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Travel Card Delinquencies
Report Number I-2001-008
August 2001


Although the Department has an overall travel card coordinator, the travel charge card program is decentralized with each component adapting the program to fit its mission and needs. Consequently, each component has developed its own practices in administering the program, and those practices involve varying degrees of control over travel cards.

During our overall review of Department travel charge card delinquencies, we observed that most components had established effective systems for monitoring and following up on delinquencies and charge card misuse. Accordingly, these components' delinquency rates were fairly low. However, the INS has not established an effective monitoring and follow-up system for the travel card program. Although the INS has issued written guidance for the travel card program, this guidance omits important controls needed for adequate monitoring of travel card use and payments. Also, INS employees, supervisors, and management officials do not uniformly adhere to the guidance. Therefore, the INS's delinquency rate is high. We also found that INS employees had used their travel cards for inappropriate purposes such as to make a down payment on a house, make a down payment on a car, pay for a family member's wedding, buy furniture, and purchase Christmas presents. A Bank One official responsible for the Department account told us that if the INS's performance were not included in the assessment, the Department would rank as one of the better government accounts.

Based on our discussions with the Department's national and local travel card coordinators, supervisors of delinquent cardholders, and a responsible Bank One official, we identified the components' best practices for managing their travel card programs. These practices are the basic elements for an effective travel card program. Based on our review, the INS's program includes few, if any, of these elements:

Management Support

The hallmark of an effective program is management support. Considering this, INS managers need to communicate and enforce a zero tolerance policy for travel card delinquencies and abuses. In January 2000, the Assistant Commissioner of the INS's Office of Financial Management sent a memorandum to INS directors, officers-in-charge, chiefs, and other officials stressing the importance of the manager's role in ensuring that members of their staff use their travel cards appropriately and pay their bills promptly. Despite this memorandum, we did not find universal acceptance of the importance of supervisory and management oversight. Instead, from interviews with coordinators and supervisors in our sample, we found a wide range of management attitudes towards the importance of controlling delinquencies and misuse, ranging from zero tolerance to disinterest. We generally found that in locations where supervisors and managers held employees accountable for paying their travel card charges and took notice when they were delinquent, delinquencies were resolved quickly and fewer delinquencies occurred.

At 5 of the 19 INS locations reviewed, it was evident from our interviews with local coordinators and supervisory personnel that their management had both communicated and were enforcing a zero tolerance policy. For example, at one district office, the deputy director made it clear during staff meetings that managers and supervisors would be held accountable for monitoring their staff's debts and that action would be taken against them for failure to aggressively follow up on delinquencies and misuse. For each incidence of delinquency or misuse that occurred, the applicable manager or supervisor was required to provide an explanation to the deputy of what actions were taken to resolve the issue. Similarly, at one border patrol sector, the deputy chief border patrol agent routinely reviewed monthly bank reports and required those employees who were delinquent, or who had made inappropriate charges, to provide him with a written explanation. Our sample included one delinquency at each of the two locations. At both locations, the field location manager had taken decisive action, recommending that the delinquent employee be terminated.

At the other INS locations we reviewed, management either did not actively support the program or, in some cases, openly undermined the program. For example, at one headquarters location, when the coordinator brought a case of multiple inappropriate ATM withdrawals to the attention of the deputy, the coordinator was told that it was not important what charges were made as long as the employee paid the bill. The employee, a chronic delinquent, eventually defaulted after owing over $7,000. To date, no disciplinary action has been taken against the employee. In another example, at one border patrol sector the coordinator was instructed to follow up only on instances of travel card misuse, not delinquencies. According to the coordinator, the deputy chief border patrol agent's philosophy was that delinquencies are a personal matter between the bank and the cardholder and did not effect the Department. At this location, three employees, owing a total of $14,137, appeared on the bank's January 1, 2001, list of accounts that were 120 days delinquent.

Timely Identification and Referral to Cardholder's Supervisor

When an employee's account becomes delinquent or when an employee misuses the card, early identification and resolution of the problem is important. Local coordinators should notify cardholders' supervisors in a timely manner so they can determine the reasons for the delinquency and encourage the cardholder to pay the debt. Some causes of delinquencies, such as failure of the employee to submit a travel voucher timely or a delay in receiving a reimbursement check, could be resolved easily by the supervisors. Other causes, such as fiscal irresponsibility on the part of the cardholder, could result in a referral to the Employee Assistance Program for counseling. We observed that when the cardholder's supervisor is not notified in a timely manner, the delinquent amount can become so great that the employee cannot readily pay it.

