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entitled 'Military Personnel: Actions Needed to Strengthen Management 
of Imminent Danger Pay and Combat Zone Tax Relief benefits' which was 
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Report to Congressional Committees: 

United States Government Accountability Office: 

GAO: 

September 2006: 

Military Personnel: 

Actions Needed to Strengthen Management of Imminent Danger Pay and 
Combat Zone Tax Relief Benefits: 

Military Personnel: 

GAO-06-1011: 

GAO Highlights: 

Highlights of GAO-06-1011, a report to congressional committees 

Why GAO Did This Study: 

Servicemembers who are assigned, deployed, or travel on temporary duty 
to certain foreign areas are eligible for special pays and benefits 
including (1) imminent danger pay (IDP) when the Department of Defense 
(DOD) determines that members are subject to the threat of physical 
harm or imminent danger and (2) combat zone tax relief (CZTR) benefits, 
which allow members to exclude earned income from federal taxes. If 
travel to IDP- or CZTR-designated areas begins during one month and 
concludes during another (known as cross-month travel), members could 
receive 2 full months of benefits. 

GAO conducted this review under the Comptroller General’s authority to 
initiate such reviews. GAO evaluated DOD’s (1) process for reviewing 
IDP areas and (2) internal controls over servicemembers’ temporary duty 
travel to areas designated for IDP and CZTR benefits. GAO is also 
providing information on the reporting of IDP and CZTR data. GAO 
analyzed legislation, guidance, travel vouchers, and internal control 
standards and interviewed appropriate officials. 

What GAO Found: 

DOD’s processes for reviewing existing IDP areas could be improved. 
While combatant commanders have taken the initiative periodically to 
make recommendations to designate or terminate IDP areas, DOD has not 
conducted annual reviews of existing IDP designations in accordance 
with its guidance to ensure that conditions in these areas continue to 
warrant such designation. Also, DOD has not updated its guidance to 
reflect current responsibilities for initiating annual reviews or to 
include factors used to determine when conditions in foreign areas pose 
the threat of physical harm or imminent danger to servicemembers on 
duty in these locations. DOD conducted 6 annual reviews between 1992 
and 2006. When conducting reviews, DOD has queried combatant commanders 
using a set of factors to determine the nature of threats to 
servicemembers. However, DOD has not incorporated these factors into 
its guidance. By conducting annual reviews in accordance with its 
guidance, DOD could strengthen its oversight of IDP designations to 
ensure that conditions in designated areas continue to pose the threat 
of physical harm or imminent danger to servicemembers and that these 
areas should continue to be designated. 

Internal controls over servicemembers’ temporary duty travel to areas 
designated for IDP or CZTR benefits need to be strengthened. While two 
DOD components have instituted policies to regulate and monitor cross-
month travel to these areas, there is no similar departmentwide policy 
to ensure that travel to areas designated for IDP or CZTR benefits 
needs to cross calendar months. Data limitations prevented GAO from 
determining the full extent of temporary duty travel to areas 
designated for IDP and CZTR benefits, as well as how much of this 
travel crosses calendar months. The U.S. Central Command and U.S. Army, 
Europe—which collectively account for 62 percent of IDP areas and 86 
percent of CZTR benefit areas—have developed policies and controls to 
monitor and regulate cross-month travel to areas designated for IDP and 
CZTR benefits to preclude, in their view, the appearance of abuse of 
these benefits. By establishing internal controls such as a 
departmentwide policy and periodic audits to monitor cross-month 
travel, DOD could ensure all areas are covered and further strengthen 
its management of IDP and CZTR benefits. 

DOD tracks IDP costs and servicemembers’ compensation that qualifies 
for CZTR benefits. While DOD reports the cost of IDP to Congress as 
part of its budget request, the department does not report 
servicemembers’ compensation that qualifies for CZTR benefits. Combat 
zone tax relief benefits could allow servicemembers to exclude a 
significant portion of their income from federal taxes. Reporting data 
on CZTR benefits to Congress could provide information on the extent of 
this benefit and aid Congress in its oversight role. 

