Comment on FR Doc # 2012-25893

NARA does not support the proposed rule change to remove the conference lodging allowance from the FTR (FTR Case 2012-301). NARA is seriously concerned that removing the conference rate from the FTR will have the unintended effect of increasing agency travel expenditures. It is NARA's experience that lodging rates for conferences typically exceed the per diem rate for the TDY location and are, in some cases, more than double the per diem rate. NARA is concerned that, without the conference rate provision in the FTR, conference attendees will seek reimbursement for actual expenses and will be less likely to seek out lower-cost accommodations (when the conference hotel rates exceed per diem). NARA uses the FTR "conference rate" as a limitation or restriction, which provides the maximum rate at which NARA will reimburse attendees for conference lodging expenses. Without the conference rate, NARA will be forced to choose between reimbursing employees for their actual expenses or limiting reimbursements to standard per diem rates. NARA is aware that agencies may establish policies that are more restrictive than the FTR; however, it is NARA's experience that more restrictive policies are challenged more frequently and result in increased requests for waivers. This will increase the administrative burden of managing agency travel, in addition to increasing travel costs for trips that are, ultimately, approved for actual expenses. If the purpose of the subject FTR Case is to address differences in the approvals required for travel vouchers seeking reimbursement for actual expenses (which require prior approval) and travelers using the conference rate (which do not), NARA recommends that the FTR be amended to require advance approvals for use of the conference rate. This is the most direct means to address the stated problem and would allow NARA and other agencies to continue to use the conference rate as a tool to reduce travel expenditures.