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GAO-08-85R: 

U.S. Government Accountability Office: GAO: 

November 19, 2007: 

The Honorable Charles Conner: 
Acting Secretary of Agriculture: 

Subject: Management Letter: Recommendations for Improvements to USDA's 
Internal Controls and Policies on Premium Class Air Travel: 

Dear Mr. Conner: 

At the request of the Permanent Subcommittee on Investigations, Senate 
Committee on Homeland Security and Governmental Affairs, in September 
2007 we reported on the governmentwide use of premium class 
travel[Footnote 1]. As part of the audit and related investigations, we 
tested premium class transactions at the Department of Agriculture 
(USDA). The purpose of this letter is to provide you with information 
on specific matters identified during our work that relate to 
weaknesses in internal controls at USDA. Further, this letter details 
the results of investigative work we performed related to allegations 
forwarded to us by USDA's Office of Inspector General of premium class 
travel abuses by executives at the Foreign Agricultural Service (FAS). 
This letter contains six recommendations that warrant your attention. 

Results in Brief: 

We found that USDA spent over $110 million in air travel from July 1, 
2005, through September 30, 2006, of which about $3.9 million included 
at least one leg of a premium class flight. Overall, the percentage of 
USDA flights in premium class was less than the overall governmentwide 
average of 7 percent. However, we found that FAS used premium class 
travel nearly 30 percent of the time and accounted for the majority of 
USDA's premium class travel, due in part to policies and procedures 
that were more permissive than USDA departmentwide policies. Other 
issues of significance included the following: 

* USDA, and its component organizations, did not track premium class 
travel other than first class. Consequently, USDA and its component 
organizations were not aware of the magnitude of premium class travel 
by department or by component organization. Further, we found that FAS 
accounted for $2.0 million of the $3.9 million USDA spent on premium 
class travel.[Footnote 2] 

* Of the 145 USDA premium class trips we examined, 140 trips did not 
have documentation to justify premium class travel. Without this 
documentation, FAS and USDA cannot confirm that employees are using 
premium class in accordance with the Federal Travel Regulation (FTR) or 
department and agency policies.[Footnote 3] Lacking such documentation, 
USDA has little assurance that these trips are in accordance with 
federal regulations and exposes the government to excess travel costs. 

* FAS officials accounted for 112 of the 145 USDA trips we audited and 
investigated. These trips were taken mostly by senior executives, and 
included 79 FAS premium class trips that were authorized by USDA staff 
subordinate to the traveler or by an employee not permitted to 
authorize premium class travel. These transactions did not follow 
USDA's policy for proper authorization. Premium class transactions 
approved by subordinates, while not expressly prohibited by the FTR, 
reduce the scrutiny of premium class travel and amount to self- 
approval. 

* We found 25 instances in which FAS executives used "exceptional 
circumstances" or the 14-hour rule to justify the need for premium 
class travel, at the same time that other FAS staff traveling on the 
same flights for the same purpose traveled in coach. For example, in 
December 2005, a FAS executive traveled in business class from 
Washington, D.C., to Hong Kong and back at a cost of nearly $7,000. In 
contrast, 11 other FAS employees did not travel in premium class, even 
though they were eligible for premium class travel according to General 
Services Administration (GSA) policy if their supervisor approved the 
expenditure of additional funds. Instead, the 11 employees traveled on 
the same plane in coach at the cost of less than $1,400 per ticket. We 
found an additional 47 instances in which executives violated FAS 
policy by claiming "exceptional circumstances" to justify flights less 
than 14 hours to Western Europe. FAS policy specifically prohibits the 
use of this criterion for flights from the United States to Western 
Europe. Further, no explanation was given on the travel vouchers 
related to the exceptional circumstance criterion that warranted the 
additional cost for premium class travel. 

At the end of our discussion of these issues, we offer recommendations 
for strengthening USDA's internal controls and travel policies. We also 
referred to you on October 18, 2007, individuals who violated USDA's 
premium class policy, potentially abused executive travel, or both, for 
further review and appropriate action. Actions could include, if 
warranted, repayment of the difference between the price of coach and 
premium class and administrative actions. 

