DOD Joint Travel Regulations: Actions Are Needed to Clarify Flat Rate Per Diem Policy
Published: 2017-05-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In response to government-wide direction for agencies to reduce travel costs, in November 2014 DOD changed its JTR by instituting a flat rate per diem policy on long-term TDY travel. This policy reduced the locality rate payable for each full day at the location, depending on the duration of the TDY: for TDYs of between 31 and 180 days the flat rate per diem is 75 percent, and for TDYs of greater than 180 days it is 55 percent.
The National Defense Authorization Act for Fiscal Year 2016 included a provision that GAO assess the impact of DOD's policy change to the JTR on shipyard and depot workers. This report assesses the extent to which (1) depot officials identified benefits and challenges resulting from the policy change, and any effects on civilian employees and operations; (2) DOD established clear guidance regarding the policy; and (3) DOD followed its processes when considering the policy change and included an assessment of benefits and costs. GAO collected and analyzed responses to a questionnaire disseminated at DOD's 17 depot maintenance industrial sites, reviewed relevant documentation, and interviewed cognizant officials.
section_title: What GAO Found
paragraphs: Officials at depots responding to a GAO questionnaire identified various benefits, such as cost-savings, and challenges, such as increased processing time for vouchers, resulting from the Department of Defense (DOD) Joint Travel Regulations (JTR) flat rate per diem policy change for long-term temporary duty (TDY) travel. While more than half of depot officials reported that the policy has affected civilian employees' willingness to volunteer for long-term TDYs, a majority of depot officials reported that the policy has generally not affected depot operations.
GAO's review of the JTR and analysis of questionnaire responses found that certain aspects of DOD's flat rate per diem policy are not clear. For example, the requirement to provide lodging receipts for long-term travel was replaced by a requirement to provide proof that lodging costs were incurred, but according to depot officials it is not clear what constitutes proof of lodging. As a result, the majority of the depots still require long-term travelers to submit lodging receipts. Such lack of clarity may hinder DOD's ability to achieve the policy's intended objectives, such as simplifying the administrative aspects of travel.
DOD did not ensure that certain required processes established in DOD guidance were completed prior to the policy's approval, and its assessment of the policy's costs and benefits was not comprehensive. Specifically, GAO found that prior to the flat rate per diem policy's approval certain required steps, such as providing cost data and budgetary impact statements and a legal sufficiency review, were not completed. This occurred because DOD has not established procedures to ensure that these required steps are completed prior to approving a major change to the JTR. Further, although DOD's Defense Travel Management Office (DTMO) estimated total savings of approximately $194 million resulting from the flat rate per diem as of January 2017, GAO found that DOD's cost-savings assessment did not comprehensively consider all potential costs and benefits of the policy change. DOD guidance, which applies to all DOD components, establishes responsibilities for following Office of Management and Budget (OMB) Circular A-94 guidelines concerning benefit-cost analysis of federal programs. OMB Circular A-94 states that a comprehensive enumeration of the different types of benefits and costs, monetized or not, can be helpful in identifying the full range of program effects when conducting a benefit-cost analysis of a policy. However, DTMO's assessment of the JTR policy change was not comprehensive and did not include the full range of potential costs and benefits. For example, it included some potential costs to implement the policy, but not others, such as the cost to update the travel system with the needed functionality to support the policy. DTMO has recently developed a draft Performance Measurement Plan, which officials described as a first step in a larger effort to track and report savings from the flat rate per diem policy. However, GAO's review of the draft plan found that it also does not include a comprehensive approach to capture costs and benefits of the policy. As a result, DOD may not be well positioned to understand whether the flat rate per diem policy is cost-beneficial and meeting its objectives to reduce travel costs without negatively affecting the traveler and the mission.
section_title: What GAO Recommends
paragraphs: DOD should clarify certain aspects of the flat rate per diem policy; establish procedures to ensure required steps are completed before major JTR policy changes are approved; and ensure that OMB benefit-cost analysis guidelines are followed in future policy assessments. DOD concurred with all four recommendations and highlighted actions it was taking to address each recommendation.

section_title: Letter
paragraphs: Following the November 2011 Executive Order on Promoting Efficient  Spending that, among other things, required executive agencies to  reduce travel costs by 20 percent below fiscal year 2010 levels, agencies  government-wide have taken steps to do so. In May 2012 the Office of  Management and Budget (OMB) also issued a memorandum that called  on executive agencies to reduce travel costs. The memorandum  specifically required the Department of Defense (DOD) to review the Joint  Travel Regulations (JTR) to ensure, among other things, that DOD’s  policies reduced travel costs, and that DOD employees received per diem  reimbursement-–that is, lodging and meals and incidental expenses  (M&IE)—only to the extent to which costs were incurred. In response to  these government-wide requirements and prior internal efforts to reduce  travel costs, on November 1, 2014, DOD added a flat rate per diem policy  to the JTR for long-term temporary duty (TDY) travel. According to the flat  rate per diem policy, for TDYs of between 31 and 180 days’ duration, the  flat rate per diem is 75 percent of the locality rate (i.e., the per diem rate  for lodging and M&IE expenses) payable for each full day at the location.  For TDYs of greater than 180 days’ duration, the flat rate per diem is 55  percent of the locality rate. In January 2017 Defense Travel Management  Office (DTMO) officials estimated the total savings from the flat rate per  diem policy to be approximately $194 million for travel vouchers approved  between November 2014 and September 2016.
The National Defense Authorization Act (NDAA) for Fiscal Year 2016  included a provision for us to study the effect of policy changes to the JTR  concerning the flat rate per diem for long-term TDY travel. Specifically,  the provision asked us to assess the impact of such changes on shipyard  and depot workers who travel on long-term TDY, and whether the  changes have discouraged civilian employees from volunteering for long- term TDY. In this report, we assess the extent to which (1) depot officials  identified benefits and challenges resulting from the flat rate per diem  policy, and any effects on civilian employees and operations at the  selected depots; (2) DOD established clear guidance regarding the policy;  and (3) DOD followed its processes for considering the flat rate per diem  policy change and included an assessment of benefits and costs prior to  making the change.
