2016 PRESIDENTIAL 

CAMPAIGN

Actions Needed to 

Address U.S. Secret 

Service 

Overpayments for 

Travel Costs

Report to the Ranking Member, 

Committee on Homeland Security, 

House of Representatives

May 2018

GAO-18-419

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-419, a report to the 

Ranking Member, Committee on Homeland 

Security, House of Representatives

May 2018

2016 PRESIDENTIAL CAMPAIGN

Actions Needed to Address U.S. Secret Service 

Overpayments for Travel Costs

What GAO Found

The U.S. Secret Service’s (Secret Service) travel expenses during the 2016 

presidential campaign totaled approximately $58 million. Of the $58 million, 

$17.1 million was for reimbursements to the four campaign committees for 

chartered aircraft flights. In the case of campaign travel, Secret Service special 

agents often fly with protected individuals on aircraft chartered by the campaign 

committees. The Secret Service reimburses the campaign committees for the 

number of seats occupied by special agents on board each charter flight. 

U.S. Secret Service Travel Expensesfor the 2016 Presidential Campaign

For the 40 overnight trips GAO reviewed, the Secret Service generally followed 

its policies and regulations for lodging payments. However, GAO found that the 

agency overpaid the campaign committees at least an estimated $3.9 million 

when reimbursing them for special agents’ seats on charter flights. Since at least 

1977, the Secret Service’s policy has been to pay the lower of two fares when 

reimbursing campaign committees for special agents’ travel on chartered aircraft 

flights. Specifically, the Secret Service is to pay the lower of the following two 

fares: the lowest commercially available first-class airfare, or the pro rata fare—

the cost of the agent’s seat on the charter flight calculated by taking the total cost 

of the charter divided by the number of passengers on board. However, during 

the 2016 presidential campaign, Secret Service officials misinterpreted a Federal 

Election Commission regulation, and as a result, did not conduct the comparison.

Instead, the Secret Service solely paid the pro rata fare to the campaign 

committees. Eight months before the end of the 2016 presidential campaign, 

Secret Service officials determined the interpretation was erroneous, but did not 

ensure the agency reverted to its long standing policy. During these 8 months, 

66 percent of all campaign-related flights with special agents on board were 

taken.

Federal agencies are generally required to collect on debts that have been 

determined by an appropriate official of the federal government to be owed to the 

United States. Debts include overpayments. Pursuing debt collection, however, 

will require the Secret Service to calculate the specific amount it overpaid to the 

campaign committees and determine how to proceed with seeking repayment 

from the various committees, as appropriate.

View GAO-18-419. For more information, 

contact Diana Maurer at (202) 512-9627 or 

maurerd@gao.gov.

Why GAO Did This Study

The Secret Service incurs millions of 

dollars in travel expenses to provide 

security during the fast-paced 

operational tempo of a presidential 

campaign. In connection with the 2016 

presidential campaign, the Secret 

Service provided protection for four

presidential candidates, two vice 

presidential candidates, and six of the 

candidates’ family members.

GAO was asked to review the Secret 

Service’s travel-related expenses for

the 2016 presidential campaign. This 

report examines (1) how much the 

Secret Service incurred in travelrelated expenses, and (2) the extent to 

which travel-related payments and 

reimbursements were made in 

accordance with laws, regulations, and 

policies. GAO analyzed Secret Service

data to determine the travel expenses 

incurred by the agency for the 2016 

presidential campaign. GAO also 

randomly selected 40 overnight trips to 

assess the Secret Service’s 

compliance with provisions of its 

lodging policies and the Federal Travel 

Regulation. GAO analyzed the Secret 

Service’s payments to campaign

committees to determine whether 

committees were reimbursed the 

correct amounts for charter flights.

What GAO Recommends

GAO is making five recommendations,

including that the Secret Service 

should (1) calculate its overpayments 

to the campaign committees for special

agents’ seats on chartered aircraft

flights, and (2) determine how it should 

proceed with respect to collecting on 

identified debts. The Department of 

Homeland Security concurred with the 

recommendations and identified 

actions underway to address them.
Page i GAO-18-419 2016 Presidential Campaign

Letter 1

Background 3

Secret Service’s 2016 Presidential Campaign Travel Expenses 

Totaled Approximately $58 Million, Including $17.1 Million in 

Reimbursements to the Campaign Committees 9

Secret Service Did Not Always Follow its Travel Policies, 

Resulting in Overpayments of at Least an Estimated $3.9 

Million 11

Conclusions 27

Recommendations for Executive Action 27

Agency Comments 28

Appendix I Objectives, Scope and Methodology 30

Appendix II Analysis of a Stratified Random Sample of Flight Segments for 

GAO’s Overpayment Analysis 35

Appendix III Comments from the Department of Homeland Security 38

Appendix IV GAO Contact and Staff Acknowledgments 42

Table

Table 1: U.S. Secret Service Protected Individuals by Campaign 

Committee, 2016 Presidential Campaign 30

Figures

Figure 1: Timeline of U.S. Secret Service Protection, 2016 

Presidential Campaign 5

Figure 2: U.S. Secret Service Travel Expenses by Protected 

Individual and Campaign Committee, 2016 Presidential 

Campaign 10

Figure 3: U.S. Secret Service Reimbursements to Campaign 

Committees for Chartered Aircraft Flights, 2016 

Presidential Campaign 11

Contents
Page ii GAO-18-419 2016 Presidential Campaign

Figure 4: Summary of Key Steps in the U.S. Secret Service’s 

Policy Creation, Revision, and Issuance Process 19

Abbreviations

DHS Department of Homeland Security

FAA Federal Aviation Administration

FEC Federal Election Commission 

FMD Financial Management Division

FTR Federal Travel Regulation

GSA General Services Administration 

IATA International Air Transport Association

LRC Logistics Resource Center

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-18-419 2016 Presidential Campaign

441 G St. N.W.

Washington, DC 20548

May 30, 2018 

The Honorable Bennie G. Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

Dear Mr. Thompson:

The U.S. Secret Service (Secret Service), a component within the 

Department of Homeland Security (DHS), incurs millions of dollars in 

travel expenses to provide protection during the fast-paced operational

tempo of a presidential campaign. The Secret Service is authorized to 

protect major presidential and vice presidential candidates,

1 and within 

120 days of a general presidential election, their spouses.

2

In addition,

protection is provided for children or others not specifically identified in 

statute when directed by the President. Accompanying each protected 

individual, among others, are special agents who provide 24/7 protection,

and advance teams who provide site security. Secret Service special

agents often fly with protected individuals on aircraft chartered by the 

campaign committees and the agency reimburses the committees for the 

number of seats occupied by special agents on board each charter flight.

Candidates often visit multiple cities per day and multiple states per week,

and the necessary Secret Service protective assets must always arrive 

and deploy before each visit.

You requested that we review the Secret Service’s travel expenses during 

the 2016 presidential campaign. Specifically, this report addresses the 

following questions:

(1) How much did the Secret Service incur in transportation, lodging, and

other travel-related expenses when providing protection during the

2016 presidential campaign?

(2) To what extent did the Secret Service reasonably assure that

payments and reimbursements for travel-related protection expenses

1“Major” presidential and vice presidential candidates are determined by the DHS 

Secretary after consulting with an advisory committee.

218 U.S.C. § 3056.

Letter
Page 2 GAO-18-419 2016 Presidential Campaign

were made in accordance with applicable laws, regulations, and 

policies during the 2016 presidential campaign?

To determine how much the Secret Service incurred in travel-related

expenses, we obtained expense data from the Secret Service for the 

2016 presidential campaign. Specifically, we reviewed expenses for the 

12 protected individuals associated with campaign committees for the 

following Presidential candidates: Senator Bernie Sanders, Dr. Benjamin 

Carson, Mr. Donald Trump, and Secretary of State Hillary Clinton. We 

analyzed the travel expenses incurred by the Secret Service for each of 

the protected individuals (a total of 12) to determine the total expenses for 

each campaign committee and for the 2016 presidential campaign as a 

whole. Additionally, we determined the amount of the total travel-related 

expenses that were reimbursed to the campaign committees for special 

agents’ seats on aircraft chartered by the committees. We determined 

that the expense data were sufficiently reliable after, among other things, 

discussing with Secret Service officials how the data are entered and 

maintained in the agency’s financial systems, reviewing the data for 

obvious errors and anomalies, and comparing the reimbursement data to 

data campaign committees reported to the Federal Election Commission 

(FEC).

To determine the extent to which the Secret Service’s payments and 

reimbursements for travel-related protection expenses were made in 

accordance with applicable laws, regulations, and policies, we analyzed 

the Secret Service’s lodging payments and charter aircraft 

reimbursements to the campaign committees. Of the 962 overnight trips 

taken during the 2016 presidential campaign, we randomly selected 40—

10 for each of the 4 presidential candidates—to assess the Secret 

Service’s compliance with its internal lodging policy and select provisions 

of the Federal Travel Regulation (FTR).3 Although the results of our 

analysis are not generalizable to all overnight trips taken during the 2016 

presidential campaign, it provided us insight to the Secret Service’s 

compliance with select provisions of its lodging policy and the FTR. With 

regard to whether the Secret Service reimbursed the four campaign 

committees the correct amounts for special agents’ seats on campaign 

chartered aircraft, we compared the Secret Service’s payments to the 

committees to the agency’s charter aircraft reimbursement policy.4 To 

 3The FTR is found at 41 C.F.R. chs. 300-304.