When delinquencies occur, a supervisor's early intervention may reduce the risk of the employee's card privileges being suspended, which currently can occur when the employee fails to make a payment within 60 days. 6 If a delinquency is not resolved by 120 days, Bank One will cancel the account and the employee will most likely lose the travel card permanently. When an employee's job requires travel, suspension or cancellation of the employee's travel card makes employee travel more complicated for the component.

At the time of our review, the INS travel card program guidance required local coordinators to notify the cardholder's manager or supervisor if the cardholder's account became 60 days past due. Only 9 of the 19 locations in our sample (47 percent) complied with this requirement. 7 At three of the nine locations that complied with the requirement, the coordinator directly referred delinquencies to the cardholder's supervisor; at the other six locations, the coordinator directly referred delinquencies to a management level above the cardholder's supervisor.

At four locations that did not comply with the 60-day referral requirement, coordinators waited until the account was suspended or canceled before referring the delinquency to the cardholder's supervisor for follow-up. At three other locations that did not comply with the requirement, the coordinators were not proactive and would follow up only when a bank representative would call and ask them to do so. These seven locations accounted for 18 (33 percent) of the 54 INS delinquent employees included in our sample. Earlier referral of these accounts to the cardholder's supervisor could have resolved the delinquency and prevented the suspension or cancellation of the employee's account.

At locations where coordinators were reporting delinquencies directly to managers above the cardholders' first-line supervisors, the coordinators relied on these managers, in turn, to refer the cases to the supervisors for follow-up. At these locations, we found that supervisors were not always informed in a timely manner or, in some cases, were not informed at all. As a result, timely action was not taken to resolve the delinquencies. The officer-in-charge at one district office, who had supervisory responsibility over four of the delinquent cardholders in our sample, complained that the deputy frequently informed her of delinquencies late in the process and then required her to respond to management within 30 days. It was often difficult to contact employees and resolve delinquencies within the short time-frame provided due to the employees' training, overseas travel, rotating shifts, and annual leave. When questioned about the four delinquencies in the sample, the officer-in-charge was unaware of two of them. Because the cardholder's first-line supervisor is ultimately responsible for following up on delinquencies, it is important that the supervisor be notified early in the delinquency process. Therefore, it would be more effective to provide simultaneous notifications to management and first-line supervisors at those locations where management prefers to be kept aware of monthly delinquencies.

Written Feedback to Coordinators

Once a delinquent account or charge card misuse is referred to the cardholder's supervisor, most Department components require that the supervisor or the cardholder provide a written explanation of the reasons for the delinquency or misuse and an accounting of how the situation will be resolved. Obtaining a written explanation for delinquency or misuse is useful to not only document the circumstances for the purposes of possible disciplinary action, but also to ensure that supervisors are properly following up to resolve the delinquency or misuse.

Most of the INS coordinators we contacted stated that they required delinquent cardholders or their supervisors to provide a written explanation to the coordinator of the circumstances of the delinquency or misuse and a description of the action to be taken to resolve the situation. However, this practice was not always followed. We found that when we questioned the coordinators on specific delinquencies included in our sample, many were unable to provide us the information without first contacting the cardholder or the cardholder's supervisor. One of the district office coordinators we contacted admitted that, although she requests written explanations from delinquent cardholders, she generally does not receive any.

INS's El Paso District Office has implemented a particularly good practice for documenting charge card delinquencies and misuse. This office has created a standard memorandum that is routinely sent to the delinquent cardholder's supervisor. This memorandum contains a checklist of questions that the supervisor must respond to, such as whether the employee submitted a travel voucher timely and whether the employee has received a reimbursement check. At this office, there is little problem with compliance; if the supervisor does not respond, the coordinator has been instructed to inform the deputy district director. The INS should consider implementing this checklist at all its locations.

Referral to Higher Levels of Management

Most instances of delinquency or misuse can be resolved at the first-line supervisory level. However, upper management should be made aware of instances of unresolved delinquencies or of serious or frequent misuse when the first-line supervisor has not resolved the problems. This not only helps hold the supervisor accountable for taking action, but it also helps alert management to systemic or serious problems.

