U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Hotline Report 

Review of 

Hotline Complaint 2010-282 

 Report No. 10-P-0165 

 July 15, 2010
 
Report Contributors: Bram Hass 

 Eric Lewis 

Abbreviations 

EPA U.S. Environmental Protection Agency 

FLETC Federal Law Enforcement Training Center 

FTR Federal Travel Regulations 

IAG Interagency Agreement 

OIG Office of Inspector General 

OPE Office of Program Evaluation 
 

 

 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

July 15, 2010 

MEMORANDUM 

SUBJECT: Review of Hotline Complaint 2010-282 

 Report No. 10-P-0165 

FROM:	 Wade T. Najjum 

Assistant Inspector General 

Office of Program Evaluation 

TO:	 Arthur A. Elkins, Jr. 

 Inspector General 

This is a final Hotline report on the subject evaluation conducted by the Office of Program 

Evaluation (OPE), Office of Inspector General (OIG) of the U.S. Environmental Protection 

Agency (EPA). This report contains findings that describe the problems OPE has identified 

and corrective actions OPE recommends. This report represents the opinion of OPE and does 

not necessarily represent the final OIG position. Final determination on matters in this report 

will be made by the Inspector General in accordance with established audit resolution 

procedures. The Inspector General provided comments to our draft report. OPE evaluated 

these comments and, where appropriate, made necessary changes in this report. We have 

included the response in Appendix A. 

The estimated cost of this report – calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rates in effect at the time – is $74,077. 

Action Required 

In accordance with EPA Manual 2750, EPA’s Audit Management Process, you are required to 

provide a written response to this report within 90 calendar days. OIG’s response should include 

a corrective action plan and planned completion dates for the Recommendations. Your response 

will be posted on the OIG’s public Website, along with our comments on your response. Your 

response should be provided in an Adobe PDF file that complies with the accessibility 

requirements of section 508 of the Rehabilitation Act of 1973, as amended. If your response 

contains data that you do not want to be released to the public, you should identify the data for 

redaction. We have no objection to the further release of this report to the public. This report 

will be available at http://www.epa.gov/oig. 
If you or your staff have any questions regarding this report, please contact me at (202) 566-0832 

or najjum.wade@epa.gov, or Eric Lewis at (202) 566-2664 or lewis.eric@epa.gov. 
 

 

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Allegation 

The OIG reviewed an anonymous Hotline allegation that an EPA OIG employee was 

defrauding the government by staying in a hotel instead of using less expensive and 

available accommodations at a government training location. The complainant stated that 

the employee said he received a waiver for personal reasons. The complainant stated that 

others have to use the most reasonable accommodations for the government and 

questioned why other OIG employees have to stay on site when the employee in question 

did not. 

Finding 

We could not substantiate the allegation of fraud; however, the actions of the employee 

and his supervisor were contrary to existing travel policies and were unnecessarily costly. 

This was a waste of government funds. The employee traveled to the training located at a 

government facility, the Federal Law Enforcement Training Center (FLETC). Training 

program costs at FLETC include tuition, lodging, and meals. The employee in question 

opted not to use government-furnished lodging and meals at the facility for personal 

reasons. The supervisor authorized commercial lodging and per diem for meals for his 

subordinate, even though the government would not benefit from the increased lodging 

and meal costs. The employee submitted and the supervisor approved a travel voucher 

totaling $2,003. 

Criteria 

The Federal Travel Regulations (FTR) emphasizes that agencies may only pay expenses 

that are essential to the transaction of official business. The FTR provides for reduced 

reimbursement when meals are furnished by the government. EPA’s Resources 

Management Directive 2550B (Travel Manual) describes the responsibilities of the 

traveler and supervisor. Travelers are responsible for: 

•	 Becoming familiar with the FTR and EPA’s travel policies so they can properly 

claim reimbursement for authorized travel. 

•	 Seeking clarification from supervisors or financial staff when needed. 

•	 Exercising prudence and economy when incurring expenses on official travel. 

•	 Paying for additional expenses resulting from scheduling travel for personal 

convenience. 

Supervisors are responsible for: 

•	 Providing employees access to the Travel Manual and other travel regulations, as 

well as giving them an opportunity to review these requirements before traveling. 

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•	 Ensuring sound financial management of all aspects of official travel, and 

ensuring that travel is in the best interest of the government. 

•	 Applying the standards of the travel regulations when authorizing, reviewing, and 

approving travel documents. 

The Interagency Agreement (IAG) that sets up a reimbursable agreement between EPA 

OIG and FLETC lists projected costs for a number of training courses. The estimated 

per-student cost for each course at FLETC’s Glynco, Georgia, location includes lodging 

and meals. FLETC policy is to provide lodging to all students unless a waiver is granted 

by the student’s agency representative. The lodging is located either on FLETC’s 

campus or in contracted hotels or apartments nearby. Reporting instructions e-mailed to 

students have a link to the online Student Bulletin, which states that: 

“If a student uses housing other than assigned by FLETC, the costs incurred for 

the accommodations will be the responsibility of the student and not 

reimbursable by their agency. The student will be notified to utilize the housing 

assigned by FLETC.” 