To determine the extent to which depot officials identified benefits and  challenges resulting from the flat rate per diem policy, including any  effects on civilian employees and operations at the selected depots, we  focused on DOD civilian employees at DOD’s 17 depot maintenance  industrial sites. We selected the depot maintenance industrial sites  because in their mix of depots they reflect diversity across the military  services, and because they account for a majority of the department’s  depot-level workload. We sent a questionnaire to the 17 depots to obtain  the commanders’ perspectives as well as documentation on the policy’s  benefits and challenges to civilian employees and operations, and we  received responses from all 17. We conducted quantitative and qualitative  analyses of the responses. At the time of our review the flat rate per  diem policy was in effect at 13 of the 17 depots for bargaining unit  employees and at all depots for non-bargaining unit employees, and  therefore we believed that the depots could provide knowledgeable  perspectives on the benefits and challenges of the policy. However,  subsequent to our dissemination of the questionnaire, Marine Corps  officials indicated that civilian employees at the Production Plant in  Barstow, California, never travel on long-term TDY, and therefore we  excluded their questionnaire responses from our analysis related to  benefits and challenges of the policy. We also conducted discussion  groups with depot workers at Puget Sound Naval Shipyard to obtain the  perspectives of civilian employees affected by the policy. Although the  results from the discussion groups are not generalizable, they provide  important insights. We also held interviews with officials from the depots  in the scope of our review, such as Portsmouth Naval Shipyard.
To determine the extent to which DOD established clear guidance  regarding the policy, we reviewed and analyzed the flat rate per diem  policy in the JTR and compared the guidance with the Federal Standards  for Internal Controls related to information and communications to identify  areas of the policy that could be clarified to assist DOD in meeting its  objectives to simplify travel. We also interviewed relevant agency  officials from DTMO and Department of the Navy, Office of Civilian  Human Resources.
To determine the extent to which DOD followed its processes for  considering the flat rate per diem policy change and included an  assessment of benefits and costs prior to making the change, we  analyzed and reviewed the Per Diem, Travel and Transportation  Allowance Committee Organization and Functions Manual and other  relevant documents related to the process, such as memorandums. We  also reviewed Department of Defense Instruction 7041.03, Economic  Analysis for Decision-making, which establishes responsibilities for the  DOD components in following OMB Circular A-94 guidelines for benefit- cost analysis of federal programs. Further, we compared the Per Diem,  Travel and Transportation Allowance Committee’s (hereinafter the  Committee) documents and actions with its Organization and Functions  Manual and relevant guidance included in Committee memorandums.  Additionally, we compared DTMO’s cost-savings assessment with  selected elements in OMB Circular A-94 guidelines for benefit-cost  analysis of federal programs to identify gaps, if any, in the processes or  assessments used when considering the flat rate per diem policy  change. Appendix I discusses our scope and methodology in greater  detail.
We conducted this performance audit from February 2016 to May 2017 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: Background
subsections: section_title: Committee Structure and Coordination of Major Joint Travel Regulations Changes
paragraphs: Changes to the JTR are coordinated through the Committee, which is  responsible for publishing the JTR and evaluating significant travel and  transportation matters, such as the flat rate per diem policy change. The  Committee is chaired by the Deputy Assistant Secretary of Defense for  Military Personnel Policy and also includes Military and Civilian Advisory  Panels (the Advisory Panels), composed of members of each of the  uniformed services, among others. Besides serving as the Committee  Staff and chairing the Advisory Panels, the DTMO is the focal point for  commercial travel and assists in establishing and administering  commercial travel policy within DOD, among other things. Other offices  from across the department also participate on the Committee and  Advisory Panels, but not all members have voting rights. Figure 1, below,  provides an overview of the Committee structure and members.
The Per Diem, Travel and Transportation Allowance Committee  Organization and Functions Manual provides guidance for how the  Committee should operate and coordinate major changes to the JTR, as  described in figure 2, below. Specifically, the Committee coordinates a  proposed major change through a series of memorandums to members of  the Advisory Panels. Memorandum 1 provides the Advisory Panels with  information and instructions concerning the policy change, such as  information concerning the source of the proposed policy change;  examples of the proposed revisions to the JTR; and the due date for  comments. The Advisory Panels’ comments and positions (concurrence  or non-concurrence) concerning a proposed major policy change are  formalized in a subsequent memorandum, described in the guidance as  Memorandum 2. Subsequent to the memorandums, the Advisory Panels  vote to approve the proposed major policy change. Information  concerning the Advisory Panels’ actions and comments regarding the  policy change is then forwarded to the Committee’s members and Chair  for further coordination, review, and approval.
section_title: The Flat Rate Per Diem Policy, Exceptions, and Factors in the Joint Travel Regulations
paragraphs: The flat rate per diem policy for long-term TDY became effective  November 1, 2014. According to DTMO officials, the flat rate per diem  policy change was made in response to government-wide efforts—such  as OMB Memorandum M-12-12—to reduce travel costs, and internal  efforts to simplify DOD’s travel policies. The JTR states that the flat rate  per diem policy applies to long-term TDYs of more than 30 days.  Specifically, the policy reduces the amount of per diem paid for long-term  TDYs: for TDYs of between 31 and 180 days’ duration, the flat rate per  diem is 75 percent of the locality rate payable for each full day at the  location. For TDYs of greater than 180 days’ duration, the flat rate per  diem is 55 percent of the locality rate. Further, the JTR states that there  are exceptions and additional factors related to the flat rate per diem  policy that, under certain circumstances, may affect per diem  reimbursement. These exceptions and factors include the following  circumstances:
Lodging receipts are not required, but proof that lodging costs were  incurred shall be required. The fixed rate per diem may not be  reduced further even if the actual lodging costs incurred are less than  the lodging portion of the reduced per diem.
The Secretary concerned, combatant command commander, or  Director of a DOD agency/component may authorize/approve  payment of actual expenses for M&IE, up to the full locality rate when  the reduced flat rate M&IE is not sufficient, based on the  circumstances of the TDY. Authority may not be delegated below  the three-star general officer/flag officer (or civilian equivalent)  deputy/vice commander level. Travelers requesting reimbursement in  excess of the authorized flat rate M&IE must provide receipts to  substantiate claims for actual expenses unless itemized charges are  documented through the use of the government travel charge card. All  authorizations for payment of actual costs for M&IE for TDYs over 30  days must be reported to the Committee. This waiver was approved  by the Committee Chair in May 2016.
