oversight

Defense Travel: DOD Should Strengthen Its Ongoing Actions to Reduce Improper Travel Payments

Published by the Government Accountability Office on 2019-08-15.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

              United States Government Accountability Office
              Report to Congressional Addressee




              DEFENSE TRAVEL
August 2019




              DOD Should
              Strengthen Its
              Ongoing Actions to
              Reduce Improper
              Travel Payments




GAO-19-530
                                               August 2019

                                               DEFENSE TRAVEL
                                               DOD Should Strengthen Its Ongoing Actions to
                                               Reduce Improper Travel Payments
Highlights of GAO-19-530, a report to
congressional addressee




Why GAO Did This Study                         What GAO Found
Improper payments—including                    The Department of Defense’s (DOD) Defense Travel System (DTS)—the primary
payments that should not have been             system DOD uses to process travel payments—accounts for most of DOD’s
made or were made in an incorrect              travel payments. DOD spent $18.3 billion on DTS travel payments from fiscal
amount—are a long-standing,                    years 2016 through 2018, while incurring a reported $965.5 million in improper
significant challenge in the federal           travel payments. In that period, DOD averaged $6.1 billion in DTS travel
government. Both GAO and the DOD               payments and $322 million in improper travel payments annually. Not all
Inspector General have reported on             improper travel payments—such as legitimate payments that initially lacked
problems related to improper payments          supporting documentation―represented a monetary loss to the government.
in DOD’s travel pay program.                   Officials said DOD first estimated a monetary loss from improper travel payments
                                               in fiscal year 2017. For fiscal years 2017 and 2018 it estimated a total monetary
This report examines (1) the amount
                                               loss of $205 million out of $549 million in improper DTS payments (see fig.).
DOD spent on DTS travel payments for
fiscal years 2016 through 2018 and             Defense Travel System Total and Improper Travel Payments (Fiscal Years 2017 and 2018)
how much of those payments DOD
estimated to be improper and the
extent to which DOD has (2)
implemented its Remediation Plan and
(3) identified travel payment errors, the
root causes of those errors, and the
cost-effectiveness of addressing root
causes. GAO analyzed fiscal years
2016 through 2018 data on DTS
payments, reviewed DOD’s Plan and
documentation, interviewed officials
about implementation efforts, and
surveyed 52 DOD components about
steps taken to address improper travel
payments.

What GAO Recommends
GAO made 5 recommendations,
including that DOD consider data on
                                               In October 2016, DOD established a Remediation Plan to reduce improper travel
improper payment rates in its
                                               payments and a committee to monitor implementation of the plan at 10 DOD
remediation approach; define the term
                                               components. DOD selected these 10 components because they accounted for a
“root cause”, and consider cost
                                               significant percentage of total travel payments. However, DOD did not take into
effectiveness in deciding how to
                                               account the components’ own estimates of their improper payment rates. As of
address improper payments. DOD
                                               March 2019, only 4 of the 9 components that responded to GAO’s survey had
generally concurred with 4
                                               completed all of the plan’s requirements, in part because of a lack of milestones
recommendations, but did not concur
with revising its approach for selecting
                                               in the plan and ineffective monitoring for required actions. As a result, DOD does
components to implement its
                                               not have reasonable assurance that its actions have been sufficient.
Remediation Plan, stating that it has          DOD has mechanisms to identify errors leading to improper travel payments, and
already taken actions that address this        some components have developed specific corrective plans to address the
issue. GAO believes the                        errors. However, GAO found that these efforts did not clearly identify the root
recommendation remains valid.                  causes of the errors, in part because there is no common understanding of what
                                               constitutes the root cause of improper travel payments. DOD components also
View GAO-19-530. For more information,         have not incorporated considerations of cost-effectiveness into decisions about
contact Elizabeth Field at (202) 512-2775 or   whether to take actions that could reduce improper payments. Without
fielde1@gao.gov.                               addressing these issues, DOD will likely miss opportunities to implement the
                                               changes necessary to address the root causes of improper travel payments.
                                                                                          United States Government Accountability Office
Contents


Letter                                                                                 1
               Background                                                              5
               DOD Spent $18.3 Billion on DTS Travel Payments for Fiscal
                 Years 2016 through 2018, Including an Estimated $965.5
                 million in Improper Travel Payments for Those Years                   9
               DOD Has Taken Steps to Implement Its Remediation Plan, but Its
                 Approach May Not Manage Risk Sufficiently, Many Actions
                 Remain Incomplete, and Communication of Requirements Was
                 Lacking                                                             15
               DOD Has Implemented Mechanisms to Identify Errors Leading to
                 Improper Travel Payments, but these Efforts Do Not Clearly
                 Identify the Root Causes of These Errors or the Cost-
                 Effectiveness of Addressing Them                                    25
               Conclusions                                                           30
               Recommendations for Executive Action                                  31
               Agency Comments and Our Evaluation                                    32

Appendix I     DOD Components Included in GAO’s Web-Based Survey                     36



Appendix II    Objectives, Scope, and Methodology                                    38



Appendix III   Comments from the Department of Defense                               44



Appendix IV    GAO Contact and Staff Acknowledgments                                 47


Tables
               Table 1: DOD Defense Travel System Payment Amounts by Trip
                       Purpose Fiscal Years 2016 – 2018 (dollars in millions)        11
               Table 2: Requirements Specified in DOD’s October 2016 Travel
                       Pay Improper Payments Remediation Plan                        16
               Table 3: DOD’s October 2016 Travel Pay Improper Payments
                       Remediation Plan Requirements Completed as of March
                       2019                                                          21
               Table 4: DOD Components Included in GAO’s Web-Based Survey            36




               Page i                                           GAO-19-530 Defense Travel
Figures
          Figure 1: Defense Travel System Payments by Personnel Type
                   (Fiscal Years 2016 through 2018)                             10
          Figure 2: Defense Travel System Travel Payments (Fiscal Years
                   2016 through 2018)                                           12
          Figure 3: Defense Travel System Total and Improper Travel
                   Payments (Fiscal Years 2017 and 2018)                        14




          Page ii                                          GAO-19-530 Defense Travel
Abbreviations

CO                 Certifying Officers
DAO                Departmental Accountable Officials
DCFO               Defense Chief Financial Officer
DFAS               Defense Finance and Accounting Service
DOD                Department of Defense
DODIG              Department of Defense Office of Inspector General
DTMO               Defense Travel Management Office
DTS                Defense Travel System
FMR                Financial Management Regulation
IPERA              Improper Payments Elimination and Recovery Act
IPERIA             Improper Payments Elimination and Recovery
                   Improvement Act
IPIA               Improper Payments Information Act
OMB                Office of Management and Budget
OUSD (Comptroller) Office of the Under Secretary of Defense
                   (Comptroller)
SAO                Senior Accountable Official




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Page iii                                                        GAO-19-530 Defense Travel
                       Letter




441 G St. N.W.
Washington, DC 20548




                       August 15, 2019

                       The Honorable Gary Palmer
                       House of Representatives

                       Dear Mr. Palmer:

                       Improper payments—payments that should not have been made or were
                       made in an incorrect amount—are a long-standing, significant problem in
                       the federal government, estimated at about $151 billion for fiscal year
                       2018. 1 Both we and the Department of Defense Inspector General
                       (DODIG) have reported on problems related to improper payments in the
                       Department of Defense (DOD) travel pay program. DOD travel payments
                       are made to active and reserve or guard servicemembers and civilian
                       employees and cover travel for both temporary duty and permanent
                       change of station. DOD’s Defense Travel System (DTS) is the primary
                       system used to process travel payments and accounts for most of the
                       department’s travel payments. 2 For fiscal year 2018, the department
                       reported $365.32 million in improper payments related to its travel pay
                       program.

                       In March 2019, we reported on our priority open recommendations
                       directed to DOD, including six open recommendations related to improper
                       payments. 3 For example, in 2013, we reported that DOD’s process for
                       estimating and reporting improper travel payments needed to be
                       1
                        Under the Improper Payments Information Act of 2002 (IPIA), as amended, an improper
                       payment is defined as any payment that should not have been made or that was made in
                       an incorrect amount (including overpayments and underpayments) under statutory,
                       contractual, administrative, or other legally applicable requirements. It includes any
                       payment to an ineligible recipient, any payment for an ineligible good or service, any
                       duplicate payment, any payment for a good or service that was not received (except
                       where such payments were authorized by law), and any payment that does not account
                       for credit for applicable discounts. See, 31 U.S.C. § 3321 note. Office of Management and
                       Budget (OMB) guidance also provides that when an agency’s review is unable to discern
                       whether a payment was proper as a result of insufficient or lack of documentation, this
                       payment must also be considered an improper payment.
                       2
                        Department of Defense (DOD) officials stated that Defense Travel System (DTS)
                       payments accounted for most of the travel payments for fiscal years 2016 through 2018.
                       For example, in fiscal year 2018, DTS payments accounted for approximately 83 percent
                       of total DOD travel payments.
                       3
                        GAO, Priority Open Recommendations: Department of Defense, GAO-19-366SP
                       (Washington, D.C.: Mar. 28, 2019).




                       Page 1                                                        GAO-19-530 Defense Travel
improved to meet statutory requirements and Office of Management and
Budget (OMB) guidance. 4 The Improper Payments Elimination and
Recovery Act of 2010 (IPERA) requires the DODIG to report annually on
DOD’s compliance with statutory requirements for estimating and
reporting improper payments; since 2012, the DODIG has consistently
reported that the department has not met those requirements. For
example, the DODIG found that DOD had not published statistically valid
estimates of improper payments for DOD travel in fiscal years 2015
through 2018. 5 In addition, the DODIG has reported on the actions that
DOD has taken to identify the underlying reasons for improper travel
payments. In 2016, the DODIG reported that DOD’s actions to reduce
estimated improper travel payments were inadequate, because the
corrective actions that DOD components had developed did not include
identifying the underlying reasons that authorizing officials had approved
deficient vouchers for payment. 6 Due, in part, to the DODIG’s findings, in
October 2016, DOD developed a DOD Travel Pay Improper Payments
Remediation Plan (Remediation Plan) to reinforce internal controls and
accountability in the DOD travel pay program and help to reduce improper
payments. 7

We conducted this work under the authority of the Comptroller General to
assist Congress with its oversight responsibilities. In this report, we
examine (1) the amount DOD spent on DTS travel payments for fiscal
4
 The Improper Payments Information Act of 2002 (IPIA), as amended by the Improper
Payments Elimination and Recovery Act of 2010 (IPERA) and the Improper Payments
Elimination and Recovery Improvement Act of 2012 (IPERIA), requires agencies to
estimate and report improper payment rates for specific programs each fiscal year. OMB
Circular A-123 provides guidance for agencies to implement the requirements of IPIA, as
amended.
5
 Department of Defense, Office of Inspector General Report No. DODIG-2013-054, DOD
Efforts to Meet the Requirements of the Improper Payments Elimination and Recovery Act
in FY 2012 (March 13, 2013); DODIG-2016-086, DOD Met Most Requirements of the
Improper Payments Elimination and Recovery Act in FY 2015, but Improper Payment
Estimates Were Unreliable (May 3 2016); Report No. DODIG-2017-078, The DOD Did Not
Comply With the Improper Payment Elimination and Recovery Act in FY 2016 (May 8,
2017); Report No. DODIG-2018-115, DOD FY 2017 Compliance With the Improper
Payments Elimination and Recovery Act Requirements (May 9, 2018); and Report No.
DODIG-2019-087, Audit of the DOD’s FY 2018 Compliance With the Improper Payments
Elimination and Recovery Act Requirements (May 15, 2019).
6
 Department of Defense, Office of Inspector General Report No. DODIG-2016-060, DOD
Actions Were Not Adequate to Reduce Improper Travel Payments (March 10, 2016).
7
 Department of Defense, Under Secretary of Defense (Comptroller) Memorandum,
Preventing Travel Pay Improper Payments and Enforcing Recovery (Oct. 7, 2016).