Most of the INS coordinators we contacted stated that they notified senior management of delinquencies at some point in the process. As described earlier, coordinators at some locations notified management officials directly, prior to the cardholder's first-line supervisor. At other locations, there was a hierarchical reporting process; the coordinator initially notified the cardholder's supervisor and then, if the delinquency was not resolved within the next 30 days, the coordinator notified management.

We identified several high-dollar delinquencies at INS locations where coordinators did not routinely notify management of unresolved delinquencies. For example, at one district office where only the cardholder's supervisor was notified, there were three delinquencies in our sample totaling $20,531. Management attention to these delinquencies may have helped limit the amounts owed.

We found, however, that referral to management alone did not necessarily result in delinquencies being resolved quickly. For the process to be effective, management also must be diligent about following up with the cardholder's supervisor to ensure that the delinquency is resolved. From our discussions with the coordinators, we found that those locations where management took the program seriously and routinely followed up with the supervisors experienced less overall problems with delinquencies.

Referral to Component Investigative Units

Referring unresolved delinquencies and serious or frequent misuse of travel cards to component internal affairs units helps demonstrate to employees that a zero tolerance policy is being enforced. There are other compelling reasons to implement a mandatory referral policy. First, referral ensures that payment and misuse problems are reviewed by an objective third party. Currently, some cardholders' supervisors are reluctant to take necessary action. Second, an investigation of an employee who fails to pay bills may uncover evidence of deeper problems or a vulnerability to corrupting influences.

The INS does require automatic referrals to its internal investigative unit for failure to pay travel card debts. The INS travel card program guidance states, "If the supervisor determines a misuse occurred, the misuse or reason for nonpayment should be reported to the Office of Internal Audit (OIA). Under the provisions of the OIA's Operations Instruction 287.10, misuse or unauthorized use of the Government Travel Card and failure to honor just debts where Service operations or reputation are affected are Class 3 allegations." 8

We found, however, that referrals of unresolved delinquencies or instances of misuse were not routinely made to the OIA. At only one location in our sample did the coordinator mention an external referral. This referral was made directly to the OIG, not to the OIA, and pertained to a misuse situation, not a delinquency. In this particular case, the referral of a supervisory employee, who used ATM withdrawals for a down payment on a house, was made because the coordinator could not get the cardholder's supervisor to take any action. Another coordinator we contacted was conducting her own "investigation" of an employee suspected of using the charge card for gambling purposes. This coordinator believed that conducting this investigation was her responsibility and was unaware that the case should be referred to the OIA or the OIG for investigation.

INS's referral policy is appropriate; however, the INS needs to ensure that its personnel are complying with the policy. Ensuring that supervisors routinely report unresolved travel card delinquencies and misuse would allow OIA to investigate these problems sooner and preclude further abuses.

Application of Consistent, Meaningful Disciplinary Action

To clearly demonstrate management's intent to control delinquencies and misuse, disciplinary action against employees who fail to pay their bills or knowingly make inappropriate charges may be necessary. Employees who use travel reimbursements for purposes other than paying their travel card bill are misusing Department money. Employees who make inappropriate charges also are misusing their travel card privileges for personal gain. For delinquency or misuse, the employee should be subject to disciplinary action. To be effective, the disciplinary action should be appropriate to the situation and should be applied consistently and in a timely manner.

We found that, in general, INS employees were not being disciplined for delinquencies. Of the 54 delinquent INS employees in our sample, only 12 (22 percent) had been disciplined or were in the process of being disciplined. These 12 employees were located in 9 of the 19 INS locations we contacted.

Most of the delinquencies in our sample were due to negligence or irresponsibility on the part of the cardholder, for which the cardholder should be held accountable. We were able to discern, from the local coordinators or the cardholders' supervisors, the specific reasons for 38 of the 54 delinquencies. 9 The reasons are summarized in the table below.