The M&IE portion of the flat rate per diem may be waived in advance  when the mission, health, welfare, or safety of the traveler, TDY to a  foreign location, would result in extreme personal hardship if the M&IE  were reduced. The combatant command commander/joint task force  commander may authorize payment of the full locality rate M&IE when  the reduced flat rate M&IE is not sufficient. Authority may not be  delegated below the three-star general officer/flag officer deputy/vice  commander level. The Secretarial Process for each service may  authorize full per diem M&IE for a traveler who is not located in or part  of the combatant command/joint task force area of responsibility, but  is operating in a support capacity or located in the combatant  command/joint task force area of responsibility. Full per diem M&IE  requests may be authorized, only in advance of the dates required. All  authorizations for payment of full M&IE for TDYs over 30 days must  be reported to the Committee, Chief.
The M&IE portion of the flat-rate per diem policy does not apply to the  Johnston Atoll, Midway Islands, Republic of Palau, or Wake Island  because these locations are deemed to be so remote that the traveler  has very limited access to a food source for meals, such that the cost  of meals exceeds the meal portion of reduced flat rate per diem.
If a traveler is unable to arrange suitable commercial lodging (e.g.,  safe, secure, clean, and within a reasonable proximity to the TDY duty  location) at the flat rate per diem on their own, the Travel  Management Center (i.e., commercial travel office) must be contacted  for assistance. If the Travel Management Center is unable to arrange  suitable lodging at the reduced per diem rate, then the authorizing  official may authorize actual lodging (i.e., full lodging), not to exceed  the locality per diem rate. However, M&IE is still paid at the 75 percent  or 55 percent rate, as applicable.
section_title: Depot Maintenance Industrial Sites and When the Policy Went into Effect at the Different Depots
paragraphs: The military services operate 17 government-owned facilities (i.e., depot  maintenance industrial sites)—such as Anniston Army Depot at Anniston,  Alabama; Air Force Logistic Complex at Ogden, Utah; Norfolk Naval  Shipyard at Portsmouth, Virginia; and Marine Depot Maintenance  Command at Albany, Georgia—that primarily perform depot-level  maintenance on a wide range of vehicles and other military assets,  including helicopters, combat vehicles, ships, aircraft, engines, and  software. According to DOD, in fiscal year 2015 there were approximately  45,000 civilian employees at the depots that perform maintenance and  30,000 other civilian non-maintainers—engineers, scientists, analysts,  and supply specialists—essential to depot maintenance production.  Figure 3, below, provides a map of the depot maintenance industrial sites.
The flat rate per diem policy went into effect at the depots at different  times, in part depending on bargaining with unions. At the time of our  review, the flat rate per diem policy was in effect at 13 of the 17 depots for  bargaining unit employees, and was in effect at all depots for non- bargaining unit employees. Specifically, one depot reported that the policy  was in effect for one, but not all, unions; and three depots reported that  the policy was not yet in effect for bargaining unit employees. Appendix II  provides a list of the depot maintenance industrial sites and the dates  when the policy went into effect at each depot for bargaining and non- bargaining employees.
section_title: Depot Officials Identified Benefits and Challenges of the Policy, with an Effect on Civilian Employees’ Willingness to Volunteer, but Generally No Effect on Depot Operations
paragraphs: Officials at the depots identified both benefits and challenges resulting  from the flat rate per diem policy. Further, while more than half of depot  officials responding to our questionnaire reported that the policy has  affected civilian employees’ willingness to volunteer for long-term TDYs,  the majority of depot officials reported that the policy has not affected  depot operations.
subsections: section_title: Depot Officials Identified Both Benefits and Challenges of the Policy
paragraphs: Depot officials responding to our questionnaire identified some benefits  and some challenges associated with the flat rate per diem policy.
Depot officials reported some benefits associated with the flat rate per  diem policy, including the following:
Flexibility: Depot officials from 3 of the 16 depots reported that a  benefit from the flat rate per diem policy is the flexibility it provides to  depot workers traveling on long-term TDY in choosing how to  distribute their flat rate per diem allotment between lodging and M&IE,  as they no longer have to provide lodging receipts. Additionally, depot  workers in the discussion groups at Puget Sound Naval Shipyard also  indicated that this flexibility was a benefit of the policy.
Cost savings: Depot officials from 6 of the 16 depots reported that a  benefit from the flat rate per diem policy is cost-savings; however,  they were unable to provide documentation of cost-savings that were  attributable to the policy change. Depot officials from 3 of these 6  depots reported that they do not track increased or decreased costs  related to the flat rate per diem policy. In response to a different  question related to costs, depot officials from one depot provided  documentation related to lodging and M&IE savings; however, depot  officials from this depot indicated that the flat rate per diem policy has  resulted in higher overall costs, but they did not provide  documentation to support this statement.
Depot officials also reported some challenges associated with the flat rate  per diem policy, including the following:
Lodging accommodations: Depot officials from 8 of 16 depots  reported that it is more difficult to find lodging accommodations that  will accept the flat rate per diem; that some hotels are not willing to  reduce their rates to accommodate the flat rate; and that some depot  workers are staying in less desirable hotels. These challenges were  confirmed in our meetings with Army depot officials and during  discussion groups at Puget Sound Naval Shipyard. For example, an  official at Anniston Army Depot explained that before the flat rate per  diem policy change was made, booking hotel accommodations for a  team of travelers was accomplished within an hour, but since the  policy change occurred this same process can take up to a day to  look for hotels that will accept the flat rate per diem. Depot workers at  Puget Sound Naval Shipyard explained in our discussion groups that  the accommodations willing to accept the flat rate per diem may be  farther from the job site, which increases the employees’ commuting  time.
