DECISION MEMORANDUM FOR THE PRINCIPAL DEPUTY ASSISTANT
SECRETARY - POLICY, MANAGEMENT AND BUDGET

FROM: Kim Thorsen, Deputy Assistant - Public Safety, Resource Protection,
and Emergency Services pficare
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Olivia B. Ferriter, uty Assistant Secretary - Budget, Finance, Performance and
Acquisition 5 Ue vA f

cc: Jim Douglas, Director, Office of Wildland Fire
Douglas Glenn, Director, Office of Financial Management

Denise Flanagan, Director, Office of Budget
Martin Quinlan, Director, Business Integration Office

SUBJECT: Waiver of E-Gov Travel Service (ETS) Requirements for Casual Hires

Introduction

The DOI fire bureaus have the authority to hire casual employees (Casual Hires) to assist in
coping with sudden and unexpected emergencies caused by a fire, or extreme fire danger, flood,
storm, or any other all-hazard emergency that threatens damage to federally protected property,
has the potential to cause loss of life, serious injury, public health risk, or damage to natural or
cultural resources, unless brought under immediate control.

These Casual Hires are hired for temporary durations to assist with these emergency incidents.
As federal employees, Casual Hires are entitled to reimbursement for travel expenses incurred.
Approximately 33,000 payments are made annually for these travel expenses. The Federal Travel
Regulations require utilizing an E-Gov Travel Service (ETS) for travel reimbursements. The
DOIETS is the Concur Government Edition or CGE.

This waiver is an opportunity to increase efficiency, eliminate undue burden and save an
estimated $556,000 annually by establishing a payment process outside of the DOI’s travel
system, CGE, for incidental travel related payments for these casual employees.

Background

Like all agencies, the wildland fire bureaus in the Department of the Interior utilize the
ETS/CGE to process travel related reimbursements for short-term (one — three month) personnel
called Casual Hires. The majority of these Casual Hires are hand crew members. Casual Hires
are generally only entitled to incidental travel reimbursement, which is de minimis (e.g., $5 per
day). Paying Casual Hires through ETS/CGE requires the data entry of traveler profiles, travel
authorizations, and multiple vouchers along with approvals for each. This is unnecessarily
burdensome to bureau personnel and also triggers a $14.75 fee, per voucher, to the General
Services Administration. In other words, the GSA voucher fee alone usually exceeds the amount
of the reimbursement provided to the Casual Hire. This disparity is compounded by the DOI
staff costs incurred in processing the travel documents.


The FTR (§301-50.4) allows agency heads, or their designee, to grant a waiver to the required
use of E-Gov Travel Service (ETS), on a case by case basis when, “Such use would result in an
unreasonable burden on mission accomplishment.”

The bureau incident business leads, bureau fire directors, and the bureau Chief Financial Officers
developed and approved a business case in support of a waiver to the required use of ETS/CGE
and an alternative payment method for reimbursing Casual Hires. This business case details the
use of Casual Hires in support of wildland fire response and the costs and administrative burdens
associated with use of CGE. The Financial Officer’s Partnership community was briefed on the
business case and agreed it did not present any significant internal control concerns and the
travel payments could be easily monitored.

The DOI Solicitor’s Office reviewed the allowances for waivers of the FTR and concurred that
this request may fall under the ‘case by case’ waiver described in the regulations due to the
‘unreasonable burden’. The circumstances, i.e. the “case” in which this waiver will be applied,
must be narrowly tailored to address the identified, unreasonably burdensome process for travel
reimbursements.

The U.S. Forest Service has been operating under a similar agency waiver for several years
utilizing the same payment process noted below.

Over the last five years, the DOI fire bureaus have hired on average approximately 7,200 casual
employees each year to support fire and all hazard incidents. The estimated number of travel
payments for these employees is in excess of 33,000 annually which results in the estimated
ETS/CGE processing costs of $350,000 and administrative costs of $206,000.

This waiver will allow travel expense payments for Causal Hires for their Privately Owned
Vehicle (POV) mileage and incidental expenses and a maximum of 15 meals per payment to be
included on the Emergency Firefighter Time Report (OF-288), which is the process used to make
their salary payments.

The official electronic travel system, ETS/CGE, must and will continue to be used for Casual
Hire travel reimbursement beyond the two reimbursable items identified in the preceding
paragraph. Documentation currently used to support Casual Hire authorizations to travel will
continue to be used to document the travel payment on the OF-288.

Decision Options

1. Continue to function under the ETS/CGE requirements for processing the travel
reimbursements for Casual Hires. Costs and workload for processing will continue to
impact personnel and financial accounts.

2. Waive use of ETS/CGE for Casual Hires under the specific conditions that a Casual Hire
has travelled to an incident and will incur only POV mileage and incidental expenses and
up to 15 meals per payment. This waiver removes an unreasonable burden for the class of
casual hires, as permitted under the FTR. Under the waiver travel reimbursement
payments would take place through the Emergency Firefighter Time Report (OF-288).


The official electronic travel system, ETS/CGE, must be used for Casual Hire travel
reimbursement beyond the stated reimbursable items granted by this waiver.

The Office of Wildland Fire and the Office of Financial Management, in coordination
with the Business Integration Office, are responsible for implementing this waiver.
Implementation actions include:

a. Issue appropriate policy.

b. Modify the pay code table in Federal Personnel/Payroll System (FPPS) to
associate pay code (TRAVEL) TRV to budget object class 211E for per diem and
(COMMISSARY) CMN to budget object class 211P for POV mileage.

c. Develop and test the Financial Business Management System (FBMS) import of
FPPS to ensure travel data uploads correctly.

d. Issue procedures for hiring offices to audit and process travel on the OF-288.

e. Develop a spot audit schedule to ensure compliance to the new process.

Recommendation

Option 2 removes undue burden, saves costs, and increases administrative efficiency, as well as
brings the Department of the Interior procedures into alignment with the Forest Service. This
option does not present any significant internal control concerns and the travel payments could
be easily monitored.

PRINCIPAL DEPUTY ASSISTANT SECRETARY’S DECISION
4 APPROVE
_ DISAPPROVE

COMMENTS

Wp [201
Date