A-66369, JANUARY 17, 1936, 15 COMP. GEN. 624

A-66369: Jan 17, 1936

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TRAVELING EXPENSES - HEADQUARTERS OF FIELD EMPLOYEES - GEOLOGICAL SURVEY WHERE PERSONS ARE APPOINTED FOR GENERAL FIELD DUTY REQUIRING SUBSTANTIALLY CONTINUOUS MOVEMENT FROM PLACE TO PLACE IN THE FIELD. THE HEADQUARTERS ARE AT WASHINGTON. WHEN AN EMPLOYEE IS SO APPOINTED AND ENTERS UPON DUTY AT PLACE OF APPOINTMENT. AS FOLLOWS: REFERENCE IS MADE TO RECENT EXCEPTIONS TAKEN BY YOUR OFFICE TO VOUCHERS PAID BY THE DIVISION OF DISBURSEMENT. OF WHICH THE FOLLOWING IS AN EXAMPLE: "/NATIONAL INDUSTRIAL RECOVERY. L. SUMMERS' VOUCHER NO. 9110) WILL BE WITHHELD IN THE NEXT SETTLEMENT UNLESS A SATISFACTORY EXPLANATION IS MADE. APPARENTLY DUTIES HAVE BEEN PERFORMED FROM HAYESVILLE. IT WOULD APPEAR THAT HAYESVILLE IS THE OFFICIAL HEADQUARTERS RATHER THAN THE PLACE DESIGNATED AS MURPHY.

A-66369, JANUARY 17, 1936, 15 COMP. GEN. 624

TRAVELING EXPENSES - HEADQUARTERS OF FIELD EMPLOYEES - GEOLOGICAL SURVEY WHERE PERSONS ARE APPOINTED FOR GENERAL FIELD DUTY REQUIRING SUBSTANTIALLY CONTINUOUS MOVEMENT FROM PLACE TO PLACE IN THE FIELD, AS IN THE CASE OF ITINERANT TOPOGRAPHIC ENGINEERS OF THE GEOLOGICAL SURVEY, THE HEADQUARTERS ARE AT WASHINGTON, D.C., THE SEAT OF GOVERNMENT. WHEN AN EMPLOYEE IS SO APPOINTED AND ENTERS UPON DUTY AT PLACE OF APPOINTMENT, A TRAVEL STATUS ENTITLING HIM TO REIMBURSEMENT OF TRAVELING EXPENSES OR PER DIEM IN LIEU OF SUBSISTENCE WOULD NOT BEGIN UNTIL HE ACTUALLY BEGINS TRAVEL FROM THAT POINT.

COMPTROLLER GENERAL MCCARL TO THE SECRETARY OF THE INTERIOR, JANUARY 17, 1936:

THERE HAS BEEN CONSIDERED YOUR LETTER OF AUGUST 21, 1935, AS FOLLOWS:

REFERENCE IS MADE TO RECENT EXCEPTIONS TAKEN BY YOUR OFFICE TO VOUCHERS PAID BY THE DIVISION OF DISBURSEMENT, TREASURY DEPARTMENT, FROM APPROPRIATIONS OF THE GEOLOGICAL SURVEY, OF WHICH THE FOLLOWING IS AN EXAMPLE:

"/NATIONAL INDUSTRIAL RECOVERY, INTERIOR, GEOLOGICAL SURVEY, 1933 35).

"CREDIT FOR $62.00, PAID TO WILLIAM E. CHNIEL, JR., TOPOGRAPHIC ENGINEER, ON THE ABOVE VOUCHER (J. L. SUMMERS' VOUCHER NO. 9110) WILL BE WITHHELD IN THE NEXT SETTLEMENT UNLESS A SATISFACTORY EXPLANATION IS MADE, OR THE AMOUNT DEPOSITED, FOR THE REASON THAT:

"PER DIEM CLAIMED MAY 1, TO 31, 1934, INCLUSIVE, 31 DAYS AT $2.00 AT HAYESVILLE, N.C. EMPLOYEE'S HEADQUARTERS DESIGNATED AS MURPHY, N.C. APPARENTLY DUTIES HAVE BEEN PERFORMED FROM HAYESVILLE, N.C., SINCE ARRIVAL AT THAT POINT ON MARCH 1ST, 1934. IT WOULD APPEAR THAT HAYESVILLE IS THE OFFICIAL HEADQUARTERS RATHER THAN THE PLACE DESIGNATED AS MURPHY, N.C.

"HEADQUARTERS ARE TO BE DETERMINED BY ACTUAL FACTS AND CIRCUMSTANCES RATHER THAN BY AN ARBITRARY DESIGNATION. 2 COMP. 757, 3 ID. 43, 6 ID. 400. T.R. PAR. 48 (A).'

IN THIS CASE, MR. CHNIEL REPORTED FOR DUTY AT MURPHY, N.C., ON FEBRUARY 20, 1934, AND WORKED AT THAT POINT UNTIL MARCH 1, 1934, WHEN HE WAS MOVED TO HAYESVILLE, N.C., TO CONTINUE THE MAPPING. HE REMAINED AT HAYESVILLE UNTIL JUNE 18, WHEN HE WAS MOVED TO SUIT, N.C., WHERE HE REMAINED UNTIL JULY 9, ON WHICH DAY HE LEFT FOR BLOWING ROCK, N.C. AFTER A PERIOD OF DUTY AT THAT POINT HE MOVED ON OCTOBER 27 TO NEW LAND, N.C. IN THIS CONNECTION, SEE J. L. SUMMERS' VOUCHER NO. 1293, PAID APRIL 17, SYMBOL 95-071; AND G. F. ALLEN'S VOUCHERS 1996, PAID JULY 20, 1934; 8919, PAID AUGUST 28; AND 488185 PAID NOVEMBER 12, 1934, SYMBOL 94-909.