Page 2                                                        GAO-19-530 Defense Travel
years 2016 through 2018 and how much of those payments DOD
estimated to be improper; (2) the extent to which DOD has implemented
its Remediation Plan; and (3) the extent to which DOD has established
mechanisms to identify errors leading to improper travel payments, the
root causes of those errors, and the cost-effectiveness of addressing root
causes.

To address our first objective, we collected data on DTS travel payments
for fiscal years 2016 through 2018, by DOD component and trip purpose,
from the Defense Travel Management Office (DTMO). We used this time
period because DOD issued its plan to remediate improper payments in
2016. We calculated the total payments for that time period, as well as
the average annual payments and subtotals for various categories, such
as the trip purposes that represented the top three highest percentages of
payments. We also collected data from the Defense Finance and
Accounting Service (DFAS) on travel payments made in DTS that were
identified as improper. The data included the dollar amount of those
improper payments that were estimated to result in a monetary loss to the
government, which represent amounts that should not have been paid by
the government and could be recovered.

To assess the reliability of the data we obtained, we reviewed
corroborating documentation, analyzed the data for inconsistencies, and
interviewed service officials about the reliability of the data. We
determined that the data were sufficiently reliable for our reporting
purposes, which were to determine the amount of DOD’s DTS travel
payments and provide insight into the estimated improper travel payment
amounts the department reported for fiscal years 2016 through 2018.
However, we also determined that, based on persistent problems with
DOD’s improper payment estimates that we and the DODIG have
reported since 2013, these data were not sufficiently reliable for other
purposes, such as determining the specific progress DOD has made in
reducing its improper travel payment rates during this time period. 8

To address our second objective, we reviewed documents and met with
officials to discuss DOD’s implementation of its Remediation Plan. We
also conducted a web-based survey in February and March 2019 of travel

8
 GAO, DOD Financial Management: Significant Improvements Needed in Efforts to
Address Improper Payment Requirements, GAO-13-227 (Washington, D.C.: May 13,
2013); DODIG-2013-054; DODIG-2016-086, DODIG-2017-078, DODIG-2018-115, and
DODIG-2019-087.




Page 3                                                  GAO-19-530 Defense Travel
administrators in 52 DOD components to obtain information on their
familiarity with and implementation of the plan. These 52 components
represent the universe of DOD components that manage payments
processed in DTS for official travel by DOD personnel, according to DOD
records, our prior work, and reports by the DODIG. 9 We received 37
completed surveys, for an overall response rate of 71 percent. The survey
results represent the views only of those components that responded and
may not be generalizable to all components.

To address our third objective, we reviewed DOD’s Remediation Plan,
documents related to DOD’s implementation of the Remediation Plan,
and the June 2018 DOD Improper Payments Senior Accountable Officials
Steering Committee Charter. We met with DOD and component officials
to discuss efforts to identify and address root causes of improper travel
payments and conducted a web-based survey of travel administrators in
52 DOD components (as mentioned above) to obtain information on their
efforts to identify and address the root causes of improper travel
payments. We compared the information we obtained with OMB guidance
on how agencies are to identify and address the root causes of improper
payments, 10 as well as the definition of root cause contained in the
template DOD uses for corrective action plans intended to address
improper travel payments. 11 More details on our objectives, scope, and
methodology can be found in appendix II.

We conducted this performance audit from April 2018 to August 2019 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


9
 GAO, Defense Management: DOD Needs to Address Inefficiencies and Implement
Reform across Its Defense Agencies and DOD Field Activities, GAO-18-592 (Washington,
D.C.: September 6, 2018); and DODIG-2016-060. Based on our analysis, we determined
that there are 52 such components, not including offices or sub-units within components.
Please see appendix I for a list of the 52 components and appendix II for more information
on the methodology we used to make this determination.
10
  OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management
and Internal Control, Appendix C, Requirements for Payment Integrity Improvement (June
26, 2018).
11
 Office of the Under Secretary of Defense (Comptroller), Improper Payments: General
Guidance and Best Practices for CAP Development (April 2018).




Page 4                                                         GAO-19-530 Defense Travel
                       the evidence obtained provides a reasonable basis for our findings and
                       conclusions based on our audit objectives.



Background
Travel Pay Roles and   DOD’s travel pay program is comprised of payments made by the
Responsibilities       department to active, reserve, and National Guard service members and
                       civilian employees for temporary and permanent travel expenses. DOD
                       travel is generally documented using authorizations and vouchers. Travel
                       authorizations direct an individual or group of individuals to travel and
                       provide information regarding what travel expenses are authorized to be
                       paid. Travelers submit travel vouchers after the travel is completed to
                       claim reimbursement for the official travel expenses they have incurred. 12
                       There are a number of DOD entities involved in creating, reviewing and
                       approving, paying, and reporting on DOD travel payments:

                       •     Travelers are the service-members and civilian employees engaging
                             in travel who create, amend, and digitally sign travel authorizations
                             and vouchers and are legally liable for submitting false or fraudulent
                             claims for payment.
                       •     Authorizing officials are responsible for authorizing travel and
                             controlling the use of travel funds. The DTS Regulations state that
                             authorizing officials must review, verify, and approve authorizations
                             prior to travel.
                       •     Certifying officers certify vouchers for payment. According to the
                             DOD guidance on DTS, known as the DTS Regulations, certifying
                             officers must implement, maintain, and enforce internal procedures
                             and controls to minimize erroneous payments; they are presumed
                             negligent and may be pecuniarily liable for all improper payments that
                             they certify. 13 Authorizing officials who are also certifying officers
                             review and certify travel vouchers and verify all required supporting
                             documentation before the vouchers are paid. 14


                       12
                        Department of Defense Financial Management Regulation 7000.14-R (May 2019); and
                       Defense Travel Management Office, Defense Travel System Regulations (October 2017).
                       13
                           Defense Travel System Regulations (October 2017).
                       14
                           Defense Travel System Regulations (October 2017).




                       Page 5                                                    GAO-19-530 Defense Travel
                         •    The Defense Travel Management Office (DTMO) oversees and
                              facilitates DTS, including any necessary changes or enhancements to
                              the system. It establishes and maintains the DTS Regulations, which
                              define the responsibilities of users by role and the minimum required
                              training for each user role, among other things. DTMO also maintains
                              DTS travel payment data that are used for estimating and reporting on
                              improper payments.
                         •    The Defense Finance and Accounting Service (DFAS), as part of
                              DOD’s efforts to reduce improper travel payments, is responsible for
                              reviewing a sample of paid DTS travel vouchers to estimate and
                              report improper travel payments. DFAS also provides data on
                              improper travel payments to DOD components on a quarterly basis.
                         •    The Office of the Under Secretary of Defense (Comptroller)
                              compiles DOD-wide data on improper payments annually as part of
                              DOD’s Agency Financial Report. It also oversees and facilitates DOD
                              efforts to reduce improper travel payments.

Improper Payments        The Improper Payments Information Act of 2002, which was later
Information Act (IPIA)   amended by the Improper Payments Elimination and Recovery Act of
                         2010 (IPERA) and the Improper Payments Elimination and Recovery
                         Improvement Act of 2012 (IPERIA), defines an improper payment as any
                         payment that should not have been made or that was made in an
                         incorrect amount (including overpayments and underpayments) under
                         statutory, contractual, administrative, or other legally applicable
                         requirements. 15

                         In accordance with OMB guidance, DOD has identified travel pay as
                         susceptible to improper payments based on the large volume of
                         transactions and high dollar amount of the program. 16 As a program
                         considered susceptible to significant improper payments, DOD travel pay
                         is subject to certain IPIA requirements. Specifically, IPIA, as amended,
                         15
                           Improper Payments Information Act of 2002, Pub. L. No. 107-300 (Nov. 26, 2002),
                         codified as amended at 31 U.S.C. § 3321 note.
                         16
                           OMB requires agencies to establish a systematic method of identifying programs
                         susceptible to significant improper payments. OMB guidance defines significant improper
                         payments as gross annual improper payments in the program exceeding (1) both 1.5
                         percent of program outlays and $10 million of all program payments made during the fiscal
                         year reported or (2) $100 million, regardless of the improper payment percentage of total
                         program outlays. OMB Circular No. A-123, Management’s Responsibility for Enterprise
                         Risk Management and Internal Control, Appendix C, Requirements for Payment Integrity
                         Improvement (June 2018).




                         Page 6                                                        GAO-19-530 Defense Travel
               requires federal executive branch agencies to (1) develop a statistically
               valid estimate of the annual amount of improper payments for programs
               identified as susceptible to significant improper payments, (2) implement
               corrective actions to reduce improper payments and set reduction targets,
               and (3) report on the results of addressing these requirements.

               IPERA also requires executive agencies’ Offices of Inspector General to
               annually determine and report on whether their agencies complied with
               certain IPERA-related criteria. These criteria include the requirements to
               publish a report for the most recent fiscal year that meets OMB reporting
               requirements, publish statistically valid improper payment estimates,
               publish and meet reduction targets for improper payment rates, and
               publish corrective action plans. If an agency does not meet one or more
               of the six IPERA criteria for any of its programs or activities, the agency is
               considered noncompliant with IPERA. The DODIG reported that in fiscal
               year 2018, DOD travel pay was not in compliance with IPIA, as amended,
               for the seventh consecutive year. 17 Specifically, DOD met three of the six
               IPERA-related criteria for its travel pay program, by publishing all required
               information in the Payment Integrity section of its Agency Financial
               Report; conducting program-specific risk assessments; and reporting an
               improper payment rate of less than 10 percent for each of the eight
               programs that included an improper payment estimate in the fiscal year
               2018 Agency Financial Report. However, the DODIG reported that DOD
               did not publish reliable improper payment estimates, include all required
               elements for the descriptions of corrective action plans, or meet its targets
               for reducing improper payments.


OMB Guidance   To meet IPIA requirements, agencies follow guidance issued by OMB for
               estimating improper payments. OMB Circular No. A-123, Appendix C
               instructs agencies to obtain the input of a statistician to prepare a
               statistical sampling and estimation method that produces statistically valid
               estimates of improper payments. 18 Agencies are required to meet a
               number of requirements on the content of the sampling plans, including
               providing clear and concise descriptions of the methods used that also
               address the assumptions used, sample sizes, and precision, among other

               17
                DODIG-2019-087.
               18
                 OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management
               and Internal Control, Appendix C, Requirements for Payment Integrity Improvement (June
               26, 2018).




               Page 7                                                      GAO-19-530 Defense Travel
                          aspects. The guidance also says that agencies should incorporate
                          refinements to their methods based on recommendations from agency
                          staff or auditors, such as their agency Inspector General or GAO,
                          whenever possible.

                          OMB guidance also includes requirements for annual reporting on
                          improper payment estimates. According to the guidance, when calculating
                          a program’s annual improper payment amount, agencies should use only
                          the amount paid improperly. For example, if a $100 payment was due, but
                          a $110 payment was made erroneously, then the amount applied to the
                          annual estimated improper payment amount should be $10. In addition,
                          when an agency’s review is unable to discern whether a payment was
                          proper as a result of insufficient or lack of documentation, this payment
                          must also be considered an improper payment.

                          OMB also requires agencies to identify and report on the root causes of
                          the improper payments and implement corrective actions to prevent and
                          reduce these causes for programs that have been identified as
                          susceptible to significant improper payments, including DOD’s travel pay
                          program. OMB emphasizes that, in identifying root cause, it is important
                          to distinguish between what constitutes a root cause that created an error
                          and an internal control problem that failed to catch an error. The guidance
                          instructs agencies to implement corrective actions that are responsive to
                          root causes, are proportional to the severity of the associated amount and
                          rate of the root cause, and are measurable. It also instructs agencies to
                          annually review their existing corrective actions to determine whether any
                          action can be intensified or expanded to achieve its intended result.