Reasons for Delinquencies

Reason for Nonpayment Number in Sample
Reimbursement check spent on personal items instead of on credit card bill 23
Misuse of card 6
Travel vouchers not filed, or filed late 5
Travel voucher processing delays 3
Bank error 1
Total 38

Source: Interviews with INS coordinators and supervisors

The INS's travel card program guidance related to required disciplinary action is very general. This guidance states that for a first-time offense, the manager should counsel the individual and that for repeated offenses, the manager may prepare a written warning and may consider sanctions, ranging from reprimand to removal. None of the locations we contacted seemed to be aware of this guidance; in fact, several supervisors we contacted stated that they were reluctant to administer disciplinary action for infractions involving travel cards because they believed there was no applicable guidance. Because these locations were not aware of the INS guidance, we found that each location had its own practices for administering disciplinary action for travel card delinquencies and misuse. Only one location had a definitive policy, requiring counseling for the first offense, written reprimand for the second offense, and a suspension of three to five days for the third offense. None of the other locations appeared to have a similarly consistent policy and disciplinary decisions were made on a case-by-case basis.

At those locations where management did not take travel card delinquencies or misuse seriously, no disciplinary action beyond a reprimand had been administered regardless of the extent of the delinquency or misuse. For example, one headquarters employee, who was not in travel status, routinely made inappropriate ATM withdrawals (we identified 41 such withdrawals over a six-week period), eventually accruing an unresolved delinquency of $7,640. Although the coordinator stated that management was aware that the employee was both misusing the travel card and was chronically late making payments, the employee received only a reprimand. A border patrol sector whose four employees, included in our sample, owed a total of $14,137 did not discipline delinquents because the deputy believed that delinquencies were a personal matter between the cardholder and the bank and therefore did not have an impact on the Department.

Most locations in our sample applied minimal or no disciplinary action against employees who became delinquent or who misused their travel card. Some examples:

We believe that disciplinary action can have a deterrent effect on subsequent infractions, provided that this action is applied consistently and is sufficiently serious. From our discussions with the coordinators, we found that locations where management took the program seriously and routinely followed up with the supervisors experienced less overall problems with delinquencies. Some managers in our review routinely took substantive action against employees who were delinquent or who misused their travel cards. In fact, three of the individuals included in our sample (at three locations) had either been terminated or were being considered for termination. Coordinators from two other locations cited noticeable declines in delinquencies when new managers implemented tougher disciplinary policies. One district office coordinator noted that the majority of the delinquency and misuse cases were centered in one of the district's branch offices and attributed this, in part, to the tougher disciplinary policies in place at the other branch office.

To implement effective discipline for charge card delinquents and employees who misuse their travel cards, we believe the INS needs to develop and disseminate a written policy requiring specific disciplinary actions, as well as guidance on mitigating circumstances that would affect disciplinary action. Although supervisors need to consider individual circumstances when assessing penalties, it is good practice to require substantive penalties while allowing supervisors or managers to make exceptions for mitigating circumstances. Such exceptions should be justified in writing and should conform to the INS's written policy.

Headquarters Oversight

Although local coordinators are responsible for following up on specific delinquencies and individuals who misuse their travel cards, national coordinators need to ensure that this follow-up is conducted. The INS national coordinator performs a cursory review of the monthly reports provided by Bank One, but generally relies on the local coordinators to identify and follow up on delinquencies or instances of suspected misuse. The national coordinator indicated that when she follows up with local coordinators on unresolved delinquencies, she is often told that the local coordinator has referred the delinquency to the employee's supervisor, but that the supervisor has failed to take action to resolve the delinquency. Local coordinators are often lower level staff who believe they do not have the authority to challenge the supervisors. During our review, we found that other components addressed this problem by requiring their national coordinators to elevate unresolved cases to senior management headquarters officials. For example, the DEA national coordinator refers unresolved cases to the DEA Deputy Assistant Administrator in the Office of Finance.

We believe headquarters oversight provides an extra step to resolve delinquencies before travel cards are canceled and helps identify local coordinators, supervisors, and managers who are not adequately performing their duties relating to the travel card program.

Elimination of the Use of Advances by Delinquent Cardholders

The FTR requires federal employees to use the government contractor-issued travel charge card for official travel expenses unless an exemption has been granted. The ATM feature of the card allows the traveler to obtain cash to pay for official expenses that cannot be charged using the card. The FTR also requires federal agencies to minimize the use of cash travel advances.

