B-145883, SEP. 1, 1970

B-145883, SEP. 1, 1970

PEACE CORPS RECRUITERS - EXPENSE REIMBURSEMENT - CONTRACTING OUT SERVICES DECISION AUTHORIZING CERTIFICATION OF VOUCHER FOR EXPENSE OF INDIVIDUALS IN ASSISTING AREA REPRESENTITIVE IN RECRUITING ACTIVITIES WITHIN 50-MILE RADIUS OF HEADQUARTERS. SINCE SERVICE IN TYPING SPEECHES, MANNING EXHIBIT BOOTHS AND OTHER CLERICAL ASSISTANCE, ARE SERVICES ESSENTIALLY FOR PERFORMANCE UNDER CIVIL SERVICE RULES THEY MAY UNDER THE CIRCUMSTANCES BE VIEWED AS PERFORMANCE OF SPECIFIC TASKS WITHOUT GOVERNMENT SUPERVISION. THEREFORE SINCE GOVERNMENT HAS RECEIVED BENEFIT AND METHOD WAS REASONABLE AND ECONOMICAL PAYMENT MAY BE MADE.

TO MR. GEORGE BLOOM:

THIS IS IN REFERENCE TO YOUR LETTER DATED JUNE 25, 1970, REQUESTING A DECISION AS TO THE PROPRIETY OF CERTIFICATION FOR PAYMENT A RECLAIM VOUCHER IN FAVOR OF MR. W. BENTON HOSKINS IN THE AMOUNT OF $586.60. THE RECLAIM REPRESENTS THE AMOUNT ORIGINALLY CLAIMED ON TRAVEL VOUCHERS FOR REIMBURSEMENT OF CASH PAYMENTS MADE BY MR. HOSKINS TO INDIVIDUALS FOR ASSISTING HIM IN RECRUITING ACTIVITIES.

THE FACTS ARE STATED IN YOUR LETTER AS FOLLOWS:

"THE PEACE CORPS HAS ESTABLISHED AREA OFFICES THROUGHOUT THE UNITED STATES TO FACILITATE THE RECRUITMENT OF APPLICANTS AS VOLUNTEERS. THE AREA OFFICES ARE SO LOCATED AS TO ALLOW QUICK AND EASY ACCESS TO THE CAMPUS COMMUNITY. AS A RESULT, THERE ARE SEVERAL COLLEGES, UNIVERSITIES AND OTHER INSTITUTIONS WITHIN A 50-MILE RADIUS OF THE AREA OFFICES THAT THE PEACE CORPS MUST RECRUIT TO FILL PROGRAM REQUESTS WITH POSSIBLE CANDIDATES. BECAUSE THE AREA OFFICES ARE STAFFED WITH ONLY AN AREA REPRESENTATIVE AND MAYBE ONE OR TWO RECRUITERS IT IS NECESSARY TO UTILIZE THE ASSISTANCE OF FORMER PC VOLUNTEERS TO PERFORM ADVANCE WORK ON THE CAMPUS PRIOR TO THE SENDING OF A TEAM OF RECRUITERS. THIS WORK IS OF AN EXTREMELY TEMPORARY AND SPORADIC NATURE. IN ADDITION, ASSISTANCE IS REQUIRED TO MAKE AND TYPE SPEECHES, SETTING UP AND MANNING BOOTHS AND ARRANGING FOR PUBLICITY AND OTHER FORMS OF CLERICAL ASSISTANCE. AT TIMES, ASSISTANCE IS REQUIRED OUTSIDE A 50-MILE RADIUS, WHEN THE TRAVELER IS IN A TRAVEL STATUS BUT NOT IN THE SAME LOCATION AS THE INDIVIDUAL ASSISTING IN RECRUITMENT.

"BEN HOSKINS, A FOREIGN SERVICE EMPLOYEE, IS AREA MANAGER OF THE PHILADELPHIA, PA., OFFICE AND IS RESPONSIBLE FOR RECRUITMENT OF APPLICANTS AS VOLUNTEERS FOR HIS AREA. PAYMENT HAS BEEN MADE FOR ASSISTANCE WHILE THE TRAVELER WAS IN A TRAVEL STATUS AS AUTHORIZED BY TRAVEL AUTHORIZATION IN ACCORDANCE WITH 6 FAM 141K."