Methodology DOD Uses to   To comply with IPIA and OMB requirements, and in response to our prior
Calculate Improper        recommendations, DFAS updated its statistical sampling plan in fiscal
                          year 2017 to develop and report improper payment estimates for DTS.
Payment Amounts and
                          The plan is designed to estimate the dollar amount of improper payments,
Rates                     which includes both travel payments that were made in excess of the
                          correct amount (overpayments) and those that were made for less than
                          the correct amount (underpayments). When DOD is unable to discern
                          whether a travel payment is proper because there is insufficient or no
                          documentation to support it, that payment is also included in the improper
                          payment estimate.

                          On a monthly basis, DFAS statistically samples paid travel vouchers,
                          stratified first by component and then by dollar amount. DFAS officials
                          then conduct a review of the sampled post-payment vouchers to identify


                          Page 8                                              GAO-19-530 Defense Travel
                            erroneous travel vouchers and the types of errors that were made. Based
                            on the errors found during the review, DFAS calculates an estimate of the
                            improper payments for each component. The military services process a
                            small portion of their travel payments through other disbursing systems
                            and are responsible for conducting their own post-payment reviews to
                            estimate the improper payments for those systems. The DOD improper
                            payment rate is the estimated total of improper payments from all post-
                            payment reviews divided by the total number of payments. For example,
                            in fiscal year 2018, DOD reported an improper payment rate of 4.59
                            percent, or $365.32 million of the $7.96 billion total travel payments.



DOD Spent $18.3
Billion on DTS Travel
Payments for Fiscal
Years 2016 through
2018, Including an
Estimated $965.5
million in Improper
Travel Payments for
Those Years
DOD Data Show an            Using DTS data, we calculated that DOD had spent an average of $6.1
Average of $6.1 Billion a   billion annually on DTS travel payments in fiscal years 2016 through
                            2018—a total of about $18.3 billion in travel payments for those years.
Year in DTS Travel
                            Travel for active duty servicemembers accounted for the largest portion of
Payments for Fiscal Years   those travel payments. We calculated that DOD components reported
2016 through 2018, and      over $9.5 billion in DTS travel payments for active duty servicemembers
Travel Spending Increased   in fiscal years 2016 through 2018, accounting for approximately 52
during that Period          percent of the total travel payments. For the same time period, DTS travel
                            payments for DOD civilian employees totaled about $5.3 billion (29
                            percent of the total), and travel payments for Reserve and Guard
                            members totaled about $3.5 billion (19 percent of the total) (see fig. 1).




                            Page 9                                              GAO-19-530 Defense Travel
Figure 1: Defense Travel System Payments by Personnel Type (Fiscal Years 2016
through 2018)




Note: The total travel payments were calculated using data reported in the Defense Travel System
(DTS) and do not include payments that were processed in other travel systems used by DOD, such
as the Air Force Reserve Travel System and the Windows Integrated Automated Travel System.
DOD officials stated that DTS payments accounted for most of the travel payments for fiscal years
2016 through 2018. For example, in fiscal year 2018, DTS payments accounted for approximately 83
percent of total DOD travel payments.


DOD data on DTS travel payments show that out of 10 different
categories used to identify the purpose of travel, the category
representing “training” accounted for the largest percentage of the travel
payments. Payments for “training attendance” accounted for about $6.6
billion (36 percent) of the $18.3 billion in total travel payments for fiscal
years 2016 through 2018 (see table 1). Payments for the trip purpose
“other travel” accounted for about $3.1 billion (17 percent) of the total
travel payments for that time period. “Other travel” is any travel for
reasons not covered by the other trip purpose categories; the purpose
must be further specified in the travel authorization. Based on our
analysis, most travel categorized as “other travel” was further specified
with the trip type “routine TDY,” which refers to a travel assignment to a
location other than the employee’s permanent duty station. The two other
trip purposes that accounted for the highest percentage of travel
payments, based on our analysis of the DTS data, are “special mission”




Page 10                                                             GAO-19-530 Defense Travel
                                                              and “site visit,” which each accounted for about $2.9 billion (16 percent) of
                                                              the total travel payments for fiscal years 2016 through 2018.

Table 1: DOD Defense Travel System Payment Amounts by Trip Purpose Fiscal Years 2016 – 2018 (dollars in millions)

                                             Fiscal year 2016                   Fiscal year 2017              Fiscal year 2018          Fiscal years 2016-2018
                                             Payment          Percent          Payment        Percent        Payment        Percent       Payment      Percent of
Trip Purpose                                  amount           of total         amount         of total       amount         of total      amount           total
                                 a
Training Attendance                              2,038                35.8          2,171           6.1             2,385       36.0          6,595              36
                     b
Other Travel                                       968                17.0          1,010          16.8             1,162       17.5          3,140            17.1
                         c
Special Mission                                    905                15.9            956          15.9             1,073       16.2          2,933              16
             d
Site Visit                                         932                16.4            960          16.0             1,027       15.5          2,920            15.9
                                 e
Information Meeting                                439                 7.7            477           7.9              544         8.2          1,460                8
                                         f
Conference Attendance                              323                 5.7            336           5.6              333         5.0            992              5.4
                                         g
Speech or Presentation                               57                1.0             63           1.0               64         1.0            185                1
                             h
Emergency Travel                                     22                0.4             25           0.4               30         0.5              78             0.4
                                     i
Between Tours Travel                                   7               0.1              7           0.1                6         0.1              20             0.1
                 j
Relocation                                             4               0.1              4           0.1                6         0.1              14             0.1
Source: GAO analysis of Department of Defense (DOD) data. | GAO-19-530

                                                              Note: The percentages of total travel payment amounts were calculated using data reported in the
                                                              Defense Travel System (DTS) and do not include payments that were processed in other travel
                                                              systems used by DOD, such as the Air Force Reserve Travel System and the Windows Integrated
                                                              Automated Travel System. DOD officials stated that DTS payments accounted for most of the travel
                                                              payments for fiscal years 2016 through 2018. For example, in fiscal year 2018, DTS payments
                                                              accounted for approximately 83 percent of total DOD travel payments. Percentages may not total
                                                              because of rounding.
                                                              a
                                                                  Training Attendance—travel to receive training.
                                                              b
                                                               Other Travel—any travel for reasons not covered by the other trip purpose categories; must be
                                                              further specified in the travel authorization.
                                                              c
                                                                Special Mission—travel for non-combat military missions and travel to provide security for a person
                                                              or shipment, among other missions.
                                                              d
                                                               Site Visit—travel to perform operational, managerial activities such as overseeing program activities
                                                              and grant operations, carrying out an audit or inspection, or providing technical assistance.
                                                              e
                                                               Information Meeting—travel to attend meetings to gather career information and seek advice on
                                                              career development, among others.
                                                              f
                                                               Conference Attendance—travel to attend a meeting, retreat, seminar, symposium, or event outside
                                                              the local duty station, or registration fees for an event within the area of the local duty station.
                                                              g
                                                               Speech or Presentation—travel to make a speech or presentation, deliver a paper, or take part in a
                                                              formal program that is not a training course.
                                                              h
                                                               Emergency Travel—return a traveler from a temporary duty assignment to the designated duty
                                                              location to attend to an emergency situation that the traveler would ordinarily have been present for if
                                                              the government had not given the traveler the temporary duty assignment.
                                                              i
                                                                Between Tours Travel—travel conducted by eligible civilian employees, uniformed service members,
                                                              or dependents while at a duty station outside the continental United States, usually in conjunction with
                                                              travel for a permanent change of station or renewal of a tour of duty.
                                                              j
                                                                  Relocation—transfer from one permanent duty station to another.




                                                              Page 11                                                                   GAO-19-530 Defense Travel
Using DTS data, we also calculated that DOD’s reported total travel
payments increased from fiscal years 2016 through 2018, for a total
increase of approximately $1 billion (16 percent) in nominal dollars and
$0.68 billion (11 percent) in constant dollars during fiscal years 2016
through 2018 (see fig. 2).

Figure 2: Defense Travel System Travel Payments (Fiscal Years 2016 through 2018)




Note: The total travel payments were calculated using data reported in the Defense Travel System
(DTS) and do not include payments that were processed in other travel systems used by DOD, such
as the Air Force Reserve Travel System and the Windows Integrated Automated Travel System.
DOD officials stated that DTS payments accounted for most of the travel payments for fiscal years
2016 through 2018. For example, in fiscal year 2018, DTS payments accounted for approximately 83
percent of total DOD travel payments

The DOD officials we interviewed were unable to explain why travel
payments increased during fiscal years 2016 through 2018 but
speculated that overall increases in DOD’s budget likely corresponded
with additional travel expenses. Officials also stated that travel expenses
are tied to DOD’s mission requirements. For instance, DOD military and
civilian personnel provided support to civil authorities in areas such as
humanitarian assistance and disaster recovery during the period of our
review, according to these officials. Travel by DOD personnel to locations
for these missions would contribute to DOD’s travel expenses.




Page 12                                                             GAO-19-530 Defense Travel
DOD Estimated an Annual      According to data provided by DFAS, the annual average of DOD
Average of $322 Million in   improper travel payments was about $322 million for fiscal years 2016
                             through 2018, totaling $965.5 million (or 5.3 percent of total DTS travel
Improper Travel Payments
                             payments) for those years.
for Fiscal Years 2016
through 2018                 •    For fiscal year 2016, DFAS calculated that an estimated $416.6
                                  million in travel payments (7.3 percent of total fiscal year 2016 DTS
                                  travel payments) were improper.
                             •    For fiscal year 2017, DFAS’s estimate of improper payments was
                                  $252.4 million (4.2 percent of total fiscal year 2017 DTS travel
                                  payments). However, data availability issues limited the scope of that
                                  year’s post-payment review, which is used to estimate the improper
                                  payment rate. 19
                             •    For fiscal year 2018, DFAS’s estimate of improper payments was
                                  $296.6 million (4.5 percent of total fiscal year 2018 DTS travel
                                  payments).
                             These improper payment amounts include both overpayments and
                             underpayments and do not necessarily indicate a monetary loss to the
                             government. According to DOD’s Agency Financial Report, payments
                             identified as improper do not always represent a monetary loss. For
                             instance, an otherwise legitimate payment that lacks sufficient supporting
                             documentation or approval is reported as improper but is not considered
                             a monetary loss if documentation or approval is subsequently provided.
                             Monetary loss is an amount that should not have been paid and could be
                             recovered.

                             With respect to monetary loss, DFAS calculated that of the DTS improper
                             payments, the department incurred an estimated $205 million (1.6
                             percent of total DTS travel payments) loss to the government for fiscal




                             19
                                According to DOD documentation, the estimated improper payment amount for fiscal
                             year 2017 was based on data from less than 9 months rather than a full year. Although
                             DOD had complete data on travel payments for fiscal year 2017, a data failure caused an
                             irrecoverable loss of supporting travel documentation for more than three months of that
                             year. As a result, according to DOD documentation, the estimated improper payment
                             amount for fiscal year 2017 was based on less than 9 months of data.




                             Page 13                                                       GAO-19-530 Defense Travel
years 2017 and 2018 (see fig. 3). 20 Specifically, for fiscal year 2017,
DFAS calculated an estimated monetary loss of $97.7 million (1.6 percent
of total DTS travel payments), and for fiscal year 2018, it calculated an
estimated monetary loss of $107.3 million (1.6 percent of total DTS travel
payments).

Figure 3: Defense Travel System Total and Improper Travel Payments (Fiscal Years
2017 and 2018)




Note: The total travel payments were calculated using data reported in the Defense Travel System
(DTS) and do not include payments that were processed in other travel systems used by DOD, such
as the Air Force Reserve Travel System and the Windows Integrated Automated Travel System.
DOD officials stated that DTS payments accounted for most of the travel payments for fiscal years
2016 through 2018. For example, in fiscal year 2018, DTS payments accounted for approximately 83
percent of total DOD travel payments. Payments identified as improper do not always represent a
monetary loss. For instance, an otherwise legitimate payment that lacks sufficient supporting
documentation or approval is reported as improper, if documentation or approval is subsequently
provided. Monetary loss is an amount that should not have been paid and could be recovered.