The INS travel card program guidance states, "If your Travel Card is suspended or canceled because of delinquency or misuse, the Service shall authorize an advance for the full cost of the trip, less common carrier transportation tickets." The INS is one of the few Department components that authorizes cash advances under these circumstances. 10

Although the INS guidance endorses this practice, we found that not all the INS locations are following it. Seven of the 19 INS locations we contacted did not provide such employees with cash advances. Instead the employees were required to pay their travel expenses out-of-pocket and then to submit a travel voucher for reimbursement.

Several coordinators and supervisors at those locations that routinely provided cash advances to employees whose travel cards had been suspended or canceled complained that the practice was detrimental because the employees were not being held accountable for their irresponsible behavior. Some examples of employees whose travel cards have been canceled, yet who are still eligible for cash advances under the INS's policy are:

We do not believe that travel advances should be used to fund the travel of individuals whose travel cards have been canceled due to delinquency or misuse. This practice not only counteracts the benefits derived by the Department from having the travel charge card program in place, but it also fails to hold employees accountable for irresponsible actions. It also reduces the incentive for employees to avoid having their travel cards canceled.

Maintaining Updated Information

Bank One identifies employees' work stations by hierarchy (location) codes provided by the components. Each hierarchy code is associated with a specific local coordinator. Bank One uses these codes to sort and distribute monthly monitoring reports. When an employee transfers to a different location within a component, the employee maintains the same travel card and the local coordinator notifies Bank One of the change in hierarchy code. (Employees who transfer to a different Department component relinquish their old travel cards and are provided with new ones.) Transfers can result in a gap in monitoring coverage, particularly when there is a delay in reporting changes in hierarchy codes. When delays occur, the employee's new local coordinator will not be aware of any delinquency or misuse problems that are occurring because Bank One's reports will still be going to the employee's former local coordinator. The lack of monitoring and follow up by the employee's current local coordinator increases the likelihood that the employee's delinquency will continue to the point where the card is canceled.

We found that the work station locations for 8 of the 54 INS employees in our sample were incorrect on Bank One's reports. Delinquencies for these eight employees totaled $28,166. According to the coordinators, five of these cardholders had transferred to other INS locations but were still appearing on the bank reports at their prior work stations. The remaining three cardholders, representing $6,660 in unpaid debt, had been assigned to a "default" hierarchy code. This default code represents any cardholders for which the bank's records are missing an actual hierarchy code. We found that the report for cardholders assigned to the default code was not reviewed timely by INS headquarters personnel. The INS headquarters coordinator responsible for determining the proper work stations of the cardholders and notifying the bank of the correct hierarchy code reviews the default report only periodically, every two to three months. Because hierarchy codes for these eight cardholders were no longer correct, their current coordinators, supervisors, and managers were unaware of the unresolved debt and, as a result, all eight travel cards had been canceled.

Even when coordinators notify the bank of work station changes in a timely manner, the manual notification process makes it inevitable that costly delays will occur. One Department component, the FBI, has addressed this problem by automating the process. Currently, the FBI sends Bank One a monthly update of name and address changes obtained from its personnel system, which Bank One uses to update its records.

Sending Bank One monthly updates of personnel changes has proven valuable to the FBI in notifying coordinators of delinquencies in a timely manner, and we believe that the INS should assess whether it is feasible to adopt such a practice. Updating name and address changes monthly would improve the accuracy of travel card reports, ensuring that local coordinators would receive timely information about cardholders' accounts, thus reducing delinquencies. Automatic updates also would save local coordinators the effort of monitoring or tracking down employees who no longer work in their divisions.

Controls over ATM Access

The ATM cash advance feature of the travel card program allows travelers to use their travel cards to obtain cash advances for official expenses that cannot be paid for using the card. ATM withdrawals are allowed only when authorized for official travel and are limited to the estimated amount of the traveler's meals and incidental expense allowance; miscellaneous transportation expenses, such as taxis; and other authorized miscellaneous expenses that cannot be charged. Employees are prohibited from withdrawing cash from an ATM without having an approved travel authorization and from withdrawing more than the authorized amount. Expenditures for ATM withdrawals are not included in the rebate program and, because Bank One charges $2.00 per ATM transaction, actually increase the Department's costs for the travel card program. The Department incurs additional costs when the ATM transactions include a bank surcharge for which the traveler also requests reimbursement.

