TDY POV/PARKING FEES: WEBSITE ESTIMATIONS V. REALITY

Terri, a Dep’t. of Interior employee, took an Uber to the airport for  her four-day trip.  When she filed a voucher asking for the agency to reimburse her $40.00 costs, it refused to pay.  It alleged that if she had taken a cab, Uber or similar ride to the airport it would only have cost her $16.74. It based that on a website estimation of what the cost of the trip would have been on average. The employee appealed to the Civilian Board of Contract Appeals (CBCA) which is where feds take travel disputes if they cannot grieve the agency’s denial. The Board slapped Interior down and ordered Terri fully paid.  But it is the reasoning it used that is important because we would not be surprised if other agencies are also using website estimations to reject employee travel claims.

Interior claimed that “[u]sing the average estimate provided by [the website] allows the Agency to treat airport parking reimbursements consistently, in light of the complex, dynamic variables used to calculate taxi/TNC fares at any given point in time.” It probably relied upon the Board having previously found that a traveler’s presentation of alternative cost calculations from the agency’s chosen website, made at different times of day in markets with dynamic transport pricing, is a reasonable way to challenge an agency’s more limited cost calculation as unreliable. The traveler can also attempt to show extenuating circumstances that might have made regular taxi or TNC service effectively unavailable at the time of travel, making the cost comparisons mostly meaningless.

But, and this is the very big critical but, here the claimant presented even stronger evidence than that: she provided actual receipts for four Uber rides that she took between the airport and her residence using Uber for Government in December 2025, after her November 2025 parking reimbursement was reduced, with pre-tip costs of $27.58, $41.22, $28.26, and $46.96.

Although the agency has a right to try to contest that evidence, perhaps by showing that unusual circumstances such as weather or road construction delays affected the costs of those Uber rides in a manner that would not have affected her November 2025 travel, the agency here provided no such evidence. “The evidence of actual recent costs for the route that claimant must travel to and from the airport is far more credible than a calculation from a taxi fare estimating website, see Paul F. Anderson, 14-1 BCA at 174,901 (finding claimant’s fare estimate more credible where it “was derived by calling the taxi company, as compared with an estimate used by the [agency] from an internet site”), and is much more consistent with our own review of the website to which the agency cited as well as related Uber and Lyft sites.”

Although the desire for administrative ease in dealing with travel claims is understandable, the Board wrote that the agency’s ultimate goal has to be to compensate its employees fairly and as fully as possible for engaging in travel that furthers the Government’s interests and mission.

You might  want to check to see if your agency uses website estimations.  If it does, an email to all members making them aware that they can challenge the denial of their vouchers would be appropriate.

For more details, see March 2, 2026 CBCA 8792-TRAV In the Matter of TERRI D.