DOJ Civil Rights Division Travel: Division Strengthened Controls over Travel, but Additional Areas for Improvement Identified
Published: 2015-11-12T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The sensitive nature of taxpayer-funded travel necessitates that federal agencies have strong internal controls in place to help ensure that travel complies with rules and regulations.
GAO was asked to review the Division's travel controls. This report examines the extent to which the Division effectively implemented internal controls and complied with travel policy in key areas, including appropriate (1) authorization and reimbursement of travel and (2) use of travel charge cards.
GAO analyzed Division travel data for all trips associated with investigations resulting in a court case and completed investigations not resulting in a court case (“closed investigations”), and travel charge card use from October 2011 through June 2013, the most recent data available at the time of GAO's data request. GAO did not analyze travel data associated with ongoing investigations. GAO also analyzed a generalizable sample of travel documents for 105 of the 3,157 trips within the period of its review. GAO also reviewed relevant federal and agency-specific travel rules and interviewed officials.
section_title: What GAO Found
paragraphs: GAO tested the implementation of internal controls and compliance with key policies in nine areas of the Department of Justice's (DOJ) Civil Rights Division (Division) travel authorization and reimbursement process for the period from October 2011 through June 2013 and found indications that controls functioned effectively in four of those areas. Weaknesses existed in the remaining five areas. Two of these weaknesses should be addressed by the design of a new travel system the Division began using in August 2013. Although the new travel system was in use during GAO's review, the Division had used the new system for too few trips for GAO to analyze its data. The four areas of travel in which the Division complied with policy and controls were generally functioning effectively included appropriate levels of per diem reimbursement, presence of required receipts, prior approval of higher-than-per-diem lodging, and appropriate length of trip for certain oversight activities (related to ensuring compliance with fair-housing laws). GAO identified weaknesses in three areas including the following:
GAO found that 16 percent of travel authorizations did not include documentation of approval prior to travel, contrary to DOJ policy, which could hinder the effective management of travel funds. Although unanticipated travel may require flexibility for travelers, strengthening controls to promote prior written authorization could help the Division better ensure that travel is necessary and funds are available.
GAO estimated that 14 percent of Division airfares were on noncontract carriers, and none of the eight highest cost vouchers in GAO’s sample had documentation of prior approvals as required by DOJ policy. The new DOJ travel system has controls designed to document approval of noncontract airfares but not if travelers book flights outside the system. The department has not yet evaluated whether this is occurring, yet doing so would confirm whether the new configuration of controls are functioning as intended.
GAO estimated that 42 percent of Division travel vouchers were not submitted within required time frames per DOJ policy, which could result in difficulties in managing travel funds.
Most Division travel charge card use appeared appropriate indicating effectively functioning controls and compliance with certain travel policies—for instance, more than 97 percent of purchases on Division travel cards aligned with evidence of official travel and appeared appropriate. GAO found three weaknesses related to travel card controls. First, cash advance transactions did not always comply with travel policies, as 19 percent of transactions did not align with evidence of official travel. Second, travel cards were not closed timely in 29 percent of cases reviewed. The Division has implemented new procedures since the start of GAO's audit, implementing new controls whose design should address these two issues. Third, the Division did not maintain documentation of communication with delinquent cardholders, a key component in addressing delinquent accounts. Without this documentation, the Division will not be able to determine whether staff are implementing this control, and thus, if delinquencies persist, it will be hindered in determining if the underlying cause is lack of implementation of this control or the need to strengthen controls or implement different processes.
section_title: What GAO Recommends
paragraphs: GAO recommends, among other things, that the Division strengthen controls related to prior authorization of travel and timely submission of vouchers, evaluate whether new controls for noncontract airfares are functioning properly, and improve how it documents oversight of delinquent travel card accounts. The agency concurred with GAO's recommendations.

section_title: Letter
paragraphs: The serious fiscal challenges facing our nation today as well as the  sensitive nature of taxpayer-funded travel necessitates that federal  agencies have strong internal controls in place to help ensure that travel  complies with rules and regulations, and that travel spending is prudent  and in line with agency mission needs. Moreover, travel improprieties can  significantly damage the credibility of government agencies. For example,  controversy around a 2010 General Services Administration (GSA)  conference garnered significant media attention and resulted in increased  scrutiny of government travel. To help safeguard taxpayers’ money,  federal regulations state that agencies are to conduct all travel in the most  economical and effective manner. For their part, travelers are told to  exercise the same standard of care in incurring expenses that a prudent  person would exercise if traveling on personal business.
You requested that we review the Department of Justice (DOJ) Civil  Rights Division (Division) travel program’s compliance with travel policy  and internal controls in place to help ensure compliance with travel rules.  This report thus examines the extent to which the Division effectively  implemented internal controls and complied with travel policy in key  areas, including appropriate (1) authorization and reimbursement of travel  and (2) use of travel charge cards.
To achieve these objectives, we reviewed Division travel data from  October 2011 through June 2013 (the most recent travel data available  when we began our examination) that included all trips associated with  investigations resulting in a court case (which we refer to as “cases” in  this report) and completed investigations not resulting in a court case  (which we refer to as “closed investigations”). We excluded travel  information related to ongoing investigations that could result in ongoing  litigation. We estimate that the travel vouchers associated with cases and  closed investigations represented approximately 61 percent of Division  travel. After identifying federal travel regulations and DOJ travel policies,  we tested the implementation of policies and controls over travel by  analyzing data that indicated whether the policy or control had been  implemented.  In some cases, the data we analyzed directly indicated  whether the control had been implemented, such as through compliance  with policy, and we report on those outcomes. Where we found that  Division travel complied with policy, we did not conduct further testing of  related controls.  In other cases, the data pointed to a control weakness  that required additional testing. If we identified a weakness in the  implementation of controls that may have been addressed through a  change in DOJ’s travel system subsequent to the time frames of the data  we tested, we evaluated the design of any related new control as a way of  assessing whether the control weakness we identified could be  mitigated. To do so, we consulted with GAO travel experts familiar with  the new travel system the Division put in place and reviewed the  Division’s documentation of controls related to that system.
For the first objective, we evaluated the implementation of nine policies  and control activities to determine the extent to which travel authorization  and reimbursement processes complied with relevant requirements, such  as requirements to properly authorize and document travel. To this end,  we drew a stratified random probability sample of 105 Division trips,  generalizable to the population of 3,157 Division trips in the scope of our  review, and examined that sample to determine the extent to which travel  was approved prior to the trip, whether travel documents were approved  by an appropriate-level official, and whether travel vouchers were  submitted timely and included all required receipts to justify  reimbursement, in line with travel rules. We also analyzed all travel  authorization and voucher data within the period of our review from the  Division’s financial system of records, the Financial Management  Information System (FMIS), to review the extent to which the Division  utilized premium airfares, utilized noncontract airfares, or paid per diem  above the GSA authorized rates. Where we identified potential premium  airfares, noncontract airfares, or per diem above authorized rates, we  reviewed travel documents to identify the extent to which Division  employees provided justifications and obtained approvals as required by  DOJ policy. We also compared travel by fair-housing testers to dates of  testing work activities to review the extent to which travel aligned with  official testing dates.
For the second objective, we reviewed travel card transactions occurring  from October 2011 through June 2013 to test the implementation of the  Division’s policies and controls that were designed to help ensure  appropriate use of travel charge cards. For example, this included  controls to prevent potentially inappropriate transactions or personal use  and oversight processes to monitor for potential misuse of travel cards.  To this end, we reviewed travel data to determine the extent that  transactions appeared appropriate for travel, such as charges for hotels  and airfare, and aligned with official travel dates. We also reviewed  Division controls related to management of travel cards including timely  closure of accounts and oversight of delinquent accounts. We performed  data-reliability assessments of all travel data reviewed. These  assessments included analyzing related documentation, interviewing  knowledgeable officials on how the data are compiled, electronically  testing data fields for completeness, evaluating control totals, and  comparing records in the file against agency totals for travel vouchers and  charge card transactions. All of the data included in this report were  assessed and determined to be sufficiently reliable for the purposes of  this report. Appendix I contains additional details regarding our scope and  methodology.
