MEMORANDUM

TO: John Quinlan

Chief Financial Officer

Alec Palmer

Staff Director/Chief Information Officer

Lisa Stevenson

Acting General Counsel

THROUGH: Christopher Skinner

Inspector General

FROM: Michael Mitchell 

Senior Auditor 

SUBJECT: Special Review 23-02: Review of the FEC Travel and Purchase Card Programs

DATE: August 1, 2023

ENCL: (a) Appendices 1 and 2

(b) Management Response

Executive Summary

The Federal Election Commission (FEC) Office of the Inspector General (OIG) conducted a 

special review of the travel and purchase card programs as planned in the OIG Fiscal Year (FY) 

2023 Work Plan. The objective of the special review was to determine if the FEC’s travel, and 

purchase card programs comply with federal laws and regulations.

The OIG conducted the special review from February 20, 2023, to May 19, 2023. During the 

review, several areas were identified where management could enhance program controls, 

including ensuring that the responsibilities of Approving Officials (AOs) align with the guidance 

provided in Office of Management and Budget (OMB) A-123, Appendix B, and General 

Services Administration (GSA) SmartPay Training. Additionally, monitoring the completion of 

training and improving the timely submission of travel vouchers (TV) to the Office of the Chief 

Financial Officer (OCFO) were identified as areas for control improvement within the process.

1050 First Street NE Washington, DC 20463 | www.fec.gov/oig
Accordingly, the OIG recommends the following five actions: 

1. That the agency follows the general purchase card training requirements from 

OMB A-123, Appendix B and GSA SmartPay guidelines, to ensure all program 

participants have completed training requirements and maintain training 

certifications as required.

2. That the agency negotiate with the NTEU to update the LMA to include the travel 

voucher requirements documented in the Federal Travel Regulations § 301–52.7. 

3. That the agency monitor that the travel voucher is submitted within five working 

days according to FTR § 301-52.7. 

4. That the agency evaluate whether the current travel oversight for the Commissioner 

and other senior leaders is appropriate. 

5. That the agency update and finalize the travel policy, travel manual, and procurement 

office policies and procedures. 

Background

The FEC OIG reviewed travel and purchase card transactions, as scheduled in the OIG Fiscal 

Year 2023 Work Plan. Specifically, the review aimed to ensure that the FEC adhered to the 

requirements outlined in the Government Charge Card Abuse Prevention Act of 2012 (Charge 

Card Act) and the guidelines provided in the Office of Management and Budget (OMB) Circular

No. A-123, Appendix B: A Risk Management Framework for Government Charge Card 

Programs, General Services Administration (GSA) SmartPay Training, Federal Travel 

Regulations, and FEC's internal travel and procurement policies. 

Objectives, Scope, and Methodology

The scope of the special review includes but was not limited to the testing of FY 22 (October 

1, 2021 – September 20, 2022) travel/ purchase charge card transactions to ensure agency 

compliance with the aforementioned regulations and guidance.

Findings and Recommendations

A. Documentation of Purchase Card Approving Official (AO) Training Certification

The OIG requested training documentation for program officials and found that training 

certifications for AOs are not on file with the OCFO. As a result, the OIG could not confirm 

whether AOs had completed the required training. The OCFO confirmed and indicated that they 

would request certifications from cardholders and AOs in the future. 

2 
AOs must receive the same training as the cardholders and other relevant training as agency 

policy requires.2

According to the revised Appendix B to OMB Circular A-123, the general training 

requirements provide that:

1. All program participants must be trained prior to appointment;

2. All program participants must take refresher training in accordance with agency policy but, 

at a minimum, every 3 years;

3. All program participants must certify that they have received the training, understand the 

regulations and procedures and know the consequences of inappropriate actions. Agencies 

will determine the method of certification; and

4. Copies of required training certificates must be maintained pursuant to National Archives 

and Records Administration (NARA) records requirements.