20
  According to Defense Finance and Accounting Service (DFAS) officials, the post-
payment review process that is used to develop the overall improper payment estimate
includes coding by error type, and certain error types are associated with monetary loss.
These officials stated that through the post-payment review, DFAS identifies the amount
of monetary loss in the sample and extrapolates that number to estimate monetary losses
for the total travel payment population. The officials also stated that fiscal year 2017 was
the first year in which they began tracking the monetary losses specific to DTS travel
payments.




Page 14                                                             GAO-19-530 Defense Travel
                        According to DFAS officials, the monetary losses estimated by DFAS
                        were a result of travel voucher errors such as claiming an expense that is
                        automatically generated by DTS during the booking process, rather than
                        updating the travel voucher with the amount actually paid. Other errors
                        that DFAS considers to indicate a monetary loss to the government
                        include duplicate paid vouchers, mileage paid incorrectly, lodging
                        expenses paid twice, and expenses that do not match the receipts (e.g.,
                        lodging).


                        DOD established and has taken steps to implement a Remediation Plan
DOD Has Taken           aimed at reducing improper travel payments that includes specific
Steps to Implement      requirements for all DOD components as well as a committee to monitor
                        the efforts of 10 components that DOD identified as key to addressing
Its Remediation Plan,   improper travel payments. However, DOD did not consider available data
but Its Approach May    on improper travel payment rates in its selection of these 10 components
                        to implement its risk-based approach. Further, the 10 components have
Not Manage Risk         not fully implemented the Remediation Plan requirements, and other
Sufficiently, Many      components were generally unaware of the requirements in the
                        Remediation Plan and DOD’s broader efforts to resolve and mitigate
Actions Remain          improper travel payments.
Incomplete, and
Communication of
Requirements Was
Lacking




                        Page 15                                             GAO-19-530 Defense Travel
DOD Established a                          In October 2016, DOD established a Remediation Plan for improper
Remediation Plan to                        payments in its travel pay program. 21 The memorandum establishing the
Address Improper Travel                    plan specified that it applied to the Military Departments, Defense
                                           Agencies, Joint Staff, and Combatant Commands. 22 The Under Secretary
Payments and a                             of Defense (Comptroller) noted in the memorandum that the rate of
Committee to Monitor                       improper travel payments had reached an unacceptable level, causing
Implementation by Key                      the department’s program for preventing improper payments to be non-
DOD Components                             compliant with IPERA. Accordingly, the Remediation Plan specified steps
                                           that DOD components were required to take to reverse the department’s
                                           poor performance. Specifically, it stated that the military services, defense
                                           agencies, DOD field activities, Joint Staff, and combatant commands
                                           must each designate in writing a Senior Accountable Official (SAO)
                                           responsible for implementing the plan’s requirements for that component,
                                           train travelers and approving officials, issue guidance on holding
                                           approving officials pecuniarily liable for improper travel payments, and
                                           prepare component-specific remediation plans and identify corrective
                                           actions, among other things. 23 DOD specified that certain steps were to
                                           be completed by November 1, 2016. The requirements specified in
                                           DOD’s Remediation Plan are listed in table 2.

Table 2: Requirements Specified in DOD’s October 2016 Travel Pay Improper Payments Remediation Plan

Requirement as written in remediation plan                                      Frequency                       Due date
Each Principle Staff Assistant, Military Department, and Fourth Estate          One-time                        Not specified
Component must designate in writing a Senior Accountable Official (SAO) at
the Senior Executive Service, general officer, or flag officer level.
Component SAOs will issue guidance to ensure front end internal controls are    One-time                        Not specified
in place to prevent travel pay improper payments.
Component SAOs will send a copy of guidance to the Office of the Under          One-time                        November 1, 2016
Secretary of Defense (OUSD) (Comptroller).
Each SAO must review current training plans and provide an assessment as to     One-time                        November 1, 2016
their effectiveness to the OUSD (Comptroller).



                                           21
                                             Under Secretary of Defense (Comptroller) Memorandum, Preventing Travel Pay
                                           Improper Payments and Enforcing Recovery (Oct. 7, 2016).
                                           22
                                             DOD refers to these organizations collectively as the “DOD components.” For a full list
                                           of the DOD components we included in our review, see appendix I.
                                           23
                                             Based on our analysis, we determined that there are 52 such components, not including
                                           offices or sub-units within components. Please see appendix I for more information on the
                                           methodology we used to make this determination and appendix II for a listing of the 52
                                           components.




                                           Page 16                                                         GAO-19-530 Defense Travel
Requirement as written in remediation plan                                                      Frequency                       Due date
SAO issue guidance on holding Departmental Accountable Officials                                One-time                        November 1, 2016
(DAOs)/Certifying Officers (COs) pecuniarily liable for improper travel
payments.
In coordination with the Defense Travel Management Office (DTMO) and                            Quarterly                       Not specified
Defense Finance and Accounting Service (DFAS), SAOs will review quarterly
feedback DTMO/DFAS-generated reports to determine the effectiveness of
these reports in terms of providing actionable information, identifying
accountability, and identifying opportunities to enhance existing processes,
systems, and reviews.
Upon review of those reports, SAO requires its organization to identify root                    Quarterly                       Quarterly
causes for currently identified improper payments, recommend corrective
actions, and provide estimated completion dates to the Office of the Under
Secretary of Defense (Comptroller).
DOD will reestablish Travel Pay improper payment metrics under the Defense                      Quarterly                       Not specified
Chief Financial Officer’s (DCFO) Financial Operations metrics program.
Quarterly error rates reported by Components will be reviewed. Specific
corrective actions will be implemented to address root causes identified within
the quarterly review.
OUSD/DCFO will chair quarterly meetings to address Military Departments and                     Quarterly                       Not specified
Fourth Estate entities’ top three most frequent errors to assess traveler
accountability and approving official compliance.
All components must provide and document either initial training or refresher                   One-time                        November 1, 2016
training for all travelers and DAOs/COs travel voucher approving/certifying
officials. Training must include specified topics.
Source: GAO analysis of Department of Defense (DOD) Remediation Plan. | GAO-19-530



                                                             DOD officials informed us that they also established a Senior Accountable
                                                             Official Committee (SAO committee) consisting of the SAOs from the 10
                                                             components. The committee provided a mechanism for DOD’s Deputy
                                                             Chief Financial Officer to monitor the implementation of the Remediation
                                                             Plan’s requirements by those components. The SAO committee included
                                                             the four military services and six additional components: the U.S. Special
                                                             Operations Command, the Defense Logistics Agency, the Defense
                                                             Contract Management Agency, the Defense Information Systems
                                                             Agency, the Missile Defense Agency, and the Defense Contract Audit
                                                             Agency. 24 An Office of the Under Secretary of Defense (OUSD)
                                                             (Comptroller) official told us that DOD did not monitor the implementation
                                                             of other components’ efforts to implement the Remediation Plan’s
                                                             requirements.
                                                             24
                                                               The Senior Accountable Official (SAO) committee included SAOs from a total of 13
                                                             member components, but DOD officials told us that 3 of those components (the Office of
                                                             the Under Secretary of Defense (Comptroller), the Defense Finance and Accounting
                                                             Service (DFAS), and the Defense Travel Management Office (DTMO)) served in support
                                                             roles and were not held accountable for completing the Remediation Plan requirements.




                                                             Page 17                                                      GAO-19-530 Defense Travel
                           The SAO committee met four times from January 2017 through
                           September 2017, with a fifth meeting in May 2018. At these meetings,
                           components represented on the committee discussed approaches they
                           had taken to prevent improper travel payments and highlighted examples
                           of best practices to educate travelers and approving officials about how to
                           avoid improper travel payments. In addition, DFAS officials presented the
                           results of monthly post-payment reviews to identify the most common
                           errors associated with improper travel payments. In June 2018, DOD
                           broadened the scope of the SAO committee and chartered the DOD
                           Improper Payments Senior Accountable Officials Steering Committee,
                           which was established to address all programs included in DOD’s
                           improper payments reporting—not just travel pay. 25 As of May 2019, this
                           steering committee had met twice, in December 2018 and again in March
                           2019.


DOD Selected               DOD identified components to include on the SAO committee based on
Components for the SAO     fiscal year 2016 DTS travel payments but did not consider components’
                           improper payment rates as selection criteria. According to OUSD
Committee Based on Total
                           (Comptroller) officials, DOD used a risk-based approach to select the 10
Travel Payments, but Did   components to include in the SAO committee, because these
Not Consider               components accounted for the significant majority of the department’s
Components’ Improper       DTS travel payments. 26 However, as a result of the way in which DOD
Payment Rates              reports its estimated rates of improper travel payments, it is unclear
                           whether there is an association between the volume of DTS travel
                           payments and improper travel payment rates. DOD officials told us that
                           they did not use estimated improper travel rates as a selection criterion
                           because DFAS does not report estimated improper payment rates for all
                           DOD components in its annual agency financial report. Instead, DFAS
                           uses a stratified sampling method for the post-payment review of travel
                           vouchers, which means that the sample sizes for certain individual
                           components—such as smaller defense agencies—may be too small to be


                           25
                            These programs are civilian pay, commercial pay, military health benefits, military pay,
                           military retiree and annuitant benefits, and travel pay.
                           26
                             DTS data for fiscal year 2016 that DOD provided to us indicated that 9 of the
                           components represented on the SAO committee accounted for about 95 percent of DTS
                           travel payments in fiscal year 2016. We could not determine the amount of travel
                                                th
                           payments for the 10 component (U.S. Special Operations Command) from the DTS data
                           provided to us, because the DTS data did not separate travel payments for U.S. Special
                           Operations Command from the other combatant commands and the Joint Staff.




                           Page 18                                                         GAO-19-530 Defense Travel
statistically reliable. 27 As a result, DFAS reports improper payment rates
for the individual military services and U.S. Special Operations
Command, but it reports an aggregate rate for the defense agencies that
DFAS officials told us also includes “joint commands.” 28

Notwithstanding DOD’s current sampling approach for determining
improper payment rates, DOD has previously reported discrete improper
payment rates for components that are not represented on the SAO
committee, and there may be additional data sources on component-
specific improper payment rates. First, a 2016 DODIG report on improper
travel payments presented the results of a DFAS review of DTS vouchers
for 58 DOD components for July through December, 2014, including 48
components not represented on DOD’s SAO committee. 29 Second, DOD
has reported improper payment rates for specific components other than
the military services as part of the Remediation Plan effort. Specifically,
DFAS has reported an improper payment rate for U.S. Special Operations
Command in the quarterly reports it provided to the SAO committee
separately from the aggregate rate it reports for other “joint commands.”
Third, we found that other sources of data on estimated improper travel
payment rates may be available to the department. For example, of the
non-SAO components that responded to our survey, 7 of 28 indicated that
they track their rate of improper travel payments.

Because DOD’s approach to monitoring specific components’
implementation of the Remediation Plan was based solely on the amount
of DTS travel payments, DOD lacks assurance that the components it
selected for greater scrutiny were the ones most at risk for improper travel
payments. Standards for Internal Control in the Federal Government
notes that management can define risk tolerances for defined objectives,
specifically the acceptable level of variation in performance relative to the

27
  For example, DFAS officials told us that the sample may include as few as one voucher
for smaller DOD agencies. DOD agencies are defense organizations separate from the
military departments and are intended to provide a common supply or service across more
than one DOD organization.
28
 “Joint commands” includes the combatant commands and Joint Staff.
29
  Department of Defense, Office of Inspector General Report No. DODIG-2016-060, DOD
Actions Were Not Adequate to Reduce Improper Travel Payments (Mar. 10, 2016). The
58 components listed in the DODIG report did not exactly match our survey population for
reasons including DOD had either eliminated them or consolidated them into other
components, or the components did not meet the selection criteria we discuss in detail in
appendix II.