Scope and Methodology: 

This letter is based on the work performed during our audit of the 
federal government's use of premium class air travel and investigative 
work on allegations of abuse of premium class travel at USDA. To 
determine the magnitude of premium class travel at USDA, we extracted 
premium class transactions from July 1, 2005 through June 30, 2006, 
from the databases provided by Bank of America. Premium class 
transactions were defined as debit air travel transactions that 
included at least one leg of first or business class travel. Our review 
included charges made to both the individually billed accounts, which 
are travel cards assigned to individual travelers for transportation 
expenses, lodging, and miscellaneous expenses, and the centrally billed 
accounts, which are travel cards assigned to the agencies and used 
primarily to procure transportation for travelers. We selected and 
tested a statistical sample of governmentwide premium class travel 
transactions, which included trips taken by USDA employees, and 
conducted other audit work to determine the extent to which this travel 
was improper.[Footnote 4] To determine whether USDA tracked premium 
class travel other than first class, we interviewed USDA and FAS 
officials. Because first class travel at USDA was immaterial-- 
accounting for only 4 percent of total premium class travel--we did not 
review the completeness of USDA's reporting of first class travel to 
GSA. To identify specific cases of improper or abusive use of premium 
class travel, we used data mining to identify instances in which 
individuals flew many premium class flights during the period or groups 
of individuals flew together in premium class.[Footnote 5] Because we 
included additional data provided by the bank subsequent to our 
selection of the statistical sample, our data-mining work was performed 
on data from July 1, 2005, through September 30, 2006. In addition, as 
part of our investigative work, we reviewed premium class transactions 
from executives as part of an allegation we received in May 2006 
related specifically to improper use of premium class travel by FAS 
executives.[Footnote 6] To identify underlying causes contributing to 
improper premium class travel, we reviewed federal laws and regulations 
and USDA's and FAS's implementing guidance for premium class travel, 
and interviewed USDA and FAS officials on the processes and procedures 
in place to authorize and justify premium class travel. Enclosure I 
contains a summary of when federal regulations allow premium class 
travel to be authorized. We also interviewed GSA and Office of 
Management and Budget (OMB) officials on their oversight of premium 
class travel. 

We conducted our audit from July 2006 through August 2007 in accordance 
with U.S. generally accepted government auditing standards, and we 
performed our investigative work during the same period in accordance 
with standards prescribed by the President's Council on Integrity and 
Efficiency. 

Premium Class Travel Not Tracked: 

We found that USDA spent over $110 million in air travel from July 1, 
2005, through September 30, 2006, of which about $3.9 million included 
at least one leg of a premium class flight. Overall, the percentage of 
USDA flights in premium class is less than the overall governmentwide 
average of 7 percent. Further, we found that FAS, was the most 
extensive user of premium class travel within USDA and spent nearly 30 
percent of its air travel dollars on premium class flights. 
Specifically, we found that FAS accounted for $2.0 million of the $3.9 
million USDA spent on premium class airfare.[Footnote 7] According to 
officials we interviewed, neither USDA nor FAS tracked premium class 
travel other than first class, even though premium class travel other 
than first class accounted for 96 percent of all premium class travel. 
Without collecting this information, USDA and FAS were unaware of the 
magnitude of premium class travel. 

The FTR requires all executive branch agencies to provide GSA annual 
reports, which are forwarded to OMB, listing all instances when the 
agency approved the use of first class transportation accommodations. 
However, neither OMB nor GSA requires reporting on business class 
travel, which accounts for the vast majority of all premium class 
travel in the government. Tracking all premium class travel, including 
business class travel, is crucial to USDA's ability to manage its 
budget and ensure that all travelers adhere to the FTR's standard of 
care requirement. Without knowing how much is spent on premium class 
travel and without internal controls sufficient to prevent improper 
premium class travel, USDA is unable to systematically determine 
whether such travel is necessary to the performance of its mission, or 
whether it is unnecessary and thus should be reduced to provide funds 
for other higher-priority services. 

Premium Class Travel Not Properly Authorized, Justified, or Both: 

Of the 145 USDA premium class trips we audited and investigated, 140 
trips did not have adequate documentation to support that the trip was 
authorized and justified for the use of premium class travel. The FTR 
states that in order to be valid, premium class travel has to be 
specifically authorized and justified, that is, meet one of a number of 
criteria specified in the regulations. Nearly 97 percent of the USDA 
transactions we audited were not properly authorized, justified, or 
both. 