The FEC Procurement Procedures for Government Small Purchase Card (Credit Card) 

Program § 6.03.1 (b) states in pertinent part: 

Training and Refresher Training Registration. All Cardholders and Approving Officials are 

required, on an annual basis, to take a refresher course (online) or attend a briefing as 

instructed by the A/OPC at a minimum, every 3 years.4

Recommendation 1: That the agency follow the general purchase card training 

requirements from OMB A-123, Appendix B, and GSA SmartPay guidelines to ensure all

program participants, including AOs, have met the general training requirements and maintain

training certifications as required.

B. Guidance for the Timely Submission of Travel Vouchers is Inconsistent

Federal Travel Regulations § 301–52.7 states in pertinent part:

Unless your agency administratively requires you to submit your travel claim within a shorter 

timeframe, you must submit your travel claim as follows: 

a) Within 5 working days after you complete your trip or period of travel; or

b) Every 30 days if you are on continuous travel status.

2 OMB Circular A-123, Appendix B, Chapter 4.5

3

 FEC Administrative Services Division Travel Card Policy, Jan 2015, p10

4 FEC Procurement Office Policy & Procedures - Procurement Procedures -030 Government Small Purchase Card 

(Credit Card) Program, § 6.03.1 (b), Jan 2010

3 
As indicated in Appendix 1, the FEC Travel Manual § 4.7 Employee Traveler indicates the 

employee traveler is required to:

• Submit Travel Authorizations prior to commencement of travel.

• File Travel Vouchers with required receipts, withing five days of completion of the trip.

• Pay travel card balances timely and ensure prompt reporting of questionable charges and 

disputes. 

Footnote 2 on page 9 of the FEC Travel Manual references the 2013 FEC and the National 

Treasury Employees Union (NTEU) Labor Management Agreement (LMA).5

 However, the 

referenced policy, Article 33 §4 (B) of the LMA, states:

Within ten (10) workdays of returning from travel, employees must submit their travel voucher.

The LMA conflicts with the Federal Travel Regulations § 301–52.7 and is inconsistent with 

the guidance provided in the FEC Travel Manual. During the course of this review, the OIG 

communicated this inconsistency with agency leadership and leadership intends to address the 

issue during future negotiations with the NTEU. 

As documented in Appendix 2, the testing for timely submission of TVs indicates the net 

working days between the traveler's return from travel and the submission of the travel vouchers 

to the AO ranges from 5 to 72 days. 

Recommendation 2: That the agency negotiate with the NTEU to update the LMA to 

include the travel voucher requirements documented in Federal Travel Regulations § 301–52.7. 

Recommendation 3: That the agency monitor that the travel voucher is submitted 

according to FTR § 301-52.7. 

C. AO Approval by Subordinates

The Staff Director is responsible for approving open travel authorizations for Commissioner 

travel. GSA SmartPay Travel Training (Account Holders/AOs)6 states in pertinent part:

An Approving Official is able to act independently. For example, an employee should not be the 

Approving Official for a supervisor. This type of arrangement may put the employee in a 

compromising position and jeopardize their role as an Approving Official. 

Recommendation 4: That the agency evaluate whether the current travel oversight for the 

Commissioners and other senior leaders is appropriate.

5 The Federal Election Commission and the National Treasury Employees Union, Labor Management Agreement

Between the Federal Election Commission and the National Treasury Employees Union, 2013

6 GSA SmartPay Travel Training (Account Holders/AOs), pg. 27

4 
D. Policy update

The agency's procurement policy was last updated in 2010, while the travel policy was last 

revised in 2015. These policies still reference the previous contractor for charge cards, even 

though their services ended with the FEC in 2019. 

Furthermore, the procurement policy makes mention of the agency's previous procurement 

system, which was replaced on August 2, 2021. All purchase requests are routed through the new 

system as of August 9, 2021. 

Recommendation 5: That the agency take action to update and finalize the travel policy, 

travel manual, and procurement office policies and procedures. 

