GENERAL 

SERVICES 

ADMINISTRATION

GSA Should Clarify Its 

Reporting Exemption 

and Collect Additional 

Data on Executives’ 

Use of Aircraft for 

Nonmission Purposes

Report to the Ranking Member, 

Committee on the Judiciary, 

U.S. Senate

February 2014

GAO-14-151

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-151, a report to the 

Ranking Member, Committee on the Judiciary, 

U.S. Senate

February 2014

GENERAL SERVICES ADMINISTRATION 

GSA Should Clarify Its Reporting Exemption and 

Collect Additional Data on Executives’ Use of 

Aircraft for Nonmission Purposes

Why GAO Did This Study

The federal government owns or 

leases over 1,700 aircraft to 

accomplish a wide variety of missions. 

Federal agencies are generally 

required to report trips taken by senior 

federal officials on their aircraft to GSA 

unless the trips are classified pursuant 

to executive branch requirements. In 

February 2013, GAO reported on DOJ

senior executives’ use of DOJ aviation 

assets for nonmission purposes for 

fiscal years 2007 through 2011. GAO

identified several issues with respect to 

the implementation of a provision of 

GSA regulations that exempts 

intelligence agencies from reporting 

information about government aircraft 

to GSA and that provision’s application 

to unclassified data on senior federal 

official travel for nonmission purposes. 

GAO was asked to review GSA’s 

oversight of executives’ use of 

government aircraft for nonmission 

purposes. This report addresses the 

extent to which (1) GSA’s reporting 

exemption for intelligence agencies is 

consistent with executive branch 

requirements and (2) GSA ensures the 

accuracy of its reporting on the use of 

government aircraft by senior federal 

officials. GAO reviewed relevant 

executive branch requirements and 

GSA regulations, as well as data 

submitted by DOJ to GSA on trips 

taken by senior federal officials on DOJ 

aircraft and interviewed GSA officials.

What GAO Recommends

GAO recommends that GSA identify 

the basis of its reporting exemption, 

and collect additional information when 

travel is not being reported. GSA 

concurred and identified actions to 

address our recommendations.

What GAO Found

The exemption in General Services Administration (GSA) regulations that allows 

intelligence agencies not to report unclassified data on senior federal official 

travel for nonmission purposes is not consistent with executive branch 

requirements, and GSA has not provided a basis for deviating from these 

requirements. Specifically, executive branch documents—including Office of 

Management and Budget (OMB) Circular A-126, OMB Bulletin 93-11, and a 1993 

presidential memorandum to the heads of all executive departments and 

agencies—require agencies to report to GSA, and for GSA to collect data, on 

senior federal official travel on government aircraft for nonmission purposes, 

except for trips that are classified. As a result, GSA is not collecting all specified 

unclassified data as directed, and GSA has not provided a basis for deviating 

from executive branch requirements. Identifying an adequate basis for the 

intelligence agency reporting exemption or removing the exemption from its 

regulations if a basis cannot be identified could help GSA ensure its regulations 

for senior federal official travel comply with executive branch requirements.

GSA aggregates data on senior federal official travel to create publically available 

Senior Federal Official Travel Reports that, among other things, provide 

transparency of senior federal officials’ use of government aircraft. However, 

GSA does not determine which agencies’ travel is not reported under the 

exemption for intelligence agencies. For example, in February 2013 GAO found 

that the Federal Bureau of Investigation (FBI)—which is a member of the 

intelligence community—did not report to GSA, based on the intelligence agency 

exemption, information for 395 unclassified nonmission flights taken by the 

Attorney General, FBI Director, and other Department of Justice (DOJ)

executives from fiscal years 2009 through 2011. However, GSA’s Senior Federal 

Official Travel Reports GAO reviewed for those years provided information on 

flights for other DOJ components but did not indicate that additional flights may 

have been omitted on the basis of GSA’s exemption for intelligence agencies. 