4U.S. Secret Service, Methods of Transportation, FMD-08(04), (November 22, 2011). 
Page 3 GAO-18-419 2016 Presidential Campaign

estimate whether and, if so, by how much the Secret Service incorrectly 

paid the campaign committees for special agents’ seats on chartered 

aircraft flights, we selected a generalizable stratified random sample of 

650 flight segments from the 2,318 flight segments taken from November 

1, 2015 through the end of the 2016 presidential campaign that had an 

identifiable airport.

To determine whether the Secret Service followed its policy with regard to 

accepting and reviewing chartered aircraft invoices submitted by the 

campaign committees, we compared the agency’s policy requirements to 

all 76 invoices submitted by the four campaign committees. Further, we 

used the Standards for Internal Control in the Federal Government to 

assess whether the Secret Service’s requirements for chartered aircraft 

invoices, and the review of the invoices, are specific enough to help 

ensure that the Secret Service is making correct reimbursements for 

chartered aircraft flights.5 Additional details regarding our scope and 

methodology are provided in appendixes I and II.

We conducted this performance audit from April 2017 to May 2018 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.

During the 2016 presidential campaign, a Secret Service detail was to be 

activated once a candidate for the Office of the President or Vice 

President requested protection, met the requirements for major candidate 

status (e.g., entered at least 10 state primaries),6 and received 

 5GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C., September 2014).

6The requirements for major candidate status were outlined in Advisory Committee 

Guidelines for Secret Service Protection to Presidential Candidates (October 2015). 

These guidelines were updated by DHS in January 2017 to clarify, among other things, 

that a candidate’s request must be in writing and that authorization can also be based on 

threats to the candidate.

Background

Authorization of Secret 

Service Protection during 

Presidential Campaigns
Page 4 GAO-18-419 2016 Presidential Campaign

authorization by the Secretary of Homeland Security after consultation 

with an advisory committee.7 Under the direction of the Secretary of 

Homeland Security, the Secret Service is authorized to provide protection 

for spouses of major presidential and vice presidential candidates within 

120 days of the general presidential election.8 There is no statute that 

addresses the protection of candidates’ children during the campaign. 

During the 2016 presidential campaign, the Secret Service provided 

protection for certain children of candidates at the request of the 

President. According to Secret Service officials, the Secret Service has 

historically provided protection for individuals not specifically identified in 

statute when directed by the President.9 In connection with the 2016 

presidential campaign, the Secret Service provided protection for 12 

individuals—4 presidential candidates, 2 vice presidential candidates, and 

6 of the candidates’ family members. Figure 1 below shows the dates of 

protection through Election Day, November 8, 2016.

 7The committee consists of the Senate Majority Leader, the Senate Minority Leader, the 

Speaker of the House of Representatives, the Minority Leader of the House of 

Representatives, and one additional member to be selected by the other members of the 

committee. 18 U.S.C. § 3056(a)(7).

818 U.S.C. § 3056(a)(7).

9The Departments of the Treasury and Homeland Security General Counsels have taken 

the position that the Secret Service may provide protection to persons not included within 

18 U.S.C. § 3056 when ordered by the President pursuant to the President’s constitutional 

authority. See, e.g., Memorandum for Secretary Shultz, from Edward C. Schmults, 

General Counsel of the Treasury (Mar. 19, 1974); Memorandum for the Secretary of 

Homeland Security, from Joe D. Whitley, General Counsel, Dep’t of Homeland Security 

(Apr. 14, 2004); see also, Memorandum for the Honorable John W. Dean, III, Counsel to 

the President, from Ralph E. Erickson, Assistant Attorney General, Office of Legal 

Counsel (Mar. 27, 1972) (finding that “reasonable arguments can be marshalled in support 

of the legal authority” to provide protection for public officials absent specific congressional 

authorization); B-149372, Jan. 28, 1975 (acknowledging but not addressing Treasury’s 

legal view that the President can order protection on a temporary basis to persons not 

included within 18 U.S.C. § 3056(a)).
Page 5 GAO-18-419 2016 Presidential Campaign

Figure 1: Timeline of U.S. Secret Service Protection, 2016 Presidential Campaign

a

As the former president and first lady, respectively, Bill and Hillary Clinton w ere receiving Secret 

Service protection prior to the 2016 presidential campaign. The start dates in the figure reflect when 

the Secret Service identified them as candidate and spouse.

Secret Service protective operations have evolved over the years. 

Originally, protection involved special agents serving as bodyguards. 

Protection now includes not only special agents in close proximity to the 

protected individual, but also advance security surveys of locations to be 

visited, coordination with state and local law enforcement entities, and 

analysis of present and future threats. Site surveys and threat 

assessments help the Secret Service determine the resources and assets 

needed to accompany each candidate and other individuals protected 

during the presidential campaign. These resources and assets, among 

other things, generally include:

• special agents who provide 24/7 protection while on detail;

Role of the Secret Service 

in Providing Presidential 

Campaign Protection
Page 6 GAO-18-419 2016 Presidential Campaign

• advance teams who provide site security;

• Explosive Ordnance Disposal and other technical support personnel 

(e.g., counter-surveillance and counter sniper personnel);

• magnetometer screening capabilities; and

• protective intelligence personnel who investigate threats.

Federal law provides for agencies to pay for or reimburse transportation 

and lodging expenses for their employees when they are traveling on 

official business. It further directs the General Services Administration 

(GSA) to issue regulations governing this travel.10 The FTR issued by 

GSA is applicable to Secret Service special agents’ transportation and 

use of hotel rooms when traveling during presidential campaigns to 

protect candidates and their family members.11

Transportation. According to the FTR, coach-class service is to be 

utilized unless an agency determines that an exception is warranted. For 

example, an exception may be granted to allow a special agent to use 

business class accommodations when the protected individual is doing 

the same and security demands warrant it.12 In the case of presidential 

campaign travel, the Secret Service may also accompany protected 

individuals aboard chartered aircraft.13 The Secret Service reimburses 

campaign committees for the seats occupied by its special agents. In 

1977, we were asked to review the Secret Service’s reimbursement 

method, and in that decision stated that GAO did not object to the method 

 105 U.S.C. §§ 5702, 5707.

11However, the Consolidated Appropriations Act, 2017, enacted after the time period of 

our review, provided authority to the Secret Service to pay per diem travel expenses (i.e., 

lodging, meals, and incidental expenses) of employees on protective missions without 

regard to GSA’s reimbursement rates for federal employee travel. Pub. L. No. 115-31, div. 

F, tit. II, 131 Stat. 135, 410. This language also appears in the Consolidated 

Appropriations Act, 2018, Pub. L. No. 115-141, div. F, tit. II.

12FTR § 301-10.123.

13As used in the report, a chartered aircraft is an aircraft rented in its entirety as opposed 

to individuals purchasing seats on commercial aircraft.

Travel Laws and 

Regulations
Page 7 GAO-18-419 2016 Presidential Campaign

used by the Secret Service as long as it was used consistently and the 

amount reimbursed did not exceed the first-class airfare.14

Lodging and other use of hotel rooms. The Secret Service utilizes 

hotel rooms for various purposes when protecting a candidate. The 

purpose of the room dictates the authority the Secret Service relies on to 

authorize payment and the related requirements. Hotel rooms used 

exclusively for special agent overnight sleeping facilities are governed by 

the FTR. The FTR allows agencies to pay for lodging based on per diem 

allowances 15 set by GSA for the applicable location and date or the actual 

expenses of the travel.16 Actual expense allowance, which can be in 

excess of the per diem rate, is permitted for a variety of reasons, such as 

costs escalating due to special events (e.g., sporting events or disasters) 

or because of mission requirements.17 However, the maximum amount 

that an employee may be reimbursed under the actual expense 

allowance method is limited to 300 percent of the applicable per diem 

rate.18

The Secret Service also utilizes hotel rooms for operational purposes. For 

example, the Secret Service may use a room as a command center or 

reserve rooms adjacent to the protected individual to better secure the 

individual. In addition, to meet operational security demands, the Secret 

Service may require a certain number of special agents to stay in the 

particular hotel that the protected individual is staying and within certain 

 14The Secret Service has engaged in this reimbursement practice since at least 1977, 

when the Comptroller General was asked to review payment to a campaign committee for 

space occupied by special agents on chartered aircraft. That decision held that “in the 

absence of any other laws or regulations (and we found none)...the reimbursement 

method to be used is discretionary with the Secretary of the Treasury [the Secret Service’s 

former department] and [GAO] would not object to the method as long as it is used 

consistently and does not exceed the first class airfare, which we understand had been 

the criteria used by the Secret Service in the past.” B-130961.141, July 5, 1977. By 

statute, GAO’s authority to adjudicate these kinds of claims was transferred to GSA, 

among other agencies, in 1996.

15The per diem allowance (also referred to as subsistence allowance) is a daily payment 

instead of reimbursement for actual expenses for lodging, meals, and related incidental 

expenses. FTR § 300-3.1.

16GSA has authority to establish per diem rates for destinations within the lower 48 

continental United States and establishes locality-based allowances for these expenses.