Conclusions

Based on our analysis, it is recommended that the agency revise its policies, including the 

LMA, to better align with the training provided in GSA SmartPay Travel and Purchase Training, 

OMB A-123, Appendix B, and FTR. This alignment is necessary to ensure cardholders and AOs 

complete the required training and maintain proper documentation. It will also provide 

employees with consistent guidance and facilitate timely travel voucher processing. 

Furthermore, it was observed that the span of control for AOs overseeing commissioner travel

might not align with the recommendations outlined in GSA SmartPay Training. The agency should 

reassess the responsibilities of AOs and evaluate the current oversight of travel for the commissioners 

and other senior leaders as appropriate. If you have any questions regarding this report, please contact

the OIG. 

Summary Table of Recommendations

Recommendation # Recommendation Details

1

That the agency follows the general purchase card training requirements from OMB 

A-123, Appendix B, and GSA SmartPay guidelines to ensure all program participants

have completed training requirements and maintain training certifications as required.

2

That the agency negotiate with the NTEU to update the LMA to include the travel

voucher requirements documented in the Federal Travel Regulations § 

301–52.7.

3 That the agency monitor that the travel voucher is submitted within five working days

according to FTR § 301-52.7.

4

That the agency evaluate whether the current travel oversight for the Commissioner is 

appropriate.

5

That the agency update and finalize the travel policy, travel manual, and procurement 

office policies and procedures.

cc: The Commission

5 
Appendix 1 - Pages 8-9 of the FEC Travel Manual

Fedel'lll Elecffoo Commll Tnvd Mawual FY :1015 

C. Deputy St.ff Direciors/Chi:e;f Officers. Authorizing Official II fhority IllllY be delepted w Assii!Jmt Staff 

Direcloni/Directors (L1a., one SllJlefVlSOry level below th£ SE11ior level). 

D. Ge11eral Counsel, Deputy General Counsel, and Associate Gene:ral C<iunsels. Aulh.orizing Official aulh.ority 

maybe delegated to Assistant General Cou11sels (i.e., one supervisory revel below the senior level). 

E. mspector General (JO), Deputy IO and Counsel to them. The Counsel to the JO is the back-up official to 

the O and Deputy IO. 

F. ChlefFlill8llcial Offi0Er. Authorizmg Official authority may be dcle.ga.ted to Division IIIJd Office eadli (i.e.., 

one supervisory level below the senior level). 

4,6 OCFO Respon11bllltle11 

The F"mance Division and Budget Office are respollSible for reviewing the Travel Authorimrioo for completeness, 

accuracy, and oompliance w:ilh the FTR. md FEC poUcies. The offices nolify lhe authori.n_ng or approving official 

within the n:spc,ctivc program office if there att any i!lsucti with travel doowncobltion submitted for prooCl'liS:inQ. The 

Budget Office obligates funds approved on each TA and de-obligates funds: for any· ,~llatlons. 

A. Travel Examiner in 11te Fill81l.Cc Division must: 

1. Provide the TA number to the traveling employee to ensure that the, T!llvel Management Connctor bacs 

fuc appropri11te authorization number to directly charge the CBA for lravel '8ffll11gcmcnts. 

2. Review TVs to ensure that a.U ela.itllll me in a.coorda.nee with lhe TA, expenses claimed me properly 

supported by original receipts, and. the cxpaiscs arc in a.ccotdancc with the FTR. 

3. Contact. the 1mveler for BIi)' additional infummtion or docume11tatio11 to facilitate pmci:ssing th.c 1V fur 

payment. 

4. Verify that the TV i8 adequately 9upported by tb.e TA,. original receipts, and appropriate signatures for 

review md approval. 

S. Prep transmitfllls for TA.s and TVs for bmission to the F'msncial Manageme11t External Servic 

Provider (ie. Federal Shared SlilI'Vice Provioo) for processing. 

ote: The baclr-up Tttvel Exru:ninc:r is the Fimmcilll An11lyst/Special Assistant. 