Administrative burden: According to the questionnaire responses  we received from depot officials from 4 of the 16 depots, the flat rate  per diem policy is administratively burdensome, in that it has  increased processing and adjustments related to travel. This was also  a challenge explained during a meeting with Puget Sound Naval  Shipyard officials who provided a comparison of voucher-processing  times before and after the flat rate per diem policy change, showing  that the processing time has nearly doubled. According to their  estimates, processing a voucher took up to 10 minutes and  processing an authorization took up to 5 minutes before the policy  change, but after the policy change these tasks have taken twice the  amount of time (20 minutes and 10 minutes, respectively). According  to Puget Sound Naval Shipyard officials, this represents a significant  increase in workload for the four full-time employees who process  travel vouchers. Puget Sound Naval Shipyard officials also said that  they have had to log more overtime hours and will have to hire more  employees in the travel office as a result of the flat rate per diem  policy.
section_title: Depot Officials Reported That the Policy Has Affected Civilian Employees’ Willingness to Travel on Long-term TDYs, but Not Depot Operations
paragraphs: More than half of depot officials responding to our questionnaire reported  that the flat rate per diem policy has affected civilian employees’  willingness to travel on long-term TDYs. Specifically, depot officials from 9  of the 16 depots reported, as seen in figure 4, that depot workers are less  willing to volunteer for long-term TDY as a result of the policy. However,  none of the depot officials from these depots provided documentation of  volunteer rates before or after the policy took effect at their depots, or  documentation of the impacts caused by decreased volunteer rates. In a  related question regarding willingness to volunteer on long-term TDYs,  depot officials from 5 of the 16 depots also reported having to direct depot  workers to travel for such assignments.
The majority of depot officials reported that the flat rate per diem policy  has not had an effect on depot operations. As seen in figure 5, depot  officials from 12 depots reported that there was no meaningful difference  in the quality of work performed by depot workers while on long-term  TDY; 9 depots reported there was no meaningful difference in the ability  to deliver a quality product or in the timeliness of work; and 10 depots  reported that there was no meaningful difference in the ability to perform  the mission as a result of the flat rate per diem policy change. However,  depot officials were unable to provide documentation to support those  statements. In our questionnaire, none of the depot officials from the 16  depots provided documentation for questions related to quality of civilian  work, ability to deliver a quality product, timeliness, or the ability to  perform the mission as a result of the flat rate per diem policy. Officials  from one depot reported in the questionnaire that policies that affect  traveler payment, such as the flat rate per diem policy, do not have any  impact on the quality of work provided to the customer. Further,  Portsmouth Naval Shipyard officials we met with said it is difficult to make  a causal link between operations-related issues, such as slipped  timeframes, and the implementation of the flat rate per diem policy. They  explained that a variety of other issues can affect timeframes, such as  unforeseen repair work that was not identified when the project began.
section_title: DOD Guidance Regarding the Flat Rate Per Diem Policy Is Unclear
paragraphs: Some aspects of DOD’s flat rate per diem policy, such as the guidance  for lodging receipts and application of the M&IE waiver, are not clear. This  unclear guidance may hinder the policy’s achieving its intended  objectives, such as simplifying travel. In its November 2014 changes to  the JTR regarding the flat rate per diem policy, the Committee removed  the receipt requirement for lodging, but it added language that is not clear  regarding what is required to demonstrate that lodging costs were  incurred. Before the flat rate per diem policy was added, the JTR required  travelers to provide receipts for all lodging costs. According to DTMO  officials, the requirement to provide lodging receipts for long-term travel  was removed to simplify the reimbursement process, which had required  long-term travelers to provide lodging receipts and to divide the charges  evenly throughout the travel period, either on a weekly or monthly basis.  According to these officials, those procedures were burdensome for both  the traveler and the approving official. The Deputy Assistant Secretary of  Defense for Military Personnel Policy stated that the removal of the  receipt requirement for long-term TDY was intended to make the process  less stressful for travelers. The lodging receipt guidance in the new flat  rate per diem policy states that lodging receipts are not required, but  proof that lodging costs were incurred shall be required; however, the  policy does not specify what is meant by proof that lodging costs were  incurred. As a result of the unclear guidance, a majority of depots still  require lodging receipts. Based on results from our questionnaire, we  found that 15 out of 16 depots still require long-term travelers to submit  lodging receipts, which is contrary to the intent of the flat rate per diem  policy to simplify the reimbursement process for long-term travelers.  DTMO officials told us that they intentionally did not define “proof of  lodging costs” in the JTR so as not to be too prescriptive. Officials said  that they were concerned that if they were to provide a list, authorizing  officials and travelers would view it as a definitive list.
Similarly, the M&IE waiver, approved by the Committee Chair in May  2016, does not clearly state when long-term travelers should submit  requests to receive actual expenses. While the Deputy Assistant  Secretary of Defense for Military Personnel Policy maintains that the  submission process is clearly explained in the JTR, our review of the JTR  flat rate per diem policy and our contact with depot officials showed that  there was a lack of clarity in the guidance. Specifically, we found that the  flat rate per diem policy does not specify when long-term travelers should  submit requests to receive actual expenses for M&IE—that is, whether  before going on the TDY, or after returning from it. Additionally, we found  that depot officials from across the military services varied as to when the  traveler would receive approval for the M&IE waiver. Army officials said it  would be granted prior to the TDY, while Navy, Marine Corps, and Air  Force officials varied as to when the waiver would be granted. Further, a  senior DTMO official we met with told us that the waiver should be  approved before the traveler leaves for TDY, and that it did not make  sense for the approval to occur after returning from TDY—especially if the  point of the policy is to not harm the traveler. If the waiver were not to be  approved until the traveler returned, the traveler would be unsure during  the trip whether actual expenses for M&IE would be approved.
According to the Standards for Internal Control in the Federal  Government related to information and communications, information  should be recorded and communicated to management and others within  the entity in a form and within a timeframe that enables them to carry out  their internal control and other responsibilities. A senior DTMO official  affirmed that information related to the flat rate per diem policy may not  have been communicated effectively, and that more information regarding  the policy could be included—for example, in DTMO’s newsletter. Without  clear guidance in the JTR relating to the flat rate per diem policy  specifying what is meant by proof of lodging and at what point in the  travel process the M&IE for actual expense should be requested and  approved, the Committee and DTMO may not have assurance that the  policy is meeting stated objectives, such as the simplification of the travel  reimbursement process for long-term TDYs.
section_title: DOD Lacks Procedures to Ensure That Required Processes Are Completed Prior to a Major Change, and Its Assessment of Costs and Benefits Was Not Comprehensive
paragraphs: The Committee does not have procedures to ensure that required  processes are completed prior to finalizing a major JTR change, and its  assessment of costs and benefits was not comprehensive, lacking other  potential costs and benefits that could result from the policy change.
subsections: section_title: The Committee Did Not Ensure That Certain Required Processes Were Completed
paragraphs: The Committee did not ensure that certain required processes to inform  the flat rate per diem policy change were completed prior to the policy’s  approval. According to the Per Diem, Travel and Transportation  Allowance Committee Organization and Functions Manual, the  Committee should follow certain processes when considering a major  change to the JTR. Specifically, the manual states that the Advisory  Panels should provide cost data and budgetary impact statements when  considering major changes to the JTR, among other things.