What GAO Recommends: 

GAO recommends that DOD strengthen management of IDP and CZTR benefits, 
and added a matter for congressional consideration to improve reporting 
DOD generally agreed with two recommendations and disagreed with a 
third one to monitor cross-month travel. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-1011]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Sharon Pickup at (202) 
512-9619 or pickups@gao.gov. 

[End of Section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

DOD's Management of Its Imminent Danger Pay Program Could Benefit from 
Additional Oversight: 

DOD Does Not Have a Departmentwide Policy to Monitor Cross-Month Travel 
to Areas Designated for Imminent Danger Pay or Combat Zone Tax Relief 
Benefits: 

DOD Tracks Imminent Danger Pay and Combat Zone Tax Relief Benefits and 
Reports Some Data to Congress: 

Conclusions: 

Recommendations for Executive Action: 

Matter for Congressional Consideration: 

Agency Comments and Our Evaluation: 

Appendix I: Areas Currently Designated for Imminent Danger Pay and 
Combat Zone Tax Relief Benefits: 

Appendix II: Presidentially Designated Combat Zones and Congressionally 
Legislated Qualified Hazardous Duty Areas: 

Appendix III: Military Service Certified as in Direct Support of Combat 
Zone Operations: 

Appendix IV: Scope and Methodology: 

Appendix V: Comments from the Department of Defense: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Summary of Imminent Danger Pay and Combat Zone Tax Relief 
Benefits: 

Table 2: Number and Duration of Cross-Month Trips Eligible for 1 or 2 
Months of Imminent Danger Pay or Combat Zone Tax Relief Benefits, 
October 1, 2002, to September 30, 2005: 

Table 3: Duration of Cross-Month Trips Eligible for 1 or 2 Months of 
Imminent Danger Pay or Combat Zone Tax Relief Benefits by Combatant 
Command, October 1, 2002, to September 30, 2005: 

Table 4: Duration of Cross-Month Travel to Areas Not Designated for 
Imminent Danger Pay or Combat Zone Tax Relief Benefits, October 1, 
2002, to September 30, 2005: 

Table 5: Port Visits to Areas within the U.S. European Command That Are 
Designated for Imminent Danger Pay or Combat Zone Tax Relief Benefits: 

Table 6: Summary of Areas Designated for Imminent Danger Pay and Combat 
Zone Tax Relief Benefits: 

Table 7: Combat Zones as of July 2006: 

Table 8: Qualified Hazardous Duty Areas as of July 2006: 

Table 9: Areas Certified by DOD Where Military Service Is in Direct 
Support of Combat Zone Operations as of July 2006: 

Figure: 

Figure 1: Terrorist Threat Levels and Associated Number of Designated 
Imminent Danger Pay Areas as of July 2006: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

September 28, 2006: 

Congressional Committees: 

In recognition of the dangers military servicemembers face and the 
sacrifices they make on behalf of the United States, Congress has 
established several special pays and benefits. In particular, 
servicemembers who are assigned, deployed, or travel on temporary duty 
to certain foreign areas are eligible for certain special pays and 
benefits. These include (1) imminent danger pay for servicemembers on 
duty in foreign areas designated by the Secretary of Defense in which a 
servicemember is subject to the threat of physical harm or imminent 
danger on the basis of civil insurrection, civil war, terrorism, or 
wartime conditions[Footnote 1] and (2) combat zone tax relief benefits 
that permit servicemembers to exclude all or a portion of their 
compensation from federal taxes while serving in specific areas 
designated by the President through Executive Order, known as combat 
zones, or in areas designated by Congress, known as qualified hazardous 
duty areas (see app. I and II).[Footnote 2] 

Servicemembers may also qualify to receive combat zone tax relief 
benefits when they are performing military duty outside of a combat 
zone or in a congressionally established qualified hazardous duty area 
if (1) duty in this area is in direct support of military operations in 
a combat zone or qualified hazardous duty area and (2) the duty 
qualifies a servicemember for hostile fire or imminent danger pay based 
on the risks and dangers related to the combat zone.[Footnote 3] If a 
servicemember travels to an area designated for imminent danger pay or 
combat zone tax relief benefits, and the travel begins during one month 
and concludes during another month (known as cross-month travel), the 
servicemember receives 2 full months of the special pay and 
benefit.[Footnote 4] Combat zone tax relief benefits can provide 
significant financial benefits, especially if a servicemember qualifies 
for this benefit on more than one occasion during a calendar year. 