Page 19                                                       GAO-19-530 Defense Travel
                          achievement of objectives. 30 Federal internal control standards also state
                          that agencies should evaluate whether a risk-based approach is
                          appropriately designed by considering whether it is consistent with
                          expectations for the defined objectives. 31 If the approach is not consistent
                          with expectations, agencies should revise the approach to achieve
                          consistency. In this case, DOD decided to accept the risk associated with
                          targeting its Remediation Plan efforts to only those components that
                          accounted for most of the department’s total travel payments in fiscal year
                          2016. However, without including improper payment rates in its analysis,
                          DOD may have excluded components with lower overall travel payments
                          that had significant improper payment rates. As a result, DOD cannot be
                          assured that it has implemented the Remediation Plan in a way that is
                          both efficient and effective in reducing improper travel payments.


Components that DOD       The 10 components that make up the SAO committee and were identified
Identified as Key to      as key to the effort to reduce improper payments took some steps to
                          address the Remediation Plan requirements but did not complete all of
Addressing Improper
                          the requirements outlined in the Plan. For example, 7 of the 9
Travel Payments Did Not   components that responded to our survey reported that they had
Fully Implement the       designated an SAO. Further, these components indicated that their SAOs
Remediation Plan          had completed some required steps, such as issuing guidance to ensure
                          that front-end internal controls were in place to prevent improper travel
                          payments; reviewing training plans to determine their effectiveness in
                          preventing improper travel payments; and providing initial or refresher
                          training to all travelers and approving officials, among other actions.
                          However, none of the components that responded to our survey had
                          completed all of the requirements by the due date of November 1, 2016.

                          As of March, 2019, when we surveyed the 10 DOD components, only four
                          of the 9 components that responded to our survey had completed all of
                          the requirements (see table 3). For instance, 1 component (the Defense
                          Information Systems Agency) had not developed a component-level
                          remediation plan, and 6 of the 10 components had not developed
                          corrective action plans to address the improper travel payments they
                          identified, as required by the Remediation Plan. OUSD (Comptroller)
                          officials told us that they required only the military services to complete


                          30
                           GAO-14-704G.
                          31
                           GAO-14-704G.




                          Page 20                                               GAO-19-530 Defense Travel
corrective action plans, because these components accounted for about
92 percent of DTS travel payments.

Table 3: DOD’s October 2016 Travel Pay Improper Payments Remediation Plan
Requirements Completed as of March 2019

                                                                           DOD Remediation Plan
    Component                                                              requirements
    U.S. Army                                                              Completed (December 2018)
    U.S. Navy                                                              Partially completed
    U.S. Air Force                                                         Partially completed
                                                                                a
    U.S. Marine Corps                                                      N/A
    U.S. Special Operations Command                                        Partially completed
    Defense Logistics Agency                                               Completed (June 2018)
                                                                                          b
    Defense Contract Management Agency                                     No response
    Defense Information Systems Agency                                     Completed (March 2017)
    Missile Defense Agency                                                 Completed (March 2017)
    Defense Contract Audit Agency                                          Partially completed
Source: GAO analysis of Department of Defense (DOD) documents, GAO survey. | GAO-19-530

Notes: DOD officials told us that the Office of the Under Secretary of Defense (Comptroller), the
Defense Finance and Accounting Service, and the Defense Travel Management Office were also
included in the Senior Accountable Official (SAO) committee. However, because they participated in
leadership or advisory roles, and DOD officials told us they were not expected to complete the
Remediation Plan requirements, they are not listed in this table.
a
 The Navy represented the Marine Corps on the SAO committee, and the Navy’s remediation plan
applies to the Marine Corps.
b
 We were unable to determine whether the Defense Contract Management Agency had completed
the Remediation Plan steps, because component officials did not respond to our survey.


We found that, while DOD established specific milestones for certain
actions in the Remediation Plan, it did not establish milestones for
completing most of the actions. Specifically, as shown in table 2 earlier in
this report, only 5 of the 11 requirements in the Remediation Plan had an
associated due date. Further, while DOD established a mechanism to
monitor whether the components had implemented the Remediation Plan
requirements through the SAO committee, this mechanism was not
effective in holding them accountable for doing so.

For example, at the first SAO committee meeting (January 18, 2017), the
SAOs were told to complete the Remediation Plan requirements by
March 1, 2017, and to be prepared to discuss them at the next SAO
committee meeting. However, at the next meeting (March 29, 2017), only
3 components—the Navy, the Defense Information Systems Agency, and
the Defense Logistics Agency—were prepared to present their


Page 21                                                                              GAO-19-530 Defense Travel
component-level remediation plans to the committee. 32 At the meeting,
the DOD Deputy Chief Financial Officer, serving as the chair of the
committee, emphasized that components needed to document progress
in order to demonstrate that the department was working toward
identifying root causes and implementing corrective action plans to
prevent and reduce improper travel payments. At the May 24, 2018 SAO
committee meeting, 3 additional components—the Air Force, the Defense
Contract Management Agency, and the Missile Defense Agency—
presented their plans to the committee. However, as of March 2019, the
U.S. Special Operations Command and the Defense Contract Audit
Agency had still not presented their plans to the committee.

Standards for Internal Control in the Federal Government states that
management should evaluate performance and hold individuals
accountable for their internal control responsibilities. 33 Accountability is
driven by the tone at the top of an organization and supported by the
commitment to integrity and ethical values, organizational structure, and
expectations of competence, which influence the control culture of the
entity. In addition, the standards state that management should establish
and operate monitoring activities to monitor the internal control system
and evaluate the results.

As we stated earlier in this report, DOD has been challenged by
inaccurate and inconsistent estimates of improper payment rates, which
do not allow for reliably tracking the rate of improper travel payments over
time. By establishing milestones, monitoring progress, and holding
component leadership accountable for the implementation of the
requirements of the Remediation Plan, DOD would have greater
assurance that it has taken sufficient actions to reduce improper travel
payments.




32
  At the March 29, 2017 SAO committee meeting, the Army discussed planned actions for
addressing improper payments. However, at that time, the Army had not developed its
written remediation plan or established timelines for implementation. On June 21, 2017,
the Army completed its remediation plan and submitted it to the Office of the Under
Secretary of Defense (Comptroller). The Army, however, did not present the plan at any
subsequent SAO committee meetings, according to the meeting minutes.
33
 GAO-14-704G.




Page 22                                                      GAO-19-530 Defense Travel
Non-SAO Committee            As we noted above, the department memorandum outlining the
Components Took Some         Remediation Plan was addressed to all components, and DOD officials
                             confirmed that, although they monitored implementation of the
Steps to Implement the
                             Remediation Plan for the 10 components represented on the SAO
Remediation Plan             committee, the 42 components not represented on the SAO committee
Requirements but Were        (non-SAO committee components) were still required to complete the
Generally Unaware of         actions specified in the Plan. However, we found that, based on our
DOD’s Actions in this Area   survey results, half of the components that responded to our survey were
                             unaware of the requirements established in the Remediation Plan. Of the
                             28 non-SAO committee components that completed our survey, 14 (50
                             percent) responded that they were either not at all familiar with the
                             Remediation Plan requirements or only slightly familiar with the
                             requirements. Our survey results and review of DOD documentation also
                             indicate that many of the 42 non-SAO committee components had taken
                             some steps to reduce improper payments, consistent with the
                             Remediation Plan requirements, but had not completed all of the Plan’s
                             requirements. For example, of the 28 non-SAO committee components
                             that completed our survey, 10 (36 percent) responded that they had not
                             designated an SAO or other lead entity in writing, and 8 (29 percent) did
                             not know whether their component had designated a SAO.

                             Our survey results also indicate that most of the components not
                             represented on the SAO committee who responded to our survey were
                             unaware of department efforts to prevent and reduce improper travel
                             payments. Specifically, many of the non-SAO committee components had
                             not been made aware of efforts to implement the Remediation Plan
                             across the department through mechanisms such as the SAO committee
                             meeting minutes or quarterly DFAS reports. Sixteen of the 28 non-SAO
                             committee components who responded to our survey reported that no
                             one from their organization had ever attended an SAO committee
                             meeting, and 11 responded that they did not know if anyone from their
                             component had attended. Further, 15 of the 28 components who
                             responded to our survey reported that they had never received a copy of
                             the official SAO committee meeting minutes, and 13 responded that they
                             did not know whether they had. Nine of the 28 components responded
                             that they did not receive copies of the DFAS quarterly reports on improper
                             payments, which are used to track the types of errors that occur in travel
                             payments and help components to target actions to address them.

                             Standards for Internal Control in the Federal Government states that
                             management should internally communicate the necessary quality




                             Page 23                                             GAO-19-530 Defense Travel
information to achieve the entity’s objectives. 34 Communicating quality
information down, across, up, and around reporting lines to all levels of an
entity contributes to the design, implementation, and operating
effectiveness of this principle.

An OUSD (Comptroller) official confirmed that DOD did not take action to
share information on the Remediation Plan requirements or
implementation efforts with components not represented on the SAO
committee. When DOD made the decision to focus the SAO committee
on 10 components, it did not establish a mechanism or document how
information on Remediation Plan efforts would be communicated to the
non-SAO committee components, which are also required to implement
the Plan. As a result, the components that are not represented on the
SAO committee have not benefited from information on the Plan’s
requirements or lessons learned and best practices that were identified
during the SAO committee effort—which may have helped them to reduce
their improper payments. Providing opportunities for all components to
benefit from the Remediation Plan efforts would give DOD greater
assurance that it has taken steps to reduce its overall improper payment
rate.




34
 GAO-14-704G.




Page 24                                              GAO-19-530 Defense Travel
DOD Has
Implemented
Mechanisms to
Identify Errors
Leading to Improper
Travel Payments, but
these Efforts Do Not
Clearly Identify the
Root Causes of
These Errors or the
Cost-Effectiveness of
Addressing Them
DOD Identified Errors      DOD has established mechanisms to identify and address the errors that
Leading to Improper        most frequently lead to improper travel payments, but we found some
                           limitations with these mechanisms because they did not consistently
Travel Payments but Did
                           identify the root causes of the errors.
Not Clearly Identify the
Root Causes of These       •    DTMO Compliance Tool. In response to a requirement in the National
Errors                          Defense Authorization Act for Fiscal Year 2012, DTMO developed a
                                compliance tool that uses a set of digital queries to automatically
                                review vouchers submitted for payment through DTS to determine
                                whether they meet criteria that indicate the potential for improper
                                payment. 35 According to DTMO, as of fiscal year 2018, the tool had
                                recovered $25 million over 5 years.
                                If a voucher is flagged by this tool, an email is automatically generated
                                to the traveler and approving official associated with that voucher with
                                instructions for correcting the error. For example, the compliance tool
                                flags vouchers with duplicate expenses, such as expenses for lodging
                                or rental cars. However, the tool does not flag all potential improper
                                payments, because it does not identify all types of voucher errors. For
                                instance, according to DTMO officials, the tool cannot identify

                           35
                             National Defense Authorization Act for Fiscal Year 2012, Pub. L. No. 112-81, § 631
                           (2011), codified at 37 U.S.C. § 463.




                           Page 25                                                       GAO-19-530 Defense Travel
    vouchers that have been submitted without required receipts. For
    fiscal year 2018, the average rate for DTS vouchers identified as
    erroneous by the DTMO compliance tool was 0.044 percent. In
    contrast, DOD reported an improper payment rate of 4.5 percent for
    DTS vouchers in fiscal year 2018. In addition, the tool does not
    identify the root causes leading to those errors. Rather, the tool simply
    notifies the traveler and approving official associated with a specific
    voucher with characteristics indicative of a potential improper payment
    and requests that they amend the voucher to remove any errors.