17FTR § 301-11.300.

18FTR §§ 301-11.303, 301-11.305. 
Page 8 GAO-18-419 2016 Presidential Campaign

proximity to the individual. The legal authorities the Secret Service relies 

on to pay for these kinds of rooms do not limit how much the agency can 

pay.19

 19The FTR provides that payment for miscellaneous expenses—including the hire of a 

conference center or a hotel room for official business—may be made when authorized by 

the agency and under the agency’s governing policy. FTR §§ 301-12.1, 301-70.301. In 

addition, according to Secret Service counsel, during the 2016 campaign, the Secret 

Service relied on a 1982 GAO decision that provides that an agency may rent 

accommodations that cost more than applicable limitations where (a) use of the particular 

accommodations is an integral part of the employee’s job assignment, and (b) failure to 

provide such accommodations would frustrate the ability of the agency to carry out its 

statutory mandate. B-209375, Dec. 7, 1982. By statute, GAO’s authority to adjudicate 

these kinds of claims as they relate to lodging rooms was transferred to GSA, among 

other agencies, in 1996. Following the 2016 presidential campaign, the Consolidated 

Appropriations Act, 2017 provided authority to the Secret Service to pay per diem travel 

expenses (i.e., lodging, meals, and incidental expenses) of employees on protective 

missions without regard to GSA’s reimbursement rates for federal employee travel. Pub. 

L. No. 115-31,131 Stat. at 410. Therefore, since that time, the Secret Service has not 

been subject to regulatory caps on room rental, regardless of room purpose.
Page 9 GAO-18-419 2016 Presidential Campaign

The Secret Service’s travel expenses for the 12 individuals protected 

during the 2016 presidential campaign totaled approximately $58 million, 

according to our analysis of Secret Service data. Travel expenses 

included airfare, vehicle rentals, hotel rooms, meals and incidental 

expenses, and baggage charges for special agents accompanying 

protected individuals.20 The $58 million in travel expenses was used by 

the Secret Service to support 3,236 travel stops made by the 12 protected 

individuals throughout the presidential campaign.21 The breakdown of 

these expenses and number of travel stops by campaign committee and 

protected individual are shown in figure 2 below.

20The Office of Management and Budget established a system of object codes to be used 

when reporting funding obligations (transactions) of items or services purchased by the 

federal government. See Office of Management and Budget Circular No. A-11, Section 83 

(July 2017). Travel expenses include those captured by the Secret Service under object 

class 21—travel and transportation of persons—and do not include special agents’ 

salaries.

21A protective travel “stop” is a single instance (e.g., event attendance, overnight lodging) 

that a particular protected individual spends within the jurisdiction of a single Secret 

Service field office. Each jurisdictional change during a trip is considered a separate stop. 

For example, a candidate could make four travel stops in four different cities within the 

jurisdiction of different Secret Service field offices during the same day. Each city would 

count as a travel stop.

Secret Service’s 2016 

Presidential 

Campaign Travel 

Expenses Totaled 

Approximately $58 

Million, Including 

$17.1 Million in 

Reimbursements to 

the Campaign 

Committees
Page 10 GAO-18-419 2016 Presidential Campaign

Figure 2: U.S. Secret Service Travel Expenses by Protected Individual and Campaign Committee, 2016 Presidential Campaign

Of the $58 million the Secret Service incurred in 2016 presidential 

campaign travel expenses, $17.1 million was for reimbursements to the 4 

campaign committees for 2,548 chartered aircraft flights.22 In the case of 

campaign travel, Secret Service special agents often fly with protected 

individuals on aircraft chartered by the campaign committees. The Secret 

Service reimburses the campaign committees for the number of seats 

occupied by special agents on board each charter flight. Figure 3 below 

shows the amount and number of flights for which the Secret Service 

reimbursed each of the campaign committees.

 22We attempted to determine whether any portion of the Secret Service’s reimbursements 

for chartered aircraft flights were for the use of candidate-owned assets. However, the 

information we collected from the FEC, Secret Service, and the presidential campaigns 

was not sufficient to allow us to make such a determination. See appendix I for additional 

information.
Page 11 GAO-18-419 2016 Presidential Campaign

Figure 3: U.S. Secret Service Reimbursements to Campaign Committees for 

Chartered Aircraft Flights, 2016 Presidential Campaign

Note: The U.S. Secret Service captured all charter flight reimbursements it made to the Hillary for 

America Committee as a campaign expense regardless of whether special agents w ere on the flight 

to protect Secretary Hillary Clinton as the former first lady or as a presidential candidate beginning in 

September 2015.

Secret Service Did 

Not Always Follow its 

Travel Policies, 

Resulting in 

Overpayments of at 

Least an Estimated 

$3.9 Million
Page 12 GAO-18-419 2016 Presidential Campaign

We reviewed special agents’ lodging expenses while accompanying 

individuals protected during the 2016 presidential campaign on 40 

randomly selected overnight trips. Our review found that (1) for most 

trips—30 of 40—the documented hotel expenses were within GSA per 

diem lodging rates, (2) the Secret Service generally followed its policy of 

requiring a lodging variance (i.e., waiver) for any hotel rooms exceeding 

the GSA lodging rate for that location, and (3) the Secret Service did not 

exceed the maximum amount allowed for lodging for these trips.23

The Secret Service required field offices responsible for booking hotel 

rooms to request and submit a waiver for any room that may exceed the 

designated GSA lodging rate by any amount.24 Our review of the receipts 

for hotel room expenses incurred by the Secret Service found that each 

trip involved multiple special agents staying in multiple rooms. 

Specifically, of the 40 trips we reviewed, 30 included hotel rooms that 

were within GSA lodging rates and 9 included hotel stays exceeding the 

GSA lodging rate. The Secret Service was unable to locate a hotel bill for 

1 trip and we therefore were unable to determine the rate paid for that 

trip.

In accordance with Secret Service policy, special agents submitted 

waivers to the agency’s Logistics Resource Center (LRC) for all 9 hotel 

stays exceeding the GSA lodging rate. According to LRC officials, before 

approving a waiver, they generally wanted to know how many alternative 

hotels were contacted, whether any hotels were available at or below the 

GSA lodging rate, and whether staying at a hotel at or below the GSA 

lodging rate would incur additional expenses that would negate the 

savings. For example, if a rental vehicle would be required, use and 

parking of the vehicle may have resulted in total costs that exceeded the 

price of the more expensive hotel. According to LRC officials, in order to 

spend travel money judiciously, some special agents stayed at hotels 

nearby the protected individual’s hotel that had rates at or closer to the 

GSA lodging rate.

 23The FTR defines lodging as including expenses for overnight sleeping facilities, baths, 

and personal use of the room during daytime, among other things (but not including 

lodging taxes). FTR § 300.3.1.

24U.S. Secret Service, Logistics Resource Center Operating Procedures Regarding 

Lodging, ADM-06(03), (March 27, 2015). 

Secret Service Generally 

Followed its Policies and 

Applicable Regulations for 

Lodging Payments during 

the 2016 Presidential 

Campaign for the Trips 

Reviewed
Page 13 GAO-18-419 2016 Presidential Campaign

Under the FTR’s actual expense reimbursement method, agencies may 

pay up to 300 percent of the applicable total GSA per diem allowance—

the GSA established rates for (1) lodging and (2) meals and incidental 

expenses—for an employee’s daily expenses. However, the agency is to 

subtract any allowance granted for meals and incidental expenses from 

the total, with the remainder being available for lodging.25 DHS and 

Secret Service policy, however, restricts the 300 percent actual expense 

allowance for lodging to 300 percent of the GSA lodging rate only.26

Consistent with DHS and Secret Service policy, none of the hotel rates 

paid exclusively for lodging in the 40 trips we reviewed exceeded the 

applicable GSA lodging rate by more than 300 percent.27 As a result, we 

determined that the Secret Service’s expenditures for lodging for the trips 

we reviewed were consistent with its policies and applicable regulations.

 25To calculate the maximum FTR actual expense reimbursement rate for lodging for a 

given location, the following equation can be used: ([Lodging per diem rate + meals and 

incidental expenses per diem rate] X 300 percent) – allowance granted for meals and 

incidental expenses = Maximum dollar amount allowable for hotel lodging under the FTR’s 

actual expense reimbursement method.

26For example, if the GSA lodging rate for a location is $100, the maximum the Secret 

Service would be able to spend is up to $300 (i.e., 300 percent).

27According to DHS officials, the Secret Service has the authority to exceed lodging rates 

set in its policy and the FTR when acquiring space needed to meet operational security 

standards; for example, Secret Service security standards may require that special agents 

stay in the particular hotel that the protected individual is staying and within certain 

proximity to the protected individual. Two trips in our sample included hotel rooms used to 

meet operational security standards where the protected individual—Secretary Hillary 

Clinton—stayed. The rooms exceeded the maximum allowed by the Secret Service’s 

policy on rooms to be used exclusively for lodging. However, none of the rooms used to 

meet operational security standards exceeded the maximum allowed under the FTR’s 

actual expense reimbursement method.