The Department of Defense (DOD) is responsible for designating imminent 
danger pay areas and certifying locations where military service is in 
direct support of combat zone operations. Over the past few decades, 
DOD has designated an increasing number of areas for imminent danger 
pay. Since imminent danger pay was first authorized on October 1, 1983, 
the number of areas designated for this pay has increased from a few to 
54 areas due primarily to the global security environment, according to 
DOD.[Footnote 5] DOD has stated that a goal is to limit imminent danger 
pay to only those servicemembers who face the threat of physical harm 
or imminent danger,[Footnote 6] and DOD's guidance requires at least 
annual reviews of designated areas to determine whether conditions 
warrant the continued designation. In addition, since September 2001, 
DOD has certified military service in several countries as directly 
supporting combat operations in Afghanistan and Iraq. Currently, these 
locations include Djibouti, Jordan, Pakistan, the Philippines, and 
Yemen, among others (see app. III). 

We have previously reported that clear policies, procedures, criteria, 
and management oversight are needed to help agencies use resources 
effectively and efficiently to meet organizational and program 
objectives.[Footnote 7] We also previously reported that the federal 
government's total costs to provide military compensation are 
substantial and rising and that the nation's growing fiscal concerns 
will require DOD and the federal government to consider difficult trade-
offs in the years ahead.[Footnote 8] According to DOD, since the 
beginning of the Global War on Terrorism, military basic pay has 
increased approximately 25 percent. DOD has reported paying more than 
$2 billion in hostile fire and imminent danger pay to servicemembers 
assigned, deployed, or traveling on temporary duty.[Footnote 9] 
Furthermore, the Defense Finance and Accounting Service calculated that 
between tax years 2003 and 2005, active duty servicemembers 
collectively qualified to exclude more than $26 billion of their 
compensation as a result of performing duty that qualified for combat 
zone tax relief benefits. This amount includes servicemembers who 
performed duty in areas that DOD has designated as in direct support of 
military operations in combat zones. 

Because of broad congressional interest in military pay and 
compensation, we prepared this report under the authority of the 
Comptroller General to conduct evaluations at his own 
initiative.[Footnote 10] Our objectives were to evaluate DOD's (1) 
process for reviewing imminent danger pay area designations and (2) 
internal controls over servicemembers' temporary duty travel to areas 
designated for imminent danger pay and combat zone tax relief benefits. 
We are also providing information on DOD's tracking and reporting of 
imminent danger pay and combat zone tax relief benefits to Congress. We 
are addressing this report to you because of your jurisdiction over the 
issues discussed in this report. 

To evaluate DOD's process for reviewing imminent danger pay area 
designations, to understand how servicemembers become eligible for 
combat zone tax relief benefits, and to understand how DOD reports data 
associated with this pay and benefit, we analyzed legislation, 
regulations, and DOD guidance. We compared this guidance to the 
objectives and fundamental concepts of internal control defined in 
Standards for Internal Control in the Federal Government.[Footnote 11] 
We also held discussions with knowledgeable officials from the Office 
of the Under Secretary of Defense (Personnel and Readiness), the Joint 
Chiefs of Staff, each of the services, and the geographic combatant 
commands.[Footnote 12] We also reviewed questionnaires completed by 
commanders at unified combatant commands with geographic responsibility 
and used by the Office of the Under Secretary of Defense (Personnel and 
Readiness) to evaluate area designations and the threat of imminent 
danger. To understand the extent to which DOD has internal controls in 
place to monitor servicemembers' temporary duty travel to foreign areas 
designated for imminent danger pay or combat zone tax relief benefits, 
we reviewed DOD's Foreign Clearance Guide that establishes DOD policy 
for military personnel traveling overseas as well as combatant 
commands' travel policies. We discussed these with officials 
responsible for approving travel in accordance with the Foreign 
Clearance Guide. We also obtained and analyzed 28,404 travel vouchers 
processed by individual servicemembers using the Defense Travel System, 
from October 1, 2002, through September 30, 2005. To assess the 
reliability of these data, we interviewed knowledgeable officials, 
reviewed relevant documentation, and conducted electronic testing. We 
found these data to be sufficiently reliable for the purposes of our 
work. However, data limitations prevented us from determining the full 
extent of temporary duty travel to areas designated for imminent danger 
pay or combat zone tax relief benefits, the total number of trips taken 
by individual servicemembers during fiscal years 2003 through 2005, or 
how much of this travel crossed calendar months. Furthermore, we were 
unable to extrapolate travel patterns from the Defense Travel System to 
DOD travel as a whole. Under DOD's Financial Management Regulations, 
authorizing officials are responsible for determining the necessity of 
trips and funds availability for temporary duty travel.[Footnote 13] 
Further, DOD guidance states that DOD airlift authorizing officials 
shall ensure that an official purpose is served by air travel.[Footnote 
14] Therefore, we did not evaluate whether the purpose of the trips 
were valid, but we did note that the U.S. Central Command and U.S. 
Army, Europe, have developed policies and controls to preclude, in 
their view, the appearance of abuse of imminent danger pay and combat 
zone tax relief benefits. We conducted our review from October 2005 
through July 2006 in accordance with generally accepted government 
auditing standards. See appendix IV for more information about our 
scope and methodology. 