We conducted this performance audit from November 2014 through  November 2015 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 we obtained provides a reasonable basis for our  findings and conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: DOJ Civil Rights Division
paragraphs: DOJ’s Civil Rights Division (Division) was established in 1957 to enforce  federal statutes prohibiting discrimination on the basis of race, sex,  gender preference, disability, religion, and national origin. The Division’s  enforcement responsibilities include enforcing antidiscrimination  protections in education, employment, credit, housing, public  accommodations and facilities, voting, and certain federally funded and  conducted programs. The Division has three significant goals: (1) to fulfill  the promise of basic civil-rights protections through effective and vigorous  enforcement of the law; (2) to deter and remedy discriminatory and illegal  conduct through the successful prosecution of these federal laws; and (3)  to promote voluntary compliance and civil-rights protection through a  variety of educational, technical-assistance, and outreach programs. To  fulfill these goals, Division employees are required to travel to investigate  potential discrimination, and pursue litigation in court where appropriate.  Division employees also travel to engage in community outreach and  education, and for training, conference, or administrative purposes. The  Division comprises 11 sections, as shown in figure 1 below, all of which  are stationed in Washington, D.C. Because of this, nearly all Division  attorneys and, occasionally, some nonattorney personnel are required to  travel since litigation activities occur in all parts of the United States.
The Division spent a combined total of $6 million on travel in fiscal year  2012 and fiscal year 2013 as shown in table 1 below. Travel made up  approximately 2 percent of the Division budget in fiscal year 2012 and  fiscal year 2013.
section_title: Fair-Housing Testing Program
paragraphs: In 1991, the Division established a fair-housing testing program within its  Housing and Civil Enforcement Section and commenced testing in 1992.  Housing testing involves sending individuals who pose as prospective  buyers or renters of real estate to gather information that can indicate  whether a housing provider is complying with fair-housing laws. The  primary focus of the section's fair-housing testing program has been to  identify housing discrimination based on race, national origin, disability, or  familial status. Under the Fair Housing Act, DOJ may initiate a lawsuit  where it has reason to believe that a person or entity is engaged in a  “pattern or practice” of discrimination or where a denial of rights to a  group of persons raises an issue of general public importance. The  section employs various means to accomplish testing in local  communities, including contracts with private fair-housing organizations,  contracts with individuals, and by using nonattorney DOJ employees  throughout the country. The majority of fair-housing testing cases filed in  court are based on testing evidence that involved allegations of agents  misrepresenting the availability of rental units or offering different terms  and conditions based on race, national origin, familial status, or disability.  DOJ also uses the testing program to test for discrimination in lending  and public accommodations.
section_title: Division Travel Process
paragraphs: Most federal government travel is regulated by the Federal Travel  Regulation (FTR) issued by GSA. The FTR implements statutory  requirements and executive branch policies that applicable federal  entities must follow, including the general principle that employees  traveling on official government business exercise the same care in  incurring expenses that a prudent person would exercise if traveling on  personal business. In addition to the FTR, DOJ has issued its own travel  policies, supplements, and bulletins to further describe and implement the  specific travel requirements for the agency. Division employees are  issued government travel charge cards through J.P. Morgan Chase and  are to use them for all costs associated with government travel, including  airfare, hotel rooms, food, and other miscellaneous expenses. The travel  charge cards are issued directly to employees, and the cardholder holds  all liability for any charges made to the travel card. Employees are  expected to pay the card balance in full at the time it is due. There is no  interest assessed on unpaid balances but cardholders may be charged a  late fee.
According to the travel authorization process the Division had in place at  the time of our review (see fig. 2), prior to travel, generally the traveler or  a travel arranger was to complete an authorization form. The  authorization form would then be routed to the appropriate travel  authorization-approving official within the section. According to Division  officials, approving officials are generally the Section Chief, Deputy  Section Chief, or Special Counsel. According to Division travel officials,  the authorization must also be signed by a funds certifier, indicating that  funds are available to cover travel expenses. Once the authorization form  has been signed by the appropriate approving official, the forms are then  either e-mailed or faxed to the Division’s finance group, which is  responsible for entering the travel authorization information into the  Financial Management Information System (FMIS). FMIS is the financial  system of record that contains data on travel authorizations and vouchers  for the Division.
Upon completion of travel, Division employees are to submit a travel  voucher document requesting reimbursement for travel expenses, per  DOJ policy. In preparing and submitting voucher documents, Division  employees are to follow a similar process to the authorization process.  According to DOJ policy, the traveler or a travel arranger is to fill out the  appropriate travel voucher forms, attach required receipts, and then  submit the voucher to the travel voucher-approving official at the section  level. The traveler must sign the voucher before the travel voucher- approving official signs the approval. According to Division officials, the  same approving official generally signs off on both the authorization and  the voucher unless the official is absent. After that, the voucher is to be  sent to the Division’s finance group where an accounting technician  enters the voucher information into FMIS. At the time of our review, all  copies of travel authorization and voucher documents were maintained in  a separate data system called Web Docs.
The Division implemented the department’s new travel system called E2  in August 2013, shortly after the period covered by our review. E2 is a  web-based, end-to-end travel-management application used for travel  authorizations; booking of flights, rooms, and cars; and vouchering for  reimbursement. E2 is intended to streamline travel management and  enable real-time visibility into the buying choices of travelers, as well as  assist in optimizing travel budgets while saving taxpayers’ money.  According to DOJ financial management officials, this new travel system  automates certain tasks compared to the process in place during the  period of this review. For example, the E2 system allows travelers to  submit and obtain approval for travel requests electronically. The new  system directly interfaces with FMIS so that travel authorization and  voucher information is automatically entered into the financial system. We  did not analyze data from E2 because at the time of our review there was  not a sufficient number of trips made and processed through E2 for valid  analysis. Instead, after identifying weaknesses in the Division’s existing  system, we consulted with GAO travel experts familiar with E2 and  reviewed the Division’s documentation of E2 controls to determine  whether these controls were designed in a manner that could address  these weaknesses.
section_title: Weaknesses in Controls Identified, Some of Which Should Be Addressed by the Department’s New Travel System, but Others May Remain
paragraphs: We tested the outcomes of compliance with key travel policies and  implementation of related internal controls in nine areas and found  indications that controls functioned effectively in four areas but that  weaknesses existed in five other areas. Two of these weaknesses should  be addressed by the design of the new travel system. In three other areas  our testing indicated that the control did not always function as intended  and these weaknesses may remain unaddressed by the design of new or  existing controls. Table 2 summarizes the travel policies and controls we  tested and whether E2 is designed to address any weaknesses we  identified.
subsections: section_title: Areas in Which Outcomes Indicated That the Division Complied with Policy or Implemented Controls That Functioned Effectively
paragraphs: For four areas of travel that we tested, we found the outcomes indicated  the Division complied with policy and that controls were effectively  implemented and functioning to help ensure that travel complied with  applicable rules. Because the outcomes of the related policy testing in  three of these areas indicated effectively functioning systems, we did not  conduct additional analysis of the underlying control mechanisms in those  areas.