Examples of Federal Travel Regulation 

(FTR) actual expense reimbursement 

method calculations for lodging

General Services Administration (GSA) 

Established Per Diem Rates

Lodging: $100 per day

Meals and Incidental Expenses (M&IE): 

$50 per day

Example 1: $400 Maximum FTR Allow ance

$100 (GSA lodging rate) + $50 (M&IE rate)= 

$150 total GSA per diem

$150 (total GSA per diem) X 300 

percent = $450 per night allow ed for 

all expenses

Less $50 M&IE allow ance

Total maximum FTR allow ance for lodging: 

$400 per night

Example 2: $300 Maximum Allow ance Per 

Department of Homeland Security Policy

$100 (GSA lodging rate) X 300 percent = 

$300 per night maximum allow ance for 

lodging

Source: GAO. | GAO-18-419
Page 14 GAO-18-419 2016 Presidential Campaign

As discussed earlier, as part of their mission to protect presidential 

candidates, Secret Service special agents frequently accompany 

candidates on chartered aircraft provided by the presidential campaigns. 

The Secret Service is to later reimburse the candidate’s campaign 

committee for the cost of having special agents fly on those planes. The 

Secret Service’s policy for determining the amount to reimburse has been 

used since at least 1977. Under this policy, the Secret Service is to pay 

the lower of two applicable fares when reimbursing the campaign 

committees for special agents’ travel on chartered aircraft flights.28

Specifically, according to the policy the Secret Service is to compare the 

lowest commercially available first-class airfare29 for a flight segment (one 

airport to another airport) to the pro rata fare of the charter (total charter 

cost divided by the number of passengers). The Secret Service is then to 

reimburse the campaign committee for the lower of the two fares. The 

following text box includes an example of the pro rata fare calculation.

Pro rata fare calculation example if two special agents on board charter flight: 

$10,000 (total charter flight cost) /10 (total number of passengers) = $1,000 per 

passenger

$1,000 x 2 special agents = $2,000 owed by the Secret Service to campaign committee

Source: GAO. I GAO-18-419.

In July 2015, an attorney from the law firm representing the Hillary for 

America Committee sent Secret Service Financial Management Division 

(FMD) officials an e-mail stating that in their view, the reimbursements for 

 28U.S. Secret Service, Methods of Transportation, FMD-08(04), (November 22, 2011). 

The policy states that it was developed in accordance with guidelines provided in 

Comptroller General Decision B-130961.141, July 5, 1977.

29The lowest commercially available first-class airfare on the date of travel is determined 

by the Secret Service’s travel agency. Commercially available airfare is a fare available to 

the general public on a scheduled air carrier.

Secret Service Did Not 

Follow its Policies for 

Chartered Aircraft Flights 

and Did Not Thoroughly 

Review Invoices Prior to 

Payment

Secret Service Overpaid the 

Campaign Committees an 

Estimated $3.9 Million or More 

for Chartered Aircraft Flights
Page 15 GAO-18-419 2016 Presidential Campaign

special agents’ seats should be the pro rata fare based on an FEC 

regulation.30 In response, in August 2015, the Secret Service’s Office of 

the Chief Counsel made a decision to agree with the interpretation of this 

law firm. As a result, the Secret Service ceased to adhere to its 

longstanding reimbursement policy and agency officials were directed to 

use the pro rata calculation method for reimbursing all campaigns for 

agent airfares. Consequently, the Secret Service did not conduct the 

comparison between first-class and pro rata fares during the 2016 

presidential campaign. Instead, the Secret Service solely paid the pro rata 

fare to the campaign committees.

In March 2016, in response to a congressional inquiry about presidential 

campaign charter flight reimbursements, the Office of the Chief Counsel 

determined that its August 2015 decision was a mistake. Specifically, the 

Office recognized that the FEC regulation at issue did not apply to the 

Secret Service’s use of chartered aircraft.31 According to the Office of the 

Chief Counsel, they notified an official in the Office of Protective 

Operations, which collects submissions for reimbursements from the 

protected individual or the related campaign committee. However, the 

Office of the Chief Counsel did not notify LRC, which is to obtain the firstclass airfares for comparison from the Secret Service’s travel agency. 

Further, the Office of the Chief Counsel was uncertain but believed FMD, 

which issues payments for the flights, was notified. FMD officials told us 

that they were not notified. As a result, the Secret Service continued to 

reimburse the campaign committees the pro rata fares for the remainder 

of the 2016 political campaign (i.e., through mid-November 2016).

Despite being aware of the error for eight months before the end of the 

2016 presidential campaign that the pro rata fare should be compared to 

the lowest available first-class airfare, the Office of the Chief Counsel did 

not ensure the agency reverted to its long standing policy. During this 8 

month period, the Secret Service accompanied protected individuals on 

 30The regulation cited was 11 C.F.R. § 100.93 (FEC requirements related to noncommercial travel).

31In issuing a regulation in 1995, the FEC stated that “the amount of reimbursement 

received from Secret Service and national security personnel is limited by the rules of 

other federal agencies, not the FEC, and in some cases is not enough to cover the costs 

of transporting these persons.” See Public Financing of Presidential Primary and General 

Election Candidates, 60 Fed. Reg. 31854, 31859 (June 16, 1995). According to a senior 

attorney from the Secret Service’s Office of the Chief Counsel, the Secret Service did not 

consult with the FEC regarding its interpretation of the FEC regulation.
Page 16 GAO-18-419 2016 Presidential Campaign

1,671 (66 percent) of the 2,548 total campaign-related flight segments. As 

a result of solely reimbursing the pro rata fare instead of reimbursing the 

lower of the pro rata fare versus the lowest commercially available firstclass airfare, we estimate based on our sample of 650 flight segments 

that the Secret Service overpaid the 4 campaign committees at least $3.9 

million for special agents’ seats on chartered aircraft.32

Federal agencies are generally required to try to collect on debts—

including overpayments—they determine are owed to them. A federal 

debt or claim is any amount of funds that has been determined by an 

appropriate official of the federal government to be owed to the United 

States.33 It includes, without limitation, overpayments.34 Under the federal 

debt collection authorities as provided in 31 U.S.C. chapter 37, federal 

agencies are required to try to collect on claims arising out of their 

activities. However, they have the authority to compromise (i.e., accept 

less than full value) claims, or suspend or end collection, such as when 

 32Given issues identified with information on chartered aircraft flights provided by the 

campaign committees and available historical data on airfares, we were unable to 

determine the actual amounts that may have been overpaid to each campaign committee 

for all flight segments. Based on our sample results (650 of 2,318 flight segments), we 

estimate that the Secret Service overpaid invoices for about 49 percent (+/- 4 percentage 

points) of flight segments from November 1, 2015 through the end of the campaign, 

November 8, 2016. See appendices I and II for more information.

3331 U.S.C. § 3701(b)(1). The terms “debt” and “claim” are used synonymously in the 

federal debt collection authorities. See 31 C.F.R. § 900.2(a).

3431 U.S.C. § 3701(b)(1)(C). The mistakes of federal employees will not bar the federal 

government from fulfilling its duties to collect claims of the United States. GAO, 3 

Principles of Federal Appropriations Law, GAO-08-978SP, at 14-75 (Washington, D.C.: 

September 2008) (citing Aetna Casualty & Surety Co. v. United States, 526 F.2d 1127, 

1130 (Ct. Cl. 1975), cert. denied, 425 U.S. 973 (1976); Lawrence v. United States, 69 Fed. 

Cl. 550, 557, aff’d, 206 Fed. Appx. 993 (2006); Amtec Corp. v. United States, 69 Fed. Cl. 

79, 88 (Fed. Cl. 2005), aff’d, 239 Fed. Appx. 585 (Fed. Cir. 2007) (unpublished)). 
Page 17 GAO-18-419 2016 Presidential Campaign

the cost of collecting the claim is likely to be more than the amount 

recovered.35

In response to our finding that the Secret Service had overpaid for travel 

on chartered aircraft, Secret Service officials told us in February 2018 that 

they planned to take action to determine the overpayment amounts and 

seek refunds from the campaign committees. In light of the problems we 

discuss in appendix II regarding information on aircraft flights provided by 

the campaign committees and available historical data on airfares, Secret 

Service officials told us they were attempting to calculate the 

overpayments and would weigh the feasibility and costs of collecting 

refunds. However, as of April 2018, the Secret Service lacked specific 

plans, timeframes, and milestones for calculating the amounts of 

overpayments to the campaign committees and making key decisions on 

how and the extent to which the Secret Service will proceed with 

collections. Making such determinations can help ensure the Secret 

Service is complying with applicable federal law and recovering funds that 

could be used to support its protective operations or deposited into the 

general fund of the United States Treasury as appropriate.