With respect to cost data and budgetary impact statements, the  November 15, 2013, memorandum (Memorandum 1) from the Committee  to the Advisory Panels stated that the military services must provide the  number of personnel affected and the costs related to the flat rate per  diem for long-term TDY. According to DTMO officials, the military  services were unable to provide the number of affected personnel.  Officials also said that DTMO calculated the number of personnel who  would be affected annually by the flat rate per diem policy using 2013  voucher data from the Defense Travel System, but this calculation did not  include travel data from other DOD systems. According to a May 2010  Under Secretary of Defense for Personnel and Readiness report to  Congress, the Defense Travel System includes only 70 percent of DOD  travel data; approximately 30 percent of the department’s travel is  processed outside of this system. Further, our review of the  Committee’s February 3, 2014, memorandum (Memorandum 2) found  that the Advisory Panel's comments did not include information  concerning the number of personnel affected, and that they provided little  to no information concerning costs. Only the Air Force provided cost  data that were specific to cost-savings that could be achieved as a result  of the flat rate per diem policy. No other comments by members of the  Advisory Panels in Memorandum 2 included information concerning  costs.
Regarding the requirement in the manual to provide cost data and  budgetary impact statements, DTMO officials told us that from their  perspective, the flat rate per diem policy did not have any budgetary  impacts, so they did not prepare these statements. Further, according to  DTMO officials, the military services did not provide any cost data. They  said that there is no requirement for the military services to provide costs,  including administrative costs, to implement a policy change, such as the  flat rate per diem policy. However, these statements contradict the  requirements in the manual and Memorandum 1 from the Committee,  which state that the military services must provide costs related to the flat  rate per diem for long-term TDY.
The process for coordinating legal review is another example of the need  to establish procedures to ensure that required processes to inform major  JTR policy changes are completed prior to the approval of those changes.  According to the Per Diem, Travel and Transportation Allowance  Committee Organization and Functions Manual, legal counsel should  review proposed JTR changes, as requested, to determine their legal  sufficiency. Further, in Memorandum 1 to the Advisory Panels, the  Committee requested that legal counsel provide a statement of legal  sufficiency concerning the flat rate per diem policy change. However, we  could not verify that a legal sufficiency review took place prior to the  policy’s approval. We identified a document in the Committee Chair’s  materials that stated that legal counsel had reviewed and concurred with  the flat rate per diem policy. A similar statement also appeared in other  documents related to the coordination of the flat rate per diem policy  change. However, according to DTMO officials, any documentation  indicating that the policy was coordinated for legal review was incorrect.
In a subsequent meeting, DTMO officials told us that a legal review of the  policy did occur, but that they could not find any documentation of this  review. As such, we were unable to verify that this process was  completed by the Committee when considering the flat rate per diem  policy change prior to the policy’s approval.
The Committee does not have procedures in place to ensure that  required processes, such as completing cost data and budgetary impact  statements and a legal sufficiency review, are completed prior to a major  JTR policy change’s approval. Further, DTMO officials acknowledged the  existence of issues with the process, in light of our review. In October  2016 DTMO officials told us that for future changes it was their intent to  require a signature from legal counsel prior to the Committee’s approval  of a major JTR policy change as a means to document that this process  was completed. Without establishing procedures to track what processes  related to a major JTR change have been completed, the Committee may  lack the full range of information and data necessary to understand how  the policy may affect diverse workforces, such as depots, prior to its  approval.
section_title: DTMO Assessed Cost- savings, but the Assessment Was Not Comprehensive in That It Did Not Assess Other Potential Costs or Benefits That Could Result from the Policy
paragraphs: DTMO conducted a cost-savings (i.e., benefits) assessment to estimate  the savings resulting from the flat rate per diem policy, but that  assessment was not comprehensive and did not assess other potential  costs or benefits that may result from the policy. For example, according  to DTMO officials, they performed their cost-savings assessment in  October 2012 using fiscal year 2011 voucher travel data from the  Defense Travel System. However, as previously noted, the Defense  Travel System contains only 70 percent of department-wide travel data.  Because DTMO’s cost-savings assessment includes only Defense Travel  System data, officials said they believe their reported estimates of cost- savings are lower than the actual cost-savings being realized.
Further, DTMO’s assessment did not assess other potential costs that  would be incurred as a result of the flat rate per diem policy. Specifically,  DTMO did not assess the costs that DOD would incur in administering or  in monitoring and enforcing the new policy, such as the cost to update the  Defense Travel System with the functionality to support long-term  travelers, which, according to DTMO officials, is estimated to cost more  than $650,000. DTMO also did not factor approvals for full lodging into  their cost-savings assessment. DTMO officials told us that they knew that  in some instances the full lodging would be necessary, but they did not  account for them in their cost-savings assessment. According to Army,  Navy, and Air Force depot officials, the travel office has authorized the full  lodging amount to depot workers who are scheduled for, as well as depot  workers who are on, long-term TDY. This factor could reduce DTMO’s  estimate of cost-savings, but 7 of the 16 depots reported that they did not  track when a traveler was authorized full lodging.
DOD Instruction 7041.03, Economic Analysis for Decision-making, which  applies to all DOD components, establishes their responsibility for  following OMB Circular A-94 guidelines concerning benefit-cost analysis  of federal programs. OMB Circular A-94 states that agencies should  follow the guidelines provided when preparing analyses in support of  federal activities, and that a comprehensive enumeration of the different  types of benefits and costs, monetized or not, can be helpful in identifying  the full range of program effects when conducting a benefit-cost analysis  of a policy. Such analyses should also include an evaluation of  alternatives and studies, among other things, to determine whether  anticipated benefits and costs have been realized.