We found that FAS accounts for the majority of the improper USDA 
premium class travel. Specifically, of the 145 instances of premium 
class travel we tested, 112 were premium class travel undertaken by FAS 
employees, of which 110 were improperly authorized, improperly 
justified, or both. FAS implementing policy specifies that individuals 
who use "mission-critical (or exceptional circumstances)" as a 
justification for premium class travel must provide additional 
documentation that further justifies the need for "mission-critical" 
travel. However, FAS was unable to provide documentation for any of the 
57 trips that were taken in premium class using this criterion, as 
required by its policy. These mission-critical trips included travelers 
claiming to be attending meetings and accompanying senior officials. 
Similarly, FAS policies require a traveler to submit a statement 
regarding his/her first duty day if the traveler uses premium class for 
a flight longer than 14 hours. However, we found that for 27 trips in 
premium class travel, travelers did not report times of arrival at a 
work duty station after flying over 14 hours in premium class. 

Premium Class Travel Not Authorized at the Proper Level: 

We found 79 of 112 FAS premium class transactions we tested were 
authorized by an employee subordinate to the traveler or by an employee 
not permitted to authorize premium class travel.[Footnote 8] The FAS 
trips we reviewed were taken by nine different senior executives and 
one other FAS employee.[Footnote 9] One senior executive took 23 trips 
authorized by a subordinate. 

Our internal control standards provide that "Transactions and other 
significant events should be authorized and executed only by persons 
acting within the scope of their authority. This is the principal means 
of assuring that only valid transactions to exchange, transfer, use, or 
commit resources and other events are initiated or entered 
into."[Footnote 10] As we have reported previously,[Footnote 11] 
allowing subordinates to approve their supervisors' premium class 
travel is, in effect, self-approval that eliminates an important 
oversight control. This is especially problematic because executive 
travel is listed in our Sensitive Payments Guide as a high-risk area 
susceptible to abuse or noncompliance with laws and 
regulations.[Footnote 12] 

Furthermore, USDA policy states that only general officers of the 
department may approve premium class travel; the general officer for 
FAS is the Undersecretary for Farm and Foreign Agricultural 
Services.[Footnote 13] According to FAS travel policy, business class 
travel is required to be approved by a deputy administrator or above, 
who is to consider a cost comparison between business class and coach 
class. Approved trips must then be forwarded to the Administrator who 
makes the final authorization. Since FAS policy has delegated premium 
class authorizing authority below the level required by USDA policy, 
FAS policy appears to not be following USDA policies for premium class 
travel. 

Improper and Abusive Executive Travel: 

We also found instances in which premium class travel by FAS executives 
was not supported by proper justification or appeared abusive. 
Specifically, executives misused the "exceptional circumstances" 
criterion, and used the 14-hour rule to justify premium class travel 
when other employees traveling on the same flight sat in coach. 
Specifically, of the 112 trips taken by FAS executives that we tested, 
47[Footnote 14] improperly used the "exceptional circumstances" 
criterion as justification of premium class travel. In these cases, 
executives used "exceptional circumstances" to justify flights to 
Western Europe, even though FAS policy specifically prohibited the use 
of this criterion for these flights. Further, no explanation was given 
on the travel vouchers related to the exceptional circumstance 
criterion that warranted the additional cost for premium class travel. 
For example, in December 2005, a FAS executive traveled from 
Washington, D.C., to Geneva and back in business class, a trip lasting 
10 hours that cost the government about $7,500. In contrast, a coach 
ticket for the same itinerary would have cost the government about 
$1,000. 

We also found indications that executives traveled in premium class 
simply because of their rank, and in many cases these trips were 
authorized by their subordinates. In 25 instances, we found that 
executives used the 14-hour rule or the "exceptional circumstances" 
criterion to justify the need for premium class travel when their staff 
traveling on the same flights for the same purpose traveled in coach. 
For example, in December 2005, a FAS executive traveled in business 
class from Washington, D.C., to Hong Kong and back at a cost of nearly 
$7,000. In contrast, 11 other FAS employees did not travel in premium 
class, even though they were eligible to do so under GSA regulations if 
their supervisor approved the expenditure of additional funds. Instead, 
the 11 employees traveled on the same plane in coach at the cost of 
less than $1,400 per ticket. 