According to Secret Service officials, the decision to change the 

reimbursement calculation method in August 2015 was inconsistent with 

the Secret Service’s directive on policy revisions. Specifically, the Secret 

Service’s directive on policy revisions states that the “responsible 

office”—FMD in this case—is accountable for ensuring policies are 

current and accurate. In addition, this office is to review, research, and 

revise the policy, if such a revision is deemed necessary.36 Further, all 

significantly affected offices and divisions of the Secret Service, including 

members of the Secret Service’s Executive Resources Board, are to be 

 3531 U.S.C. § 3711(a). The head of an agency may compromise (i.e., accept less than full 

value) a claim of up to $100,000 (excluding interest, penalties, and administrative costs), 

or a higher amount authorized by the Attorney General. Government-wide regulations 

prescribe standards for federal agencies in the administrative collection, offset, 

compromise, and the suspension or termination of collection activity, and provide that 

agencies must aggressivelycollect all debts arising out of the activities of that agency. 31 

C.F.R. §§ 900.1, 901.1(a). In addition to the Federal Claims Collection Standards found at 

31 C.F.R. parts 901-04, DHS has issued procedures for the collection of DHS debts at 6 

C.F.R. part 11, and section 3.13 of the DHS Financial Management Policy Manual 

provides guidance for identifying, servicing, collecting, and accounting for non-tax 

delinquent debt.

36U.S. Secret Service, Creating, Revising and Issuing Policy, MNO-05(01) (January 29, 

2014).

Secret Service Did Not Adhere 

to Its Directive on Policy 

Revisions
Page 18 GAO-18-419 2016 Presidential Campaign

provided the opportunity to read and comment on the changes, among 

other required actions.37 See figure 4 for a summary of key steps in the 

Secret Service’s policy creation, revision, and issuance process.

 37The Executive Resources Board is the final authority over all of the Secret Service’s 

project proposals. It is to ensure: (1) effective planning for and management of resources 

throughout the Secret Service, (2) that all Secret Service organizations have a voice in the 

decision-making process, and (3) that decisions best meet the needs of the entire Secret 

Service. Membership of this board includes the Deputy Director, all Assistant Directors, 

the Chief Counsel, and the Chief of the Secret Service Uniformed Division.
Page 19 GAO-18-419 2016 Presidential Campaign

Figure 4: Summary of Key Steps in the U.S. Secret Service’s Policy Creation, 

Revision, and Issuance Process

According to Secret Service officials, however, the process outlined in the 

directive on policy revisions was not followed in August 2015. As a result, 

the decision to change the reimbursement calculation method was not 

fully vetted or reviewed by all members of the Secret Service’s Executive 

Resource Board as would be required under the directive on policy 
Page 20 GAO-18-419 2016 Presidential Campaign

revisions. According to agency officials and confirmed in communications 

we reviewed, the Office of the Chief Counsel misinterpreted the regulation 

and directed that the erroneous interpretation be followed. The official 

leading FMD at the time, who was in the role on a temporary basis, 

adhered to the Office of the Chief Counsel’s interpretation of the 

regulation because the matter was legal in nature. Agency officials further 

added that the increased operational tempo (i.e., heavy workload) at the 

time may have resulted in a failure to adhere to the Secret Service’s 

directive on policy revisions.

An important role within the Secret Service’s policy creation and revision 

process is the directives control point. The directives control point is to 

help develop and implement policy that is clear, enforceable, and 

effective. In addition, the directives control point provides guidance for 

filing, structuring, and organizing policy instruments. Standards for 

Internal Control in the Federal Government states that management 

should design control activities to achieve objectives and respond to 

risks.38 Control activities are the policies, procedures, techniques, and 

mechanisms that enforce management’s directives to achieve the entity’s 

objectives and address related risks. Secret Service officials stated that 

the agency could better ensure that its existing directive for policy 

revisions is followed by requiring that its directives control point be 

notified of any legal advice or direction proposed by the Office of the 

Chief Counsel that could modify or amend agency policy. By requiring—in 

policy and practice—that the Secret Service’s directives control point be 

notified when the Office of the Chief Counsel provides advice to offices 

that is likely to result in policy changes, the Secret Service could better 

ensure that operational changes inconsistent with existing policy are not 

made without the full consideration of all affected parties. Moreover, it 

could reduce errors and the potential for unnecessary costs associated 

with decisions that do not go through the required review process.

Secret Service policy requires that protected individuals—and by 

extension their campaign committees—seeking reimbursement for 

special agents on chartered aircraft flights to submit an invoice with the 

following information:

(1) Name, address, and bank account information for the protected 

individual.

 38GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C., September 2014).

Secret Service Did Not Ensure 

the Accuracy of Charter Flight 

Invoices Prior to Reimbursing 

Campaign Committees
Page 21 GAO-18-419 2016 Presidential Campaign

(2) Taxpayer Identification Number.

(3) Date(s) of charter.

(4) Itinerary by flight segment (the three letter airport code should be 

provided for the departure and arrival airports for each segment).

(5) Total aircraft cost per flight segment.

(6) Total number of passengers for each flight segment (to include seats 

occupied by the Secret Service).

(7) Total number of seats occupied by the Secret Service for each flight 

segment.39

The policy also requires that if an invoice is incomplete or inaccurate that 

it should be returned to the protected individual within seven days of 

receipt for completion or correction.

We found that 20 of the 76 invoices submitted to the Secret Service 

during the 2016 presidential campaign had incomplete or inaccurate 

information, and therefore should have been returned to the protected 

individual, or the related campaign committee. The 76 invoices included 

2,548 flight segments. Information for 558 (22 percent) of the flight 

segments was incomplete or inaccurate. However, the Secret Service did 

not return any invoices to the four candidates or their campaign 

committees during the 2016 presidential campaign, according to Secret 

Service officials. Specifically, we found the following instances of 

incomplete and inaccurate information in the charter flight invoices 

provided by the campaign committees on behalf of protected individuals 

to the Secret Service:

• Airport Code: The Hillary for America Committee submitted two 

invoices containing two flight segments missing an airport code. The 

Carson America Committee submitted one invoice that did not clearly 

show the destination airport for seven flight segments and one invoice 

with three flight segments missing an airport code. The Donald J. 

Trump for President Committee submitted 12 invoices for thencandidate Trump with 336 flight segments missing an airport code. 

Only a city name with multiple possible airports was listed, leaving it 

unclear which airport was used. For example, in several instances 

 39U.S. Secret Service, Methods of Transportation, FMD-08(04), (November 22, 2011). 

This policy applies to all individuals protected by the Secret Service and not just those 

associated with campaign committees.
Page 22 GAO-18-419 2016 Presidential Campaign

“New York, NY” was listed, which could be LaGuardia Airport or JFK 

International Airport.

• Total Cost or Passengers: The Donald J. Trump for President

Committee submitted 4 invoices for flights taken by Vice Presidential 

Candidate Mike Pence with 210 flight segments which did not include 

the total cost or the total number of passengers for each flight 

segment. The total cost and number of passengers are necessary to 

verify the pro rata cost of the flight segment.

• Double Billing: The Donald J. Trump for President Committee 

double-billed the Secret Service for three flight segments taken on 

March 1, 2016 resulting in a cumulative overpayment of approximately 

$21,000 by the Secret Service for these segments.

• Other Errors: The invoices for the Hillary for America Committee had 

1 (less than 1 percent) of 1,317 flight segments with a mathematical 

error; the Donald J. Trump for President Committee had errors on 16 

(2 percent) of 965 flight segments; and the Bernie 2016 Committee 

had errors on 29 (18 percent) of 159 flight segments.40 These 46 flight 

segments with mathematical errors resulted in a net Secret Service 

underpayment to the campaign committees of approximately 

$63,000.41

According to Secret Service officials, although these errors were made by 

the campaign committees, Secret Service officials failed to detect the 

errors. Per the Secret Service’s reimbursement policy, it is the 

responsibility of the special agents overseeing the protected individual’s 

travel to review the invoices to ensure they include the required 

information and the provided information is accurate. The policy further 

states that absent complete and accurate information, the invoices are to 

be rejected for correction prior to reimbursement. Based on our review of 

the invoices, the special agents verified the dates of the flights and 

number of special agents on board the flight segments included in the 

invoices, but did not, for example, reject invoices that did not contain the 

three letter airport code or total number of passengers. According to 

Secret Service officials, the incomplete invoices should have been 

rejected, but were not because of the operational tempo associated with 

 40The Carson America Committee had no mathematical errors in any of its invoices.

41The $63,000 underpayment is based on the Secret Service paying the pro rata fares 

billed by the campaign committees and does not take into account that, as previously 

discussed, the Secret Service should have compared the pro rata fare to the lowest 

available first-class airfare.
Page 23 GAO-18-419 2016 Presidential Campaign

the presidential campaign. As discussed earlier, operational tempo was 

also a rationale provided by Secret Service officials for why they did not 

adhere to the directive on policy revisions. Standards for Internal Control 

in the Federal Government states that management should design control 

activities to achieve objectives, such as compliance with policies.42 In 

addition, the standards suggest that agency management should 

evaluate excessive pressure on personnel and help personnel fulfill their 

assigned duties. To help ensure that the Secret Service is adhering to its 

travel policies, the Secret Service may need to assess its existing control 

activities and determine how they can be enhanced to address the fastpaced operational tempo of presidential campaigns.

Further, according to FMD officials, when invoices marked certified 

reached FMD for payment, it was assumed by FMD that the invoices had 

been certified as complete and accurate, as indicated by the signature of 

a special agent or an authorized certifying officer. Secret Service policy 

does not assign responsibility for verifying the accuracy of the pro rata 

fare and checking that flight segments have not already been billed. 

