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THESE ITEMS WERE ADMINISTRATIVELY DISALLOWED BECAUSE THEY WERE BELIEVED TO BE PROHIBITED BY THE PROVISIONS OF 5 GAO 2013.20. THE SOVIET GOVERNMENT REQUIRES PROOF THAT ALL TRAVELER ACCOMMODATIONS HAVE BEEN ARRANGED IN ADVANCE AND PREPAID. THOSE AGENCIES ARE REMUNERATED FOR THEIR SERVICES IN PART BY THE ASSESSMENT OF A FEE AGAINST EACH TRAVELER WHO ALSO IS REQUIRED TO PAY THE AGENCY'S OUT-OF POCKET EXPENSES OF CABLING FOR THE ACCOMMODATIONS. WE HAVE ASCERTAINED THAT THE SERVICE FEE CHARGED BY THE AMERICAN EXPRESS COMPANY DURING 1958 WAS $10 AND THAT THE CABLE COSTS USUALLY AMOUNTED TO $6 IN EACH TRANSACTION. REPRESENTATIVE OF THE COMPANY HAS ADVISED US INFORMALLY THAT IT MAKES NO CHARGE TO THE TRAVELER FOR OBTAINING AIR TRANSPORTATION TO THE SOVIET PORT OF ENTRY AND THAT THE SERVICE FEE IS CONSIDERED TO COVER ONLY THE COMPANY'S SERVICES IN ARRANGING THROUGH INTOURIST FOR OTHER ACCOMMODATIONS WITHIN RUSSIA.

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B-139733, JUNE 26, 1959, 38 COMP. GEN. 879

CIVILIAN PERSONNEL - TRAVEL EXPENSES - TRAVEL AGENTS - FEES - TRAVEL IN THE SOVIET UNION ALTHOUGH THE EMPLOYMENT OF A TRAVEL AGENT IN THIS COUNTRY TO ARRANGE FOR ACCOMMODATIONS FOR GOVERNMENT EMPLOYEES TO TRAVEL IN THE SOVIET UNION MAY BE A CONVENIENCE TO THE TRAVELER, THIS DOES NOT SATISFY THE REQUIREMENT IN PARAGRAPH 10.5 OF THE STANDARDIZED GOVERNMENT TRAVEL REGULATIONS FOR A SHOWING OF NECESSITY FOR THE USE OF SUCH SERVICES TO PERMIT REIMBURSEMENT TO THE EMPLOYEES OF THE SERVICE CHARGE AS A MISCELLANEOUS EXPENDITURE.

TO HAROLD R. FATZINGER, NATIONAL SCIENCE FOUNDATION, JUNE 26, 1959:

ON MAY 25, 1959, YOU SUBMITTED TO US TWO RECLAIM VOUCHERS IN FAVOR OF LEE ANNA EMBREY AND J. W. JOYCE, RESPECTIVELY, IN THE AMOUNT OF $16 EACH REPRESENTING SERVICE CHARGES BY THE AMERICAN EXPRESS COMPANY ARRANGING ACCOMMODATIONS USED BY THE TWO EMPLOYEES WHILE IN AN OFFICIAL TRAVEL STATUS TO THE SOVIET UNION. THESE ITEMS WERE ADMINISTRATIVELY DISALLOWED BECAUSE THEY WERE BELIEVED TO BE PROHIBITED BY THE PROVISIONS OF 5 GAO 2013.20, CONCERNING THE USE OF TRAVEL AGENTS IN OBTAINING GOVERNMENT TRANSPORTATION.

WE UNDERSTAND THAT, BEFORE ISSUING A VISA TO AN ORDINARY TRAVELER TO ENTER THE COUNTRY, THE SOVIET GOVERNMENT REQUIRES PROOF THAT ALL TRAVELER ACCOMMODATIONS HAVE BEEN ARRANGED IN ADVANCE AND PREPAID. WE UNDERSTAND, ALSO, THAT FOR THE ORDINARY TRAVELER SUCH ARRANGEMENTS MUST BE MADE THROUGH INTOURIST, THE SOVIET GOVERNMENTAL TRAVEL BUREAU, WHICH OPERATES IN THE UNITED STATES ONLY THROUGH DESIGNATED AGENTS SUCH AS THE AMERICAN EXPRESS COMPANY AND OTHER TRAVEL AGENCIES. THOSE AGENCIES ARE REMUNERATED FOR THEIR SERVICES IN PART BY THE ASSESSMENT OF A FEE AGAINST EACH TRAVELER WHO ALSO IS REQUIRED TO PAY THE AGENCY'S OUT-OF POCKET EXPENSES OF CABLING FOR THE ACCOMMODATIONS. WE HAVE ASCERTAINED THAT THE SERVICE FEE CHARGED BY THE AMERICAN EXPRESS COMPANY DURING 1958 WAS $10 AND THAT THE CABLE COSTS USUALLY AMOUNTED TO $6 IN EACH TRANSACTION. REPRESENTATIVE OF THE COMPANY HAS ADVISED US INFORMALLY THAT IT MAKES NO CHARGE TO THE TRAVELER FOR OBTAINING AIR TRANSPORTATION TO THE SOVIET PORT OF ENTRY AND THAT THE SERVICE FEE IS CONSIDERED TO COVER ONLY THE COMPANY'S SERVICES IN ARRANGING THROUGH INTOURIST FOR OTHER ACCOMMODATIONS WITHIN RUSSIA. THOSE ACCOMMODATIONS, FOR WHICH INTOURIST IS PAID A FIXED DAILY RATE, INCLUDE LOCAL TRANSPORTATION WITHIN RUSSIA BY RAIL, BUS, AND TAXIS, HOTELS, AND MEALS, AND PERHAPS OTHER ITEMS.