Recommendations for Executive Action: 

To improve USDA's ability to detect and prevent improper premium class 
travel, we recommend that the Secretary of Agriculture strengthen 
existing internal controls over the use of premium class travel by 
taking the following six actions: 

* Develop and implement procedures to: 

- identify the extent of premium class travel, including business class 
travel, and; 
- monitor for trends and frequency of premium class travel use, 
including potential misuse by executives. 

* Reiterate to USDA components existing USDA policy that premium class 
travel can only be approved by general officers, unless specifically 
exempted. 

* Develop and implement policies and procedures to specifically 
prohibit travelers or their subordinates from approving travelers' 
requests for premium class travel. 

* Require that premium class travel be approved by individuals who are 
at least of the same rank/grade as the travelers. 

* Develop and implement policies and procedures to specifically 
prohibit the approval of premium class travel if all documentation 
supporting premium class travel is not provided. 

* Issue policies and procedures requiring that USDA and USDA components 
monitor the frequency and cost of executive premium class travel. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report, USDA agreed with our 
recommendations and stated that it had already made several changes to 
its policies and procedures in response. In October 2007 USDA 
implemented interim guidance requiring the Chief Financial Officer to 
review and approve all premium class travel in advance of booking the 
trip. All subcabinet officials at USDA were briefed on these interim 
procedures. In addition, the office of the Chief Financial Officer has 
completed a review of the department's travel policies and procedures, 
and has begun an audit of premium class travel in the department. USDA 
has also requested monthly premium class travel reports for review from 
its travel service provider. 

This report contains recommendations to you. The head of a federal 
agency is required by 31 U.S.C. 720 to submit a written statement on 
actions taken on these recommendations. You should submit your 
statement to the Senate Committee on Homeland Security and Governmental 
Affairs and the House Committee on Oversight and Government Reform 
within 60 days of the date of this report. A written statement must 
also be sent to the House and Senate Committees on Appropriations with 
the agency's first request for appropriations made more than 60 days 
after the date of the report. 

This report is intended for use by the management of USDA. We are 
sending copies to the Honorable Carl Levin and the Honorable Norm 
Coleman, Chairman and Ranking Member, Permanent Subcommittee on 
Investigations, Senate Committee on Homeland Security and Governmental 
Affairs, and the Honorable Charles Grassley, Ranking Member, Senate 
Committee on Finance. Copies will be made available to others upon 
request. The report is also available at no charge on GAO's homepage at 
[hyperlink, http://www.gao.gov]. If you or your staff have any 
questions concerning this letter, please contact me at (202) 512-6722 
or kutzg@gao.gov. 

Sincerely yours, 

Signed by: 

Gregory Kutz: 
Managing Director: 
Forensic Audits and Special Investigations: 

Enclosures - 2: 

[End of section] 

Enclosure I: 

GSA Regulations Governing Premium Class Travel Use: 

The Federal Travel Regulation (FTR), issued by the General Services 
Administration (GSA), implements statutory and Office of Management and 
Budget (OMB) requirements and policies for most federal civilian 
employees and others authorized to travel at government expense. The 
purpose of the FTR is to ensure that official travel is conducted 
responsibly and at minimal administrative expense. Unless exempt by 
specific legislation,[Footnote 15] executive agencies, fully owned 
government corporations, and independent establishments are expected to 
follow the FTR, including its promulgation related to premium class 
travel. The Department of Defense's uniformed servicemembers and 
Department of State employees exempt from the FTR are covered by their 
agencies' travel regulations. 

OMB's general policy related to travel is that the taxpayers should pay 
no more than necessary to transport government officials. Consistent 
with this principle, the FTR states that with limited exceptions, 
travelers must use coach class accommodations for both domestic and 
international travel. Premium class travel can occur only when the 
traveler's agency specifically authorizes the use of such 
accommodations (authorization) and only under specific circumstances 
(justification). Specifically, the FTR states that first class 
accommodation is authorized only when at least one of the following 
conditions exists[Footnote 16]: 

* coach class airline accommodations or premium class other than first 
class airline accommodations are not reasonably available; 

* when use of first class is necessary to accommodate a disability or 
other special need that is substantiated in writing by a competent 
medical authority; 

* exceptional security circumstances require first class travel, or; 
* when required because of agency mission.[Footnote 17] 

The FTR authorizes premium class accommodations other than first class 
(business class) when at least one of the following conditions exists: 