GSA senior officials stated that they do not collect this information because they 

do not distinguish between instances where an agency reports no information 

because it is invoking the exemption or some other reason, such as that no 

flights were taken on its aircraft. However, these officials also stated that it could 

be possible to obtain follow-up information from agencies that did not provide 

travel data in order to determine why agencies had not reported data. Consistent 

with Standards for Internal Control in the Federal Government, if GSA collected 

additional information from agencies on instances where nonmission travel was 

not reported because of the exemption for intelligence agencies, as opposed to 

some other reason, and included such information in its reports, it could help 

GSA ensure the accuracy of its Senior Federal Official Travel Reports.

View GAO-14-151 . For more information, 

contact, David C. Maurer at (202) 512-9627 or 

:maurerd@gao.gov.
Page i GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

Letter 1

Background 4

GSA’s Intelligence Agency Exemption for Reporting Senior 

Federal Official Travel for Nonmission Purposes Is Inconsistent 

with Executive Branch Requirements, and GSA Has Not 

Identified a Basis for the Exemption 8

GSA Does Not Identify Which Agencies Do Not Report Senior 

Federal Travel Data as a Result of the Intelligence Agency 

Exemption, Which Limits the Accuracy of Its Reports 10

Conclusions 11

Recommendations for Executive Action 12

Agency Comments 12

Appendix I Comments from the General Services Administration 14

Appendix II GAO Contact and Staff Acknowledgments 16

Table Table 1: Summary of Selected Provisions of the General 

Services Administration’s (GSA) Regulations Related to 

Senior Federal Official Travel 6

Contents
Page ii GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

__________________________________________________________

Abbreviations

AAIRS Aircraft Accident Incident Reporting System

DEA Drug Enforcement Administration

DOJ Department of Justice

FAIRS Federal Aviation Interactive Reporting System

FBI Federal Bureau of Investigation

FMR Federal Management Regulation

FOIA Freedom of Information Act

FPMA Federal Property Management Regulation

FTR Federal Travel Regulation

GSA General Services Administration

ICAP Interagency Committee for Aviation Policy

OMB Office of Management and Budget

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Page 1 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

441 G St. N.W.

Washington, DC 20548

February 28, 2014

The Honorable Charles E. Grassley

Ranking Member

Committee on the Judiciary

United States Senate

Dear Senator Grassley:

The federal government owns or leases over 1,700 aircraft to accomplish 

a wide variety of missions that include the management of natural 

resources, fire fighting, research and development, and law enforcement. 

These aircraft play a critical role in supporting agencies’ mission-related 

responsibilities and operations. In addition, federal agencies use 

government aircraft to transport certain executives for travel other than for 

mission purposes.

The Office of Management and Budget (OMB) and the General Services 

Administration (GSA) established requirements for federal agencies 

regarding the use of government aircraft, including executive travel on 

these aircraft. OMB Circular A-126 sets forth requirements for agencies’

use of government aircraft, including the types of travel that are 

appropriate and that travelers reimburse the government for use of these 

aircraft for certain nonmission purposes.1 According to the circular, 

agencies may use their aircraft only for official purposes and must report 

semiannually to GSA each use of such aircraft for nonmission travel by 

senior executives.2

 1 Office of Management and Budget, Executive Office of the President, OMB Circular No. 

A-126, Improving the Management and Use of Government Aircraft (Washington DC: May 

22, 1992). Government aircraft means any aircraft owned, leased, chartered, or rented 

and operated by an executive agency. Examples of nonmission travel include official 

travel to give speeches, attend conferences or meetings, or make routine site visits.

GSA issued the Federal Travel Regulation (FTR), 

which also requires federal agencies to report on the use of their aviation 

assets, including executive travel. These provisions include the 

presumption that travel by common air carrier is the most advantageous 

2 In addition, 31 U.S.C. § 1344 provides that agency funds may be expended only for the 

maintenance, operation, or repair of any passenger carrier to the extent that the carrier is 

used to provide transportation for official purposes. According to OMB Circular A-126, 

official travel means (1) travel to meet mission requirements, (2) required use travel, and 