Because allowable advance amounts vary from trip to trip, it is not feasible to place physical controls over ATM withdrawals to ensure that cardholders are withdrawing only correct amounts. It also is difficult to initiate controls to ensure that withdrawals are made only when a cardholder is in travel status. Therefore, ATM withdrawals are susceptible to abuse. And unauthorized ATM withdrawals often lead to delinquencies because employees do not receive reimbursement for those transactions and may not have personal funds available to pay these charges.

National and local coordinators told us that they regularly review monthly lists of charges to identify inappropriate ATM withdrawals. Because many travel card coordinators work in administrative or financial units, they can readily verify whether an employee has an approved travel authorization on file and thus determine whether the employee is authorized to make ATM withdrawals. For cardholders with a current valid travel authorization, the coordinators could verify that the amounts of ATM withdrawals were appropriate, but that would be very labor-intensive, particularly in units where the coordinators are responsible for large numbers of travelers. Consequently, the amounts of ATM withdrawals are rarely monitored.

ATM misuse appears to be a problem within the INS. At least seven cardholders in our sample collectively had made inappropriate ATM withdrawals in excess of $23,000. These include:

We also identified an additional eight cardholders listed on Bank One's 120-day delinquency report as of February 2001, who appeared to have $12,316 in unauthorized ATM withdrawals. In addition, nine of the coordinators we spoke to indicated that inappropriate ATM withdrawals were a serious problem at their locations. Two of the coordinators stated that they were particularly diligent in reviewing the bank reports around Christmas due to the propensity of employees for withdrawing funds to purchase Christmas presents.

One Department component took strong measures to address the problem of ATM abuse. Several years ago, the FBI analyzed its delinquent travel card accounts and found that the majority of the written-off amounts were for nonpayment of ATM withdrawals that should not have been made in the first place. When Bank One became the Department's travel card contractor, the FBI met with bank officials to have additional controls built into the FBI's program. To control delinquencies and misuse, the FBI eliminated ATM access from its program. The FBI's rationale was that credit cards are widely accepted and that any cash outlays needed would not cause a true hardship to the employee. Any hardship situations would be addressed on a case-by-case basis. According to the FBI national coordinator, the FBI has not experienced any problems since it eliminated ATM access and there has been a decrease in travel card delinquencies.

INS should conduct a similar evaluation to determine whether its travel card program could benefit from increased controls over, or elimination of, ATM access. In conducting the evaluation, the INS should consider whether the benefits (access to ATMs) outweigh the costs (delinquencies stemming from inappropriate ATM use, as well as ATM fees and surcharges associated with all ATM withdrawals, both authorized and unauthorized).

Controlling Access to the Travel Charge Card

Restricting distribution of travel charge cards is one way to reduce delinquencies and curtail misuse. The INS travel card program guidance does not specify criteria for issuance of travel cards, but instead leaves it up to the local managers to decide. As a result, employees who rarely or never travel may still be provided with a travel card. Three of the delinquencies in our sample pertained to employees who, according to their local coordinators, rarely traveled and who had used their cards for inappropriate purposes, accruing a total of $18,632 in unpaid debt. These included:

During our review, we identified employees who had a history of travel card misuse, yet were allowed to maintain custody of their travel cards. These employees continued to misuse their travel cards. For example, we found that at one location a supervisory criminal investigator, who had previously used the travel card inappropriately to fund a relative's wedding, had been identified by the coordinator as having subsequently misused the card. At another location, a border patrol agent who had previously been suspended for using the travel card for personal purchases was threatened with termination when the card was again misused one year later. In these instances, eliminating physical access to the travel card when not on travel status would have reduced future opportunities for misuse. This practice had been adopted for at least one of the cardholders in our sample. The cardholder's tendency to misuse the travel card was apparently noted by his supervisors; according to the coordinator, the employee's travel card was taken away from him when he was not traveling.

The INS should assess the travel requirements of their employees and set criteria for issuing the card or have administrative staff maintain custody of travel cards for employees who rarely travel. By restricting the availability of the travel card, the INS could reduce misuse and delinquencies.