Meals and Incidental Expenses (M&IE) Reimbursed  Appropriately. Federal employees on official travel are reimbursed  for lodging and for M&IE up to a set daily rate that varies by location  and, for some locations, by time of year. These rates are published  annually by the GSA. To examine the extent to which Division M&IE  reimbursements complied with standard rates, we analyzed all  Division travel for which we had location information from October  2011 through June 2013, by comparing the M&IE reimbursements  from FMIS travel data to the standard rates. In almost all cases, the  traveler’s reimbursement for M&IE was the amount it should have  been or lower. Out of the 2,494 travel vouchers included in this  analysis, we identified 13 instances where a higher amount was  reimbursed, but the aggregate amount of potential overpayment was  $159.50, and in all 13 cases the amount was $18.75 or less per case.  Given the small number of cases identified and small dollar amounts  potentially reimbursed above standard rates, we did not conduct  further review of the associated travel documents for these trips.
Required Receipts Provided to Justify Reimbursement. The FTR  requires travelers to include receipts for lodging and any single  expense over $75 when filing a travel voucher. DOJ policy states  that travelers should submit all receipts for expenses over $75, and  also specifies that the official approving the voucher should verify that  all required receipts are included in the voucher documents. We  analyzed travel documents for a generalizable sample of 105 Division  trips covering travel from October 2011 through June 2013 to  determine the extent to which Division travel complied with DOJ policy  regarding the inclusion of required receipts to justify reimbursement.  We estimate that approximately 95 percent of all travel vouchers  included required receipts. Our sample data were not designed to  estimate the dollar value of expenses without receipt for all Division  travel, but through our review of trips in our sample we identified a  total of $2,023 in travel expenses for four trips that lacked required  receipts to justify reimbursement. For example, one voucher did not  include a required receipt for $271.60 in airfare and another voucher  included partial airfare receipts for $498.20 in airfare. Given the high  level of compliance documenting expenses and that E2 currently  offers a centralized way for travelers to capture receipts, we did not  conduct tests of controls related to ensuring compliance with this  policy.
Prior Approval of Lodging Costs Higher Than Standard Per Diem.
The FTR permits agencies to reimburse travelers above the per diem  rate in specific, limited circumstances. The FTR states that travelers  should request authorization for reimbursement above per diem rates  in advance of travel. DOJ policy requires travelers to provide written  justification for requesting lodging above the standard per diem rate  and this justification should be on or attached to the travel  authorization form for approval prior to traveling. We tested the extent  to which this control was in place during the period of our review.  Specifically, we analyzed FMIS travel data including all trips occurring  from October 2011 through June 2013 where the traveler was  reimbursed for lodging and we received location information for the  trip. Through this analysis, we identified a small proportion of  Division travel including reimbursement for hotel stays above the  standard per diem rate, and found that most travelers obtained  approval for hotel stays above per diem prior to travel. Specifically, we  found that 111 of 2,099 trips with hotel stays, or about 5.3 percent of  these trips, were potentially reimbursed above standard per diem  rates, including about 1.6 percent of trips with hotel stays that cost  $100 or more above the expected amount for the total stay. The total  amount of lodging reimbursements above standard per diem rates is  less than $22,000, or 3.4 percent of Division lodging reimbursements.
Out of the 111 trips that we identified with lodging potentially greater  than standard per diem, we reviewed supporting documentation for all  trips where Division hotel reimbursement was $100 or more above per  diem, which occurred on a total of 25 trips. The documents showed  evidence of prior approval in 23 of 25 cases, and this approval was  generally obtained through an e-mail from the traveler to the Division  travel group that was included with the travel documents. According  to Division officials, the traveler was expected to include the e-mail  with the authorization document. The new E2 travel system is  designed to automatically route any lodging over per diem for proper  justification and approval at the time of travel authorization.
Length of Travel for Fair-Housing Testing Was Consistent with  Testing Activities. To determine whether travel for fair-housing  testing was an appropriate length for the days in which testing  occurred, we compared vouchers for travel associated with testing to  testing data documenting activities. According to the FTR, only those  travel expenses essential to the transaction of official business should  be paid. DOJ policy states that travelers are only to be reimbursed for  travel expenses related to official business. Based on our review of  fair-housing tests that occurred from October 2011 through June  2013, travel for housing testing that we reviewed appeared consistent  with fair-housing testing activities. All of the testing dates the  Division provided matched to corresponding travel vouchers. In  general, the length of travel conducted for fair-housing testing was  consistent with the test dates provided. For example, a trip that  included 3 consecutive days of testing should take no more than 5  days—the 3 days of testing and a travel day at the beginning and end  of the trip. This is what we observed in 54 of the 56 testing trips in our  data. The two other trips were 1 day longer than expected. On one  trip, the traveler was unable to complete any tests on one day of the  trip but did perform testing on the other days. According to officials in  the Division’s Housing and Civil Enforcement section, they do not  record dates in the testing database when testers are not able to  complete a housing test. This can occur, for instance, when a tester  arrives in town but is unable to reach a property manager. In regard to  the second trip, the traveler was the testing coordinator and  performed testing on one day of the trip. Officials explained that the  traveler would not have conducted testing on all travel days as the  testing coordinator’s main role is to oversee and coordinate the work  of other testers during the trip.
section_title: Areas in Which Control Weaknesses Should Be Addressed by New Travel System Controls
paragraphs: We found weaknesses in two control activities we tested but determined  that the design of the controls in the new E2 travel system should address  these weaknesses.
Appropriate Authority of Officials Approving Travel  Authorizations and Vouchers. DOJ policy generally requires that  travel authorizations be approved by an individual at a higher level  than the traveler, and that travel vouchers be approved by an official  at a higher level than the traveler or a senior financial manager. To  test the extent to which this control was functioning during the period  of our review, we analyzed a generalizable sample of 105 travel  vouchers for trips from October 2011 through June 2013 and  estimated that 94 percent of travel authorization documents and 76  percent of travel voucher documents were approved by an official  with the authority to do so. In some cases, it was unclear whether the  control functioned as intended. Specifically, we could not match the  signature we observed on authorizations and vouchers to the  signature form of individuals with the authority to approve travel—we  estimate this occurred in 5 percent of travel authorizations and 7  percent of travel vouchers. Also, we estimate that approximately 1  percent of travel authorizations and 17 percent of travel vouchers  were approved by an official who did not have authority to approve  travel vouchers according to documents provided by the Division.  Division officials stated that this official, a financial management  specialist, was authorized to approve travel but officials did not  provide sufficient evidence to support this position. Despite these  limitations, our review of documentation and consultation with GAO  experts familiar with the E2 travel system showed that E2 is designed  to enhance this control. Specifically, approvals are designed to be  captured and recorded electronically in the system, and travel is to be  automatically routed to the proper officials according to system rules  that specify the officials who are authorized to approve a traveler’s  authorization and voucher documents.
