Temporary Quarters Subsistence Expenses

A Federal employee appealed the action of the GAO Claims Division which disallowed his claim for additional temporary quarters subsistence expenses representing the amounts he paid his mother-in-law attributable to the room, board, and laundry expenses that she provided to his wife and two children while he was being relocated. The Claims Division had upheld the disbursing officer's conclusion that the amounts claimed did not appear to be reasonable and that the amounts claimed for lodging and laundry expenses were excessive, considering the cost of living in the applicable region. In his appeal, the claimant explained that due to the birth of a premature son, the family had been housebound so that his mother-in-law was subjected to extra housework, including cooking, cleaning, and laundry. She also incurred extra utility expenses to provide air conditioning for the premature baby. The employee also contended that the rate for his dependents should be based on the overseas rate allowable for his new duty station. GAO found that the rates for the region in which the dependents resided were the applicable rates. GAO has held that reimbursement for charges for lodging and related services supplied by relatives may be allowable, but what is a reasonable rate depends upon the circumstances of each case. Factors such as an increase in the use of utilities, hiring extra help, and extra costs incurred by the relative are to be taken into consideration. The claimant must provide sufficient information to enable his agency to determine the reasonableness of his claim. It is not enough to show that the amount is less than the commercial rate or the maximum rate allowable under the regulations. In this case, the agency gave insufficient reasons why it considered the food and lodging costs unreasonable. GAO found that the inconvenience experienced by the employee's mother-in-law, the significant increase in labor required, and the increased cost of utilities justified payment of the claim. GAO also found that a claim for commercial lunches and dinners and the laundry expenses was reasonable and therefore reimbursable. Accordingly, the employee's reclaim voucher should be paid, less those amounts previously paid.