(3) other travel for the conduct of agency business.
Page 2 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

method of transportation and must be used when reasonably available.3

GSA regulations provide that taxpayers should pay no more than 

necessary for the transportation and that travel on government aircraft 

may be authorized only when a government aircraft is the most cost 

effective mode of travel.4 In addition, agencies may not determine that 

another mode of transportation is more advantageous on the basis of 

personal preference or inconvenience to the traveler.5

In February 2013, we issued a report on the Department of Justice (DOJ) 

senior executives’ use of DOJ aviation assets for nonmission purposes 

for fiscal years 2007 through 2011.6

You asked us to review GSA’s oversight of executives’ use of federal 

government aircraft for nonmission purposes, including the reporting of 

these data to GSA. This report addresses the following questions: (1) To 

what extent is GSA’s exemption for intelligence agencies to report senior 

federal official travel for nonmission purposes consistent with executive 

branch requirements? (2) To what extent does GSA ensure the accuracy 

of its reporting on senior federal official use of government aircraft?

In the course of our review, we 

identified several issues with respect to the implementation of GSA 

reporting requirements under its FTR and Federal Management 

Regulation (FMR). The issues related to a provision of GSA regulations 

that exempts intelligence agencies from reporting information about 

government aircraft to GSA and that provision’s application to unclassified 

data on senior federal official travel for nonmission purposes.

To address these questions, we reviewed executive branch requirements 

related to the reporting of senior federal official travel, such as OMB 

 3 FTR §§ 301-10.5(a), 301-70.101(b). The GSA regulations also pertain to common carrier 

travel by rail and bus as the most advantageous modes of transportation.

4 FTR § 301-10.260; see also FTR § 301-70.800. 

5 FTR § 301-70.101(b).

6

GAO, Department of Justice: Executives’ Use of Aircraft for Nonmission Purposes, 

GAO-13-235 (Washington, D.C.: Feb. 26, 2013). Senior federal officials are persons 

employed at the Senior Executive Service level or above, and include presidential 

appointees, but for purposes of OMB Circular A-126, do not include active duty military 

officers.
Page 3 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

Circular A-126, and we reviewed GSA regulations.7 We also reviewed 

GSA regulations and associated Federal Register notices from 1992—

when the definition of “intelligence agencies” was first added to GSA 

regulations—to 2012 to determine whether GSA provided a rationale for 

the exemption for intelligence agencies to report information about 

government aircraft. We reviewed information from our February 2013 

report including information provided to us by the Federal Bureau of 

Investigation (FBI), the Drug Enforcement Administration (DEA), and 

GSA, as well as data submitted by DOJ to GSA on trips taken by senior 

federal officials on DOJ aircraft for fiscal years 2007 through 2011.8 To 

obtain GSA’s views on the authority for the exemption, its scope, 

rationale, and applicability to nonmission senior federal travel, as well as 

steps GSA takes to help ensure the accuracy of its reporting of such 

travel data, we reviewed information provided by the Acting GSA 

Administrator and interviewed senior GSA officials responsible for 

collecting data about senior federal official travel.9 We compared the 

information GSA officials provided to us and GSA regulations with 

executive branch requirements and Standards for Internal Control in the 

Federal Government.

10

We conducted this performance audit from June 2013 to February 2014 

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.

 7

The executive branch documents we identified are described as guidance and instruction 

to agencies, government-wide policy guidance, as well as guidance generally. Each 

document contains requirements for federal agencies, and for purposes of this review, we 

refer to the documents collectively as executive branch requirements.

8

More information about the scope and methodology, including the data we reviewed, can 

be found in GAO-13-235.

9

The then acting administrator for GSA was sworn in as Administrator on July 5, 2013.

10GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1, 1999).
Page 4 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

OMB Circular A-126 sets forth executive branch policy with respect to the 

management and use of government aviation assets.11

• Travel to meet mission requirements: Mission requirements are 

defined as “activities that constitute the discharge of an agency’s 

official responsibilities,” and the circular provides examples of these 

kinds of activities.

The purpose of 

the circular is to minimize cost and improve the management of 

government aircraft. The circular provides that government aircraft must 

be operated only for official purposes. Under the circular, there are three 

kinds of official travel:

12 For purposes of the circular, mission 

requirements do not include official travel to give speeches, attend 

conferences or meetings, or make routine site visits.