Training Local Coordinators, Supervisors, Managers, and Cardholders

The INS relies on its local coordinators to identify and properly follow up on travel charge card delinquencies and misuse. Therefore, local coordinators should be adequately trained to follow proper procedures and to know how to identify red flags when they review monthly reports from Bank One. In addition, as noted earlier in the report, procedures for monitoring travel card delinquencies and misuse vary from location to location. Regular training would help standardize administration of the travel charge card program and improve the efforts of the local coordinators.

According to the INS national coordinator, local coordinators are invited to attend training sessions offered by Bank One in Elgin, Illinois. Not all coordinators attend this training, however. According to the national coordinator, some locations are unwilling or unable to fund the cost of the training, which means that their coordinators must rely solely upon on-the-job training. In addition, some coordinators who are responsible for large numbers of cardholders or whose area of responsibility covers distant locations may have secondary coordinators responsible for cardholders within a designated area. For example, in addition to a primary coordinator assigned responsibility for border patrol sector cardholders, there also may be secondary coordinators located in each border patrol station or sub-station. The INS should ensure that training is provided not only to the primary coordinators, but also to the secondary coordinators.

Of the 19 INS coordinators we contacted, six had not received any formal training. We found that five of these six coordinators were not properly monitoring travel card accounts. Two had been on the job for a month or less and did not appear to have a clear understanding of their roles and responsibilities. One coordinator, who had been performing the function for two years, felt that her sole responsibility was to interface with the bank on behalf of the cardholders and was surprised to hear that she should be monitoring delinquencies and misuse. Another coordinator, who also had performed the function for two years, reviewed only delinquencies and misuse when requested to do so by the bank. A fifth coordinator was monitoring solely for delinquencies and had only recently begun to review for misuse after being requested to do so by the office head. Formal training would improve the performance of these coordinators.

Supervisors and managers have an integral role in the process and, therefore, also should be informed about their responsibilities. Some of the supervisors we contacted were unaware of what their role was in the process and what actions they should be taking when notified of delinquencies or misuse of travel cards. We also found that managers had a variety of differing opinions on the importance of the travel card program and their roles in the process. It is especially important for supervisors and managers to be committed to the program, because they set the tone for the office.

Briefing cardholders about their responsibilities is also important. However, employees rarely receive any guidance unless they become delinquent or misuse their cards. Generally the extent of guidance is limited to providing the employee with the cardholder agreement and assuming that he or she will read it. According to coordinators and supervisors we contacted, some employees who were identified misusing their travel cards pleaded ignorance of the rules as an excuse. For example, one employee had been routinely using the travel card to pay for gas during the commute to work. This employee assumed that commuting was considered to be traveling and therefore the gas purchases were permissible travel card charges. Another coordinator stated that employees would, while on travel status, routinely use their travel cards at retail establishments. Their excuse was that they believed any charges while on travel status were allowable. A supervisor at a location that has many problems with delinquencies stated that these problems mainly occur because the travel card is the first credit card the employees have ever had and they are inexperienced in handling credit.

A greater effort to educate cardholders may be necessary to reduce misuse and delinquencies in the travel charge card program. One INS district office we contacted provides formal briefings, initially to new employees and then annually to all employees, regarding their responsibilities as cardholders. Employees must sign a form attesting to their attendance at the briefing. This practice serves to educate employees and eliminates the excuse of ignorance when the employee becomes delinquent or misuses the card and faces disciplinary procedures. The INS should consider initiating this practice throughout all its locations to ensure that its employees are aware of their travel card responsibilities.

  1. At the time of our review, the bank's practice was to wait until an account was more than 90-days past due before suspending it.

  2. At 2 of the 19 locations, the coordinators had been in their positions for less than a month and were unable to provide us with procedural information. Another location code ("INS Travel") represents a default category of accounts for which the bank has not been provided a valid work location code. The coordinator responsible for the "INS Travel" location code is responsible for identifying the cardholder's correct work location and notifying the bank.

  3. Class 3 allegations are those which have minimal impact on programs and operations and which are not likely to result in termination, demotion, or lengthy suspension, but which could result in some form of disciplinary action.

  4. For the remaining 16 employees, the coordinators or cardholders' supervisors could not provide us with the reasons for the delinquencies.

  5. EOUSA also authorizes cash advances to those employees whose travel charge cards have been suspended or canceled due to misuse or delinquency. Other components, including the FBI, BOP, DEA, USMS, and JMD, prohibit the use of advances under these circumstances.