Q&A Session – Travel Reimbursement for Airline Miles


Ask the Lawyer received the following question (paraphrased for easier reading and clarity) from a reader on a legal matter that might be of interest to the entire audience.


I recently filed a travel voucher with my agency following my return from leave and temporary duty. I purchased airline miles with my credit card and applied the miles toward my airfare. I used the airfare for my leave, but stopped at a TDY location on the way home. I was told that GAO doesn’t recognize airline miles and would not reimburse my ticket to the TDY location. Is this correct?


Even though you paid with your personal credit card for the miles utilized to obtain your airfare that was ultimately used for official travel, you unfortunately are not entitled to reimbursement.  As you indicated, federal employees are eligible for payment of travel expenses, such as air fare, when performing official travel.  41 C.F.R. § 301-10.1-10.2.  It appears that your trip would qualify as “official travel,” thus warranting reimbursement of your air fare.  However, as the Agency advised you, you are not entitled to reimbursement for the miles used to obtain the airfare, or for reimbursement of the credit card payment maid to purchase the miles.  Such payment is prohibited by the Federal Regulations.  Generally, travel expenses should be paid with an employee’s government-issued travel card, unless you have an exemption.  41 C.F.R. § 301-51.1.  If you receive an exemption, you may pay for transportation expenses with cash, personal credit cards, personal check, or travelers check.  41 § 301-51-101.  Because you did not pay for the airfare with cash or a cash equivalent, you are not eligible for reimbursement, and it is immaterial that you did pay for the miles with a cash equivalent. 

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About Author

Debra Roth

Debra L. Roth is a partner at the law firm Shaw Bransford & Roth, a federal employment law firm in Washington, D.C. She is general counsel to the Senior Executives Association and the Federal Managers Association, host of the “FEDtalk” program on Federal News Radio, and a regular contributor to Federal News Radio’s “Federal Drive” morning show. Email your legal questions to lawyer@federaltimes.com.

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