THE DESIGNATION OF AN OFFICIAL STATION, AS "HEADQUARTERS" FOR ITINERANT TOPOGRAPHIC ENGINEERS IS A MORE OR LESS ARTIFICIAL PROCEDURE, ALTHOUGH RECOGNIZED AS A LEGAL AND ACCOUNTING NECESSITY. AS A MATTER OF ACTUAL FACT THESE MEN USUALLY HAVE NO REAL HEADQUARTERS IN THE SENSE OF A FIELD OFFICE OR A BASE AT WHICH A TEMPORARY HOME COULD BE ESTABLISHED, BUT ARE MOVED FROM POINT TO POINT AS THEIR WORK PROGRESSES AND AS THE NECESSITIES AND THE EFFICIENT CONDUCT OF THAT WORK REQUIRE. THEY MAY BE A FEW DAYS OR A MONTH OR MORE AT A GIVEN POINT, REMAINING THERE UNTIL THE WORK ACCESSIBLE FROM THAT POINT IS COMPLETED AND THEN ARE MOVED TO ANOTHER POINT FOR ANOTHER MORE OR LESS INDEFINITE PERIOD.

THE NATURE OF THE COUNTRY AND OF THE ROADS OR TRAILS, THE SCALE OF THE MAPS, THE SEASON OF THE YEAR AND CLIMATIC CONDITIONS, THE TYPE OF TRANSPORTATION USABLE AND USED, ALL AFFECT THE PERIOD REQUIRED TO COMPLETE THE WORK THAT IS ACCESSIBLE FROM A GIVEN POINT.

THESE BEING THE CONDITIONS, THE PRACTICE OF THE SURVEY HAS BEEN TO CONSIDER AS AN EMPLOYEE'S HEADQUARTERS, THE POINT WHERE THE FIRST OFFICIAL DUTY IS PERFORMED UNDER AN APPOINTMENT. IN SOME CASES THE NEEDS OF THE WORK HAVE LED TO A CHANGE OF THE BASE OF OPERATIONS WITHIN A FEW DAYS AFTER THE DESIGNATION OF HEADQUARTERS. THIS SEEMS TO HAVE CREATED THE IMPRESSION THAT THE EMPLOYEE'S REAL POINT OF DUTY AND CONSEQUENTLY HIS HEADQUARTERS IS THE SECOND LOCATION RATHER THAN THE FIRST AND HAS LED TO DISALLOWANCES.

I SHALL BE GLAD TO HAVE ANY SUGGESTIONS THAT YOUR OFFICE MAY DEEM IT APPROPRIATE TO MAKE AS TO PROCEDURE BY THE GEOLOGICAL SURVEY UNDER THE CONDITIONS GOVERNING ITS TOPOGRAPHIC MAPPING ACTIVITIES IN THE FIELD AS THEY ARE OUTLINED ABOVE, TO THE END THAT THE SURVEY MAY HARMONIZE ITS ACTION WITH ACCOUNTING REQUIREMENTS AND FACILITATE THE HANDLING OF ITS ACCOUNTS.

UPON THE FACTS STATED BY YOU IT IS EVIDENT THAT THE EMPLOYEES OF THE UNITED STATES GEOLOGICAL SURVEY ENGAGED ON FIELD MAPPING WORK HAVE NO PERMANENT HEADQUARTERS IN THE FIELD AND IT WAS THEREFORE ERRONEOUS TO DESIGNATE AS THEIR PERMANENT OR REGULAR HEADQUARTERS THE PLACE AT WHICH THEY FIRST REPORTED FOR DUTY. HOWEVER, IT HAS BEEN HELD BY THIS OFFICE IN SIMILAR CASES THAT WHERE A PERSON IS APPOINTED FOR GENERAL FIELD DUTY REQUIRING SUBSTANTIALLY CONTINUOUS MOVEMENT FROM PLACE TO PLACE IN THE FIELD HIS HEADQUARTERS IS WASHINGTON, D.C., AS THE SEAT OF THE GOVERNMENT. 5 COMP. GEN. 76. WHEN AN EMPLOYEE IS SO APPOINTED AND ENTERS UPON DUTY AT THE PLACE OF APPOINTMENT OR FIRST DUTY STATION A TRAVEL STATUS ENTITLING HIM TO REIMBURSEMENT OF TRAVEL EXPENSES OR PER DIEM IN LIEU OF SUBSISTENCE WOULD NOT BEGIN UNTIL HE ACTUALLY BEGINS TRAVEL FROM THAT POINT. A-29042, OCTOBER 25, 1929; AND A-41560, APRIL 26, 1932.

ASIDE FROM THE ARBITRARY DESIGNATION OF THE FIRST DUTY STATION AS HEADQUARTERS, THE PRACTICE FOLLOWED BY YOUR DEPARTMENT IN THIS MATTER APPEARS TO BE SUBSTANTIALLY IN ACCORDANCE WITH THE ESTABLISHED RULES, AND CREDIT WILL BE ALLOWED FOR THE PAYMENTS IN QUESTION IF OTHERWISE CORRECT.

THERE WOULD APPEAR TO BE FOR ADMINISTRATIVE CONSIDERATION IN SUCH CASES WHETHER THE AMOUNT OF THE PER DIEM SHOULD NOT BE REDUCED WHEN THE DUTY OF THE EMPLOYEE REQUIRES THAT HE REMAIN AT ONE PLACE FOR OVER 30 DAYS AND AGAIN REDUCED IF HE REMAINS THERE OVER 60 DAYS, ETC. ..END :