OUR DECISION IS SPECIFICALLY REQUESTED ON WHETHER PAYMENT MAY BE MADE FOR ASSISTANCE IN RECRUITMENT OF VOLUNTEER TRAINEES EITHER

"1. WITHIN A 50-MILE RADIUS OF THE AREA REPRESENTATIVE'S OFFICE WHEN THE TRAVELER WAS NOT IN A TRAVEL STATUS

"2. OUTSIDE THE 50-MILE RADIUS WHERE ASSISTANCE WAS NOT IN THE SAME LOCATION AS THE AREA REPRESENTATIVE, EVEN THOUGH THE AREA REPRESENTATIVE WAS IN A TRAVEL STATUS."

PARAGRAPH 10.1 OF THE STANDARDIZED GOVERNMENT TRAVEL REGULATIONS, AS AMENDED, AND THE SIMILAR PROVISIONS IN 6 FAM 141K, REFERRED TO IN YOUR LETTER, INCLUDE AS ALLOWABLE MISCELLANEOUS EXPENSES:

"CHARGES FOR NECESSARY STENOGRAPHIC OR TYPING SERVICES OR RENTAL OF TYPEWRITERS IN CONNECTION WITH THE PREPARATION OF REPORTS OR CORRESPONDENCE, CLERICAL ASSISTANCE, SERVICES OF GUIDES, INTERPRETERS, PACKERS, DRIVERS OF VEHICLES, AND STORAGE OF PROPERTY USED ON OFFICIAL BUSINESS WILL BE ALLOWED WHEN AUTHORIZED OR APPROVED." WHILE THIS AUTHORITY, AS INDICATED IN YOUR LETTER, WAS RELIED UPON TO MAKE PAYMENT FOR THE ASSISTANCE IN QUESTION WHEN THE CLAIMANT WAS IN A TRAVEL STATUS, IT WOULD NOT APPEAR TO HAVE ANY BEARING UNDER THE CIRCUMSTANCES PRESENTED WHERE THE REQUIRED SERVICES WERE BEYOND THE TYPE CONTEMPLATED BY THE REGULATION AND WERE UNRELATED TO SPECIAL NEEDS OF THE TRAVELER.

THE TYPE OF ASSISTANCE HERE INVOLVED APPEARS TO BE ESSENTIALLY FOR SERVICES WHICH WOULD ORDINARILY BE FOR PERFORMANCE UNDER GOVERNMENT SUPERVISION BY FEDERAL PERSONNEL EMPLOYED IN ACCORDANCE WITH THE CIVIL SERVICE RULES AND REGULATIONS AND THE CLASSIFICATION LAWS. HOWEVER, UNDER THE CIRCUMSTANCES INVOLVED THEY MAY ALSO REASONABLY BE VIEWED AS BEING FOR THE PERFORMANCE OF SPECIFIC TASKS WITH NO PARTICULAR REQUIREMENT FOR GOVERNMENT SUPERVISION.

ACCORDINGLY, IN LIGHT OF THE SPECIAL CIRCUMSTANCES OUTLINED IN YOUR LETTER, AND SINCE THE SERVICES HAVE BEEN PERFORMED, THE UNITED STATES HAS RECEIVED BENEFIT THEREFROM, AND THE METHOD EMPLOYED WAS REASONABLE AND ECONOMICAL, THE RECLAIM VOUCHER MAY BE CERTIFIED FOR PAYMENT, PROVIDED THE CONTRACTUAL ARRANGEMENTS INVOLVED WERE INITIATED OR RATIFIED BY SOMEONE WITH AUTHORITY TO ENTER INTO CONTRACTS ON BEHALF OF THE PEACE CORPS.

THE VOUCHER AND ATTACHMENTS ARE RETURNED HEREWITH.