•   DFAS Sampling. Each month, DFAS selects a sample of vouchers
    that have been processed in DTS and assigns staff to review those
    vouchers to determine whether any resulted in an improper payment.
    According to DFAS officials, DFAS provides the results of these
    reviews to the components represented on the SAO committee. DFAS
    also prepares quarterly reports that summarize the most frequent
    errors that lead to improper travel payments and presents these
    reports for discussion at SAO committee meetings. DFAS reports the
    frequency of voucher errors for each military service and U.S. Special
    Operations Command and an aggregate rate for defense agencies
    and joint commands. The DFAS reports also suggest corrective
    actions to address the identified errors. For example, in November
    2018, DFAS reported that the voucher error leading to the third largest
    amount of improper payments was “Lodging—Paid Without a
    Receipt,” which accounted for a total of $21,810 in improper payments
    in that month. The corrective action DFAS suggested was for
    reviewers or approving officials to verify that receipts were uploaded
    to DTS and that any uploaded receipts met the criteria for valid
    receipts. If either of these conditions was not met, the reviewer was to
    return the voucher to the traveler to correct and resubmit.
    However, these corrective actions did not address the root causes of
    those errors. Specifically, neither DFAS nor the SAO committee
    determined why travelers were not uploading receipts for lodging
    expenses or why officials were approving vouchers without receipts.
    According to DFAS reports, errors related to missing lodging receipts
    were among the top 5 errors from October 2016 through June 2017.
    By December 2018, these were was the most common errors DFAS
    identified—accounting for a total of $53,125 in improper payments in
    that month—yet DOD did not develop corrective actions to address
    the root cause (i.e., why travelers were continuing to submit vouchers
    without lodging receipts).




Page 26                                               GAO-19-530 Defense Travel
•   SAO Committee Effort. As we discussed earlier in this report,
    beginning in January 2017, OUSD (Comptroller) convened five
    meetings of the SAOs from 10 components that, according to officials,
    accounted for the majority of DOD travel payments in fiscal year 2016.
    At these meetings, representatives from the components discussed
    approaches they were using to reduce improper travel payments. In
    addition, representatives from DTMO and DFAS presented trends
    resulting from their efforts to identify improper travel payments using
    the DTMO Compliance Tool and DFAS post-pay sampling. These
    presentations conveyed information about the types of voucher errors
    that were leading to improper travel payments, and SAOs in
    attendance discussed how to mitigate those errors. However, our
    review of SAO Committee meeting minutes and the remediation plans
    prepared by those components represented on the committee found
    that the components did not identify the root causes of errors leading
    to improper travel payments.
•   Military Services’ Corrective Action Plans. The military services, in
    coordination with OUSD (Comptroller), developed corrective action
    plans to address improper travel payments. OUSD (Comptroller)
    provided the military services with guidance on developing the
    corrective action plans that states that corrective action plans are
    required to reduce improper payments, as well as to address specific
    audit recommendations and issues of IPERA non-compliance. OUSD
    (Comptroller) also provided the military services with a corrective
    action plan template that instructs them to describe what the plan is
    intended to address, i.e., improper payments, a specific audit
    recommendation, or noncompliance issues. The template also defines
    root causes as “underlying issues that are reasonably identifiable, can
    be controlled by management, and require implementing corrective
    actions to mitigate.” As of May 2019, the military services had
    prepared 12 corrective action plans for the travel pay area. However,
    we found that only 4 of them included specific corrective actions
    addressing the root causes of improper travel payments.
    We also found that the plans varied in terms of their sophistication in
    discussing and identifying root causes. For example, none of the
    corrective action plans prepared by the Air Force targeted the root
    causes of improper travel payments. By contrast, one of the Navy’s
    corrective action plans clearly identified the root cause of an error
    (vouchers being approved without the required forms) and specified
    10 milestones and associated corrective actions to address the root




Page 27                                               GAO-19-530 Defense Travel
     cause. 36 Of the Army’s two corrective action plans, one addressed
     weaknesses in the Army’s sampling plan for determining improper
     payments at overseas offices but did not discuss identifying the root
     causes of improper travel payments, and the other required Army
     travel management officials at overseas offices to improve their
     reporting of improper travel payments to more clearly link corrective
     actions with root causes.

While DOD has taken some positive steps to identify the errors that most
frequently lead to improper travel payments, our review found that
component officials do not have a clear understanding of what constitutes
the “root cause” of an improper travel payment. For example, component
officials who responded to our survey consistently mischaracterized root
causes as the specific errors leading to improper payments (e.g., missing
receipts) rather than the underlying reasons for those errors.

Our survey asked respondents if their component had taken steps to
identify the root causes of voucher errors that led to improper travel
payments in fiscal year 2018 and, if so, to provide examples of root
causes they had identified. 37 While 31 of the 37 (84 percent) components
that responded to the question indicated that they had taken steps to
identify root causes, and 28 (76 percent) indicated that they had taken
steps to address those identified root causes, open-ended survey
responses indicated that the components did not understand the term
“root cause.” Specifically, 24 of the 31 (77 percent) components that
provided open-ended responses with examples of the root causes they
identified cited voucher errors—such as missing receipts—rather than
identifying the root causes for why those errors occurred. This indicates
that the 31 components that responded to this question did not
understand the term “root cause”. It also suggests that the number of
components that actually took actions to address root causes is likely
significantly lower than the numbers reported by the survey respondents.

36
  The milestones included both actions the Navy could take (such as providing additional
training for Navy travelers and approving officials) and actions the Navy needed DTMO to
take (e.g., changes to the DTS web portal interface to create alerts when vouchers are
submitted without required forms).
37
  The survey question also noted that for the purpose of the question we defined root
cause as “the reasons personnel made errors preparing or approving vouchers,” including,
but not limited to, travelers were insufficiently trained on voucher preparation, approvers
did not have sufficient time to review vouchers, and Defense Travel System was not
effectively designed to process vouchers.




Page 28                                                        GAO-19-530 Defense Travel
                          OMB guidance specifies that agencies should ensure they have identified
                          a true root cause of an improper payment, because it is critical to do so in
                          order to formulate effective corrective actions. 38 DOD’s Financial
                          Management Regulation (FMR) states that root causes of improper
                          payments must be identified and corrective plans developed and
                          monitored on a regular basis to ensure that future improper payments will
                          be reduced and eliminated. 39 However, neither DOD’s FMR nor the June
                          2018 charter for the DOD Improper Payments SAO Steering Committee
                          defines the term “root cause.” And while DOD has established some
                          mechanisms to try to help components identify root causes, our survey
                          demonstrates that many travel management officials at DOD components
                          do not clearly understand the meaning of root cause. Specifically, of the
                          31 components that provided examples of what they believed to be the
                          root causes of voucher errors, only 7 provided examples of actual root
                          causes. Until DOD defines the term “root cause” to ensure a common
                          understanding of the term across the department, DOD travel
                          management officials will likely miss opportunities to make changes that
                          could help to address the underlying causes of improper travel payments.


DOD Has Not Determined    All of the corrective action plans prepared by the military services that are
How to Assess the Cost-   intended to identify root causes of improper travel payments specified the
                          costs associated with implementing the corrective actions. While many of
Effectiveness of
                          the actions do not fully address root causes, as previously discussed, it is
Addressing Root Causes    important that the department weighs the cost-effectiveness of its actions.
Once They Have Been       However, we found that the services had not incorporated a consideration
Identified                of cost-effectiveness into their decisions on whether to implement those
                          actions, at least in part because OUSD (Comptroller) had not provided
                          guidance on how they should assess the cost-effectiveness of potential
                          corrective actions. Specifically, the template OUSD (Comptroller)
                          provided to the military services for preparing corrective action plans
                          neither asked for information on costs nor specified how to determine the
                          cost-effectiveness of specific corrective actions. In May 2019, an OUSD
                          (Comptroller) official told us that DOD is considering formulating guidance
                          on how components should determine cost-effectiveness.

                          38
                            Specifically, Appendix C to OMB Circular A-123 defines root cause as something that
                          would directly lead to an improper payment and, if corrected, would prevent the improper
                          payment.
                          39
                           Financial Management Regulation 7000.14-R, Volume 4, Chapter 14, Improper
                          Payments (June 2015).




                          Page 29                                                        GAO-19-530 Defense Travel
              OMB guidance states that agencies should be able to measure the
              effectiveness and progress of each individual corrective action on an
              annual basis. 40 The guidance further states that agencies should annually
              review their existing corrective actions to determine if any existing action
              can be intensified or expanded so that it results in a high return on
              investment in terms of reduced or prevented improper payments.

              Addressing the root causes of improper travel payments can be costly,
              requiring investments in technology changes, among others. For
              example, component officials whom we interviewed and who responded
              to our survey indicated that several of the root causes for improper travel
              payments were related to design flaws in DTS. According to DOD
              officials, a feature of DTS called “Trip Workbook” is used by travelers to
              upload and attach receipts to vouchers. However, “Trip Workbook” is not
              visible to approving officials when they process the voucher for approval
              and payment. As a result, vouchers are being approved without the
              required receipts, because approving officials cannot determine whether
              or not the receipts have been attached. Officials stated that changes to
              DTS are often costly and can take a long time, and in some instances
              they can be more costly than the improper payment amounts they are
              intended to reduce. 41 Without clear guidance to assist components in
              determining whether proposed corrective actions are cost-effective to
              implement, DOD travel management officials will be hampered in making
              informed decisions about which actions to implement and which to leave
              unfunded.


              DOD spent about $6 billion annually in DTS travel payments from fiscal
Conclusions   years 2016 through 2018 for its personnel to travel in support of its
              mission, but since 2012 the DODIG has consistently found the DOD
              travel program to be non-compliant with statutory requirements to mitigate
              improper payments. In 2016, DOD began implementing a Remediation
              Plan to address weaknesses in its management of improper travel
              payments. However, DOD did not consider component-specific improper
              payment rates in addition to overall travel payments when developing its
              risk-based approach to monitoring the implementation of the Plan. Thus,
              40
               OMB Circular A-123, Appendix C.
              41
                DTS is a joint program distributed to users across the department, and is controlled by
              DTMO. Each component has personnel who coordinate with DTMO regarding system
              changes. According to DTMO officials, to change aspects of DTS, components must
              submit a formal change request to DTMO.




              Page 30                                                         GAO-19-530 Defense Travel
                      DOD lacks assurance that the components it selected for greater scrutiny
                      were the ones most at risk for improper travel payments. Further, even
                      the components that DOD determined were critical to implementing the
                      Remediation Plan did not fully implement the Plan’s requirements,
                      because DOD had not established milestones for completing all of the
                      requirements, monitored whether the components had completed them
                      on time, or held them accountable for completing the requirements. In
                      addition, DOD did not establish a mechanism to share the results of the
                      SAO committee’s initiatives to reduce improper payments with travel
                      management officials across the department, limiting opportunities for the
                      components that were not represented on the SAO committee to benefit
                      from Remediation Plan efforts.

                      DOD has taken some positive steps to identify the errors associated with
                      improper travel payments but can do more to effectively and efficiently
                      address the underlying root causes. First, DOD has not established a
                      common definition of root cause so that travel management officials
                      across the department can clearly identify actions needed to address
                      improper travel payments. In the absence of such a definition, the
                      department is limited in its ability to address the underlying reasons for
                      improver travel payments. Second, DOD components lack guidance to
                      assist them in determining the cost-effectiveness of addressing root
                      causes of improper travel payments. Such guidance would help to
                      provide assurance that investments are targeted to actions that are cost
                      effective to implement.