FLETC Manual 72-01.A, Housing Policies, states that all students must use FLETC 

housing. The housing manual also states that both basic and advanced students 

requesting housing not covered by the manual must obtain a written waiver from their 

agency representative, who should route the written request to the housing office. The 

manual does not specify who must approve the waiver. Additionally, as stated in the 

Student Bulletin, the student’s agency will not reimburse the student when the student 

stays in other than FLETC assigned housing. 

Background 

FLETC is one of the OIG’s key training providers, offering many advanced courses in 

addition to basic-level training. FLETC provides interagency law enforcement training to 

about 90 federal agencies. It is headquartered in Glynco, Georgia. The OIG’s 2010 

Fiscal Year IAG with FLETC lists 15 courses that include lodging and meals, including 

the one attended by the student in this case. 

Scope and Methodology 

We conducted our review from February 2010 to May 2010 in accordance with 

generally accepted government auditing standards. Those standards require that we 

plan and perform our review to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based on our objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings and conclusions 

based on our objectives. 

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To accomplish our objectives, we reviewed the FTR, the Agency’s Travel Manual, and 

relevant FLETC policy. We conducted interviews with and obtained information from 

OIG employees involved with the travel arrangements and course. We also obtained and 

reviewed the OIG’s current IAG with FLETC listing the courses and anticipated costs for 

fiscal 2010 and billing information for the course in question. 

Results 

We found that the OIG employee attended the training course at FLETC and did not 

lodge or eat meals at FLETC. Tuition for the course the employee attended at FLETC 

included government-furnished lodging ($427) and meals ($171) totaling $598. The 

estimated total cost to OIG for tuition, lodging, and meals should have been $1,091. The 

employee’s travel voucher was submitted and paid for $2,003, which included $1,840 in 

additional expenses consisting of: 

•	 $1,188 for lodging, 

•	 $510 for meals and incidental expenses, and 

•	 $142 for hotel tax. 

FLETC e-mailed the OIG employee notifying him that he had been accepted into the 

class. The e-mail included a link to the FLETC Student Bulletin. The employee 

contacted an OIG resident agent assigned to FLETC and notified him in an e-mail 

message that he had finalized details for the trip, was staying off base, and would not 

need FLETC lodging. The OIG resident agent sent an e-mail to the FLETC Housing 

Program Manager as a waiver under the FLETC policy. The OIG resident agent stated 

that this e-mail met the FLETC policy’s requirement for a written waiver. Further, the 

OIG resident agent stated that immediately after contacting the housing office he sent the 

employee an e-mail informing him that advanced students normally stay in FLETCprovided housing because it is considerably less expensive. He also told the student that 

FLETC policy requires agency management approval, which he assumed was obtained, 

based on the student’s e-mail and telephone message. The OIG employee told us that: 

•	 When he learned that he was going to training at FLETC, he was not initially 

aware there was a requirement to stay on base as part of the training. His 

supervisor authorized staying off site. 

•	 He had not seen the notification memo until days before he was scheduled to 

depart because he had limited access to his e-mail while on travel status. 

•	 He was told by the FLETC registrar that if he stayed off site, FLETC would credit 

EPA OIG for the usual lodging and meal charges. 

•	 He believed it did not make sense to require someone his age to obtain a waiver to 

stay off site instead of in the barracks and that for any future training, he would be 

willing to pay out of his own pocket for off-site lodging. 

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It is apparent that the employee had received notification prior to beginning the travel that 

students were required to stay in government-furnished lodging that is less costly for the 

government. The OIG resident agent specifically informed the employee that not using 

government-furnished quarters required agency approval and a waiver provided to 

FLETC. Based on the student’s assertions, the OIG resident agent notified FLETC that 

an exemption was needed. Although FLETC does not require a formal written letter or 

memo from the student’s supervisor or upper management, we believe the resident agent 

should have verified the student’s assertions with EPA OIG management in light of the 

expected additional cost that would result. We believe that granting the waiver without 

verification was a mistake. Since the OIG resident mistakenly notified FLETC that there 

was an agency waiver, FLETC will not bill EPA OIG for the $598 cost of governmentfurnished lodging and meals. 

Although the employee’s supervisor approved the travel orders, the supervisor stated he 

was unaware that using the government lodging at the training center was mandatory for 

advanced training. He instructed the employee to stay at a hotel because a hotel was 

authorized and approved for the supervisor when he attended FLETC in 2008 and on 

other occasions. The employee’s supervisor said he was not aware that other OIG agents 

attending advanced training stayed on campus.1 The supervisor believes that the 

employee may have shared with him what the OIG resident agent at FLETC told him 

about the requirement to use government-furnished lodging and about the waiver, but did 

not recall the specifics. He did not initiate any process to issue the agent a waiver to stay 

off campus because a waiver had never been required for the supervisor to stay off 

campus. He considered the separate hotel accommodations acceptable based on his own 

past experience. He said he did not realize that off-campus lodging and meals 

contradicted any aspect of the government’s best interest. 

