[Question Concerning Reimbursement of Relocation Expenses for Short Distance Transfer]

A federal employee requested reimbursement of relocation expenses incident to his manpower shortage appointment by the Voice of America (VOA). VOA initially authorized various moving expenses; however, it later found that its authorization was erroneous and denied the claim. The employee then accepted a transfer to a position with the National Aeronautics and Space Administration and was told that he would not be authorized relocation expenses. GAO held that: (1) when an appointee to a manpower shortage position resides in the same general local or metropolitan area where his first duty station was located, relocation expenses may only be authorized when an agency determines that the relocation was incident to the appointment; (2) relocation of a residence may not be considered as incident to a change of official station unless the one-way commuting distance from the old residence to the new official station is at least 10 miles greater than from the old residence to the old official station; and (3) the continued denial of requests for reimbursement on the grounds of insufficient savings of time and distance is tantamount to a finding that the relocation of the employee's residence was not incident to the transfer. GAO found that: (1) the employee's commuting distance increased only 6 miles; and (2) the record showed that the agencies' actions were not arbitrary, capricious, or abuses of discretion. Accordingly, the claim was denied.