• Required use travel: Agencies are permitted to use government 

aircraft for nonmission travel where it is required use travel—which is 

travel that requires the use of government aircraft to meet bona fide 

communications needs, security requirements, or exceptional 

scheduling requirements of an executive agency.

• Other travel for the conduct of agency business: Government 

aircraft are also available for other travel for the conduct of agency 

business when no commercial airline or aircraft is reasonably 

available to fulfill the agency requirement or the actual cost of using a 

government aircraft is not more than the cost of using commercial 

airline or aircraft service.13

In addition to other requirements for federal agencies, the circular directs 

agencies that use government aircraft to report semiannually to GSA 

each use of such aircraft for nonmission travel by senior federal officials, 

 11The circular provides that it is issued under the authority of the Budget and Accounting 

Act of 1921, as amended; the Budget and Accounting Procedures Act of 1950, as 

amended; Reorganization Plan No. 2 of 1970; Executive Order 11541; and 31 U.S.C. § 

1344.

12According to the circular, such activities include, but are not limited to, the transport of 

troops or equipment, training, evacuation, intelligence and counternarcotics activities, 

search and rescue, transportation of prisoners, use of defense attaché–controlled aircraft, 

aeronautical research and space and science applications, and other such activities. 

13In addition, “space available” travel is authorized when an aircraft is already scheduled 

for use for official travel and a traveler’s use of the aircraft does not require a larger aircraft 

or result in more than minor additional cost to the government, among other things.

Background
Page 5 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

members of the families of such officials, and any nonfederal travelers, 

with certain exceptions.14 The circular provides that the format of the 

report is to be specified by GSA, but must list all travel during the 

preceding 6-month period and include the following information: the name 

of each such traveler, the official purpose of the trip, and the 

destination(s), among other things.15

The circular provides for one exception to these reporting requirements: 

Agencies using the aircraft are not required to report classified trips to 

GSA, but must maintain information on those trips for a period of 2 years 

and have the data available for review as authorized.16 In addition, in a 

memorandum to the heads of executive departments and agencies and 

employees of the Executive Office of the President, the President 

specifically directed that “all use of Government aircraft by senior 

executive branch officials shall be documented and such documentation 

shall be disclosed to the public upon request unless classified.”17 The 

OMB bulletin implementing this memorandum explains that “it is 

imperative that we not spend [American taxpayers’] hard-earned tax 

dollars in ways that may appear to be improper.”18

GSA has issued regulations applicable to federal aviation activities. The 

FTR implements statutory requirements and executive branch policies for 

 14In response a February 10, 1993, presidential memorandum on “Restricted Use of 

Government Aircraft,” OMB Bulletin No. 93-11 directed agencies to report all uses of 

government aircraft by senior executive branch officials, including mission travel, and 

directed GSA to modify the current guidance on agency reports on nonmission uses of 

government aircraft to incorporate this requirement. Office of Management and Budget, 

Executive Office of the President, OMB Bulletin No. 93-11, Fiscal Responsibility and 

Reducing Perquisites (Washington, D.C.: Apr. 19, 1993).

15OMB Circular A-126 ¶ 10.c. The circular also requires agencies to report a summary of 

these data to OMB semiannually in a format specified by GSA. We did not review 

agencies’ reporting of such data to OMB because our review focused on GSA’s reporting 

regulations. 

16The circular does not apply to aircraft in use by or in support of the President or Vice 

President. 

17February 10, 1993, Presidential memorandum on “Restricted Use of Government 

Aircraft.”

18OMB Bulletin No. 93-11. This document also states, “As provided in the Presidents 

February 10 memorandum, documentation of use of government aircraft by Senior 

Executive Branch Officials must be ‘disclosed to the public upon request unless 

classified.’”
Page 6 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

travel by federal civilian employees and others authorized to travel at 

government expense.19 The FMR generally pertains to the management 

of federal property and includes a specific part on management of 

government aircraft.20

As shown in table 1, the FTR specifically exempts from reporting trips that 

are classified,21 but does not contain any exemption for reporting by 

intelligence agencies.22 In contrast, the FMR states that intelligence 

agencies are exempt from the requirement to report to GSA on 

government aircraft.23

Table 1: Summary of Selected Provisions of the General Services Administration’s 

(GSA) Regulations Related to Senior Federal Official Travel

GSA regulation Selected provisions

Federal Travel 

Regulation (FTR)