B.. Authorized Ctttifying Official must: 

L Verify that the TVs !bot, erossfuot ilil.d CQiltain appropriate signatures for review and approval 

2. Review and approve TV transmitta!s priw 10 submission to the Financial Manage~nt Federal Shared 

Service Provider ,(FSS'P), for proce&Sing. 

Note; he Authorized. Certifying Offici~s aTI: either the Financial Analyst in tbe Budget Office or another Special 

Assistant to the CFO'Fina.nclal Analyst in the Finance Division. 

To lmliun:: ~ segrcgathm of duties a FinB1Dci11l Alllllyst acting 11!1 the Tuvel ExmniDllr cl!llll.ot cmfy TVs. A 

different Financi al. Analyst who is an 11pprovw. Certifying Officer that ~ not acted in the role of the Trn .I 

Examiner may am,rove Travel Vouchers. 

4,7 .Em.pl°"ec Traveler 

The employee traveler is required to: 

• Submit Travel Authorization prior to eOODDCDccmcnt of travel. 

• File Travel Voucher with requiled receipts, within five days of completion of the trip. 

PagcSof52 
 

f edernl El,ctiou Commission Trnnl i\fauual FY 2015 

4. 7.1 Initiating Employee Travel 

TI1e employee is respollSll>le for malting all travel arrangements, preparing appropriate travel dommentation, and 

submitting documentation for approval and reimblll'Sement TI1e following steps are set out to assist 1he employee 

,vi1en prejllring to travel Employees will: 

1 Make travel arrangements {transportation, hoteL and rental rar reservations) with the TMC/Travel 

Agent. 

2. Prepare the Travel Authorization (GSA Fonn 87) and submit it to the supervisor andfor Autho1izing 

Official {AO) for their signatm-e {block 25A). Note: The AO (generally the employee's in1mediate 

supenisor) is respollSll>le for 1-eviewing and approving TAs to eruure that the travel is oonsistent with 

the mission of the office and that 1he oosts n in line with the office's travel budget. The AO may 

change/ 0011-ect any portion of the TA that does not adhere to the FTR. 

l Submit the signed TA to the Finance Division before the cl.te of travel Note: TI1e Finance Division 

will review the TA and approve funds associated ,vith 1he scheduled trip. The Travel E.xaminer will 

notify the employee that they may oonfi1111 all travel ammgements with the TMC/ fravel Agent. 

4. Manage travel card d1arges and travel advance funds, i fl-eceived, in acoordance ,vith the FTR. 

5. Keep all original 1-eceipts for transportatio1~ lodging. and any expellSle of$75.00 or more. 6. Prepai-e a Travel Voucher {SF 1012) \\11hin five days alter the tra,-el bas been oompleted and submit it 

to the Finance Division for approval with original receipts { e.g. ailiine, hoteL taxi, parking, o· any other 

nliscellaneous expenses) to receive reimbursement 

7. When canceling an approved trip, innnediately notify the Travel E.xaminer via e-mail with a oopy to 

Iris/her supenisor. The Finance Division ,viU de-obligate 1he travel flmds based on the e-mail 

a When malting dianges that altet· a1 approved TA {dates, hoteL oonm1on carrier, costs, etc ... ), subnlit a 1 

aniended TA. If tlie oosts 011 the 01iginal travel plan increase o· clea-ease, only the diffe1-ence in costs 

sbo1dd be reflected 011 tlie 1-evised TA {block 20). 