Prior Approval of Premium Airfare. Federal regulations require that  agencies must specifically authorize and approve other than coach- class airfare and set forth allowable circumstances in which noncoach  airfare may be used. DOJ travel policy requires specific justifications  for using travel above coach class. We found that Division travelers  rarely used premium-class travel during the period of our review. To  test the extent to which controls over premium-class travel were  functioning from October 2011 through June 2013, we reviewed  selected travel vouchers we identified as potentially including  premium travel based on high transportation expenses or airfare  tickets potentially above standard contract fares. Out of the 40 travel  vouchers we reviewed with potential premium travel, we found two  instances where the trip included airfare above coach class. In one  case, the traveler flew to Seattle, Washington, from Washington, D.C.,  in February 2012 and took first-class flights on two of the three legs of  the trip. The traveler was a manager in the Division and his travel  voucher documents did not include evidence of prior approval for the  premium class travel or explanation for the need for first class tickets.  When asked about this trip, Division officials reported that this was a  no-cost upgrade to first class using the traveler’s frequent flier miles,  which is why the authorization document did not designate the trip as  including premium travel. However, travel documents showed that the  cost of the airfare was $1,043 whereas the contract rate for a  roundtrip flight from Washington, D.C., to Seattle in fiscal year 2012  was $464–indicating that the government paid an additional $579 for  the airfare. In the other instance of premium travel, the traveler tried to  obtain approval for a first-class airfare from the Division travel group  and reported that the tickets were obtained due to a mix up with travel  dates that necessitated a last-minute change to the tickets. The  traveler reported that the first-class tickets were the cheapest  available at the time of the ticket change. However, the traveler did  not obtain approval for the first-class tickets prior to the flight. In  addition, for 3 of the 40 trips we reviewed, the travel voucher  documents had missing or illegible receipts making it impractical to  determine whether premium travel occurred. Division travel officials  stated that the travel process in place at the time of our review relied  on the traveler reporting any premium travel, and reported that their  new travel system has the ability to identify premium travel by  automatically retrieving airfare information from the reservation and  entering it into the authorization. Travelers may also manually select  premium travel in E2. Selection of premium travel in E2 is designed to  result in special routing for authorization approval. Our review of  documentation and consultation with GAO travel experts familiar with  the E2 travel system corroborated Division officials’ observations.
section_title: Areas in Which Outcomes Indicated That the Division Did Not Always Comply with Policy or Controls Did Not Always Function as Intended
paragraphs: We identified weaknesses in two controls and one area of policy that,  absent the attention of management or compensating controls, may  remain even under the new travel system.
subsections: section_title: Prior Authorization of Travel
paragraphs: Prior authorization of travel is a key control to ensure that travel is  necessary and that travel funds are available. The FTR advises travelers  to obtain prior authorization to travel except when it is not practical or  possible. DOJ travel policy states that the approving official should sign  the travel authorization form to document approval permitting travel and  obligate estimated expenses for the trip. On the basis of our review of a  generalizable random sample of 105 Division trips occurring from October  2011 through June 2013, we estimate that 16 percent of travel did not  include documentation that travel was authorized in advance.  Specifically, the travel authorization documents for these trips indicated  that approving officials authorized the trips after travel had already  started, based on the date the approving official signed the authorization  form.
According to Division officials, all travel is to be authorized in advance,  but in some cases the approver may have given verbal approval for  travel, and the travel authorization form may be completed after travel has  already begun. Although travelers may, under unanticipated  circumstances, need such flexibility, lack of formal, documented  authorization could compromise the management of fiscal-year travel  funds given that the signed travel authorization form also obligates funds  for the trip and, without that form, the Division may not be aware that  additional funds are needed. For example, we identified a trip where a  Division official did not obtain prior authorization to cover travel costs for a  speaker at a September 2012 training event and submitted a travel  authorization 3 months after the travel, in the next fiscal year. Travel  documentation related to the trip included an e-mail from the Division  Comptroller expressing concerns about availability of funds to reimburse  the traveler for the trip given the lack of prior authorization. While Division  officials reported that there was ultimately no issue with availability of  funds, this example illustrates potential difficulties imposed in managing  travel funds when written approval for travel prior to a trip is not obtained.
E2 provides an electronic authorization process that should ensure that  the documentation of approvals is maintained, but E2 itself cannot ensure  that travelers access and submit travel authorizations in advance. Thus,  strengthening controls to promote prior authorization of travel in  accordance with Division policies even when travel needs occur at the  last minute—such as requiring an e-mail to be sent to one’s supervisor in  advance of the travel rather than obtaining verbal approval—could help  the Division better ensure that travel is necessary and that travel funds  are available to cover the trip.
section_title: Prior Approval of Noncontract Airfares
paragraphs: We reviewed travel documents for eight selected travel vouchers to test  whether there was documentation of prior approval for use of noncontract  airfares (a control), as required by travel rules, and found that none of the  Division travel vouchers we analyzed included such approvals. The FTR  generally requires travelers to purchase airfare in coach class from a  contract carrier unless an exception applies. For instance, noncontract  tickets that are less expensive than the contract price can save tax dollars  but can also carry additional risk as they are sometimes nonrefundable if  travel plans change. DOJ policy encourages the use of noncontract  airfares available to the general public when there is a high degree of  certainty that travel will occur as planned and noncontract fares are  available below the contract fare. In addition, noncontract fares can be  appropriate if tickets on the contract carrier are unavailable or impractical  based on the needs of the travel—for instance, if no flights are available  at an appropriate time to correspond with mission needs. The FTR  requires travelers to have an approved authorization for the use of a  noncontract carrier before purchasing a noncontract ticket. DOJ policy  also requires that authorizing officials approve noncontract airfares in  advance.
About 14 percent of Division airfares covering single-destination travel  from October 2011 through June 2013 were for tickets on noncontract  carriers. Of these fares, we found that in about 65 percent of cases (111  of 171 noncontract tickets), the cost of the ticket was below the  corresponding contract fare. However, in the remaining 60 cases, the  noncontract ticket cost more than the contract fare, including 41 cases  where the noncontract ticket cost $100 or more above the contract fare.  The total amount we identified that was spent on noncontract airfare  above contract fares was approximately $12,000 from October 2011  through June 2013.
We reviewed eight travel vouchers with noncontract airfares that were the  greatest amount over the contract rate to review the extent to which  controls over noncontract airfares were functioning during this same time  frame. None of the selected vouchers contained documentation of  approval for the airfares or the reason why a noncontract carrier was  used. Officials reported that the travel system in place at the time of our  review did not enable travel approvers and managers to easily identify  whether a flight was a noncontract airfare, and they relied on either the  traveler or travel preparer to self-report and manually document any use  of noncontract airfares. Without effective controls on travelers using  noncontract carriers, the Division does not have reasonable assurance  that noncontract tickets were allowable and were selected for appropriate  reasons and risks paying excessive amounts for airfare.
E2 has the potential to improve management insight into use of  noncontract airfares compared to the system in place at the time of our  audit, but it is unclear whether the new system fully addresses the control  weaknesses we identified. Specifically, E2 can be configured to document  the use of noncontract fares automatically when the airfare is booked  through its system, and officials provided documentation that the  Divisions system had been configured in this fashion. However, officials  reported that it is possible for a traveler to book an airfare outside the  system, in which case the traveler would have to manually self-report and  document that a noncontract fare was purchased—a process that is  similar to the self-reporting mechanism in place at the time of our review.  Officials believe that this type of airfare purchase would be uncommon,  though they had not tested this assertion and therefore cannot be sure to  what extent travelers will use this option and properly document  noncontract airfare use. As a result, it is unclear to what extent the new  system fully addresses control weaknesses identified by our review  unless airfare data in E2 is evaluated for compliance with travel rules  related to noncontract airfares. According to internal-control standards,  evaluations of controls can be helpful to determine the effectiveness of a  control when risks are identified, and these evaluations may include  review of the control design and direct testing of the control. Given the  challenges the Division faced under the previous system that relied on  self-reporting by travelers, evaluating this aspect of the new travel system  would confirm whether the new configuration and controls are functioning  as intended or whether additional actions are needed.
section_title: Timely Submission of Travel Vouchers
paragraphs: Travel rules generally require travelers to submit travel vouchers within 5  working days after travel ends, and this requirement is also reflected in  DOJ travel policy. We reviewed the extent to which Division travel  complied with this policy from October 2011 through June 2013 and found  that Division travelers did not consistently submit vouchers within the  required time frame. From our review of a generalizable sample of 105  travel vouchers for Division travel occurring during this time frame, we  estimate that approximately 42 percent of all vouchers were not submitted  within 5 working days, thus not complying with DOJ policy. Although  most late vouchers were estimated to be submitted within a month after  travel, we estimate approximately 5 percent of vouchers were not  submitted until more than a month after travel ended. According to  Division officials, oversight mechanisms included a monthly report of late  vouchers provided to all Division sections, and vouchers over 30 days  late would result in a notification to the Section Chief. In addition, officials  said the Division conducted a quarterly review of open obligations that  included reviewing travel authorizations that lack a corresponding  voucher, and outstanding obligations would be reviewed with the  appropriate section. However, these controls take place after a voucher is  likely already late. When asked about controls to ensure timely  submission of travel vouchers, Division officials did not identify any  controls aimed at proactively improving the timeliness with which travelers  submit vouchers. However, the Division reported that it provides policy  training regarding timely voucher submission.