• Requires federal agencies to report information on senior 

federal official travel; specifically, it requires agencies to 

report on the use of government aircraft to carry senior 

federal officials and nonfederal travelers.a

• Reports must be submitted semiannually to GSA and must 

contain specified information, including the traveler’s name, 

title, and agency, as well as the purpose, destination, and 

cost of the trip, among other things.b

• Exempts agencies from reporting trips that are classified.c

• Does not contain any exemption for reporting by 

intelligence agencies.d

• Provides that agencies that operate government aircraft 

must make records about travelers on those aircraft 

available to the public under the Freedom of Information 

Act (FOIA)e except for portions exempt from disclosure 

under that act (such as classified information).f 

 19The FTR is found at 41 C.F.R. chs. 300-304.

20The portion of the FMR dealing with government aircraft is found at C.F.R. pt. 102-33.

21FTR § 301-70.907. This exemption is also stated in the previous section, FTR § 301-

70.906, which provides: “Must we report use of our Government aircraft to carry senior 

Federal officials and non–Federal travelers? Yes, except when the trips are classified, you 

must report ...”

22See FTR § 301-70.907.

23FMR § 102-33.385.
Page 7 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

GSA regulation Selected provisions

Federal Management 

Regulation (FMR)

• Includes several different reporting requirements for 

agencies related to government aircraft in subpart E, within 

the FMR, entitled “Reporting Information on Government 

Aircraft.”

• Includes, in addition to these individual provisions, an 

overview section of FMR subpart E that states that 

“intelligence agencies are exempt from the requirement to 

report to GSA on Government aircraft.”

g

• Describes—in the subsequent section of the FMR, § 102-

33.390—information that must be reported on government 

aircraft. In particular, this section includes information on 

senior federal official travel, which must be reported to 

GSA’s Travel Management Policy Division, in addition to 

five types of information that must be reported to GSA’s 

Aircraft Management Policy Division.h

• Defines, for purposes of part 102-33 of the FMR, which 

includes these sections, the term “intelligence agencies” to 

include the following agencies or organizations:

1. The Central Intelligence Agency;

2. The National Security Agency;

3. The Defense Intelligence Agency;

4. The National Reconnaissance Office;

5. The Bureau of Intelligence and Research of the Department 

of State; and

6. Intelligence elements of the Army, Navy, Air Force, Marine 

Corps, Department of Justice, Department of the Treasury, 

and Department of Energy.

i

Source: GAO analysis of GSA regulations.

a

FTR § 301-70.907. The FTR provides a presumption that travel by common air carrier is the most 

advantageous method of transportation and must be used when reasonably available, and provides 

that travel on government aircraft may be authorized only when a government aircraft is the most 

cost-effective mode of travel. FTR §§ 301-10.5(a), 301-10.260, 301-70.101(b).

b

FTR § 301-70.907.

c

This exemption is also stated in the previous section, FTR § 301-70.906, which provides: “Must we 

report use of our Government aircraft to carry senior Federal officials and non–Federal travelers? 

Yes, except when the trips are classified, you must report ...”

d

See FTR § 301-70.907.

e

5 U.S.C. § 552.

f

FMR §§ 301–10.266, 301–70.807, 301–70.908.

g

FMR § 102-33.385.

h

FMR § 12-33.390. Information that must be reported to GSA’s Aircraft Management Policy Division 

includes (1) inventory data on federal aircraft through GSA’s Federal Aviation Interactive Reporting 

System (FAIRS); (2) cost and utilization data on federal aircraft through FAIRS; (3) cost and utilization 

data on commercial aviation services aircraft and related aviation services through FAIRS; (4) 

accident and incident data through the Interagency Committee for Aviation Policy (ICAP) Aircraft 