FIRST, WE DO NOT CONSIDER THE PROVISIONS OF 5 GAO 2013.20 TO BE APPLICABLE TO A SITUATION SUCH AS IS INVOLVED HERE SINCE THAT SECTION RELATES TO THE PROCUREMENT OF PASSENGER TRANSPORTATION SERVICES BY THE ISSUANCE OF GOVERNMENT TRANSPORTATION REQUESTS. THE STANDARDIZED GOVERNMENT TRAVEL REGULATIONS GOVERN THE REIMBURSEMENT OF SUCH EXPENSES AS THE SERVICE CHARGE PAID BY THESE TRAVELERS TO AMERICAN EXPRESS COMPANY.

IN PARAGRAPH 6.1 OF THE REGULATIONS, TELEGRAPH COSTS FOR RESERVING HOTEL ACCOMMODATIONS ARE SPECIFICALLY LISTED AS BEING INCLUDED IN THE PER DIEM AMOUNT ALLOWED A TRAVELER IN LIEU OF SUBSISTENCE EXPENSES AND, THEREFORE, SUCH COSTS ARE NOT REIMBURSABLE AS SEPARATE ITEMS. ON THE OTHER HAND, COSTS OF NECESSARY TELEGRAMS TO RESERVE "AIRPLANE SLEEPING CAR, OR STEAMER ACCOMMODATIONS" MAY BE REIMBURSED TO THE TRAVELER UNDER PARAGRAPH 7.5 OF THE REGULATIONS. WHILE THE INTOURIST ARRANGEMENT FOR ACCOMMODATIONS WITHIN THE SOVIET UNION MAY INCLUDE SLEEPING CAR OR STEAMER ACCOMMODATIONS IN SOME CASES, THE BEST INFORMATION WE HAVE BEEN ABLE TO OBTAIN INDICATES THAT THE INTOURIST ARRANGEMENTS FOR MISS EMBREY AND MR. JOYCE CONSISTED PRINCIPALLY OF HOTEL ACCOMMODATIONS, MEALS, LOCAL CONVEYANCES, AND THE SERVICE OF AN INTERPRETER OR GUIDE. TELEGRAPH COSTS TO RESERVE OR ARRANGE FOR SUCH SERVICES ARE NOT REIMBURSABLE UNDER THE TRAVEL REGULATIONS AND, FOR THAT REASON, $6 OF THE AMOUNT RECLAIMED IN EACH VOUCHER MAY NOT BE CERTIFIED FOR PAYMENT.

THE TESTS AS TO WHETHER THE REMAINING $10 FLAT SERVICE FEE CLAIMED IN EACH VOUCHER MAY BE REIMBURSABLE IS THE ACTUAL NECESSITY OF INCURRING SUCH EXPENSE IN ORDER TO TRANSACT THE OFFICIAL BUSINESS OCCASIONING THE TRAVEL. PARAGRAPH 10.5 OF THE STANDARDIZED GOVERNMENT TRAVEL REGULATIONS PROVIDES:

OTHER EXPENSES.--- MISCELLANEOUS EXPENDITURES, NOT ENUMERATED HEREIN, WHEN NECESSARILY INCURRED BY THE TRAVELER IN CONNECTION WITH THE TRANSACTION OF OFFICIAL BUSINESS, WILL BE ALLOWED WHEN APPROVED.

WE HAVE DISCUSSED THE SUBJECT INFORMALLY WITH SEVERAL DEPARTMENTS AND AGENCIES OF THE GOVERNMENT WHICH HAVE IN THE PAST AUTHORIZED OFFICIAL TRAVEL OF EMPLOYEES TO THE SOVIET UNION AND NONE, SO FAR AS WE ARE ABLE DETERMINE, FOUND IT NECESSARY TO EMPLOY THE SERVICES OF A TRAVEL AGENCY IN THIS COUNTRY AT AN ADDED COST TO THE GOVERNMENT IN ORDER TO OBTAIN EITHER A VISA OR THE INTOURIST SERVICES INSIDE THE SOVIET UNION. THE REGULATIONS EXPRESSLY REQUIRE A SHOWING OF NECESSITY WITHOUT QUALIFICATION AND, WHILE WE HAVE NO DOUBT THAT THE ADVANCE ARRANGEMENT FOR INTOURIST SERVICES THROUGH A TRAVEL AGENCY IS A DECIDED CONVENIENCE TO THE TRAVELER, DOES NOT SATISFY THE REQUIREMENTS OF THE REGULATIONS FOR A SHOWING OF NECESSITY.

THEREFORE, UPON THE PRESENT RECORD THE VOUCHERS WHICH YOU SUBMITTED MAY NOT BE CERTIFIED FOR PAYMENT.

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