                      We are making five recommendations to DOD.
Recommendations for
Executive Action      The Secretary of Defense should ensure that the Under Secretary of
                      Defense (Comptroller) revises the approach for selecting components to
                      implement the DOD Travel Pay Improper Payments Remediation Plan to
                      consider available improper payment rate data in addition to data on the
                      components’ amount of travel payments. (Recommendation 1)

                      The Secretary of Defense should ensure that the Under Secretary of
                      Defense (Comptroller) expedites completion of the remaining Travel Pay
                      Improper Payments Remediation Plan requirements by establishing
                      milestones for the requirements, monitoring whether the components
                      have completed them on time, and holding components accountable for
                      completing the requirements. (Recommendation 2)




                      Page 31                                             GAO-19-530 Defense Travel
                     The Secretary of Defense should ensure that the Under Secretary of
                     Defense (Comptroller) establishes a mechanism to share the results of
                     the SAO committee’s initiatives to reduce improper travel payments with
                     all appropriate travel management officials across the department.
                     (Recommendation 3)

                     The Secretary of Defense should ensure that the Under Secretary of
                     Defense (Comptroller) takes action to ensure a common understanding of
                     the concept of root cause across the department. This could be done by,
                     among other actions, revising the Financial Management Regulation or
                     the charter for the DOD Improper Payments SAO Steering Committee to
                     include a definition of the term and including a definition of the term in the
                     mechanism used to share the results of the SAO committee’s initiatives to
                     reduce improper travel payments with travel management officials across
                     the department. (Recommendation 4)

                     The Secretary of Defense should ensure that the DOD Deputy Chief
                     Financial Officer directs the chairs of the SAO Committee, with the input
                     of OUSD (Comptroller), DTMO and DFAS, to provide guidance to the
                     components on how to determine whether actions that would address
                     root causes are cost effective to implement. (Recommendation 5)


                     We provided a draft of this report to DOD for review and comment. In its
Agency Comments      written comments, reproduced in appendix III, DOD did not concur with
and Our Evaluation   our first recommendation, partially concurred with our second and fifth
                     recommendations, and concurred with our third and fourth
                     recommendations and outlined its plan to address them. DOD also
                     provided technical comments, which we incorporated in the report where
                     appropriate.

                     In non-concurring with our first recommendation that OUSD (Comptroller)
                     revise the approach for selecting components to implement the DOD
                     Travel Pay Improper Payments Remediation Plan (Remediation Plan) to
                     consider available improper payment data in addition to the amount of
                     travel payments of DOD components, DOD stated that OUSD
                     (Comptroller) had focused implementation of its remediation efforts on the
                     10 components that accounted for approximately 95 percent of the
                     department’s travel pay disbursements in DTS. DOD added that this
                     approach achieved maximum coverage of travel payments, given its time
                     and resource limitations. DOD also stated that improper payment metrics
                     reported by DFAS supported this approach, as these data show that the



                     Page 32                                               GAO-19-530 Defense Travel
military services accounted for 92 percent of DTS travel payments and a
majority of improper travel payments.

We acknowledge in our report that DOD identified the 10 components to
include on the SAO committee because these components accounted for
the significant majority of the department’s fiscal year 2016 DTS travel
payments. However, our report also states that it is unclear whether there
is an association between the volume of DTS travel payments and
improper travel payment rates (measured in terms of the percentage of
DTS travel payments made improperly), because DOD does not routinely
collect data on improper travel payment rates for all components even
though—as we also note in our report—such data are available. As a
result, DOD may have excluded components with relatively lower travel
payments but higher rates of improper payments. DOD’s approach can
serve to reduce DOD’s total improper travel payment amounts, but it may
not fully support a key goal of DOD’s Remediation Plan—to reduce the
risk of improper travel payments. Thus, we continue to believe that DOD
should incorporate improper payment rates into its approach to oversee
the implementation of its remediation efforts.

In partially concurring with our second recommendation that OUSD
(Comptroller) expedite completion of the remaining Remediation Plan
requirements by establishing milestones for the requirements, monitoring
whether the components have completed them on time, and holding
components accountable to completing the requirements, DOD stated
that OUSD (Comptroller) will expedite completion of the Remediation
Plan requirements for the six components that have not yet completed
them. DOD specified that OUSD (Comptroller) will establish milestones
for the remaining requirements, monitor their progress, and hold
components accountable for their completion. DOD stated that it would
complete these actions by January 31, 2020. DOD also reiterated that it
does not believe detailed oversight beyond the largest components is
cost-effective, but noted that it would continue to monitor the non-SAO
components and their impact on improper travel payments. The intent of
our recommendation is to ensure that DOD expedites completion of the
Remediation Plan requirements for, at a minimum, the 10 components
that accounted for a significant majority of DOD’s DTS travel payments.
We believe the planned actions that DOD outlined in its response will
meet the intent of our recommendation. Further, as discussed in our
report, requiring additional components to complete the Remediation Plan
requirements may be warranted if those components have relatively high
improper payment rates. Therefore, DOD’s stated plan to monitor other
components and their impact on improper travel payments would be


Page 33                                             GAO-19-530 Defense Travel
responsive to our recommendation, provided the department holds non-
SAO committee components accountable for addressing high improper
payment rates.

In partially concurring with our fifth recommendation that the DOD Deputy
Chief Financial Officer direct the chairs of the SAO Committee, with the
input of OUSD (Comptroller), DTMO and DFAS, to provide guidance to
the components on how to determine if actions that would address root
causes are cost-effective to implement, DOD stated that OUSD
(Comptroller) will revise the improper payments corrective action plan
template to require reporting components to perform a cost-benefit
analysis to determine the best or most cost-effective solution, resulting in
savings to the department. DOD added that OUSD (Comptroller) will not
provide specific steps to the components on how to determine whether
their actions are, in fact, cost-effective to implement. DOD further stated
that it believes that the criteria and/or appropriate steps to determine
whether corrective actions are cost-effective for a component must be
identified and agreed upon internally within the component. DOD stated
that it would complete these actions by October 31, 2019. The intent of
our recommendation is to ensure that DOD components determine the
cost-effectiveness of actions to address the root causes of improper travel
payments. DOD’s stated plan to require the reporting components to
perform a cost-benefit analysis will meet the intent of our
recommendation, provided that the department ensures that the
components are evaluating the cost-effectiveness of planned corrective
actions that address the root causes of improper travel payments.


We are sending copies of this report to the appropriate congressional
committees, the Secretary of Defense, the DOD Chief Management
Officer, the Under Secretary of Defense (Comptroller), the Secretary of
the Army, the Secretary of the Air Force, the Secretary of the Navy, the
Commandant of the Marine Corps, the Chairman of the Joint Chiefs of
Staff, the Director of the Defense Finance and Accounting Service, and
the Director of the Defense Travel Management Office. In addition, the
report is available at no charge on our website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact
me at (202) 512-2775 or FieldE1@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last




Page 34                                              GAO-19-530 Defense Travel
page of this report. GAO staff who made key contributions to this report
are listed in appendix IV.




Sincerely yours,
Elizabeth Field, Acting Director
Defense Capabilities and Management




Page 35                                             GAO-19-530 Defense Travel
Appendix I: DOD Components Included in
             Appendix I: DOD Components Included in
             GAO’s Web-Based Survey



GAO’s Web-Based Survey

             Table 4: DOD Components Included in GAO’s Web-Based Survey

             Component Type           Component Name
                                                  a
             Military Services        U.S. Army
                                                a
                                      U.S. Navy
                                                       a
                                      U.S. Air Force
                                                           a
                                      U.S. Marine Corps
             Defense Agencies and     Defense Media Activity (DMA)
             DOD Field Activities     Missile Defense Agency (MDA)
                                                                     a


                                      Defense Acquisition University (DAU)
                                      Defense Advanced Research Projects Agency (DARPA)
                                      Defense Commissary Agency (DECA)
                                                                               a
                                      Defense Contract Audit Agency (DCAA)
                                                                                                   a
                                      Defense Finance and Accounting Service (DFAS)
                                                                                           a
                                      Defense Information Systems Agency (DISA)
                                      Defense Intelligence Agency (DIA)
                                                                         a
                                      Defense Logistics Agency (DLA)
                                      Defense Security Service (DSS)
                                      Defense Technical Information Center (DTIC)
                                      Defense Technology Security Administration (DTSA)
                                      Defense Threat Reduction Agency (DTRA)
                                      Department of Defense Education Activity (DODEA)
                                      National Defense University (NDU)
                                      National Geospatial-Intelligence Agency (NGA)
                                      Defense POW/MIA Accounting Agency (DPAA)
                                      Defense Health Agency (DHA)
                                      Court of Appeals for the Armed Forces (CAAF)
                                      Uniformed Services University of Health Sciences (USU)
                                      DOD Inspector General (DOD IG)
                                                                                               a
                                      Defense Contract Management Agency (DCMA)
                                      Defense Security Cooperation Agency (DSCA)
                                      White House Military Office (WHMO)
                                      Defense Microelectronics Activity (DMEA)
                                      Test Resource Management Center (TRMC)
                                                                                   a
                                      Office of the Secretary of Defense (OSD)
                                      Office of Economic Adjustment (OEA)
                                      Office of General Counsel (OGC)
                                                                                       a
                                      Defense Human Resources Activity (DHRA)




             Page 36                                                         GAO-19-530 Defense Travel
Appendix I: DOD Components Included in
GAO’s Web-Based Survey




    Component Type                 Component Name
                                   Washington Headquarters Service (WHS)
                                   Pentagon Force Protection Agency (PFPA)
    Joint Commands                 Joint Chiefs of Staff (JCS)
                                   U.S. Africa Command (AFRICOM)
                                   U.S. Central Command (CENTCOM)
                                   U.S. European Command (EUCOM)
                                   U.S. Northern Command (NORTHCOM)
                                   U.S. Indo-Pacific Command (INDOPACOM)
                                                                                a
                                   U.S. Special Operations Command (SOCOM)
                                   U.S. Southern Command (SOUTHCOM)
                                   U.S. Strategic Command (STRATCOM)
                                   U.S. Transportation Command (TRANSCOM)
                                   Inter American Defense Board (IADB)
                                   Joint Interagency Task Force – West (JIATF-W)
                                   North Atlantic Treaty Organization (NATO)
                                   United Nations Command/US Forces Korea (USFK)
                                   U.S. Military Entrance Processing Command (USMEPCOM)
Source: Department of Defense (DOD) and GAO. | GAO-19-530
a
 Components represented on the Senior Accountable Official Committee (SAO committee) since
establishment of the committee. The SAO committee had a total of 13 member components, but DOD
officials told us that 3 components (the Office of the Under Secretary of Defense (Comptroller), the
Defense Finance and Accounting Service, and the Defense Travel Management Office) served in
support roles and were not held accountable for completing the Remediation Plan requirements.




Page 37                                                               GAO-19-530 Defense Travel
Appendix II: Objectives, Scope, and
              Appendix II: Objectives, Scope, and
              Methodology



Methodology

              Our objectives were to examine (1) the amount the Department of
              Defense (DOD) spent on Defense Travel System (DTS) travel payments
              for fiscal years 2016 through 2018 and how much of those payments
              DOD estimated to be improper; (2) the extent to which DOD implemented
              its Remediation Plan; and (3) the extent to which DOD established
              mechanisms to identify errors leading to improper travel payments, the
              root causes of those errors, and the cost effectiveness of addressing root
              causes.

              To address our first objective, we collected DTS data on travel payments
              for fiscal years 2016 through 2018, by DOD component and trip purpose,
              from the Defense Travel Management Office (DTMO). We used this time
              period because DOD issued its plan to remediate improper payments in
              2016. We calculated the total payments for that time period, as well as
              the average annual payments and subtotals for various categories—such
              as the military services and the trip purposes—that represented the top
              three highest percentages of payments. We discussed with DTMO
              officials how the data were generated and what the data points
              represented. We chose to focus on DTS because it is the primary system
              for processing travel vouchers for DOD, and the vouchers it processes
              account for the majority of DOD travel. 1

              We also collected data from the Defense Finance and Accounting Service
              (DFAS) on travel payments made in DTS that were identified as improper,
              as well as data on the dollar amount of those improper payments that
              were estimated to result in a monetary loss to the government. We
              discussed with DFAS officials the methodology that they used to estimate
              both the improper payment amounts and the portions of those amounts
              that were estimated to be monetary losses to the government. To assess
              the reliability of the data we obtained, we reviewed corroborating
              documentation, analyzed the data for inconsistencies, and interviewed
              service officials about the reliability of the data. We determined that the
              data were sufficiently reliable for our reporting purposes, which were to
              determine the amount of DOD’s DTS travel payments and to provide
              insight into the estimated improper travel payment amounts that the
              department reported for fiscal years 2016 through 2018. However, we
              also determined that, based on persistent problems with DOD’s improper
              payment estimates that we and the DOD Inspector General have reported

              1
               In fiscal year 2018, for example, travel vouchers processed in the Defense Travel System
              (DTS) accounted for 83 percent of all travel payments.




