 American Airlines ratio of the unused value of partially unused 

tickets to the total purchase price of those tickets.2

 We then divided the 

estimated unused value of the partially unused tickets for the four airlines 

by the total fiscal year 2002 ticket sales for those airlines. As shown in table 

8, if the American Airlines’ experience can be extrapolated to the other 

airlines, the unused value of partially unused tickets ranges from .78 

percent to 2.25 percent of total purchases. 

2

As reported previously, the airlines informed us that to calculate the residual value of 

partially unused tickets, each segment would have to be repriced. However, for the purpose 

of assessing the range of possible residual value, we used American Airlines data because 

American Airlines was the only airline that provided us with that type of data.
Appendix II

Known Value of Fully and Partially Unused 

Tickets and Potential Magnitude of Control 

Weaknesses

Page 35 GAO-04-398 DOD Travel Cards

Table 8: Analysis of Fiscal Year 2002 Partially Unused Ticket Ratios 

Source: GAO analysis of Bank of American and airline data.

a

This is the ratio of the unused value of American Airlines partially unused tickets to the total purchase 

price of American Airlines partially unused tickets in fiscal year 2002.

b

Differences due to rounding.

c

Not provided.

d

The United Airlines ratio of purchase price of partially unused tickets as a percentage of total 

purchases is understated because, as mentioned previously, the information United Airlines provided 

us did not include complete data on paper tickets that were purchased prior to April 2002 but were not 

used or refunded. Consequently, the purchase price for United Airlines is understated by the value of 

paper tickets that were purchased prior to April 2002 but were partially unused, not refunded, and not 

provided. In contrast, the total purchases column includes all data.

Again, to be conservative, we applied the lowest ratio of unused value of 

partially unused tickets (United Airlines ratio of 0.78 percent) to the 

$8 billion of all airline tickets that DOD purchased from fiscal years 1997 

through 2003. If the ratio of the unused value of partially unused tickets to 

the total value of tickets purchased with centrally billed accounts in fiscal 

year 2002 was consistent since 1997, the magnitude of unused value of 

partially unused tickets could be at least $62 million. 

To determine the possible total magnitude of the value of airline tickets 

DOD purchased with centrally billed accounts that were unused and not 

refunded, we added the minimum value of potential fully unused tickets to 

minimum value of potential partially unused tickets. As a result, we 

determined that it was possible that DOD had purchased at least 

$115 million in tickets that were unused and not refunded. 

Dollars in millions

Airline

Purchase 

price 

American Airlines 

unused value ratioa

(percentages)

Estimated unused value of 

fiscal year 2002 tickets 

Total fiscal year 

2002 purchases 

Estimated unused value 

as a percentage of total 

purchasesb

US Airways c c c c c

American $ 5.5 32.73 $1.8 $189.1 0.95

Delta 22.9 32.73 7.5 334.0 2.25

Northwest 3.2 32.73 1.0 104.8 0.95

Unitedd 8.2 32.73 2.5 344.8 0.78

Total $39.8 -- $12.8 $972.7 --
Page 36 GAO-04-398 DOD Travel Cards

Appendix III

Comments from the Department of Defense ApendxiI
Appendix III

Comments from the Department of Defense

Page 37 GAO-04-398 DOD Travel Cards
Appendix III

Comments from the Department of Defense

Page 38 GAO-04-398 DOD Travel Cards
Appendix III

Comments from the Department of Defense

Page 39 GAO-04-398 DOD Travel Cards
Appendix III

Comments from the Department of Defense

Page 40 GAO-04-398 DOD Travel Cards
Appendix III

Comments from the Department of Defense

Page 41 GAO-04-398 DOD Travel Cards
Appendix III

Comments from the Department of Defense

Page 42 GAO-04-398 DOD Travel Cards
Appendix III

Comments from the Department of Defense

Page 43 GAO-04-398 DOD Travel Cards
Page 44 GAO-04-398 DOD Travel Cards

Appendix IV

GAO Contacts and Staff Acknowledgments ApendxiIV

GAO Contacts John V. Kelly, (202) 512-6926

Quan Thai, (206) 287-4889

Acknowledgments Staff making key contributions to this report were Beverly Burke, Francine 

DelVecchio, Aaron Holling, Jeffrey Jacobson, Julie Matta, John Ryan, and 

Sidney H. Schwartz.

(192106)
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