Additionally, for three of the four campaign committees, the Secret 

Service had no assurance when paying the pro rata fare that it was being 

charged its share correctly since it did not receive copies of the charter 

companies’ invoices. Specifically, the Secret Service relied on invoices 

created by the campaign committees for reimbursement purposes without 

supporting receipts, invoices, or other documentation to verify the 

charges against. According to Secret Service officials, only the Hillary for 

America Committee forwarded copies of invoices from the charter 

companies it used, allowing the Secret Service to verify the accuracy of 

the amounts billed. The Secret Service policy on reimbursement of 

chartered aircraft flights does not require that copies of charter company 

invoices or receipts be forwarded by the protected individual or their 

campaign committee.

Standards for Internal Control in the Federal Government states that 

management should design control activities to achieve objectives and 

respond to risks.43 Such activities include proper execution of transactions 

(e.g., assuring that only valid transactions are entered into) and controls 

over information processing (e.g., comparing charter flight invoices to the 

 42GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C., September 2014).

43GAO-14-704G
Page 24 GAO-18-419 2016 Presidential Campaign

amounts billed to the Secret Service by the campaign committees). 

Secret Service officials agreed that the accuracy of flight segment details 

and costs should be verified prior to reimbursing for charter flights. In 

addition, they further agreed that responsibility for verifying the accuracy 

of the pro rata fare and checking that flight segments have not already 

been billed should be assigned. They also agreed that the Secret Service 

should require the charter companies’ invoices to verify that the campaign 

committees are correctly charging the Secret Service for its share of the 

total flight cost.

Without updating its charter aircraft reimbursement policy, the Secret 

Service does not have reasonable assurance that correct payments will 

be made. These changes include: (1) assigning responsibility for verifying 

that all calculations done by the campaign committees on behalf of the 

protected individual are accurate, (2) requiring a secondary review 

process to confirm the accuracy of charter flight costs prior to making 

payment, and (3) requiring that copies of charter companies’ invoices be 

provided to ensure that the reported pro rata costs are accurate prior to 

reimbursement. In response to our finding, in February 2018 the Secret 

Service began drafting an initial version of proposed policy changes, 

consistent with its directive on revising policy.44 Specifically, Secret 

Service officials started initial policy research and began reviewing and 

drafting the policy, consistent with step two of their policy revision process 

(see figure 4). However, several additional steps remain to be completed 

before the planned changes are implemented. Until the Secret Service 

completes all the necessary steps to update its charter aircraft 

reimbursement policy, it remains at risk for making incorrect payments.

Secret Service’s charter aircraft reimbursement policy does not specify 

whether its travel agency is to include taxes when identifying the lowest 

available first-class airfare. As discussed earlier, Secret Service is to pay 

the lower of two applicable fares (lowest available first-class fare, and the 

pro rata fare) when reimbursing the campaign committees for special 

agents’ travel on chartered aircraft flights. The Secret Service obtains the 

lowest available first-class airfare from its travel agency. LRC officials 

initially told us that the Secret Service’s travel agency had been including 

taxes in the lowest available first-class airfare. However, after inquiring 

with the travel agency, an LRC official learned that taxes had not been 

 44U.S. Secret Service, Creating, Revising and Issuing Policy, MNO-05(01) (January 29, 

2014).

Current Policy Does Not 

Ensure Correct 

Reimbursements for Chartered 

Aircraft Flights
Page 25 GAO-18-419 2016 Presidential Campaign

included. After further discussion with us, Secret Service officials told us 

that taxes should be included.45

Including taxes can make the difference between a first-class airfare 

being less or more expensive than the pro rata fare for a charter flight, 

therefore dictating which fare the Secret Service should reimburse the 

protected individual and campaign committee. For example, if a pro rata 

fare costs $1,000, and the lowest available first-class airfare (without 

taxes) is $950, then the lower fare is the first-class airfare. However, if the 

lowest available first-class airfare (with taxes) is $1,050, then the lower 

fare is the pro rata fare.

The Secret Service’s policy on reimbursement of special agents’ seats on 

chartered aircraft also lacks important details to ensure that its travel 

agency can accurately identify the lowest available first-class airfares and 

make accurate reimbursements.46 The policy requires the protected 

individual to provide the Secret Service the 3-letter airport code for the 

departure and arrival airports for each flight segment for which it is 

seeking reimbursement. However, it does not specify that the 3-letter 

airport code needs to be the International Air Transport Association 

(IATA) code and not the Federal Aviation Administration (FAA) code.47

Airports in different countries can have the same IATA and FAA codes. 

Providing the FAA code can result in the Secret Service’s travel agency 

identifying the wrong airport when determining the lowest first-class 

airfare for a travel segment since the travel agency searches IATA codes. 

For example, when we asked the Secret Service’s travel agency to 

research the lowest available first-class airfare for campaign travel 

segments based on the reported destination codes in campaign 

committee invoices the travel agency identified “SGJ” as Sagarai, Papua 

New Guinea based on the IATA code. However, SGJ is the FAA code for 

the Northeast Florida Regional Airport. Similarly, another reported 

destination code in a campaign committee’s invoice, LOM, is the FAA 

code for Wings Field Airport, Pennsylvania and is also the IATA code for 

 45Based on the Secret Service’s official decision that taxes should be included when 

identifying the lowest available first-class airfare, we included taxes when determining the 

Secret Service’s overpayment to the four campaign committees. 

46U.S. Secret Service, Methods of Transportation.

47Airports around the world are commonly identified by three and four letter codes. These 

codes are assigned by IATA, the International Civil Aviation Organization, the FAA, and 

other civil aviation organizations. IATA uses 3-letter codes for airline operations, baggage 

routing, and ticketing.
Page 26 GAO-18-419 2016 Presidential Campaign

Lagos de Moreno, Colombia. Since the travel agency searches on the 

basis of IATA codes, using FAA codes that are designated as foreign 

destinations in the IATA system can result in confusion for the travel 

agency when identifying the lowest available first-class airfare for a flight 

segment.

Secret Service officials told us that they had not considered specifying 

whether the lowest first-class airfares should include taxes since the 

Secret Service had been using the same representative at its travel 

agency since 1986 to identify the lowest available first class fare. They 

said they assumed that their representative knew the policy through 

practice. Also, Secret Service officials told us that they were not aware of 

the difference between IATA and FAA codes. Secret Service officials 

agreed that the reimbursement policy should be revised to make it clear 

that taxes are to be included when the Service’s travel agency identifies 

the lowest available first-class airfare when determining the correct 

reimbursement amount, and that protected individuals are to provide the 

IATA code for airports.

Standards for Internal Control in the Federal Government states that 

management should internally and externally communicate the necessary 

information to achieve the entity’s objectives and that effective information 

and communication are vital for an entity to achieve its objectives.48 The 

Secret Service could better ensure that its travel agency is able to identify 

the lowest commercially available first-class airfare for comparison to the 

pro rata fare by updating its charter aircraft reimbursement policy to 

specify that (1) taxes are to be included in the lowest commercially 

available first-class airfare, and (2) protected individuals’ invoices include 

the IATA airport codes for arrival and departure airports. In response to 

our finding, in February 2018 the Secret Service started to draft an initial 

version of proposed changes to its charter aircraft reimbursement policy, 

consistent with its directive on revising policy. Secret Service officials 

were in the process of conducting initial policy research, reviewing, and 

drafting the policy, consistent with step two of their policy revision process 

(see figure 4). However, the Secret Service needs to complete several 

additional steps before the planned changes go into effect. Until then, the 

Secret Service remains at risk of not correctly identifying the lowest 

applicable airfare.

 48GAO-14-704G
Page 27 GAO-18-419 2016 Presidential Campaign

The Secret Service plays a vital role in protecting our nation’s leaders,

including presidential and vice presidential candidates, and their family

members. During the 2016 presidential campaign, for the trips we 

reviewed, the Secret Service generally followed its internal policies and

federal regulations governing payment for lodging costs incurred while 

protecting candidates. However, due to an erroneous legal decision in 

August 2015, the Secret Service did not follow its reimbursement policy

for chartered aircraft during the campaign. By not adhering to its policy,

the Secret Service overpaid campaign committees at least an estimated 

$3.9 million dollars for charter flights. Until the Secret Service determines

the amounts owed and how it will proceed with seeking repayment from

the various campaign committees, these funds will not be recovered by

the federal government.

Further, in making the erroneous legal decision in August 2015, the 

Secret Service did not adhere to its directive on policy revisions. The 

decision to effectively change a policy was not fully vetted, reviewed, or

communicated in accordance with the directive. This was largely due to 

the lack of a requirement to notify the directive control point when legal

decisions are made that can result in policy changes. This could result in 

similar policy changes not being reviewed in the future.

Finally, presidential campaigns create a fast-paced operational tempo at

the Secret Service, and according to agency officials, this tempo 

contributed to their failure to comply with travel policies during the 2016 

presidential campaign. Until Secret Service evaluates the pressure 

caused by this tempo and implements appropriate mechanisms, it cannot

ensure that agency officials responsible for travel reimbursements are 

complying with policy during presidential campaigns. In addition, Secret

Service’s charter aircraft reimbursement policy does not assign primary

and secondary reviews of invoices provided by campaign committees.

The policy also does not require that campaign committees and the 

agency’s travel agency provide all the information necessary to verify the 

accuracy of the invoices. Without these requirements, Secret Service may

continue to reimburse campaign committees incorrect amounts.