              Page 38                                                       GAO-19-530 Defense Travel
Appendix II: Objectives, Scope, and
Methodology




since 2013, these data were not sufficiently reliable for other purposes,
such as determining the specific progress DOD has made in reducing its
rates of improper travel payments. 2

To address our second objective, we reviewed documents and met with
officials to discuss DOD’s implementation of its Remediation Plan. We
also conducted a web-based survey of officials at DOD components. We
administered the survey from February 4 through March 29, 2019,
soliciting information on the extent to which components had
implemented the Remediation Plan, steps the components had taken to
address improper travel payments, the types of issues that frequently
lead to improper travel payments, and challenges associated with
reducing improper travel payments. We sent this survey to 52
components, 37 (71 percent) of whom responded. 3 More specifically, 9 of
10 (90 percent) components represented on the Senior Accountable
Official (SAO) committee4 (SAO components) responded and 28 of 42
(67 percent) components not represented on the SAO committee (non-
SAO components) responded. 5 The survey results represent the views of
only those components that responded and may not be generalizable to

2
 GAO, DOD Financial Management: Significant Improvements Needed in Efforts to
Address Improper Payment Requirements, GAO-13-227 (Washington, D.C.: May 13,
2013); Department of Defense, Office of Inspector General Report No. DODIG-2013-054,
DOD Efforts to Meet the Requirements of the Improper Payments Elimination and
Recovery Act in FY 2012 (March 13, 2013); Report No. DODIG-2016-086, DOD Met Most
Requirements of the Improper Payments Elimination and Recovery Act in FY 2015, but
Improper Payment Estimates Were Unreliable (May 3 2016); Report No. DODIG-2017-
078, The DOD Did Not Comply With the Improper Payment Elimination and Recovery Act
in FY 2016 (May 8, 2017); Report No. DODIG-2018-115, DOD FY 2017 Compliance With
the Improper Payments Elimination and Recovery Act Requirements (May 9, 2018); and
Report No. DODIG-2019-087, Audit of the DOD’s FY 2018 Compliance With the Improper
Payments Elimination and Recovery Act Requirements (May 15, 2019).
3
 We initially sent the survey to 55 components but later determined that 3 of them had
either been dissolved or subsumed into other components we surveyed. We determined
these 3 to be out of scope and removed them from the overall population. We only
included components’ partial responses if the official completing the survey indicated that
we could do so—of the 3 components that did not fully complete the survey 1 responded
to us that we could use the partial responses in our analysis.
4
 According to Department of Defense (DOD) officials, DOD established a Senior
Accountable Official Committee (SAO committee) with SAOs from 10 of the components
to monitor the implementation of the Remediation Plan’s requirements.
5
 The SAO committee included SAOs from three components in advisory or leadership
roles—we categorized these as non-SAO committee components for the purpose of our
survey analysis, because DOD officials told us that they were not expected to complete
the Remediation Plan requirements.




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Appendix II: Objectives, Scope, and
Methodology




all components. The results of our survey provide measures of
component officials’ views at the time they completed the survey in
February and March 2019. Please see appendix I for a list of the 52
components we contacted.

We selected the population of DOD components to survey by applying
the following criteria: (1) the component was a military service or joint
command, (2) the component was identified as a defense agency or field
activity in our prior work, 6 (3) the component was identified as processing
DTS vouchers in prior DODIG work, 7 or (4) the component was
represented on DOD’s SAO committee as part of the implementation of
DOD’s Remediation Plan. Because we surveyed all DOD components
that met any of the selection criteria we identified, the survey did not
involve sampling errors. A social science survey specialist designed the
questionnaire in collaboration with analysts who had subject matter
expertise. To minimize non-sampling errors, and to enhance data quality,
we employed recognized survey design practices in the development of
the questionnaire and in the collection, processing, and analysis of the
survey data. To minimize errors arising from differences in how questions
might be interpreted and to reduce variability in responses that should be
qualitatively the same, we conducted pretests with six components. To
ensure that we obtained a variety of perspectives on our survey, we
selected an equal number of SAO and non-SAO committee components
with which to pretest the survey. The SAO committee components were
the U.S. Army, the U.S. Air Force, and the U.S. Marine Corps. The non-
SAO committee components were the Defense Media Activity, the
Defense Acquisition University, and the Defense Commissary Agency. An
independent survey specialist within GAO also reviewed a draft of the
questionnaire prior to its administration. To reduce nonresponse, another
source of non-sampling error, we followed up by e-mail and phone with
officials who had not responded to the survey to encourage them to
complete it. The verbatim wording of key survey questions whose results
are discussed in this report is below:

How familiar are you, in responding to this survey on behalf of the #COMPONENT,
with DOD’s Travel Pay Improper Payments Remediation Plan (dated October 1,

6
 GAO, Defense Management: DOD Needs to Address Inefficiencies and Implement
Reform across Its Defense Agencies and DOD Field Activities, GAO-18-592 (Washington,
D.C.: Sep. 6, 2018).
7
 Department of Defense, Office of Inspector General Report No. DODIG-2016-060, DOD
Actions Were Not Adequate to Reduce Improper Travel Payments (Mar. 10, 2016).




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Appendix II: Objectives, Scope, and
Methodology




2016), if at all? (Response options provided: Checkboxes labeled “Very familiar,”
“Moderately familiar,” “Slightly familiar,” “Not at all familiar,” and “No opinion/no
response.”)

Has a lead entity in the #COMPONENT been designated for implementing DOD’s
Travel Pay Improper Payments Remediation Plan (dated October 1, 2016)
requirements? (Response options provided: Checkboxes labeled “Yes, an office has
been designated the lead for this effort,” “Yes, a person has been designated the lead for
this effort,” “No entity has been designated to lead implementation requirements,” and
“Don’t know”)

Has the #COMPONENT designated in writing a Senior Accountable Official (SAO)?
(An SAO is a Senior Executive Service member, general officer, or flag officer designated
by a component as responsible for reducing improper payments.) (Response options
provided: Checkboxes labeled “Yes,” “No, but my component is represented by an SAO in
another component or organization,” “No,” and “Don’t know.”)

As of today, has the #COMPONENT Senior Accountable Official (SAO) completed
each of the following actions specified in the Remediation Plan? If yes, what was
the date the #COMPONENT SAO completed the action? Note: the actions listed here
are stated exactly as specified in DOD’s Travel Pay Improper Payments Remediation
Plan.

          [Action]

    •     Has the #COMPONENT completed this? (Response options provided:
          Checkboxes labeled “Yes,” “No,” and “Don’t know.”)
    •     If yes, what was the month the #COMPONENT completed the action?
          (Response option provided: one text box.)
    •     If yes, what was the year the #COMPONENT completed the action?
          (Response option provided: one text box.)

Has the #COMPONENT completed any of the following actions?

Review Defense Finance and Accounting Service (DFAS) reports on improper travel
payments. (Response options provided: “Yes,” “No,” “Not applicable (do not receive
DFAS reports),” and “Don’t know.”)

Have representatives of the #COMPONENT attended the quarterly Senior
Accountable Official (SAO) meetings since they were first held in January 2017? An
SAO is a Senior Executive Service member, general officer, or flag officer designated by a
component as responsible for reducing improper payments. (Response options provided:
“Yes, a representative of our component attended all of the meetings,” “Yes, a




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Appendix II: Objectives, Scope, and
Methodology




representative of our component attended some, but not all, of the meetings,” “No, a
representative of our component has never attended an SAO meeting,” and “Don’t know.”)

Has the #COMPONENT received a copy of the official minutes of the quarterly
Senior Accountable Official (SAO) meetings since they were first held in January
2017? (Response options provided: “Yes, our component received a copy of the minutes
for all of the meetings,” “Yes, our component received a copy of the minutes for some, but
not all, of the meetings,” “No, our component has not received a copy of the minutes for
any of the SAO meetings,” and “Don’t know.”)

Has the #COMPONENT taken steps to identify the root causes of voucher errors
that led to improper travel payments in fiscal year 2018? Note, for the purpose of this
question we define root causes as “the reasons personnel made errors preparing or
approving vouchers,” including but not limited to: travelers were insufficiently trained on
voucher preparation, approvers did not have sufficient time to review vouchers, and/or
Defense Travel System was not effectively designed to process vouchers. (Response
options provided: “Yes,” “No,” and “Don’t know.”)

What are some examples of root causes of voucher errors that the #COMPONENT
identified in fiscal year 2018? (Response option provided: one text box.)

Has the #COMPONENT taken steps to address any identified root causes of
voucher errors that led to improper travel payments in fiscal year 2018? (Response
options provided: “Yes,” “No,” and “Don’t know.”)

What steps have been taken by the #COMPONENT to address the root causes of
voucher errors that led to improper travel payments in fiscal year 2018? (Response
option provided: one text box.)

Because the majority of survey respondents did not provide open-ended
responses to each question, we did not conduct a formal content analysis
of the responses. We determined that the open-ended responses would
not be representative of all components that responded to our survey,
and we therefore present them only as illustrative examples. To analyze
open-ended comments provided by those responding to the survey, GAO
analysts read the comments, jointly developed categories for the
responses, and flagged relevant responses for inclusion in this report.

To address our third objective, we reviewed DOD’s Remediation Plan,
documents related to DOD’s implementation of the Remediation Plan,
such as the minutes of SAO committee meetings, and the June 2018
DOD Improper Payments Senior Accountable Officials Steering
Committee Charter. In addition, we met with DOD and component



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Appendix II: Objectives, Scope, and
Methodology




officials to discuss efforts to identify and address root causes of improper
travel payments and conducted a web-based survey of travel
administrators in 52 DOD components (summarized above) to obtain
information on their efforts to identify and address the root causes of
improper travel payments. We compared the information we obtained with
OMB guidance on how agencies are to identify and address the root
causes of improper payments, 8 as well as the definition of root cause
contained in the template DOD uses for corrective action plans intended
to address improper travel payments. 9

We conducted this performance audit from April 2018 to August 2019 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.




8
 OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management
and Internal Control, Appendix C, Requirements for Payment Integrity Improvement (June
26, 2018).
9
 Office of the Under Secretary of Defense (Comptroller), Improper Payments: General
Guidance and Best Practices for CAP Development (April 2018).




Page 43                                                      GAO-19-530 Defense Travel
Appendix III: Comments from the
              Appendix III: Comments from the Department
              of Defense



Department of Defense




              Page 44                                      GAO-19-530 Defense Travel
Appendix III: Comments from the Department
of Defense




Page 45                                      GAO-19-530 Defense Travel
Appendix III: Comments from the Department
of Defense




Page 46                                      GAO-19-530 Defense Travel
Appendix IV: GAO Contact and Staff
                  Appendix IV: GAO Contact and Staff
                  Acknowledgments



Acknowledgments


                  Elizabeth Field, (202) 512-2775 or FieldE1@gao.gov
GAO Contact
                  In addition to the contact named above, Matthew Ullengren (Assistant
Staff             Director), Vincent Buquicchio, Christopher Gezon, Foster Kerrison, Jill
Acknowledgments   Lacey, Joanne Landesman, Rob Letzler, Kelly Liptan, and Michael Silver
                  made key contributions to this report.




(102799)
                  Page 47                                           GAO-19-530 Defense Travel
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