Department of Transportation-Inspector General-Bonus Points

B-270423 Jul 01, 1996 Jump To VIEW DECISION RELATED PAGES GAO CONTACTS Highlights Government employees using personal credit cards to charge lodging and rental car expenses incident to official travel are not precluded under current regulations from retaining for personal use frequent flyer mileage points earned on the amounts charged to such credit cards. Provided that the use of such cards for such expenses is consistent with agency guidance and does not increase the costs to the government. Individual agencies have discretion to place additional requirements for employee use of agency-furnished cards for official travel. We assume it is one of the "affinity" cards now in wide use. Are standard credit cards (e.g. Points are awarded for any purchase charged on the card. View Decision Matter of: Department of Transportation-Inspector General-Bonus Points for Use of Personal Credit Cards for Certain Official Travel Expenses File: B-270423 Date: July 1, 1996 Government employees using personal credit cards to charge lodging and rental car expenses incident to official travel are not precluded under current regulations from retaining for personal use frequent flyer mileage points earned on the amounts charged to such credit cards, provided that the use of such cards for such expenses is consistent with agency guidance and does not increase the costs to the government. Under applicable federal regulation, individual agencies have discretion to place additional requirements for employee use of agency-furnished cards for official travel, and by implication may also place further limitations on employee use of personal credit cards for charging expenses of official travel. DECISION By letter of October 25, 1995, the Inspector General (IG), Department of Transportation, asks whether, and under what circumstances, a government employee may use a personal credit card to charge lodging and automobile rental costs incurred on official business and thereby accumulate bonus points for the employee's personal use. The IG states that her question arises because of an apparent conflict between our holding in Discover Charge Cards, B-236219, May 4, 1990, and a statement made in a footnote in Panama Canal Commission, B-257525, Nov. 30, 1994. Although the IG did not specify the particular credit card involved, we assume it is one of the "affinity" cards now in wide use. Those involved here, as we understand it, are standard credit cards (e.g., MasterCard, VISA) issued by a bank under arrangement with an airline or hotel chain, which in turn awards bonus or mileage points under a frequent traveler program based on amounts charged using the card (e.g., an award of a bonus mile for each dollar charged). Points are awarded for any purchase charged on the card, and are not limited to purchases of the services of the particular airline or hotel affiliated with the card. Points or miles awarded in this manner, based on aggregate amounts charged on the affinity card, are separate from, and in addition to, any points or miles awarded for flying on an affiliated airline or for using an affiliated hotel's services, the costs of which may be charged on the same affinity card. The general rule is that a federal employee is required to account for any gift, gratuity, or benefit received from private sources incident to the performance of official duty, and any payments tendered to the employee are viewed as having been received on behalf of the government. See 63 Comp.Gen. 229 (1984), and decisions cited therein. Therefore, an employee may not retain any bonus or gift coupon or similar item of value received from a commercial air carrier on the basis of purchase of an airline ticket to be used for official travel. Id. Bonus travel entitlements received by an employee through accumulation of frequent flyer mileage credits earned on government travel are considered to be the property of the government and may not be retained by the employee. Id. See also, Johnny Clark, B-215826, Jan. 23, 1985, applying these rules to bonus lodging points received for using a motel while on government travel. The Federal Travel Regulation (FTR), 41 C.F.R. Sec. 301-1.103, in essence, restates these rules. [1] As the IG recognizes, in Discover Charge Cards, supra, we held that the rules set out above do not apply to a cash or credit rebate an employee receives from a credit card company based on all purchases he or she makes during a year using the credit card, including official travel expenses charged to the card. The rebate in these circumstances is distinguishable from such promotional benefits as half-fare coupons and bonus points which are directly related to the official travel for which the benefits are received, i.e., awarded incident to the purchase of an airline ticket for official travel.