We are making the following five recommendations to the Director of the 

Secret Service.

Consistent with the federal debt collection authorities as provided in 31 

U.S.C. chapter 37, the Director should complete the process of 

calculating the amounts of its overpayments to the campaign committees 

Conclusions

Recommendations for 

Executive Action
Page 28 GAO-18-419 2016 Presidential Campaign

for special agents’ seats on chartered aircraft during the 2016 presidential 

campaign, and determine how it should proceed with respect to collecting 

on identified debts. (Recommendation 1)

To help ensure that the agency’s existing directive on policy revisions is 

followed, the Director should require in policy and practice that the 

directives control point be notified when the Office of the Chief Counsel 

provides advice to offices that is likely to result in policy changes. 

(Recommendation 2)

The Director should assess its existing control activities and implement 

appropriate mechanisms to help ensure compliance with the agency’s 

travel cost policies during presidential campaigns. (Recommendation 3)

The Director should update the charter aircraft reimbursement policy to 

assign the offices responsible for verifying that all calculations done by 

the campaign committees are accurate, and require a secondary review 

process prior to making payment. (Recommendation 4)

The Director should update the charter aircraft reimbursement policy to 

specify that protected individuals are to provide IATA codes and copies of 

the charter companies’ invoices, and that the Secret Service’s travel 

agency is to provide lowest available first-class airfares that include taxes. 

(Recommendation 5)

We provided a draft of this report for review and comment to DHS, GSA, 

and FEC.

DHS provided written comments, which are reproduced in appendix III. In 

its comments, DHS concurred with our recommendations. DHS also 

stated it had taken or planned to take actions to address all five of our 

recommendations. In addition, after we provided this report to DHS for 

comment, Secret Service provided us documentation, including a revised 

travel policy, highlighting actions they have taken to address our 

recommendations. We will review the documentation and take steps to 

close the recommendations in the future, as appropriate.

DHS and FEC provided technical comments, which we incorporated as 

appropriate. GSA and FEC did not provide written comments.

Agency Comments
Page 29 GAO-18-419 2016 Presidential Campaign

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 1 day from the report 

date. At that time, we will send copies to the Secretary of Homeland 

Security, Administrator of the General Services Administration, and Staff 

Director of the Federal Election Commission. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-9627 or maurerd@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix IV. 

Sincerely yours, 

Diana Maurer

Director

Homeland Security and Justice
Appendix I: Objectives, Scope and 

Methodology

Page 30 GAO-18-419 2016 Presidential Campaign

This report addresses the U.S. Secret Service’s (Secret Service) 2016 

presidential campaign travel expenses and payment of those expenses. 

Specifically, our objectives were to examine the following questions:

(1) How much did the Secret Service incur in transportation, lodging, and 

other travel-related expenses when providing protection during the 

2016 presidential campaign?

(2) To what extent did the Secret Service reasonably assure that 

payments and reimbursements for travel-related protection expenses 

were made in accordance with applicable laws, regulations, and 

policies during the 2016 presidential campaign?

To determine how much the Secret Service incurred in travel-related 

expenses, we obtained expense data from the Secret Service for each of 

the individuals protected for the 2016 presidential campaign. In total, the 

Secret Service protected 12 individuals associated with 4 campaign 

committees (see table 1 below).

Table 1: U.S. Secret Service Protected Individuals by Campaign Committee, 2016 Presidential Campaign

Campaign 

committee

Presidential 

candidate

Vice presidential 

(VP) candidate

Spouse of 

presidential 

candidate

Spouse of VP 

candidate 

Child of 

presidential 

candidate 

Bernie 2016 Senator Bernie 

Sanders

__ __ __ __

Carson America Dr. Benjamin Carson __ __ __ __

Donald J. Trump for 

President

Donald Trump Governor 

Mike Pence

Melania Trump Karen Pence Ivanka Trump

Hillary for America Secretary 

Hillary Clinton

Senator Tim Kaine former president 

Bill Clinton

Anne Holton Chelsea Clinton

Source: GAO analysis of U.S. Secret Service information. I GAO-18-419.

We analyzed the travel expenses for each of these protected individuals 

to determine the total travel expenses incurred by the Secret Service for 

each campaign committee and for the 2016 presidential campaign as a 

whole. Travel expenses include those captured by the Secret Service 

under object class 21—travel and transportation of persons.1 Object class 

21 expenses include airfare, vehicle rentals, hotel rooms, meals and 

 1

The Office of Management and Budget established a system of object codes to be used 

when reporting funding obligations (transactions) of items or services purchased by the 

federal government. See Office of Management and Budget Circular No. A-11, Section 83 

(July 2017).

Appendix I: Objectives, Scope and 

Methodology
Appendix I: Objectives, Scope and 

Methodology

Page 31 GAO-18-419 2016 Presidential Campaign

incidental expenses, and baggage charges for special agents 

accompanying protected individuals. Additionally, we determined the 

amount of the total travel-related expenses that were reimbursements to 

the campaign committees—all of which were for special agents’ seats on

campaign chartered aircraft.

To assess the reliability of the Secret Service’s expense data, we 

discussed with the Secret Service officials how the data are entered and 

maintained in the Secret Service’s official financial system of record—

Travel Manager, Oracle, PRISM, Sunflower system—which is used to 

track operating and travel expenses, among other things. We also 

reviewed the data for any obvious errors and anomalies. We compared 

the data to the invoices the Secret Service received from the campaign 

committees seeking reimbursements in order to verify the amounts the 

campaigns were reimbursed. Further, we compared the Secret Service’s 

reimbursement data to data the campaign committees reported to the 

Federal Election Commission (FEC) on payments they received from the 

Secret Service. As a result, we determined that the expense data were 

sufficiently reliable for reporting the Secret Service’s total travel 

expenses, expenses broken out by campaign committee and protected 

individual, and the portion of expenses that were reimbursements to the 

committees.

To determine the number of travel stops made by the campaign 

committees for which the Secret Service provided protection, we used 

data from the Secret Service’s Agent Manpower Protection System. To 

assess the reliability of these data, we reviewed responses provided by 

the Secret Service on how the data are entered and maintained in the 

system. We further matched a sample of the travel stops data to hotel 

bills for those stops. As a result, we determined that the data on travel 

stops were sufficiently reliable for reporting the total number of travel 

stops made during the campaign and number of stops per campaign 

committee.

To determine whether the campaign committees charged the Secret 

Service appropriate rates for the use of candidate-owned assets, we tried 

to identify whether any portion of the Secret Service’s reimbursements to 

the campaign committees were for the use of candidate-owned assets. 

Candidates flew on various types of charter aircraft, including jets and 

helicopters. Pursuant to law and FEC regulations, campaign committees 

must report and maintain certain information regarding the use of these 
Appendix I: Objectives, Scope and 

Methodology

Page 32 GAO-18-419 2016 Presidential Campaign

aircraft.2 However, this information was not sufficient for us to determine 

whether aircraft for which the Secret Service provided reimbursement 

were owned by candidates.3 Further, the Secret Service does not collect 

information about a campaign’s use of candidate-owned assets, including 

aircraft. We contacted all four campaign committees using various 

methods, including email, phone, and in-person visits to identify 

reimbursements received for candidate-owned assets, but none of the 

committees responded to our questions. As a result, we were unable to 

determine whether any portion of the Secret Service’s reimbursements 

were for the use of candidate-owned assets.

To determine the extent to which the Secret Service’s payments and 

reimbursements for travel-related protection expenses were made in 

accordance with applicable laws, regulations, and policies, we analyzed 

the Secret Service’s lodging payments and charter aircraft 

reimbursements. Of the 962 overnight trips taken during the 2016 

presidential campaign, we randomly selected 40—10 for each of the 

presidential candidates—to assess the Secret Service’s compliance with 

(1) its internal policy requiring a waiver when a hotel room exceeds the 

General Services Administration (GSA) per diem rate by any amount,4

and (2) provisions of Federal Travel Regulation (FTR) that limit hotel 

spending to 300 percent of the GSA rate.5 To determine the GSA per 

diem lodging rate, we reviewed the GSA rates applicable on the date of 

the hotel stay and for that location. If the amount of the room exceeded 

the GSA rate we identified whether the Secret Service had a waiver for 

the trip and also checked whether the amount paid exceeded the 

 

2The FEC is responsible for administering federal election campaign laws, including the 

Federal Election Campaign Act of 1971, as amended. The Act and FEC regulations 

impose requirements related to campaign contributions and reporting. 

3For example, information on disbursements that campaign committees must submit to 

FEC is not required to contain information sufficient to determine whether an expenditure 

was made for use of a candidate-owned aircraft nor is it required to contain information on 

itineraries or persons on board the aircraft, such as Secret Service special agents. See 52 

U.S.C. § 30102; 11 C.F.R. §§ 102.9(b) (disbursements generally), 100.93(i) (reporting on 

disbursements and contributions for use of non-commercial aircraft). 

4GSA has authority to establish per diem rates for destinations within the lower 48 

Continental United States and establishes locality-based allowances for these expenses. 

The per diem allowance (also referred to as subsistence allowance) is a daily payment 

instead of reimbursement for actual expenses for lodging, meals, and related incidental 

expenses. FTR § 300-3.1.