Other potential costs, such as potential effects on travelers’ willingness to  volunteer and on work force morale, were also not assessed in DTMO’s  cost-savings assessment. According to DTMO officials, they did not  anticipate, based on their previous experience with the flat rate per diem  policy for military personnel, that the policy would have a negative effect  on morale or that travelers would refuse to take long-term TDY  assignments. DTMO officials told us that they did not conduct any  analysis concerning the effects of the policy on civilian employees  because they assumed that the 55 percent per diem would work for  civilians as it had worked for military personnel. However, guidance in the  October 1, 2014, version of the JTR stated that a flat rate per diem rate of  55 percent may be authorized for military personnel in a TDY contingency  operation for more than 180 consecutive days at one location, and this  guidance did not apply to civilian employees. Further, a March 2011  report concerning long-term lodging options for DOD travelers—the  results of a study conducted by a private contractor with whom DTMO  had contracted—found that DOD travelers would be unable to secure  long-term travel at 55 percent of the total General Services Administration  per diem rate without a formal negotiated rate program in place. DTMO  does have a pilot program (the Integrated Lodging Pilot Program) for  providing lodging at a reduced rate, but the pilot program is eligible only  for TDY travel up to 30 days. According to DTMO officials, they plan to  include long-term TDYs in the pilot program, but they did not provide a  plan or firm timeframes for this effort.
In assessing the potential effects that might ensue from the change in its  per diem policy, we found that DTMO considered only one alternative per  diem rate for each long-term travel period. DTMO assessed only the cost- savings that would result from changing the policy from one that allowed  travelers the full per diem rate to one that allowed them a fixed  percentage (75 or 55 percent, depending on the length of travel) of that  rate. DTMO did not analyze the potential benefits and costs that might  ensue from other alternatives for reducing travel expenditures, such as  the option of leveraging the General Services Administration’s program to  negotiate minimum discounts with corporate apartment vendors for long- term TDYs, which was provided as an example in the March 2011 report  conducted by the contractor. OMB Circular A-94 guidelines for benefit- cost analysis state that agencies should consider alternative means of  achieving program objectives. Specifically, different alternatives may have  different benefits and costs, and agencies should identify the alternative  that is the most cost-beneficial.
Further, the March 2011 report helped to inform DTMO’s decision  regarding the flat rate per diem rates (75 and 55 percent). However, that  report has some limitations, including that it was based on a limited  number of site locations. Other locations may have actual costs that are  higher or lower than those assumed in the contractor’s study upon which  DTMO’s 75 and 55 percent rates were based. For example, the  contractor that did the study for DTMO focused its analysis on DOD’s top  64 travel destinations in the United States by selecting locations that  covered 80 percent of DOD’s long-term travel volume. According to  DTMO officials, the location data were obtained from the Defense Travel  System, which, as previously noted, contains only 70 percent of  department-wide travel data. Further, no overseas locations were  considered in the report, and the contractor was able to match its data on  extended stay locations to only 30 of DOD’s top 64 locations in the United  States. Based on responses of depot officials to our questionnaire, we  found 10 out of 16 depots identified an overseas location as the location  to which depot workers traveled most frequently for 31 days or more from  August 2015 through July 2016. DTMO officials said that they chose the  75 percent rate instead of the 69 percent rate recommended by the  contractor because they wanted to be conservative and not harm the  traveler. However, DTMO officials acknowledged that they did not  conduct any analysis to assess whether this alternative rate would be  cost-beneficial. DTMO has stated, through its travel newsletter, that it  employs three guiding principles when considering new polices,  programs, and solutions: do no harm, fair compensation, and evidence- based decision making.
DTMO’s studies also did not assess all costs and benefits resulting from  the flat rate per diem policy. Specifically, DTMO officials provided us with  a copy of the draft Performance Measurement Plan, which officials  described as the first step toward formalizing and more clearly  documenting their cost-savings methodology, and is part of a larger effort  to track and report savings from the flat rate per diem policy. However,  our review of that draft plan, which according to DTMO officials was  drafted in July 2016, found that it does not include an approach to capture  other potential costs and benefits from the policy beyond the cost-savings  of the policy. According to OMB Circular A-94, retrospective studies to  determine whether anticipated benefits and costs have been realized are  potentially valuable. Such studies can be used to determine necessary  corrections in existing programs, and to improve future estimates of  benefits and costs in these programs or related ones. Specifically, the  draft plan does not include an approach for identifying potential effects  that may be difficult to quantify or monetize, such as the negative effect of  the policy on morale or travelers’ willingness to go on long-term travel  assignments. Currently the draft plan includes only cost-savings (i.e.,  benefits) resulting from the policy and data from the Defense Travel  System. The draft plan states that data from other DOD travel systems  were possible future data sources. However, the draft Performance  Measurement Plan does not provide a timeframe or plan for when data  from these other sources would be included, and it does not include an  approach to capture the other potential benefits resulting from the policy  beyond the cost-savings. While DTMO officials indicated that other  metrics (to include cost-savings) might be included in the draft plan, the  plan does not include information about these other metrics. Further, we  found that DTMO’s site visit to assess the adequacy of the flat rate per  diem policy for long-term TDYs did not include a full assessment of the  policy’s per diem rates. According to DTMO officials, they conducted site  visits at two locations (Bremerton, Washington, and San Diego,  California) to assess the adequacy of the flat rate per diem at these  locations. However, the site visits (summarized in e-mail) assessed only  the adequacy of the 75 percent flat rate per diem for long-term travel  between 31 and 180 days; they did not assess the adequacy of the 55  percent flat rate per diem for long-term travel greater than 180 days.
Lastly, DTMO officials told us that they anticipated only savings to result  from the flat rate per diem policy, not potential costs. According to DTMO  officials, they did not perform an assessment of the indirect costs to  implement the policy because implementation is a service and agency  responsibility. However, as previously noted, the military services did not  provide any cost data related to the implementation of the policy. Without  having conducted a comprehensive assessment that incorporated  principles from OMB Circular A-94 and without having a Performance  Measurement Plan that considers other potential costs and benefits  resulting from the flat rate per diem policy, the Committee and DTMO  may not be well positioned to understand whether the policy is cost- beneficial and is meeting set objectives to reduce travel costs without  negatively affecting the traveler and mission.