Accident Incident Reporting System (AAIRS); and (5) the results of cost comparison studies in 

compliance with OMB Circular A-76 to justify purchasing, leasing, modernizing, replacing, or 

otherwise acquiring aircraft and related aviation services. FMR § 12-33.390(a). FAIRS is a 

management information system operated by GSA to collect, maintain, analyze, and report 
Page 8 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

information on federal aircraft inventories and cost and usage of federal aircraft and commercial 

aviation services aircraft (and related aviation services).

i

FMR § 102-33.20. GSA’s definition of the intelligence community is not consistent with the current 

definition of intelligence community under the National Security Act. For example, the GSA definition 

does not include the Department of Homeland Security, which was established by the Homeland 

Security Act of 2002, Pub. L. No. 107-296, § 101, 116 Stat. 2135. However, the GSA Administrator 

has committed to amending the FMR part 102-33 using the definition of intelligence community as 

defined by the National Security Act, 50 U.S.C. § 3003 (formerly classified at 50 U.S.C. § 401a).

According to senior GSA officials, although the exemption for intelligence 

agencies is contained in the FMR—which largely deals with the 

management of federal property—it applies to reporting requirements in 

the FTR for senior federal officials who travel on government aircraft.

Through issued executive branch documents, agencies are required to 

provide data about senior federal official nonmission travel—except for 

classified trips—to GSA, and GSA has been directed to collect this 

specified information. Accordingly, through its regulations, GSA has 

directed agencies to report required information on senior federal official 

travel; however, its regulations allow certain trips not to be reported, in 

addition to classified trips. Specifically, GSA exempted intelligence 

agencies from reporting any information on senior federal travel on 

government aircraft regardless of whether it is classified or unclassified. 

This is inconsistent with executive branch requirements we indentified. 

GSA has not articulated a basis—specifically, a source of authority or 

rationale—that would allow it to deviate from collecting what it has been 

directed to collect by the President and OMB. This could undermine the 

purposes of these requirements, which include aiding in the oversight of 

the use of government aircraft and helping to ensure that government 

aircraft are not used for nongovernmental purposes. Further, GSA 

officials stated that it is the agency’s practice to implement regulations 

that do not introduce real or potential conflicts with other authorities.

According to GSA senior officials, the agency is unable to identify the 

specific historical analysis for inclusion of the intelligence agencies’

reporting exemption in the FMR. GSA added the exemption for 

intelligence agency reporting of information on government aircraft to the 

GSA’s Intelligence 

Agency Exemption for 

Reporting Senior 

Federal Official Travel 

for Nonmission 

Purposes Is 

Inconsistent with 

Executive Branch 

Requirements, and 

GSA Has Not 

Identified a Basis for 

the Exemption
Page 9 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

FMR in 2002;24 however, there is no explanation for the inclusion of the 

exemption in the regulation or implementing rule.25 GSA senior officials 

told us that the exemption for intelligence agencies enabled intelligence 

agencies to comply with Executive Order 12333, which requires the 

heads of departments and agencies with organizations in the intelligence 

community or the heads of such organizations, as appropriate, to “protect 

intelligence and intelligence sources and methods from unauthorized 

disclosure with guidance from the Director of Central Intelligence.” 

However, GSA has not articulated how an exemption for senior federal 

official travel data for nonmission purposes is necessary for agencies to 

comply with Executive Order 12333.26 Identifying an adequate basis for 

the intelligence agency reporting exemption or removing the exemption 

from its regulations if an adequate basis cannot be identified could help 

GSA ensure its regulations for senior federal official travel comply with 

executive branch requirements.

 24In 2002, GSA revised the Federal Property Management Regulation (FPMR) by, among 

other things, moving coverage on the management of aircraft into the FMR and moving 

regulations on reporting travel of senior federal officials, approving travel on government 

aircraft, and justifying and approving the use of government aircraft to carry passengers to 

the FTR. Management of Government Aircraft, 67 Fed. Reg. 67742 (Nov. 6, 2002).

25Management of Government Aircraft, 67 Fed. Reg. 67742. GSA promulgated these 

changes as a final rule without notice and comment.

