Here are the facts as recently described by the Civilian Board of Contract Appeals (CBCA), which rules on travel expense disputes for those employees who cannot file a contract grievance to settle them.  “Claimant was authorized travel by the Environmental Protection Agency (EPA) to attend a business meeting in San Francisco, California. Claimant traveled from his home in Kansas City, Kansas, on Monday, July 23, 2012, to attend this meeting on July 24 and 25, 2012. The meeting concluded at approximately 4:30 p.m. on July 25. Thereafter, claimant took personal leave and returned to Kansas City on July 29, 2012. The EPA denied claimant’s request for reimbursement of lodging expenses for the night of July 25, on the basis that claimant was on personal leave as of the conclusion of the business meeting.” Is the EPA employee entitled to another night’s lodging expenses just to avoid the really long work day it would mean if he traveled home on July 25?

It turns out that the employee is.  Here is why the CBCA thought he was. “Ordinarily a traveler should not be required to travel during unreasonable hours at night. Travel the day after the conclusion of agency business is appropriate to avoid travel during late hours. . . . We have previously found that it is proper to pay an employee’s expenses for an overnight stay after agency business has concluded, where travel to return to his permanent duty station on the last day of official business would have resulted in an unreasonably long workday. Mark Chapman, GSBCA 13684-TRAV, 97-1 BCA ¶ 28,960. We have also held that payment for lodging at the permanent duty station is appropriate where there were safety concerns involved in driving after an extended workday. Diane M. Balderson, CBCA 2416-TRAV, 11-2 BCA ¶ 34,801. . . . It would have been unreasonable to compel claimant’s travel home after the conclusion of agency business on July 25 when his arrival at home would have been at 2:00 a.m. Claimant’s personal travel on July 26 does not affect his right to be reimbursed for lodging while still on Government business. Claimant is entitled to be paid his actual cost of lodging for the night of July 25, not to exceed the lodging rate in the temporary duty area.” In the Matter of Craig Smith, 3221-TRAV, (7/30/13).  Also check out another FEDSMILL piece about this reimbursement entitlement.

Of course, you should check your agency travel regulations to see if they address this already.  If not, then it is something the union can bargain over in the next contract, e.g., what will be considered an unreasonably long day.

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FEDSMILL staff has over 40 years of federal sector labor relations experience on the union as well as management side of the table and even some time as a neutral.
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