section_title: Conclusions
paragraphs: Depot officials have identified various benefits, such as cost savings, as  well as challenges, such as difficulties in finding lodging accommodations  that will accept the flat rate per diem, resulting from DOD’s JTR flat rate  per diem policy. However, certain aspects of DOD’s flat rate per diem  guidance remain unclear to depot officials. Without clear guidance in the  JTR related to the flat rate per diem policy concerning what is meant by  proof of lodging, and concerning at what point in the travel process the  M&IE for actual expenses should be requested and approved, the  Committee and DTMO may not have assurance that the policy is meeting  stated objectives, such as the simplification of the travel reimbursement  process for long-term TDYs. Further, the Committee did not ensure that  certain required processes were completed prior to the flat rate per diem  policy’s approval, and as a result was not fully informed concerning  potential effects on civilian employees as well as certain costs when it  considered the 2014 flat rate per diem policy change. Without  establishing procedures to track which processes related to a major JTR  change have been completed, the Committee may lack the full range of  information and data necessary to understand how the policy may affect  diverse workforces, such as depots, prior to the change’s approval.  Finally, although DTMO—the office that serves as the Committee’s staff  and assists in establishing and administering commercial travel policy  within DOD—conducted a cost-savings assessment to estimate savings  that could result from the flat rate per diem policy, the assessment was  not comprehensive and did not consider other potential costs and benefits  that could result from the policy. Without having conducted a  comprehensive assessment that incorporated principles from OMB  Circular A-94 and without having a Performance Measurement Plan that  considers other potential costs and benefits resulting from the flat rate per  diem policy, the Committee and DTMO may not be well positioned to  understand whether the policy is cost-beneficial and is meeting set  objectives to reduce travel costs without negatively affecting the traveler  and mission.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Secretary of Defense direct the Per Diem, Travel  and Transportation Allowance Committee, in coordination with the Military  and Civilian Advisory Panels, to take the following four actions to clarify  the flat rate per diem policy and ensure that the department has the full  range of information needed by decision-makers when considering a  major Joint Travel Regulations change:
Revise the Joint Travel Regulations policy related to the flat rate per diem to provide clear language concerning (1) what is meant by proof of lodging, and (2) at what point in the travel process the meals and incidental expenses waiver for actual expenses should be requested and approved;
Establish procedures to ensure that required processes to inform major Joint Travel Regulations policy changes are completed prior to the approval of those changes; Incorporate principles from Office of Management and Budget Circular A-94, including the costs and benefits of effects that may be difficult to quantify or monetize, into future assessments related to major Joint  Travel Regulations changes; and  Incorporate principles from Office of Management and Budget Circular A-94, including the costs and benefits of effects that may be difficult to quantify or monetize, into future assessments related to the flat rate per diem policy, such as the draft Performance Measurement Plan.
section_title: Agency Comments
paragraphs: We provided a draft of this report to the Department of Defense (DOD) for  review and comment. In written comments reproduced in appendix IV,  DOD concurred with all four recommendations and highlighted the actions  it was taking to address each recommendation. These actions include  initiating—through the Per Diem, Travel and Transportation Allowance  Committee—changes to the Joint Travel Regulations (JTR) to clarify the  flat rate per diem policy; establishing procedures to ensure that processes  are completed prior to the approval of a major JTR change; and  incorporating principles from Office of Management and Budget Circular  A-94 into future assessments related to major JTR changes and the flat  rate per diem policy. DOD also indicated that in some instances it may be  challenging to assess actual benefits, which may be difficult to quantify or  monetize, prior to approving a major JTR change.
We are sending copies of this report to the appropriate congressional  committees; the Secretary of Defense; the Secretaries of the Army, the  Navy and the Air Force; and the Commandant of the Marine Corps. In  addition, the report is 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) 512-5257 or merrittz@gao.gov. Contact points for our Office  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff members who made key contributions to  this report are listed in appendix V.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine the extent to which depot officials identified benefits and  challenges resulting from the flat rate per diem policy, including any  effects on civilian employees and operations at the selected depots, we  focused on the policy’s effects on Department of Defense (DOD) civilian  employees at DOD’s 17 depot maintenance industrial sites. We selected  the depot maintenance industrial sites because they reflect diversity in  their mix of depots across the military services. We also selected these  sites because although DOD has other depots—such as depot-level  software maintenance activities—the 17 depot maintenance industrial  sites accounted for a majority of the department’s depot-level workload in  fiscal year 2014, for example, according to an Office of the Assistant  Secretary of Defense for Logistics and Materiel Readiness maintenance  overview. We sent a questionnaire to the 17 depots to obtain the  commanders’ perspectives and documentation on the policy’s benefits  and challenges on civilian employees and operations. We received  responses from all 17 depots, and we then analyzed the results. For  questions that elicited closed-ended and quantitative responses, we used  the software system SAS to produce summary output. For questions that  elicited open-ended and qualitative responses, we conducted a content  analysis in which two analysts independently categorized each depot’s  responses. The pair of analysts discussed any discrepancies in their  categorizations until they reached a consensus. When we sent out our  questionnaire, the flat rate per diem policy was in effect at 13 of the 17  depots for bargaining unit employees and was in effect at all depots for  non-bargaining unit employees. Therefore, we believed that the depots  could provide knowledgeable perspectives on the benefits and challenges  of the policy. Subsequently, Marine Corps officials indicated that civilian  employees at the Production Plant in Barstow, California, never travel on  long-term TDY, and consequently we excluded their questionnaire  responses from our analysis related to the benefits and challenges of the  policy.
As part of the questionnaire’s development, a survey specialist and two  independent analysts with expertise in depot maintenance reviewed the  questionnaire. The expert review phase was intended to ensure that  content necessary to understand the questions was included and that  technical terminology included in the questionnaire was correct. To  minimize errors that might occur from respondents interpreting our  questions differently than we intended, we pre-tested our questionnaire  with staff from the budget, travel, and other relevant offices of five depots.  During the pre-tests, conducted in person or by phone, we asked the  officials to read the instructions and each question aloud and to tell us  how they interpreted the question. We then discussed the instructions  and questions with officials to determine whether (1) the instructions and  questions were clear and unambiguous, (2) the terms we used were  accurate, (3) the questionnaire was unbiased, and (4) the questionnaire  did not place an undue burden on the officials completing it, and (5) to  identify potential solutions to any problems identified. We noted any  potential problems and modified the questionnaire based on the feedback  received from the reviewers and pre-tests as appropriate. We sent email  notifications to each depot beginning on September 6, 2016. We sent the  Microsoft Word form questionnaire and a cover email and asked  recipients to fill out the questionnaire and email it back to us within 2  weeks. We closed the questionnaire on November 1, 2016. Overall we  received 17 completed questionnaires, for a response rate of 100  percent.