* regularly scheduled flights between origin/destination points provide 
only premium class accommodations, and this is certified on the travel 
voucher; 

* coach class is not available in time to accomplish the mission, which 
is urgent and cannot be postponed; 

* premium class travel is necessary to accommodate the traveler's 
disability or other physical impairment, and the condition is 
substantiated in writing by competent medical authority; 

* premium class travel is needed for security purposes or because 
exceptional circumstances make its use essential to the successful 
performance of the mission; 

* coach class accommodations on authorized/approved foreign carriers do 
not provide adequate sanitation or meet health standards; 

* premium class accommodations would result in overall savings to the 
government because of subsistence costs, overtime, or lost productive 
time that would be incurred while awaiting coach class accommodations; 

* transportation is paid in full by a nonfederal source; 

* travel is to or from a destination outside the continental United 
States, and the scheduled flight time (including stopovers) is in 
excess of 14 hours (however, a rest stop en route or a rest period upon 
arrival is prohibited when premium class accommodations are 
authorized); or; 

* when required because of agency mission.[Footnote 18] 

As specified above, employees traveling in premium class have to meet 
both authorization and justification to qualify, meaning that employees 
who, for example, traveled premium class on a trip exceeding 14 hours 
would violate the FTR if they traveled premium class without receiving 
specific authorization to do so. Agencies subject to the FTR have 
generally issued internal policies and procedures to clarify and 
implement the premium class travel provisions of the FTR. When issuing 
implementing policy, agencies have to follow executive branch policy, 
which specifies that a subordinate organization seeking to establish 
implementing regulations or guidance may make the regulations more 
stringent but not relax the rules established by higher-level guidance. 
For example, an agency's implementing policy related to premium class 
travel because of disability can require that the traveler provides 
medical certification that is updated annually, but cannot waive the 
requirement that a certification by a competent medical authority be 
provided. 

[End of enclosure] 

Comments from the United States Department of Agriculture: 

United States Department of Agriculture: 
Office of the Chief Financial Officer: 
1400 Independence Avenue, SW: 
Washington, DC 20250: 

November 15, 2007: 

Mr. Gregory D. Kutz: 
Managing Director: 
Forensic Audits and Special Investigations: 
Government Accountability Office: 
Washington, D.C. 20548: 

Dear Mr. Kutz: 

Thank you for providing a copy of your proposed report: Recommendations 
for Improvements to the United States Department of Agriculture's 
(USDA) Internal Controls and Policies on Premium Class Air Travel (GAO-
08-85R). Acting Secretary Conner has asked me to respond for the 
Department. USDA concurs with your recommendations and has taken 
several steps to improve oversight of premium class travel. The 
Department has made the following changes in response to your 
recommendations: 

* On October 2, 2007, the Department implemented interim guidance 
requiring the Chief Financial Officer (CFO) to review and approve all 
first class and/or premium class travel in advance of booking the trip. 
This guidance requires justification and documentation for General 
Officer review and concurrence prior to consideration by the CFO. In 
the event that the premium class travel is for the CFO, it will require 
review and approval from the Department's Chief of Staff to the 
Secretary. This approval process does not apply to upgrades using 
frequent flyer miles or at the traveler's personal expense that are 
allowed under the Federal Travel Regulations; 

* Each Subcabinet Official was briefed on these interim procedures in 
addition to briefings provided to management staff. We have also 
instructed our Travel Management Centers to not make reservations for 
premium class travel without verification of approval; 

* The Office of the Chief Financial Officer (OCFO) just completed an 
extensive review of the Agriculture Travel Regulation. The review 
commenced prior to the GAO audit. The review team was instructed to 
simplify the policy while providing the appropriate level of oversight 
to authorizations in domestic travel, international travel, group 
training expenses, and conference expenses. This regulation is 
completed and in the department's clearance process; 

* On November 2, 2007, the OCFO began an audit of premium class travel 
in the Department. The purpose of the audit is to examine the use of 
premium class travel and adherence to Federal and Departmental policy 
and procedures. Audit results are due by the end of the calendar year; 
and; 

* USDA has also requested monthly premium class travel reports from our 
eTravel Service providers. This will allow a monthly review process to 
continually monitor premium class travel activity and to ensure 
adherence to the new policy. 