Delayed submissions of vouchers can make managing travel funds  difficult and may lead to travel card delinquencies that could affect an  employee’s ability to travel and thus meet the Division’s mission needs.  Specifically, while Division travel cardholders are expected to pay the  balances on their cards whether they have been reimbursed for travel or  not, we identified two cases in which travelers who did not submit timely  vouchers became delinquent on their travel cards. For example, one  traveler, a manager, did not submit a voucher for more than 6 months  after an overseas trip. According to officials, control mechanisms related  to late voucher monitoring have not changed since the start of our review.  Controls aimed at preventing late voucher submission could help the  Division reduce the amount of travel vouchers that are submitted late and  better position it to manage travel funds.
section_title: Most Travel Card Purchases Indicated Controls Functioned Effectively, but Implementation of Delinquent Account Controls Was Not Documented
paragraphs: Most purchases made on Division travel cards aligned with evidence of  official travel and appeared appropriate for travel, indicating that the  Division complied with key policies we tested and that controls related to  travel card use were effective, but we found one area of weakness that  may remain (see table 3). Specifically, we found that the Division lacked  documentation that a key control regarding the oversight of delinquent  accounts was being implemented.
subsections: section_title: Most Travel Card Purchases Appeared Appropriate for Government Travel
paragraphs: FTR and DOJ travel policies state that travel cards can only be used  while an individual is on official travel and can only be used for purchases  associated with travel such as hotel costs, airline baggage fees, and  rental car costs, among other items. Thus transactions made on dates  outside of official travel or for items that would not be associated with  travel needs can indicate inappropriate personal use of the travel card. To  test the Division’s compliance with its policy regarding appropriate use of  travel cards, we reviewed all purchases that appeared on Division  employee travel charge card records from October 2011 through June  2013 and matched approximately 97 percent of travel card purchases to  evidence of official travel, and almost all purchases appeared appropriate  for government travel.We could not match 3 percent of purchase  transactions corresponding to 1,488 transactions to evidence of official  travel. Therefore we reviewed additional detailed documentation related  to these transactions and found that the majority of the 1,488 transactions  appeared appropriate for official travel but that 64 transactions totaling  $2,956 contained evidence of improper use of the travel card, and we  referred these cases to DOJ for additional review. These 64 transactions  included the following:
A Division cardholder who made a $600 purchase at a car dealership  in Rockville, Maryland, near the cardholder’s duty station. This  purchase did not align with evidence of official travel.
A Division cardholder made a $93 purchase at a large retail store that  did not align with evidence of official travel and the purchase occurred  near the cardholder’s duty station.
Lastly, we identified a Division employee who made dozens of  purchases in the Washington, D.C., area (the employee’s duty station)  that do not align with official travel dates, a suspicious pattern that  could indicate personal use of the travel card. For example, in  January 2012, the cardholder made a total of 14 purchases, all at  restaurants, stores, or gas stations in Washington, D.C., or Arlington,  Virginia (a suburb of Washington, D.C.), including four purchases at  the same fast-food restaurant in Arlington. Also, this person’s account  was suspended due to delinquency twice during the time frame  included in our review from October 2011 through June 2013.
Given that all Division offices are in Washington, D.C., local purchases  that do not align with dates of official travel, such as those described  above, may be unrelated to official travel. When we provided the Division  with information on these purchases, they reported that the dealership  purchase had been a mistake on the part of the cardholder and that  shortly after the purchase the cardholder reported the issue to the  Division and paid the bill. Also, officials stated that the Division had  already identified the other cardholder who had numerous suspicious  transactions in the Washington, D.C., area prior to our review, and taken  appropriate disciplinary action. Division officials reported that they were  continuing to look into the purchase at a large retail store described  above based on the information we provided.
section_title: High-Risk Cash Advances Could Be Identified by Controls Recently Adopted by the Division
paragraphs: In addition to analyzing purchase transactions, we also analyzed all cash  advance transactions occurring on Division employee travel cards from  October 2011 through June 2013, and found potential personal use of  travel cards related to cash advance transactions. DOJ policy requires  that cash advances align with official travel and do not exceed $40 per  day unless justification for a higher amount and prior approval were  provided. Overall, most travel cardholders did not make any cash  advance transactions during the period of our review—only 19 percent of  active cardholders made any cash advance transactions during this time.  However, of those who made cash advance transactions, over 60 percent  (61 of 98 cardholders) may not have followed DOJ travel policy, either  making cash withdrawals that do not align with evidence of official travel  or withdrawing cash above normally allowed amounts without  documented approval.
We identified 123 cash advance transactions totaling $21,424 associated  with these cardholders that do not match to evidence of official travel in  travel voucher data or travel card data, as shown in figure 3 below. There  were 39 cardholders (of 61) who made cash advance transactions that  did not match evidence of official travel. Three of these cardholders took  out over $1,000 in cash advances with no evidence of travel, with one  person withdrawing over $8,000 in cash during the period of our review  with no evidence of official travel. Eleven of these cardholders also had  accounts that were suspended due to delinquency during the period of  our review.
In addition, out of the 335 trips in which cardholders took cash advances,  we identified 174 trips where cash advances exceeded the allowed  amount per DOJ policy. As noted, according to DOJ policy in place from  October 2011 through June 2013, travelers were normally allowed to  withdraw up to $40 per day of travel. If employees needed more cash  than $40 per day, they were required to obtain approval from a  component executive officer or equivalent official and justify the need for  the additional cash. We matched cash advance transactions to official  travel dates from travel voucher data we received, and then compared the  total cash withdrawn to the normally allowed amount for the length of the  trip. Overall, 43 cardholders withdrew a total of $12,705 above the  allowed cash advance amounts. We reviewed all 11 travel voucher  documents for trips exceeding cash limits by $200 or more and did not  find evidence of approvals for cash advances above the allowed  amount.  For example, one traveler took out cash advances totaling  $1,316 over the course of three trips to Chicago, exceeding the normal  cash limits by approximately $676. One of those trips was 3 days long,  and the traveler took a cash advance of $345 for the trip. Travel  documents for the three trips did not include an explanation for why the  traveler required more cash than the allowed amounts, and there was no  evidence of approval for the additional cash advances.