Because we collected data from every depot we selected and we are not  generalizing results to other depots, there was no sampling error.  However, the practical difficulties of conducting any survey may introduce  errors, commonly referred to as non-sampling errors. For example,  differences in how a particular question is interpreted, the sources of  information available to respondents, how the responses were processed  and analyzed, or the types of people who do not respond can influence  the accuracy of the survey results. We took steps in the development of  the questionnaire, the data collection, and the data analysis to minimize  these non-sampling errors and help ensure the accuracy of the answers  that were obtained. For example, a social science survey specialist  designed the questionnaire, in collaboration with analysts having subject  matter expertise. Then, as noted earlier, the draft questionnaire was pre- tested to ensure that questions were relevant, clearly stated, and easy to  comprehend. The questionnaire was also reviewed by internal subject  matter experts and an additional survey specialist, as mentioned above.
Data were electronically extracted from the Word questionnaires into a  comma-delimited file that was then imported into a statistical program for  quantitative analysis and Excel for qualitative analysis. Only one variable  was manually entered (the name of the depot), and that data entry  accuracy was verified. We examined the questionnaire results and  performed computer analyses to identify inconsistencies and other  indications of error, and we addressed such issues as necessary.  Quantitative data analyses were conducted by a survey specialist using  statistical software. An independent data analyst checked the statistical  computer programs for accuracy. Content analyses of open-ended  responses were conducted by two analysts with subject matter expertise.  A standard coding scheme was developed, and the two analysts  independently coded each depot’s response. The pair of analysts then  discussed any discrepancies in their coding until they reached  consensus.
The verbatim wording of key questions from our questionnaire whose  results are discussed in this report is located in appendix III.
To obtain the perspectives of civilian employees affected by the flat rate  per diem policy, we conducted four discussion groups at Puget Sound  Naval Shipyard—two discussion groups with bargaining unit employees,  and two discussion groups with managers and supervisors of bargaining  unit employees. We selected Puget Sound Naval Shipyard because, of  the 17 depot maintenance industrial sites, it has the most civilian  employees, and because it had implemented the flat rate per diem policy  for non-bargaining and bargaining unit employees shortly after the policy  became effective. We also held interviews with officials from Anniston  Army Depot, Portsmouth Naval Shipyard, and Puget Sound Naval  Shipyard regarding the benefits and challenges of the flat rate per diem  policy. These results were not generalizable but provided important  insights.
To determine the extent to which DOD established clear guidance  regarding the policy, we reviewed and analyzed the flat rate per diem  policy in the Joint Travel Regulations (JTR) and compared it with Federal  Standards for Internal Controls related to information and  communications to identify areas of the policy that could be clarified to  assist DOD in meeting set objectives to simplify travel. We also  interviewed relevant agency officials from the Defense Travel  Management Office (DTMO); the Per Diem, Travel and Transportation  Allowance Committee's (hereinafter the Committee) Chair (i.e., the  Deputy Assistant Secretary of Defense for Military Personnel Policy); and  Department of the Navy, Office of Civilian Human Resources, regarding  the guidance related to the flat rate per diem policy. We also included  questions in the questionnaire sent to the 17 depots concerning the flat  rate per diem policy’s guidance regarding proof of lodging costs and the  May 2016 meals and incidental expenses waiver, as well as contacted  depot officials from the Army, Navy, Air Force, and Marine Corps.
To determine the extent to which DOD followed its processes for  considering the flat rate per diem policy change and included an  assessment of benefits and costs prior to making the change, we  analyzed and reviewed the Per Diem, Travel and Transportation  Allowance Committee Organization and Functions Manual and other  relevant documents related to the process, such as memorandums. We  compared the Committee’s documents and actions with its manual and  relevant guidance included in the Committee’s memorandums to identify  gaps, if any, in the process used. We also reviewed DOD Instruction  7041.03, Economic Analysis for Decision-making, which establishes  responsibilities for the DOD components in following Office of  Management and Budget (OMB) Circular A-94 guidelines for benefit-cost  analysis of federal programs. Further, we compared DTMO’s cost savings  assessment to selected elements in OMB Circular A-94 guidelines for  benefit-cost analysis of federal programs to identify gaps, if any, in the  assessment. Specifically, we focused on key elements of OMB Circular  A-94 for conducting a benefit-cost analysis, such as whether DTMO  conducted a benefit-cost or cost-effectiveness analysis when considering  the flat rate per diem policy; a comprehensive enumeration of the different  types of benefits and costs, monetized or not; an evaluation of  alternatives; and retrospective studies, which are potentially valuable, to  determine whether anticipated benefits and costs have been realized.
We focused on these key elements because the stated purpose of OMB  Circular A-94 is to promote efficient resource allocation through well- informed decision-making by the federal government. Further, the  guidance states that it serves as a checklist of whether an agency has  considered and properly dealt with all the elements for sound benefit-cost  analyses. We also reviewed a March 2011 report concerning long-term  lodging options for DOD travelers, which DTMO contracted with a private  contractor to conduct. We interviewed officials from DTMO and various  members of the Military and Civilian Advisory Panels from across the  military services to gain further information and clarification regarding the  Committee’s processes, as well as perspectives regarding the costs and  benefits of the policy. To obtain information about the source data that the  DTMO used to inform its cost-savings assessments resulting from the flat  rate per diem policy we interviewed officials from the Defense Travel  System Program Management Office, who provided us with specific  information concerning the system’s capabilities and the quality of travel  data, such as data related to lodging and meals and incidental expenses.
We conducted this performance audit from February 2016 to May 2017 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.
section_title: Appendix II: Status of the Flat Rate Per Diem Policy at the Seventeen Depot Maintenance Industrial Sites
paragraphs: The flat rate per diem policy went into effect at the various depot  maintenance industrial sites at different times. Table 1 below provides a  list of the depot maintenance industrial sites and the dates when the  policy went into effect at each depot, for bargaining and for non- bargaining employees.
section_title: Appendix III: Key Questions from our Questionnaire on the Flat Rate Per Diem Policy for Depots
section_title: Appendix IV: Comments from the Department of Defense
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, key contributors to this report  were Marilyn Wasleski, Assistant Director; and David Ballard, Vincent  Buquicchio, Rebecca Guerrero, Timothy Guinane, Kelly Turner, Amie  Lesser, Michael Silver, Natalie Swabb, and Cheryl Weissman.