GAO's audit showed problems with unclear travel policies and weaknesses 
in the approval process. USDA quickly addressed the problems identified 
by the audit with interim and permanent solutions. A quick review of 
the premium travel by the OCFO showed that the travel had limited 
documentation, but in most cases would have been approved. Therefore, 
notwithstanding approvals at subordinate levels or the absence of 
properly executed forms, we believe that in many cases where travel was 
performed in circumstances in which premium class accommodations were 
utilized, premium class travel was in fact justified. To be prudent in 
our responsibilities, the OCFO is conducting an audit of premium travel 
including pre-authorization and post approvals. 

Please be assured that we are working diligently to address the all of 
audit issues identified in your letter. The new procedures that have 
been put in place will allow premium class travel to occur when full 
documentation showing it was properly authorized and justified is 
provided. In addition, we will work with the Office of Inspector 
General to ensure changes in their policies and procedures will prevent 
future improper premium travel as noted in the management letter. 

Sincerely, 

Signed by: 
Charles R. Christopherson, Jr.: 
Chief Financial Officer: 

[End of enclosure] 

Footnotes: 

[1] GAO, Premium Class Travel: Internal Control Weaknesses 
Governmentwide Led to Improper and Abusive Use of Premium Class Travel, 
GAO-07-1268 (Washington, D.C.: Sept. 28, 2007). 

[2] As FAS's mission involves dealing with international entities, and 
therefore international travel, it is expected that FAS would be a more 
frequent user of premium class travel than other USDA components. 

[3] For more information on federal regulations governing premium class 
travel use, see enc. I. 

[4] Our statistical sample included five transactions from USDA 
travelers. 

[5] We reviewed 3 individual transactions identified in our initial 
data mining, and an additional 137 transactions from 12 USDA employees 
who traveled during our audit period. 

[6] We received allegations of abusive and improver travel at USDA, 
including FAS and USDA's Office of Inspector General (OIG). Results of 
the OIG travel investigation are not included in this report because, 
in response to problems we identified, the OIG has agreed to changes in 
policies and procedures that will help prevent future improper premium 
travel. FAS transactions investigated as part of the investigation are 
included in this report. 

[7] Of the $2 million FAS spent on premium class travel, less than 
$70,000 was for first class travel. Of the $3 million USDA as a whole 
spent on premium class travel, $150,000 was for first class travel. We 
did not audit whether USDA's reporting of first class travel to GSA was 
complete because first class travel is a relatively small portion of 
total premium class travel. 

[8] An additional eight transactions had no signature at all. 

[9] Senior executives are defined as members of the Senior Executive 
Service (SES) and presidential appointees. 

[10] GAO, Standards for Internal Control in the Federal Government, 
GAO/AIMD-00-21-3.1 (Washington, D.C.: November 1999). 

[11] GAO, Travel Cards: Internal Control Weaknesses at DOD Led to 
Improper Use of First and Business Class Travel, GAO-04-88 (Washington, 
D.C.: Oct. 24, 2003). 

[12] GAO, Guide for Evaluating and Testing Controls Over Sensitive 
Payments, GAO/AFMD-8.1.2 (Washington, D.C.: May 1993). 

[13] A general officer is a USDA official as defined in 7 C.F.R. 2.4. 
General officers report directly to the Secretary of Agriculture. If 
travel is not first class and frequent traveler benefits are used to 
offset additional cost of premium class, the head of an agency may 
approve the tickets, according to USDA policy. 

[14] Some of the 47 FAS premium class tickets justified using the 
exceptional circumstances criterion were authorized by the traveler's 
subordinate. 

[15] A number of federal agencies are exempt from the FTR. For example, 
the United States Postal Service (USPS) is exempt through 5 U.S.C. 104 
and 5 U.S.C. 5701. The Federal Reserve Bank also claimed exemption from 
the FTR under section 10 of the Federal Reserve Act, which provides 
that "employment, compensation, leave, and expenses" of board employees 
are "governed solely by the provisions of the Federal Reserve Act." 
Both USPS and the Federal Reserve Bank use their respective exemptions 
to promulgate their own travel policies. 

[16] The FTR also allows for the traveler to upgrade to premium-class 
accommodations, at the traveler's expense or by using frequent traveler 
benefits. 

[17] 41 C.F.R. 301-10.123. 

[18] 41 C.F.R. 301-10.124. 

[End of section] 

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