26Nonmission travel explicitly does not include activities that constitute the discharge of an 

agency’s official responsibilities, which is considered mission travel. Executive Order 

12333 was in existence at the time that OMB Circular A-126 was issued requiring 

agencies to report their data to GSA and did not change between that time and when GSA 

issued its revised regulations exempting intelligence agency reporting. United States 

Intelligence Agencies, 46 Fed. Reg. 59941 (Dec. 4, 1981). 
Page 10 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

GSA aggregates the data reported by agencies on senior federal travel to 

produce publically available reports describing the use of government 

aircraft by senior federal officials and how government aircraft are used to 

support agency missions.27 Specifically, these Senior Federal Travel 

Reports provide analysis on the number of trips taken by senior federal 

officials, the costs of such trips, the number of agencies reporting, and the 

number and costs of trips taken by cost justification.28

However, GSA does not identify in the Senior Federal Travel Reports 

which agencies do not report data on senior federal official travel as a 

result of the intelligence agency exemption. For example, during the 

course of our February 2013 review, we obtained senior federal official 

travel data from GSA that had been reported to GSA by DOJ. Through 

our review of the data, we determined that the FBI stopped reporting data 

on senior federal official travel to GSA beginning in 2009, based on the 

intelligence agency exemption contained in FMR § 102-33.385.

The reports also list 

those departments, agencies, bureaus, or services that report no use of 

senior federal official travel during the reporting time frame. According to 

the reports, they are intended to provide transparency and better 

management and control of senior federal official use of government 

aircraft and the ability to examine costs as they relate to trip use 

justifications.

29 As a 

result, the FBI did not report to GSA on 395 unclassified nonmission 

flights taken from fiscal years 2009 through 2011 by the Attorney General, 

FBI Director, and other DOJ executives—at a total cost of approximately 

$7.8 million.30

 27In addition, agencies that operate aircraft are required to make this information available 

to the public under the Freedom of Information Act.

However, GSA’s Senior Federal Official Travel Reports for 

those years provided information on flights for other DOJ components but 

28GSA data are categorized by the trip justification, which includes (1) mission required, 

(2) required use, (3) cost (when the cost of the government-owned aircraft trip is less than 

the cost of the city-pair fare for scheduled commercial airline service or the cost of the 

lowest available full coach fare if a city-pair fare is not available), and (4) space available.

29Specifically, according to the FBI, the exemption contained in FMR § 102-33.385 applies 

to all data on government aircraft stated in FMR § 102-33.390, which includes senior 

federal travel information. The FBI also determined that the exemption applies to all of the 

FBI, not just the intelligence elements, and includes all flights, both mission and 

nonmission. 

30All costs are estimated costs consisting of total flight hours multiplied by estimated 

variable costs per hour.

GSA Does Not 

Identify Which 

Agencies Do Not 

Report Senior 

Federal Travel Data 

as a Result of the 

Intelligence Agency 

Exemption, Which 

Limits the Accuracy of 

Its Reports
Page 11 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

did not indicate that additional flights may have been omitted on the basis 

of GSA’s exemption for intelligence agencies.31

Standards for Internal Control in the Federal Government calls for 

agencies to establish controls, such as those provided through policies 

and procedures, to provide reasonable assurance that agencies and 

operations comply with applicable laws and regulations. These standards 

also call for the accurate and timely recording of transactions and events 

to help ensure that all transactions are completely and accurately 

recorded, as well as for an agency to have relevant, reliable, and timely 

communications.

GSA senior officials told 

us that they cannot identify which organizations, components, or offices of 

departments or agencies within the intelligence community do not report 

senior federal official travel data to GSA. These officials stated that this is 

because they do not distinguish between instances where an agency 

reports no information because the agency is invoking the exemption and 

instances where the agency reports no information for some other 

reason, such as that no flights were taken on agency aircraft. Asking 

agencies to identify instances where they are invoking the exemption 

would better position GSA to collect and report on this information.

32 Further, GSA officials stated that it could be possible 

to obtain follow-up information from agencies that did not provide travel 

data in order to determine why agencies had not reported data. Collecting 

additional information on which agencies are invoking the exemption and 

including such information in its reports could help ensure more complete 

reporting on the use of government aircraft, which could help provide 

GSA with reasonable assurance that its Federal Official Travel Reports 

are accurate and also provide the public a more comprehensive 

understanding of these trips.