Conclusion 

In our opinion, the employee’s and supervisor’s actions resulted in wasted public funds. 

Travel choices were not in accordance with the FTR and the EPA Travel Manual. The 

travel was not conducted in the best interest of the government and was unnecessarily 

expensive. The EPA Travel manual states that travelers have the responsibility to 

become familiar with the FTR, minimize the cost to the government, seek advice from 

supervisors or financial personnel, and bear the additional expense for personal travel. 

The employee, even after being cautioned by the OIG resident agent, decided not to use 

government-furnished lodging and meals for strictly personal reasons. Both the 

supervisor and the employee contend that their actions were consistent with their past 

practices. Neither could provide other than personal justifications. Both failed to 

exercise fiscal responsibility, making travel choices that were contrary to existing travel 

policies and resulted in additional costs. The OIG should issue policy guidance stating 

1

 FLETC policy requires basic students to stay in FLETC facilities on campus; it also requires advanced 

students to obtain lodging through FLETC. Those accommodations may be on the FLETC campus itself or 

in facilities contracted by FLETC. Those costs are included in the cost of the course. 

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that OIG policy is to use government lodging and meals at FLETC and will only be 

waived with approval of the cognizant AIG. 

Recommendations 

We recommend that the Inspector General: 

1.	 Take appropriate administrative actions against the individuals involved. 

2. Direct the employee and his supervisor to obtain appropriate federal travel 

training. 

3.	 Issue policy guidance stating that OIG policy is to use government lodging 

and meals at FLETC and will only be waived with approval of the cognizant 

AIG. 

Comments on Draft Report and OPE Evaluation 

The Inspector General generally agreed with our findings, conclusions, and 

recommendations but proposed several changes. We agreed with those changes and 

incorporated them into this final report. 

He believed that the central issue described was the additional cost to the government, 

which could be better characterized as waste instead of abuse. He believed that one of 

the draft conclusions and the related recommendation (requiring travelers to get waivers 

from the OIG Planning, Analysis, and Results staff with their supervisor’s permission), 

was too broad. He suggested and we agreed that the recommendation should require a 

policy setting the ability to grant waivers of the requirement to use FLETC-furnished 

lodging at the AIG level. 

On the first draft recommendation, the Inspector General believed that the proposed 

corrective action (to direct the Planning, Analysis, and Results staff to obtain 

reimbursement of the excess funds paid to the employee) was too narrowly worded. 

Instead, he suggested and we adopted the current recommendation, to take appropriate 

administrative actions against the individuals involved. 

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Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Planned 

Rec. Page Completion Claimed Agreed To 

No. No. Subject Status1 Action Official Date Amount Amount 

1 5 Take appropriate administrative actions against the O 

individuals involved. 

2 5 Direct the employee and his supervisor to obtain O 

appropriate federal travel training. 

3 5 Issue policy guidance stating that OIG policy is to O 

use government lodging and meals at FLETC and 

will only be waived with approval of the cognizant 

AIG. 

1	 O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is undecided with resolution efforts in progress 

Inspector General 

Inspector General 

Inspector General 

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 10-P-0165 

Appendix A 

Formal Response to Draft Report 

July 9, 2010 

MEMORANDUM 

SUBJECT: Formal Response to Draft Report on Hotline 

 Complaint 2010-282 

 Project No. OPE-FY 10-0013 

TO: Wade T. Najjum

 Assistant Inspector General 

 Office of Program Evaluation 

This is the formal response to the subject review by the Office of Program 

Evaluation. I agree with the factual presentation, conclusion and recommendations made 

in the report as amended by my formal comments. 

Comment 1: Finding 

OIG agrees with the finding, but suggests that the central issue is the additional 

cost to the government of this travel. That condition could be characterized as waste 

rather than abuse. 

Comment 2: Conclusion: 

OIG agrees with the conclusion, but believes the recommendation, as stated, is 

too broad for the conditions described in the report. OIG suggests a policy requiring the 

use of government furnished quarters and lodging at the FLETC facility. The policy 

should establish that waiver of that requirement may only be granted by the cognizant 

Assistant Inspector General. 

Comment 3: Recommendation 1 

OIG believes the corrective action is too narrowly worded. OIG suggests an 

alternative recommendation: Inspector General to take the appropriate administrative 

actions against individuals involved. 

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Comment 4: Recommendation 3 

As discussed in the conclusions OIG suggests an alternate recommendation: Issue 

policy guidance stating that OIG policy is to use government lodging and meals at 

FLETC and will only be waived with approval of the cognizant AIG. 

Arthur A. Elkins, Jr. //s// 

cc: Bill Roderick, Deputy Inspector General 

Mark Bialek, Counsel, OIG 

 Eric Lewis, Director for Program Evaluation, Special Reviews 

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