Federal regulation and DOJ policy state that, while employees are  required to use government travel cards during official travel, personal  use of the card is prohibited and abuse or misuse of the card may result  in disciplinary action. While responsibility for paying off any travel card  transactions ultimately falls to the Division employee who was issued the  card, lack of conformity with travel card rules may indicate increased risk  of waste, fraud, or abuse. For example, personal use of travel charge  cards could indicate that an employee is having financial problems and  brings into question his or her suitability to hold a position of public trust.  Also, according to the Association of Certified Fraud Examiners—a  professional organization that sets fraud-examiner standards and  provides antifraud training—a common travel card fraud scheme involves  withdrawing cash for personal or inappropriate expenses and then adding  seemingly appropriate but false cash expenses to a travel voucher for  reimbursement. To help illustrate how this fraud scheme would work, a  traveler could withdraw $200 cash from a travel card and spend it on  personal items not related to official travel, and then include claims on a  travel voucher for several fictitious taxi fares under $75 to obtain  reimbursement for the cash withdrawal without having to provide receipts  for those transactions. Our analysis identified three trips where a  traveler’s transactions and voucher fit this risk profile. Specifically, one  Division employee took out cash advances totaling $1,512 over the  course of three trips, exceeding allowed cash limits by over $1,000. For  these three trips, the traveler was reimbursed $893 for taxi fares. No  receipts were provided for these taxi fares and they were all under the  $75 limit requiring a receipt. Also, the travel documents did not include a  justification for why cash over the allowed limits was needed or  documentation of approval for such cash. While these expenses may  have been legitimate, it illustrates how lack of conformance with policy— specifically the requirement for approval of excess cash advances—may  put the Division at increased risk for waste or abuse of travel resources.
We provided the Division with examples of potential travel card misuse  we identified through our analysis of cash advances. Out of the four  examples we provided, the Division had identified three of the cases prior  to our review and pursued appropriate disciplinary action, according to an  official speaking on behalf of the Division. As a result of our work, this  Division official reported that the Division is currently looking into the  fourth case to determine whether disciplinary action against the remaining  employee is appropriate. In general, officials stated that they pursue  disciplinary action against employees who misuse their travel charge  card, and that employees found guilty of misuse or abuse are generally  suspended without pay for up to 2 weeks. The employees are also  required to repay any funds that could be owed to the agency.
Division officials reported that at the time of our review, there was one  employee—the Travel Card Coordinator—who was responsible for  oversight of travel charge cards and associated transactions, and this  individual’s time was split among a range of travel-related duties. Officials  reported that the coordinator conducted oversight through reviews of  various reports produced by the travel charge card contractor, such as a  cash advance report, as well as an overall review of transactions. The  Travel Card Coordinator was expected to flag any potential misuse of the  travel charge card and report it to human resources and section officials,  according to Division officials. However, given the range of duties of this  individual and because there was only one person to oversee hundreds of  travel cards, officials report that oversight may have been less frequent  and thorough than would be desirable.
The Division has increased oversight of travel charge cards since the  start of our audit to better ensure appropriate use of the travel cards. The  Division issued a new standard operating procedure on travel charge card  oversight specifying that, in addition to reviews by Division accounting  staff, employees at the section level are to review travel charge card  transactions. The new procedure, issued in February 2014, also calls for  monthly audits of all transactions to identify local transactions that may  not be related to official travel, transactions in resort destinations, and  cash withdrawals that are outside of policy. The new travel card  procedure also specifies that 20 percent of all transactions should be  randomly sampled each month and reviewed to determine whether the  transaction occurred during official travel.  Furthermore, the procedure  calls for maintenance of records to document the results of the monthly  reviews, and reporting of results to the Division Comptroller. If effectively  implemented, these new controls may improve travel charge card  oversight and address issues we identified related to potentially  inappropriate travel card purchases and cash advance transactions.
section_title: Division Strengthened Controls for Timely Closure of Travel Card Accounts
paragraphs: According to DOJ travel policy, the Travel Card Coordinator was  responsible for closing the travel card account when an employee  terminated employment with DOJ and was to review monthly reports from  the travel card system to determine that cards are canceled for separated  employees. Our review identified travel card accounts that were not  closed in a timely manner upon employee separation from employment,  but we did not find evidence of travel card use after employee separation.  Our review of travel card accounts that were closed from October 2011  through June 2013 found that about 29 percent (25 of 87) were not closed  in a timely manner upon employee separation from DOJ, contrary to its  policy. In 6 cases, cards were closed over 100 days after employees had  separated from the Division. The Division has taken steps to improve  controls over travel charge card account closure. According to officials,  the late closure of travel card accounts was due to an inefficient exit  process as, in the past, the Travel Card Coordinator relied on notification  from the human resources office to find out an employee had left the  Division or agency, and the Travel Card Coordinator was not always  notified of employee departures. Officials reported that they have  implemented a new exit process that incorporates notifications to the  Travel Card Coordinator. Also, a new standard operating procedure  issued by the Division in February 2014 calls for monthly reviews of travel  charge card accounts to ensure that all employees are current, and  maintenance of records that the review occurred. In addition, in May 2015  DOJ implemented a policy in which finance staff review travel card  accounts quarterly to identify any open accounts associated with  employees that have separated from the Department. The new controls  the Division introduced, if effectively implemented, could address the  limitations we observed.
section_title: Division Lacks Documentation on the Implementation of Controls to Address Account Delinquency
paragraphs: Per DOJ policy, employees are required to pay their balances in full by  the due date on their billing statement. Delinquency in payment of travel  cards may result in disciplinary action and could affect the employee’s  security clearance. According to DOJ policy, as a control to ensure that  travel cardholders respond if they become delinquent, the travel card  manager is to send delinquency notices to the supervisors of cardholders  who are late paying their bill. In addition, per DOJ policy, it is expected  that supervisors will talk to the employee about paying the balance on the  travel card. According to Division officials, at the time of our audit the  Travel Card Coordinator was responsible for sending out delinquency  notifications and sent these notices to the section management team for  the cardholder.
Division officials could not provide evidence that these communications  were consistently implemented for delinquent travel charge card accounts  from October 2011 through June 2013. During the period of our review,  Division travel card accounts were suspended due to delinquency 61  times. A total of 49 cardholders had accounts suspended due to  delinquency at some point during the period of our review, with 11  cardholders facing account suspension multiple times. Furthermore, 4 of  the 49 cardholders with suspended accounts were managers in the  Division. We requested all delinquency notifications for delinquent  accounts that were suspended from October 2011 through June 2013.  Officials provided delinquent travel card account notices for about 38  percent of the suspensions due to delinquency that we identified. Also,  the documentation provided included evidence that the delinquency was  discussed with the cardholder in approximately 20 percent of the cases  we identified. In one example, the Division cardholder who had the largest  amount of cash advance transactions that could not be matched to  evidence of official travel—over $8,000 during the period of our review— also had the account suspended twice due to delinquency. The Division  could not provide evidence of delinquency notifications for this  cardholder. Officials reported that the reason delinquent account  notification documents were missing was because notifications were sent  by e-mail and documentation was not maintained by the Division Travel  Card Coordinator.
Delinquency in payment can be an indicator of financial distress that  could put the individual at greater risk of abusing his or her travel card— for instance, as noted earlier by padding a travel voucher for expenses  never incurred—or other behaviors that could put Division resources,  information, or reputation at risk. Also, DOJ receives a quarterly refund  payment from the travel charge card contractor based on sales volume  and speed of payment. If a travel charge card account becomes  delinquent, the amount of refund payment that DOJ receives from the  travel card contractor may be reduced.