Through OMB Circular A-126 and related documents, the President has 

assigned GSA responsibility for collecting agency information on senior 

federal official travel for nonmission purposes. Under these executive 

branch directives, including OMB Circular A-126, OMB Bulletin 93-11, 

and a 1993 presidential memorandum to the heads of all executive 

 31The Drug Enforcement Administration—another component of DOJ—reported executive 

travel on its aircraft to GSA for those years and is also an element of the intelligence 

community.

32GAO/AIMD-00-21.3.1

Conclusions
Page 12 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

departments and agencies, the only exception for the reporting of this 

kind of travel is for classified trips. However, GSA has established an 

exception to these reporting requirements that is inconsistent with the 

executive branch requirements that gave GSA authority to collect senior 

federal travel data. GSA has not identified the basis—specifically, a 

source of authority or rationale—for this exemption as applied to senior 

federal official travel for nonmission purposes that would allow for it to 

deviate from executive branch specifications. Identifying an adequate 

basis for the intelligence agency reporting exemption or removing the 

exemption from its regulations if an adequate basis cannot be identified 

could help GSA ensure its regulations for senior federal official travel 

comply with executive branch requirements. In addition, collecting 

additional information on which agencies or organizations within the 

federal government are utilizing this exemption, and including such 

information in its Senior Federal Travel Reports, could help provide GSA 

with reasonable assurance that its published reports using these data are 

accurate.

We recommend that the Administrator of GSA take the following two 

actions:

• To help ensure that GSA regulations comply with applicable executive 

branch requirements, identify an adequate basis for any exemption 

that allows intelligence agencies not to report to GSA unclassified 

data on senior federal official travel for nonmission purposes. If GSA 

cannot identify an adequate basis for the exemption, GSA should 

remove the exemption from its regulations.

• To help ensure the accuracy of its Senior Federal Official Travel 

Reports, collect additional information from agencies on instances 

where travel is not being reported because of an exemption for 

intelligence agencies, as opposed to some other reason, and include 

such information in its reports where departmental data do not include 

trips pursuant to an agency’s exercise of a reporting exemption.

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

provided written comments which are reprinted in appendix I and 

summarized below. In commenting on our report, GSA concurred with 

both of the recommendations and identified actions to address them.

In response to our recommendation that GSA identify an adequate basis 

for the intelligence agency exemption as applied to senior federal official 

Recommendations for 

Executive Action

Agency Comments
Page 13 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

travel for nonmission purposes, or remove it from its regulations, GSA 

stated that it will remove the exemption. Specifically, GSA stated that it 

will remove section 102.33.390(b) in Subpart E of the FMR, "Reporting 

Information on Government Aircraft.” This action will remove the reporting 

requirement related to senior federal official travel from the FMR and such 

reporting will continue to be governed by the FTR. As a consequence, the 

exemption for intelligence agencies, which is only contained in the FMR, 

will no longer be applicable to unclassified data on senior federal official 

travel for nonmission purposes. 

In response to our recommendation that GSA collect and report additional 

information from agencies on instances where travel is not being reported 

because of an exemption for intelligence agencies, GSA stated that it will 

add indicator data elements for agencies to identify when classified data 

is withheld from the senior federal official travel data they submit to GSA. 

These actions, when fully implemented, will address both of our 

recommendations.

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

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Attorney General and 

other interested parties. This report will also be available at no charge on 

GAO’s 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 Office 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. Key contributors to this report are listed in appendix II.

Sincerely yours,

David C. Maurer

Director

Homeland Security and Justice Issues
Appendix I: Comments from the General 

Services Administration

Page 14 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

Appendix I: Comments from the General 

Services Administration
Appendix I: Comments from the General 

Services Administration

Page 15 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 16 GAO-14-151 GSA Oversight of Nonmission Federal Flight Data

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

In addition to the contact named above, Chris Currie, Assistant Director; 

Chris Ferencik, Analyst in Charge; Janet Temko, Senior Attorney; and 

Mary Catherine Hult made significant contributions to the work.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(441182)
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