Training Policy Handbook

Expenses Related to Training

• Advance Payment of Expenses

• Fees, Services, and Facilities

• Per Diem

• Transportation

• Travel Costs

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The following is intended to guide agencies in: 1) ensuring equitable treatment of all employees; and 2) applying sound fiscal management principles to paying training expenses. The sections address expenses not related to an employee's pay. Training law permits an agency to pay all, some, or none of the expenses of employee training.

Advance Payment of Necessary Expenses

An agency has the authority to authorize advance payment of expenses such as tuition, per diem, travel, and other expenses essential to training as long as there is some mechanism to protect the Government's interest, such as reimbursement if the training is not completed or passed. See Title 31 USC §3324, Title 5 USC §4109(a)(2), and 41 Comp. Gen. 626 (1962).

Fees, Services, and Facilities

The following subsection addresses catering expenses, meals and refreshments; examinations, licenses and certifications; library and laboratory services; lodging and meals at place of duty; purchase or rental of books, materials and supplies; meals of outside speakers; registration fees to attend training sponsered by an interagency board, council, or commission; and tuition and matriculation fees.

Catering expenses, meals, and refreshments

As a general rule, appropriated funds cannot be used for personal expenses such as meals and refreshments, unless specifically authorized by statute. However, two exceptions exist in the Government Employees Training Act: Title 5 USC §4109, training expenses, and Title 5 USC §4110, expenses of meetings and conferences. Costs may be properly charged as training expenses under Title 5 USC §4109 or as travel expenses under Title 5 USC §4110. There is no specific limitation on the amount per meal or snack which the agency may incur. (Comp. Gen. B-244473 (January 13, 1992))

Training exception: Food may be provided at Government expense for employees attending authorized training as a necessary expense under Title 5 USC §4109 when provision of that food is necessary to achieve the training program's objectives (49 Comp. Gen. 185 (1968)). However, an agency must determine that the provision of food is necessary for employees to obtain the full benefit of the training. See Comp. Gen. B-244473 (January 13, 1992); and Comp. Gen. B-270199 (August 6, 1996). Three conditions apply:

1. the meal or refreshments must be incidental to the training program;

2. attendance at the meal or refreshment break must be necessary for full participation in the program; and

3. the employee cannot be free to take the meal or refreshment break elsewhere. (65 Comp. Gen. 143 (1985), as amended)

Meetings exception: Food may be provided in connection with the attendance of government employees at meetings and conferences under Title 5 USC §4110. The test for applying Section 4110, however, is that the food is provided at a formal conference or meeting involving topical matters of general interest to governmental and nongovernmental participants, rather than at a routine business meeting primarily involving day-to-day agency operations and concerns. See 68 Comp. Gen. 604 (1989) and Comp. Gen. B-270199 (August 6, 1996).

Catering expenses: The cost of catering services (luncheons, dinners, and coffee breaks) furnished by a hotel to a training conference held pursuant to Title 5 USC §4110 is payable as a training expense when these services are necessary to achieve the objectives of the training conference, such as establishing an environment which requires, stimulates, and fosters communication among participants and interaction among participants as often as possible. (50 Comp. Gen. 610 (1971))

Meals covered by registration fees: When meals or coffee breaks are provided for in a registration fee for training, the cost of a meal or the coffee break occurring during the training session may be paid under Title 5 USC §4109 regardless of whether the training program is held at or away from the employee's duty station.

Meals not covered by registration fees: When a meal or coffee break is not provided for in a training registration fee, the cost of the meal or the break occurring during a training session held at the employee's duty station may be paid when conditions for the exception under Title 5 USC §4109 are met.

Examinations, Licenses and Certifications

Agencies may use appropriated funds or funds otherwise available to the agency to pay expenses for employees to obtain professional credentials, including expenses for professional accreditation, State-imposed and professional licenses, and professional certification; and examinations to obtain such credentials. This authority is discretionary and may not be exercised on behalf of any employee occupying or seeking to qualify for appointment to any position that is excepted from the competitive service because of the confidential, policy-determining, policy-making, or policy-advocating character of the position. (Title 5 USC §5757; Pub. L. 107-107)

Library and laboratory services

The necessary cost of library and laboratory services are payable under Title 5 USC §4109 when they are an integral part of the course or program of study or are required by the academic institution as part of the tuition and matriculation fees.

Lodging and meals at place of duty

The head of an agency is authorized to cover all expenses necessary for a training event under Title 5 USC §4109.