The Division has taken steps to strengthen oversight of delinquent travel  card accounts since the period of our audit. Division officials report that  they have implemented a new process requiring sections to review  delinquent account information and report to the Division Comptroller and  human resources office if any potential misuse is identified, and the  Division pursues disciplinary action in cases of delinquent accounts that  remain unpaid. Also, a new operating procedure issued in 2014 calls for  monthly distribution of delinquency reports to each section, and historical  maintenance of the distributed reports. However, the new procedure does  not call for maintenance of documentation of communications with the  cardholder, a key component of delinquent-account oversight. If the  Division does not maintain evidence of communications with the  cardholder, it will not have an institutional record to determine whether  staff are implementing this key control, and therefore, if delinquencies  persist, it will not be able to determine whether the underlying cause is  lack of implementation of this control or whether additional adjustments  are needed, such as strengthening controls or different processes.
section_title: Conclusions
paragraphs: Waste, fraud, or abuse of official government travel can significantly affect  the reputation of an agency and undermine public confidence in the  integrity of federal employees, even where travel budgets are relatively  small compared to overall federal spending, as is the case with the  Division. While most Division travel we reviewed followed applicable rules  and policies, we identified weaknesses in compliance with certain policies  and related controls that could lead to travel waste or abuse. Deficiencies  in documenting prior authorization of travel may compromise the  management of fiscal-year travel funds and increase the risk that travel is  not prudent. Also, late travel voucher submissions make managing travel  funds difficult.  Overall, travel rules surrounding authorization and  reimbursement of trips are intended to help ensure that official travel is  carried out in a responsible manner, and are a key component of the  internal control system to help safeguard assets and prevent and detect  errors and fraud. Furthermore, while the Division’s new travel system  includes additional controls over proper justification and approval of  noncontract airfares, the Division has not evaluated whether the new  controls are effective, which would provide the Division with additional  assurance that the controls are functioning as intended or indicate  whether additional actions are needed. In addition, the Division has  implemented new controls to improve oversight of travel charge cards,  including improved oversight of delinquent travel card accounts. However,  without documentation of communications with delinquent account  holders, the Division does not have an institutional record to determine  whether staff are implementing this key control, and therefore, if  delinquencies continue, the Division will not be able to readily identify  whether the underlying cause is lack of implementation of this control or  whether there is a need to strengthen controls or implement different  processes.
section_title: Recommendations for Executive Action
paragraphs: To strengthen controls over Division travel, the Attorney General should  direct the Assistant Attorney General for the Division to take the following  three actions:  1.  To better ensure that travel authorization and reimbursement comply  with rules and regulations, strengthen existing or implement new  internal controls over documenting that travel is authorized in advance and  submitting travel vouchers in the required time frame.
2.  To help ensure that noncontract airfare use is properly authorized and  justified in accordance with travel rules, the Division should evaluate  whether the configuration of its new travel system has implemented  controls to address previous shortcomings in obtaining and  documenting required approvals, and that travelers booking airfares  outside of the system are documenting this decision.  3.  To better document oversight of delinquent travel charge card  accounts in accordance with DOJ policy, take steps to maintain  documentation of communications with delinquent travel cardholders.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of our report to the Attorney General for review and  comment. We received written comments from the DOJ Civil Rights  Division’s (Division) Acting Chief of Staff, which are reproduced in  appendix II. The Acting Chief of Staff concurred with our  recommendations, stating that the Division is committed to the effective  and prudent stewardship of funds, and to continuous improvements in  financial management in support of the Division’s mission. In response to  our first recommendation to strengthen existing or implement new internal  controls over documentation of travel authorization, the Division stated  that it is implementing a new policy in December 2015 requiring written  approval for all travel including cases of urgent travel where authorization  through the travel system is not feasible. If implemented effectively, this  new process should address our recommendation. In response to the  second part of the first recommendation to strengthen existing or  implement new controls over timely submission of travel vouchers, the  Division reported that in late fiscal year 2013 it started distributing monthly  reports to section management with all completed trips that had not been  vouchered, and stated that the Division requires section management to  take action to ensure travelers submit vouchers in a timely manner. In  addition, the Division stated that leadership receives a monthly report with  average number of days that a section’s vouchers are outstanding, for the  purpose of identifying patterns of noncompliance. These new processes  focus on identifying travel vouchers that are likely already late; however, it  is possible that the new processes could improve timely voucher  submission if problem areas are identified and action is taken to enforce  more timely submission among groups that have issues with late  vouchers. In response to our second recommendation regarding controls  to ensure that noncontract airfares are properly authorized and justified,  the Division responded that in cases where flight reservations are made  outside the travel system and cannot be recorded in E2, it will require  travelers to document in E2 whether a purchased flight was a contract or  noncontract fare and to provide evidence of advance approval of any  noncontract fares. If implemented effectively, this new process should  address our recommendation. Lastly, in response to our third  recommendation related to maintaining documentation of communication  with employees with delinquent travel card accounts, the Division stated  that it plans to provide instructions requiring management to document  communications and actions taken with delinquent accountholders, and  provide the documentation to the Division’s Comptroller. If implemented  effectively, this new process should address our recommendation. The  Division and DOJ’s Justice Management Division also provided technical  comments, which we have incorporated as appropriate.
We are sending copies of this report to relevant congressional  committees, the Attorney General, the Assistant Attorney General for the  Division, and other relevant parties. This report will also 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) 512-6722 or bagdoyans@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 III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines the extent to which the Department of Justice (DOJ)  Civil Rights Division (Division) implemented internal controls and  complied with travel policy in key areas: (1) authorization and  reimbursement of travel and (2) use of travel charge cards. To this end,  we interviewed DOJ officials and reviewed travel regulations and policies.  We also analyzed Division travel data from October 2011 through June  2013—the most recent data available when we made our request— including official authorization and voucher data from the Division’s  Financial Management Information System (FMIS), travel card data from  the J.P. Morgan Chase PaymentNet data system, and fair-housing testing  data from the Fair Housing Testing System (FHTS). The data we  analyzed included all trips associated with investigations resulting in a  court case (which we refer to as “cases” in this report) and completed  investigations not resulting in a court case (which we refer to as “closed  investigations”). We estimate that the travel vouchers associated with  cases and closed investigations represented approximately 61 percent of  Division travel. We developed a methodology to test whether the Division  effectively implemented internal controls and complied with policy in key  areas. We excluded travel information related to ongoing investigations  that could result in ongoing litigation.
After identifying important travel controls and requirements as indicated in  federal travel regulations and DOJ travel policies, we tested the  implementation of controls and compliance with key travel policies by  analyzing travel data, reviewing policy documents, interviewing officials,  and comparing findings to criteria from GAO’s Standards for Internal  Control in the Federal Government. We tested the implementation of  controls by analyzing data that indicated whether the control had been  implemented.  In some cases, the data we analyzed directly indicated  whether the control had been implemented, such as through compliance  with policy, and we report on those outcomes. Where we found that  Division travel complied with policy, we did not conduct further testing of  related controls.  In other cases, the data pointed to a weakness that  required additional testing. If we identified a weakness in the  implementation of controls that may have been addressed through a  change in DOJ’s travel system subsequent to our analysis, we evaluated  the design of any related new control as a way of assessing whether the  control weakness had been mitigated.
We performed data-reliability assessments on the FMIS authorization and  voucher data, the PaymentNet travel charge card data, and the FHTS  fair-housing test data. Data-reliability assessments included reviewing  related documentation, interviewing knowledgeable DOJ and J.P. Morgan  Chase officials on how the data are compiled, using control totals, and  comparing records in the file against agency totals for travel vouchers and  charge card transactions. We also performed electronic testing for  completeness and accuracy of data. Overall, our assessment found the  data to be sufficiently reliable for the purposes of this report.
We conducted this performance audit from November 2014 through  November 2015 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.
subsections: section_title: Assessing Internal Controls over Travel Authorization and Reimbursement
paragraphs: To address the first objective of the report, we reviewed travel  authorization and voucher data, as well as travel charge card data from  October 2011 through June 2013—the most recent data available at the  time of our request. DOJ implemented a new travel system in August  2013, and at the time of our request there were not a sufficient number of  trips to evaluate the implementation of controls in the new system.  Our  review included travel conducted by Division employees as well as travel  conducted by other DOJ employees who performed work for the Division  and were authorized and reimbursed by the Division.