9. If a tra,-el advance is necessary, p1-epare a request. and submit it wih the TA. Travel advance flmds n 

autho1ized at. ffi percent of the total of tlie employee's nieals and incidental expenses phis other 

estimated costs { e.g., taxi f.u-es). Lodging oosts sbo1dd not be induded in the travel advance 

calculations. Once approved, travel advance flmds are electrorucally deposited into the traveler's bank 

acoo1mt 

4.8 Pre-Employment Interview Travel 

TI1e FE C may cover tlie oosts of pre-employment interviews if it is detennined to be in the best inte1-est of tlie 

govel11ll1ent The FE C authorizes the follo,ving pre-employment travel interview expenses: 

Transportation expenses as provided in FTR § 301-10; 

Pa· diem expenses as provided in FTR § 301-11; 

Miscellaneous expenses as provided in FTR § 301-12; and 

Travel expenses ofai individual \\1th a disability o· special 1ieed as provided in FTR § 301-13. 

2The fEderal ElectlOn Commission and The National Treasury Employees UnfOn, taborMonogemenr Agreement Benveen the Federal 

E/ectio1, Comm;ssion and The Nor;onal Treasury Empl,,yees Union, 2013, 137. 

hnp:/(fecnetfec,,gav{hr/empresources{lma/2013LaborManagementAgreement.pdf, 

Page9ofS2 
Appendix 2 – Review and Timelines of Sampled Travel Vouchers

Document 

Number Amount

TA 

return 

date 

TV 

Traveler 

signature 

date

TV AO 

signature 

date 

# of workdays 

between traveler's 

return and 

signature on TV

# of workdays 

between traveler's 

return & AO 

Approval of TV

FE22T013 $3,965.62 5/7/2022 5/13/2022 5/16/2022 5 6

FE22T014 $2,158.15 5/6/2022 5/23/2022 5/23/2022 12 12

FE22T003 $2,500.00 11/8/2021 2/15/2022 2/16/2022 72 73

FE22T015 $1,929.79 7/20/2022 7/29/2022 8/2/2022 8 10
MEMORANDUM

TO: Christopher Skinner, Inspector General 

FROM: John Quinlan, CFO 

Pam Jones, Procurement Director

James Gerber, Budget Director

DATE: August 18, 2023 

SUBJECT: Management Response to the Inspector General’s Special Review (23-02) of the 

FEC Travel and Purchase Card Programs 

We appreciate the Office of the Inspector General's (OIG) review of the FEC's travel and 

purchase card programs. We acknowledge and largely agree with the recommendations outlined 

in the review. Our comments are focused on recommendations three and four. 

Recommendation three states “[t]hat the agency monitor that the travel voucher is submitted 

according to FTR § 301-52.7.” FTR § 301-52.7 advises employees to submit travel vouchers 

within five working days after completing their trips. 

While we support the notion of monitoring voucher submissions, we interpret this regulation as 

placing an obligation on employees who travel, rather than the agency. The context of the travel 

regulation itself, presented in response to a hypothetical traveler's question, reinforces our 

perspective. Furthermore, we have not come across supplemental travel regulations or 

implementing guidelines from other agencies that outline procedures for agencies to follow or 

potential consequences for travelers for failing to submit vouchers within five working days. As 

a result, we generally consider submitted vouchers as payable expenses, even if they are 

submitted after the specified timeframe.

Recommendation four states “[t]hat the agency evaluate whether the current travel oversight for 

the Commissioners and other senior leaders is appropriate.” This recommendation arose because 

the Staff Director, who is subordinate to the Commission, signs travel authorizations for FEC 

Commissioners. After undertaking an evaluation per this recommendation, we intend to maintain 

the current process.
The existing arrangement offers distinct advantages. For instance, it upholds the independence of 

individual Commission offices. Additionally, in most instances, Commissioner travel is typically 

circulated to the full Commission on an informational basis to enhance transparency (and in 

certain cases travel is circulated for Commission vote on a no-objection basis). The Staff 

Director’s placement outside the Office of the Chief Financial Officer also effectively separates 

the travel approval function from the payment function, thus fortifying safeguards against 

potential misuse. Considering this evaluation, we request that the OIG consider closing this 

recommendation.

Thank you once again for your comprehensive review, and we remain committed to 

implementing appropriate measures to enhance our travel and purchase card programs.