[Comments on Federal Employees' Use of Frequent Flyer Mileage Credits]

B-256401: Jul 29, 1994

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The Railroad Retirement Board requested a decision as to whether federal employees may use the frequent flyer mileage credits they accrue during official and personal travel for their personal use. GAO held that: (1) the mileage credits earned as a result of official government travel are the property of the federal government; (2) employees using both personal and government mileage credits for their own personal travel are responsible for the full value of the credits used; and (3) the accrued mileage credits should remain in the employees' accounts until they are used or expire.

B-256401 July 29, 1994


Catherine C. Cook General Counsel Railroad Retirement Board 844 North Rush Street Chicago, Illinois 60611-2092

Dear Ms. Cook:

We refer to your letter of February 4, 1994, in which you request our advice concerning the use by federal employees of frequent flyer mileage credits. In particular, you refer to the problem encountered in encouraging employees to deposit mileage credits earned on official travel in their frequent traveler accounts since most airlines permit individuals to maintain only one account. Thus, frequent flyer mileage credits obtained through both personal and official travel are commingled.

As an example, you mention United Airlines, which has advised that an individual may have only one frequent flyer account. In an effort to comply with the Federal Travel Regulation (FTR), 41 C.F.R. Sec. 301-1.103(f)(2) (1993), and to maximize the agency's travel budget, many of your employees have allowed frequent flyer mileage credits earned for official travel to be deposited in their personal frequent flyer accounts. The problem arises because United Airlines issues a voucher or certificate for airline travel when an employee/member accrues a certain number of miles, generally 20,000. If the member has both personal and business credits adding to 20,000 miles, both types of miles are used to generate the voucher or certificate.

You say that, if our previous advice means that each voucher based on a combination of personal and business miles is considered to be the property of the government, then employees using United Airlines for business and accruing mileage credits will, in all likelihood, never be able to make personal use of mileage credits attributable to personal travel. You conclude that such a result will force employees to forgo frequent flyer credits on official travel and increase the government's travel expenses.

To avoid that result, you suggest that employees who cannot maintain separate accounts be required to keep good records so that when an employee makes the required mileage plateau in personal miles, the next voucher issued would be considered to be personal property (the first voucher having been turned in to the government).

As you recognize, the longstanding rule is that mileage credits earned for official travel are the property of the federal government and that, if an employee receives a bonus coupon as a result of both personal and government mileage credits, the coupon is the property of the government. 41 C.F.R. Sec. 301-1.103(f)(1) (1993). See John D. McLaurin, 63 Comp.Gen. 233 (1984); Abraham Frydman, B-212559, Feb. 24, 1984. If the employee uses the coupon for personal travel he or she is responsible for the full value of the credits used. See Department of Energy, B-233388, Mar. 23, 1990. We note, however, that United Airlines has announced that starting February 1, 1995, its "AwardCheques" will no longer be issued automatically when an account balance reaches 20,000 miles. The miles remain in a member's account until he/she is ready to claim an award or until the miles expire. Therefore, after February 1, 1995, the specific issue you have raised will no longer be a problem.

We agree with you however, that the general issue of commingling of personal and official mileage credits presents a continuing problem to employees who wish to participate in an agency's frequent flyer mileage program. In fact, this Office has been asked by the Administrator, Panama Canal Commission, for a decision concerning the issue of commingling of accounts (file B-257525). Accordingly, we are consulting with the General Services Administration (GSA) and expect that a decision concerning commingling should be made in the near future.

We will provide you with a copy of our decision to the Panama Canal Commission as soon as it is issued.

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