B-187904, NOV 29, 1977

B-187904, NOV 29, 1977

WHERE IT IS PREDETERMINED THAT PURSUANT TO A CHANGE OF STATION IT WOULD BE CHEAPER TO SHIP EMPLOYEE'S HOUSEHOLD GOODS ON GBL AND EMPLOYEE ELECTS TO SHIP PART BY GBL AND PART BY U-HAUL EMPLOYEE WOULD BE LIMITED TO REIMBURSEMENT AS IF SHIPMENT HAD BEEN MADE IN ONE LOT ON GBL.

VETERANS ADMINISTRATION - TRANSPORTATION OF HOUSEHOLD EFFECTS:

THE CONTROLLER, DEPARTMENT OF MEDICINE AND SURGERY, VETERANS ADMINISTRATION, REQUESTS AN ADVANCE DECISION CONCERNING CLAIMS BY EMPLOYEES FOR TRANSPORTATION CHARGES ON SHIPMENTS OF HOUSEHOLD GOODS FROM THEIR OFFICIAL STATIONS UNDER AN AUTHORIZATION TO SHIP BY GOVERNMENT BILL OF LADING (GBL). PART OF THE AUTHORIZED WEIGHT WAS SHIPPED ON GBL AND PART BY THE EMPLOYEE BY USE OF U-HAUL.

PARAGRAPH 2-8.3(2) OF THE FEDERAL TRAVEL REGULATIONS (FPMR 101-7) (MAY 1973), IMPLEMENTING 5 U.S.C. 5724(C) (1970), SETS FORTH THE COMMUTED RATE SYSTEM, UNDER WHICH THE EMPLOYEE MAKES HIS OWN ARRANGEMENTS FOR MOVING HIS HOUSEHOLD GOODS, AND IS PAID AN ALLOWANCE DETERMINED BY THE WEIGHT AND DISTANCE OF THE SHIPMENT RATHER THAN BY THE ACTUAL COST OF THE SHIPMENT.

PARAGRAPH 2-8.3C(3) (MAY 1973) OF THOSE REGULATIONS PROVIDES:

"(3) POLICY. THE GENERAL POLICY IS THAT COMMUTED RATES SHALL BE USED FOR TRANSPORTATION OF EMPLOYEE'S HOUSEHOLD GOODS WHEN INDIVIDUAL TRANSFERS ARE INVOLVED, AND THAT APPROPRIATE ACTION, DEPENDING ON THE AMOUNT OF GOODS TO BE TRANSPORTED, SHALL BE TAKEN TO ESTIMATE AND COMPARE ACTUAL EXPENSE METHOD COSTS WITH COMMUTED RATE COSTS WHEN GROUPS OF EMPLOYEES ARE TRANSFERRED BETWEEN THE SAME OFFICIAL STATIONS AT APPROXIMATELY THE SAME TIME SO THAT THE METHOD RESULTING IN LESS COST TO THE GOVERNMENT MAY BE USED. SPECIFIC PROCEDURES TO BE FOLLOWED ARE CONTAINED IN PARAGRAPH 2- 8.3C(4)."

FURTHER, PARAGRAPH 2-8.3C(4) (A) (MAY 1973) PROVIDES:

"(A) INDIVIDUAL TRANSFERS. AGENCY EXPERIENCE WITH THE ACTUAL EXPENSE METHOD HAS SHOWN THAT SHIPMENT BY GOVERNMENT BILL OF LADING DOES NOT RESULT IN SAVINGS SIMPLY BECAUSE A LINE-HAUL (RATE) DISCOUNT IS, AVAILABLE. THEREFORE, THE COMMUTED RATE SYSTEM SHALL BE USED FOR INDIVIDUAL TRANSFERS WITHOUT CONSIDERATION BEING GIVEN THE ACTUAL EXPENSE METHOD, EXCEPT THAT THE ACTUAL EXPENSE METHOD MAY BE USED IF THE ACTUAL COSTS TO BE INCURRED BY THE GOVERNMENT FOR PACKING AND OTHER ACCESSORIAL SERVICES ARE PREDETERMINED (AT LEAST AS TO PRICE PER 100 POUNDS) AND IF THAT METHOD IS EXPECTED TO RESULT IN A REAL SAVINGS TO THE GOVERNMENT OF $100 OR MORE. ***."

