Claim for Reimbursement for Cost of First-Class Travel Accommodations

An authorized certifying officer requested an advance decision as to whether a claim for reimbursement for the additional cost of first-class accommodations used while traveling on official business should be paid. An employee requested authorization to use first-class air accommodations because he suffers from claustrophobia; and he offered medical confirmation of his condition. After an initial denial of his claim by the agency, the employee submitted an agency head's approval of his request and a letter from a physician which confirmed his medical need to fly first class. GAO stated that the use of first-class air accommodations is justified only in circumstances when an employee is so handicapped or otherwise impaired that other accommodations cannot be used and such a condition is substantiated by competent medical authority. GAO will not substitute such an agency judgment absent clear and convincing evidence that the determination was arbitrary and capricious. No such evidence was offered here. Accordingly, the voucher may be certified for payment if otherwise proper.