We reviewed the implementation of internal controls and compliance with  policy over the travel authorization and voucher process through a  number of analyses. When we identified instances in which the  implementation of controls was not effective, and if the data on  implementation did not directly identify why the controls did not work as  intended, we took additional steps as appropriate to make this  determination. As part of our review, we drew a stratified, random  probability sample of 105 trips generalizable to the 3,157 Division trips in  the scope of this review. We used this sample to analyze the extent to  which officials approving travel were authorized to do so by comparing  the approving signature with a list of individuals authorized to provide  such approvals. Using this sample we also determined the extent to  which authorization was provided in advance of travel by examining the  date of approval and comparing that to the dates of travel. We used this  sample to review approval information for vouchers, including the position  of the approver and whether the position was authorized to approve travel  by comparing the signature to a list of individuals authorized to approve  vouchers. We reviewed whether these vouchers were submitted timely in  accordance with Division policy by looking at the submission date and  determining whether it was within 5 days of completion of travel. We also  determined whether vouchers included all required receipts needed to  justify reimbursement by reviewing this documentation and comparing it  to the requirements of travel policy.
As stated above, our generalizable sample included a total of 105 trips  from the 3,157 trips in the scope of this review (travel within the time  frame of October 1, 2011, through June 30, 2013). The population of trips  was divided into a certainty stratum with the 10 most expensive trips  based on total voucher amount, and a noncertainty stratum with all  remaining trips. The sample comprised all 10 trips in the certainty stratum  and a generalizable random probability sample of 95 trips from the  noncertainty stratum. Each sample element was subsequently weighted  in the analysis to account statistically for all the trips in the population,  including those that were not selected. 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. All percentage estimates from this sample review have 95  percent confidence intervals of plus or minus 10 percentage points or  less, unless otherwise noted. This is the interval that would be expected  to contain the actual population value for about 95 percent of the samples  we could have drawn.
We also examined travel associated with the Fair Housing Testing  program to determine the extent to which fair-housing testing activities  aligned with official travel. We reviewed data from the Fair Housing  Testing System (FHTS) to include fair-housing tests that occurred from  October 2011 through June 2013, and were considered closed by the  Division. As with the travel data, we excluded data related to ongoing  investigations (in this case fair-housing tests) from our review. We  matched fair-housing test dates from FHTS to official travel voucher  dates, and reviewed the length of travel to identify any trips that appeared  longer than necessary given that housing tests normally last 1 day. For  trips that appeared longer than normal, we followed up with the Division  to determine the reason for the longer trip.
As part of our first reporting objective, we also reviewed the extent to  which Division travel included premium airfare—business- or first-class  airfare—and whether premium airfare was authorized and reimbursed in  compliance with travel rules. We identified potential premium travel  through several methods. First, we used the data field “VT_CLASS” in the  FMIS travel voucher data to identify trips categorized as including  premium travel. We reviewed travel documents for a selection of 11 trips  identified in FMIS as including premium airfare to check the extent to  which any premium airfare was properly authorized. The 11 trips were  selected because the transportation costs associated with the trips were  greater than the contract rate for airfare to the destination or there was no  established contract rate. In addition, we used travel charge card  transaction data to identify airfare purchases and compared the cost of  the airfare to General Services Administration (GSA) contract rates for the  travel destination. We identified cases where the airfare purchase  appeared more expensive than the standard contract rate, and we  selected the 10 trips where the difference between the contract rate and  the actual airfare costs were greatest for further review. We reviewed  these 10 travel vouchers and their associated travel documents to confirm  whether the trip included premium airfare, whether the premium airfare  was properly authorized, and what justification was provided for premium  travel. In addition, we also selected the 10 travel vouchers with highest  transportation costs, which would normally indicate cost of airfare, to  review for any premium travel. We also used the travel charge card  transaction data to identify airfare purchases that were on airlines other  than the contract airline for a travel destination, also called noncontract  airfares. We reviewed the 9 vouchers identified as including noncontract  airfares that were the greatest amount above the contract rate. We also  reviewed travel documents for these trips to determine whether the use of  noncontract airfares was properly authorized and justified.
We reviewed travel voucher data and compared reimbursed lodging rates  and meals and incidental expenses (M&IE) rates to the standard GSA  rates for a trip location. We identified all cases where M&IE was greater  than the standard GSA rate using the travel data provided. We also  identified cases where lodging potentially exceeded the standard GSA  rate for the location, and requested and reviewed travel documents for  trips that exceeded the standard lodging rate by $100 or more. We  identified a total of 25 trips where lodging exceeded standard rates by  $100 or more, and examined whether travelers obtained approval to  exceed the standard rate, and the reasons given for the higher rate.
section_title: Travel Charge Card Controls Review
paragraphs: To address the second objective of this report, we reviewed travel charge  card information from the J.P. Morgan Chase PaymentNet system  covering all Division travel cardholders from October 2011 through June  2013—the most recent data available at the time of our request. We  received all transactions data for the period, and information on all  Division cardholders, such as dates accounts were opened or closed. We  reviewed the extent to which Division travel card transactions aligned with  official travel by comparing PaymentNet charge card transactions to travel  voucher travel dates. Because we did not have official travel vouchers for  travel associated with ongoing investigations, we used hotel stays  appearing in the charge card data to identify additional evidence of official  travel. For those purchases that did not align with any signs of official  travel, either in travel vouchers or hotel-stay data, we reviewed the data  for any unusual transactions, such as large-dollar retail transactions,  large-dollar transactions in the Washington, D.C., area, or a number of  purchases in the area of the employee’s duty station in Washington, D.C.  We also reviewed all transactions for any indications of potentially  inappropriate purchases by reviewing the merchant categories of all  purchases and reviewing any individual transactions for those merchants  that appeared unusual for official travel.
In addition to reviewing purchases, we reviewed whether cash advance  transactions aligned with evidence of official travel, and whether cash  advance transactions followed policy rules. We used PaymentNet  transaction data to identify cash advance transactions, and then  compared the timing of these transactions to travel voucher data from  FMIS. For cash advances that could be matched to an official travel  voucher, we compared the amount of cash withdrawn to normally allowed  amounts under DOJ policy—$40 per travel day—to determine whether  the cardholder took out more cash than is normally allowed. We  requested and reviewed travel documents for 11 trips where cash  advances exceeded the normally allowed amounts by $200 or more, and  we reviewed whether the excess cash was authorized. We also identified  cash advance transactions that did not align with evidence of official  travel in FMIS travel voucher data or hotel-stay data in PaymentNet and  reviewed the extent that certain cardholders took cash advances that do  not align with evidence of official travel.
We also took several steps to assess the extent to which travel charge  cards were managed in line with DOJ policy. To review controls over  closure of travel card accounts upon employee separation from the  Division, we used PaymentNet travel charge card account data to  determine all persons with accounts that closed from October 2011  through June 2013. We then provided the Division with a list of these  account holders, and requested that they identify accounts that closed  because of separation from the agency, and provide the date of  separation. We compared the separation date to the account closure date  to determine the extent to which accounts were closed promptly. Lastly,  to review evidence of delinquent account oversight, we requested and  reviewed delinquency notifications for travel cardholders who had  accounts suspended due to delinquency during the period of our review,  October 2011 to June 2013.
section_title: Appendix II: Comments from the Department of Justice Civil Rights Division
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact mentioned above, the following staff members  made significant contributions to this report: Joah Iannotta and Phil Reiff,  Assistant Directors; Celina Davidson, Analyst-in-Charge; Tracy Abdo;  Melinda Cordero; Colin Fallon; Grant Mallie; Erin McLaughlin; Maria  McMullen; James Murphy; Sonya Vartivarian; Shana Wallace; and Chris  Zbrozek.