UNDER THESE REGULATIONS, AN EMPLOYEE MAY BE AUTHORIZED SHIPMENT OF HIS HOUSEHOLD GOODS BY GOVERNMENT BILL OF LADING ONLY WHEN THE ACTUAL COSTS TO BE INCURRED FOR PACKING AND OTHER ACCESSORIAL SERVICES ARE PREDETERMINED AND THE ACTUAL EXPENSE METHOD IS EXPECTED TO RESULT IN A SAVINGS TO THE GOVERNMENT. WE ASSUME THAT AN APPROPRIATE ADMINISTRATIVE PREDETERMINATION WILL BE MADE WHEN A GOVERNMENT BILL OF LADING IS TO BE USED. AND ONCE THAT DETERMINATION IS MADE, PAYMENT WILL BE MADE IN ACCORDANCE WITH THAT AUTHORIZATION. SEE B-168466, JANUARY 21, 1970; B-170068, AUGUST 5, 1970.

PARAGRAPH 2-8.2D (MAY 1973) OF THE FTR PROVIDES IN PERTINENT PART:

"COST OF TRANSPORTATION OF HOUSEHOLD GOODS MAY BE PAID BY THE GOVERNMENT WHETHER THE SHIPMENT ORIGINATES AT THE EMPLOYEE'S LAST OFFICIAL STATION OR PLACE OF RESIDENCE OR AT SOME OTHER POINT, OR IF PART OF THE SHIPMENT ORIGINATES AT THE LAST OFFICIAL STATION AND THE REMAINDER AT ONE OR MORE OTHER POINTS. SIMILARLY, THESE EXPENSES ARE ALLOWABLE WHETHER THE POINT OF DESTINATION IS THE NEW OFFICIAL STATION OR SOME OTHER POINT SELECTED BY THE EMPLOYEE, OR IF THE DESTINATION FOR PART OF THE PROPERTY IS THE NEW OFFICIAL STATION AND THE REMAINDER IS SHIPPED TO ONE OR MORE OTHER POINTS. HOWEVER, THE TOTAL AMOUNT WHICH MAY BE PAID OR REIMBURSED BY THE GOVERNMENT SHALL NOT EXCEED THE COST OF TRANSPORTING THE PROPERTY IN ONE LOT BY THE MOST ECONOMICAL ROUTE FROM THE LAST OFFICIAL STATION OF THE TRANSFERRING EMPLOYEE (OR THE PLACE OF ACTUAL RESIDENCE OF THE NEW APPOINTEE AT TIME OF APPOINTMENT) TO THE NEW OFFICIAL STATION***."

CONSISTENT WITH THIS PARAGRAPH OUR OFFICE HAS HELD THAT WHEN AN EMPLOYEE'S HOUSEHOLD EFFECTS ARE TRANSPORTED FROM HIS OFFICIAL STATION IN TWO OR MORE SHIPMENTS, THE TOTAL AMOUNT WHICH MAY BE PAID OR REIMBURSED BY THE GOVERNMENT SHOULD NOT EXCEED THE COST OF TRANSPORTING THE PROPERTY IN ONE LOT BY THE MOST ECONOMICAL ROUTE. B-187736, MAY 31, 1977; B-173557, AUGUST 30, 1971.

THUS, WHERE AN EMPLOYEE ELECTS TO SHIP PART OF THE AUTHORIZED WEIGHT OF HOUSEHOLD GOODS ON A GOVERNMENT BILL OF LADING AND PART BY RENTED U HAUL AFTER IT IS PREDETERMINED BY HIS AGENCY THAT THE ACTUAL EXPENSE METHOD (GBL) WOULD RESULT IN A SAVING TO THE GOVERNMENT, THE EMPLOYEE CANNOT BE PAID OR REIMBURSED MORE THAN THE COST TO SHIP THE TOTAL WEIGHT IN ONE LOT ON A GOVERNMENT BILL OF LADING.

TWO EXAMPLES WERE FURNISHED BY THE CONTROLLER. IN EACH CASE IT WOULD APPEAR THAT SHIPMENT BY GBL HAS BEEN DETERMINED BY THE VETERANS ADMINISTRATION TO BE MORE ECONOMICAL THAN SHIPMENT UNDER THE COMMUTED RATE SYSTEM. IN THE FIRST CASE, 660 POUNDS OF HOUSEHOLD GOODS WERE SHIPPED BY U-HAUL AND 9,520 POUNDS BY GBL. IN THE SECOND CASE, 2,020 POUNDS OF HOUSEHOLD GOODS WERE SHIPPED BY U-HAUL AND 5,900 POUNDS BY GBL. THUS, IN BOTH CASES THE TOTAL WEIGHT SHIPPED WAS WITHIN THE AUTHORIZED WEIGHT ALLOWANCE OF 11,000 POUNDS. ACCORDINGLY, THE MAXIMUM AMOUNT ALLOWABLE IN EACH CASE IS THE COST WHICH WOULD HAVE BEEN INCURRED FOR SHIPMENT IN ONE LOT BY GBL.