If the agency requires all participants of a training course to stay in a local hotel while in training, a per diem allowance at headquarters may be authorized as a necessary training expense. In 39 Comp. Gen. 119 (1959), an employee assigned to take a two-week training course at the employee's place of duty was allowed to receive reimbursement or advance payment for expenses connected with the use of a local hotel while in training.

Purchase or rental of books, materials, and supplies

Agencies may pay for a magazine subscription used in a training course or program of study under Title 5 USC §4109(a)(2)(E). Magazines are covered under the periodical purchase limitation in an agency's appropriation, and the cost must be charged to that limitation. See 39 Comp. Gen. 320 (1959).

Meals of outside speakers

A coordinator of a training seminar who pays the cost of meals for non-Government guest speakers may be reimbursed for that expense upon agency determination that the cost of the meals is a training expense authorized under Title 5 USC §4109. See 48 Comp. Gen. 185 (1968).

Registration fees to attend training sponsored by an interagency board, council, or commission

The payment of a registration fee for a training seminar sponsored by an interagency board, council, or commission, such as a Federal Executive Board, is permissible when:

1. the payment directly benefits the agency making the payment, and

2. the fee does not include elements designed to capture more than the direct costs of sponsoring the seminar.

Under the above circumstances, payment of the registration fee does not violate the general prohibition against interagency financing of boards or commissions. See 71 Comp. Gen. 120 (1991).

Tuition and matriculation fees

Tuition and matriculation fees are payable under Title 5 USC §4109(a)(2)(C).

Per Diem

Title 5 USC §4109(a)(2) provides that an agency may pay, or reimburse an employee, for all or a part of per diem expenses. The U.S. General Services Administration Federal Travel Regulations determine per diem rates. Therefore, an agency may not make any payment above the applicable full per diem rate specified in those regulations. See Title 41 CFR §301-11.

An agency may pay a reduced per diem rate or a standardized payment to employees in temporary duty training assignments. See Title 5 CFR §410.403(b). If a reduced or standardized per diem rate is not authorized in advance of the travel and the fees paid to a training institution include lodging or meal costs, the agency must make an appropriate deduction from the total per diem rate payable to the employee.  See Title 41 CFR §301-7.12

In Comp. Gen. B-185374 (July 29, 1976), an employee was not authorized per diem during a period of training prior to reporting to the employee's first official duty station. The denial resulted from an agreement between agency personnel and finance officers not to pay per diem to any employee whose residence was less than 50 miles from the training site. The employee resided 18 miles from the training location. The decision was a proper exercise of agency discretion.

Transportation

Transportation payment at agency discretion

Under Title 5 USC §4109(A)(2)(B), an agency may permit an employee selected for long-term training to choose to transport his or her dependents and household goods to the training site rather than receive per diem. This authority recognizes the occasional need for a Federal employee assigned for training at a temporary duty station to relocate his or her family to the site.

Limitation on transportation expenses

The maximum allowance for the transportation of dependents and household goods to an employee under Title 5 USC §4109(a)(2)(B) is based on the total per diem allowance the employee forgoes to receive the transportation benefits for his or her immediate family and effects. See 39 Comp. Gen. 140 (1959) and 40 Comp. Gen. 714 (1961).

The employee may receive either per diem or a transportation allowance, but not both.

The U.S. General Services Administration regulations allowing an agency to pay a limited set of relocation allowances in connection with a temporary change of station for a period of not less than 6, nor more than 30, months, do not apply to employees assigned to training under Title 5 USC Chapter 41. See Title 41 CFR Part 302-1.

Travel Costs

Title 5 USC §4109(a)(2) provides that an employee may be reimbursed for all or part of the necessary expenses of training, including travel costs. The GSA Federal Travel Regulations determine what specific travel costs may be paid.

Expenses for privately owned vehicle

Agencies may authorize and pay expenses of employees using privately owned vehicles to travel to and from training.

The authority contained in Title 5 USC §4109(a)(2)(A) to pay or reimburse employees for the necessary expenses of training includes costs of using privately owned vehicles when such use is for the good of the Government. See Title 5 USC §5704(d).

36 Comp. Gen. 795 (1957) found that, when an employee is properly authorized to use a privately owned vehicle for official business, it is within the administrative discretion of the agency to pay the employee the cost of mileage from whatever point the journey is begun. There is no requirement that the distance the employee would normally travel between home and headquarters be deducted from the computation. This applies irrespective of whether the employee performs duty on that day within or without the corporate limits of the headquarters city or at the headquarters office.

When travel by a privately owned vehicle is to the advantage of the United States and a parking fee is required at the training site, the parking fee is an allowable expense. See Title 5 USC §5704(b).