WHOOPS, I FORGOT MY PASSPORT, WALLET, LUGGAGE, ETC.
What are feds to do if they have booked an airline flight, but when they get to the airport they realize they left something vital at home? They rebook the flight, of course, usually through SATO. But who pays for the costs of the rebooking? The employee who made the mistake or the agency? The Department of the Navy decided that the employee would have to pay because he was not a “prudent traveler.” The CBCA decided Navy was wrong.
Navy pointed to this section of the Federal Travel Regs to defend its position.
What standard of care must I use in incurring travel expenses? You must exercise the same care in incurring expenses that a prudent person would exercise if traveling on personal business.
The Board began its analysis reminding Navy that “if a traveler intentionally and purposely misses scheduled transportation during TDY travel without a legitimate official business reason, the traveler cannot pass resulting increased travel costs through to the Government.” (We underlined the words.)
It then wrote the following, calling the employee’s error “an honest mistake.”
Claimant acted in a prudent manner by rescheduling his flight through SATO so that he could still depart in time for his meeting the next day, and the FTR and JTR would have prohibited him from personally purchasing a flight with a non-U.S. flag air carrier. FTR 301-10.143; JTR 020206.I.2. Claimant, consequently, had no alternative to using SATO to reschedule his flight, and the amount that SATO charged presented claimant with an actual “Hobson’s choice.”1 Any additional cost for the rescheduled flight was that charged by SATO, and claimant had no control over the increased fare. Under those circumstances, claimant acted in a prudent manner. Nothing in the record suggests anything other than an honest mistake on claimant’s part, and there is no evidence that claimant acted in an irresponsible manner. The additional cost that claimant incurred was necessary and justified under the circumstances. Claimant is, therefore, entitled to be paid the full amount of the cost of his airline ticket.
For more details, check out in the Matter of Brian G., CBCA 8291-TRAV (2025).