5FTR §§ 301-11.303, 301-11.305.
Appendix I: Objectives, Scope and 

Methodology

Page 33 GAO-18-419 2016 Presidential Campaign

maximum amount available for lodging under Department of Homeland 

Security (DHS) and Secret Service policy and under the FTR. The time 

and effort associated with collecting trip bills from many field offices were 

primary considerations in determining the number of candidates’ trips to 

review. The Secret Service’s retention of hotel bills is decentralized; that 

is, the field office responsible for the geographic area where the 

protective operation occurs retains hard copies of the bills. Although the 

results of our analysis are not generalizable to all overnight trips taken 

during the 2016 presidential campaign, it provided us insight to the Secret 

Service’s compliance with its lodging policy and the FTR.

With regard to whether the Secret Service reimbursed the four campaign 

committees the correct amounts for special agent travel on campaign 

chartered aircraft, we compared the Secret Service’s payments to the 

committees to our estimate of what the Secret Service would have paid 

had its own charter aircraft reimbursement policy been followed.6 We 

determined the Secret Service did not use the correct reimbursement 

method throughout the 2016 presidential campaign. To determine 

whether the Secret Service followed its directive on the review and 

approval of policy changes, we compared the steps required to effect a 

change in policy to the steps taken by the Secret Service when its 

reimbursement method was altered.7

To estimate whether and, if so, by how much the Secret Service overpaid 

the campaign committees for special agents’ seats on chartered aircraft 

flights based on the reimbursement policy change mentioned above, we 

selected a generalizable stratified random sample of 650 flight segments 

from the 2,318 flight segments taken from November 1, 2015 through the 

end of the 2016 presidential campaign that had an identifiable airport. 

Appendix II provides further technical details on the statistical methods 

we used. To determine whether the Secret Service should try to collect on 

the overpayments to the campaign committees, we reviewed relevant 

federal authorities, including 31 U.S.C. chapter 37.

To determine whether the Secret Service followed its policy with regard to 

accepting and reviewing chartered aircraft invoices, we compared all 76 

invoices submitted by the four campaign committees to the agency’s 

 6U.S. Secret Service, Methods of Transportation, FMD-08(04), (November 22, 2011). 

7U.S. Secret Service, Creating, Revising and Issuing Policy, MNO-05(01) (January 29, 

2014).
Appendix I: Objectives, Scope and 

Methodology

Page 34 GAO-18-419 2016 Presidential Campaign

policy requirements for invoice completeness and accuracy.8 Further, we 

used Standards for Internal Control in the Federal Government to assess 

whether the Secret Service’s requirements for charter aircraft invoices, 

and the review of the invoices, are specific enough to help ensure that the 

Secret Service is making correct reimbursements for charter aircraft 

flights.9

We conducted this performance audit from April 2017 to May 2018 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.

 8U.S. Secret Service, Methods of Transportation.

9GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C., September 2014).
Appendix II: Analysis of a Stratified Random

Sample of Flight Segments for GAO’s 

Overpayment Analysis

Page 35 GAO-18-419 2016 Presidential Campaign

To estimate whether and, if so, by how much the U.S. Secret Service 

(Secret Service) overpaid the campaign committees for special agents’

seats on chartered aircraft flights, we selected a generalizable stratified 

random sample of flight segments from campaign invoices sent to the 

Secret Service. Specifically, we selected 650 flight segments from the 

2,318 flight segments taken from November 1, 2015 through the end of 

the 2016 presidential campaign that had an identifiable airport.1 We 

stratified the population of 2,318 flight segments into 11 mutually 

exclusive strata by campaign (Trump, Clinton, Sanders, and Carson) and 

three size categories based on the number of special agents that 

indicated being on board a flight. We chose to stratify based on the 

number of special agents on board to minimize the variance of the total 

cost within each stratum in an attempt to gain statistical efficiency in the 

sample design.

The sample size of 650 flight segments was based primarily on available 

resources to have the Secret Service’s travel agency extract cost data 

from the airfare database. We allocated the sample of 650 flight 

segments to the 11 strata using proportional allocation within each 

campaign.2 We then adjusted the allocation in each stratum in an attempt 

to match a Neyman allocation method that would minimize the variance of 

an estimate of total cost. We randomly selected the allocated sample size 

of flight segments within each of the 11 strata.

For each of the 650 flight segments selected in the sample, we obtained 

two measures of the lowest first-class airfare from the Secret Service’s 

travel agency, one with fees and taxes and one without (base fare). This 

was due to some confusion at the Secret Service about whether taxes 

and fees should be included when determining the lowest first-class 

airfare. We then compared these first-class airfares to the individual fare 

(i.e., the pro rata fare) paid by the Secret Service to the campaign 

committees. We classified a flight segment as overpaid if the lowest first-

 1The timeframe was defined by the Secret Service’s travel agency’s ability to identify the 

lowest first-class airfare. The database used by the travel agency contains airfares only for 

the rolling two year period preceding a current date. In our initial testing of the data, we 

found that some of the airport codes for flight segments were missing, invalid or a code 

not recognized by the travel agency’s database. We identified the correct airport code 

when possible and eliminated those segments with airports we could not identify prior to 

selecting our sample.

2This stratification resulted in 11 strata rather than 12 because the Carson America 

campaign did not have any flight segments with 10 or more Secret Service special agents 

on board.

Appendix II: Analysis of a Stratified Random 

Sample of Flight Segments for GAO’s 

Overpayment Analysis
Appendix II: Analysis of a Stratified Random 

Sample of Flight Segments for GAO’s 

Overpayment Analysis

Page 36 GAO-18-419 2016 Presidential Campaign

class airfare was less than the pro rata fare paid by the Secret Service. 

To determine the total amount of overpayment per flight segment, we 

multiplied the difference between the pro rata fare paid by the agency and 

the lowest first-class airfare by the number of Secret Service special 

agents on board the flight. We assigned flight segments that were 

classified as not overpaid a total overpaid value of zero.3

From our sample of 650 flight segments, we identified 295 flights for 

which the Secret Service overpaid a total of about $1.5 million.4 To 

estimate the proportion of overpaid flight segments and the total amount 

overpaid by the Secret Service for all 2,318 flight segments in the 

population from which we sampled, we weighted the sample results by 

the inverse of the probability of selection based on the stratified sample 

design. We used estimation methods appropriate for a stratified random 

sample design and generated 95 percent confidence intervals for each 

estimate. Because we followed a probability procedure based on random 

selections, our sample is only one of a large number of samples that we 

might have drawn. Since each sample could have provided different 

estimates, we express our confidence in the precision of our particular 

sample’s results as a 95 percent confidence interval (e.g., plus or minus 7 

percentage points). This is the interval that would contain the actual 

population value for 95 percent of the samples we could have drawn. As 

a result, we are 95 percent confident that each of the confidence intervals 

in this report will include the true values in the study population. The 

weighted percentage estimates of the full population from our sample 

have margins of error at the 95 percent confidence level of plus or minus 

4 percentage points or fewer and the estimate of the total amount 

overpaid by the Secret Service has a relative error of plus or minus 12 

percent of the estimate or less.

Based on these results, we estimate that total overpayments in the 

population of 2,318 flight segments from November 1, 2015 through the 

end of the campaign would be at least $3.9 million. We estimate that the 

Secret Service overpaid invoices for about 49 percent (+/- 4 percentage 

 3The Secret Service’s travel agency was unable to determine the lowest first-class airfares 

for 79 of the 650 flight segments selected in the sample. To ensure that we did not 

overestimate the proportion of overpaid flight segments or the total amount overpaid by 

the Secret Service, we classified all 79 of these flight segments as not being overpaid and 

assigned a total overpaid value of zero in our analysis.

4These sample results are based on the lowest first-class airfare including taxes and fees 

since, after consideration, Secret Service officials told us that taxes should be included.
Appendix II: Analysis of a Stratified Random 

Sample of Flight Segments for GAO’s 

Overpayment Analysis

Page 37 GAO-18-419 2016 Presidential Campaign

points) of the flight segments. The estimated $3.9 million represents the 

lower bound of the 95 percent confidence interval of the estimated total 

dollar amount overpaid based on our sample. The lower bound 

represents relative error of about 12 percent.
Appendix III: Comments from the Department 

of Homeland Security

Page 38 GAO-18-419 2016 Presidential Campaign

Appendix III: Comments from the 

Department of Homeland Security
Appendix III: Comments from the Department 

of Homeland Security

Page 39 GAO-18-419 2016 Presidential Campaign
Appendix III: Comments from the Department 

of Homeland Security

Page 40 GAO-18-419 2016 Presidential Campaign
Appendix III: Comments from the Department 

of Homeland Security

Page 41 GAO-18-419 2016 Presidential Campaign
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 42 GAO-18-419 2016 Presidential Campaign

Diana Maurer, (202) 512-9627 or maurerd@gao.gov

In addition to the contact named above, Joseph P. Cruz (Assistant 

Director), Lisa Canini, Jeffrey Fiore, Chad Johnson, Janet Temko-Blinder, 

and Jonathan Tumin made key contributions to this report. Also 

contributing to this report were David Alexander, Jim Ashley, Dominick 

Dale, Eric Hauswirth, John Mingus, and Carol Petersen.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(102017)
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