Results in Brief: 

DOD's processes for reviewing existing imminent danger pay areas can be 
improved. While combatant commanders have taken the initiative 
periodically to make recommendations to designate or terminate imminent 
danger pay areas, DOD has not conducted annual reviews of existing 
imminent danger pay areas in accordance with its guidance to ensure 
that conditions in these areas continue to warrant such designation. 
Also, DOD has not updated its guidance to reflect current 
responsibilities for initiating and managing annual reviews or to 
include factors used to determine when conditions in foreign areas pose 
the threat of physical harm or imminent danger to servicemembers on 
duty in these locations. According to the Standards for Internal 
Control in the Federal Government,[Footnote 15] clear policies, 
procedures, and criteria are needed to help agencies use resources 
effectively and efficiently to meet organizational and program 
objectives. The Standards also emphasize the importance of management 
oversight and review to ensure that programs continue to meet their 
intended goals and comply with law and policies. DOD's imminent danger 
pay guidance requires the unified combatant commanders to continuously 
appraise conditions within designated areas to ensure that these areas 
continue to present the threat of physical harm or imminent danger from 
civil insurrection, civil war, terrorism, or wartime conditions, and to 
submit their recommendations to continue or terminate area 
designations, at least annually, to the Chairman, Joint Chiefs of 
Staff, for review. At any time, unified combatant commanders may 
recommend that additional areas be designated for imminent danger pay 
or that existing area designations be terminated. The Chairman, in 
turn, evaluates designation recommendations and, if the Chairman 
recommends them for approval, forwards the unified combatant 
commander's recommendations to the Under Secretary of Defense 
(Personnel and Readiness).[Footnote 16] In practice, however, officials 
in the Office of the Under Secretary of Defense (Personnel and 
Readiness) have assumed responsibility for initiating and directly 
managing these reviews. However, the combatant commanders have not 
forwarded their recommendations to the Chairman, Joint Chiefs of Staff, 
on existing designations at least annually, and the Under Secretary of 
Defense (Personnel and Readiness) has not requested the combatant 
commanders to do so. Rather, the Office of the Under Secretary of 
Defense (Personnel and Readiness) requested the combatant commanders to 
conduct these reviews six times between 1992 and 2006, and the 2006 
review is ongoing. In the absence of annual reviews, unified combatant 
commanders continued to recommend the designation of additional areas 
for imminent danger pay as well as the termination of some designated 
areas during that time period and the overall number of designated 
areas increased from 34 to 54. According to DOD, the overall number of 
designated areas increased during that time due to the changing global 
security environment and the increase in the number of areas where 
servicemembers face imminent danger, including areas supporting 
Operation Enduring Freedom and Operation Iraqi Freedom. When DOD has 
conducted reviews of areas designated for imminent danger pay, it has 
queried combatant commanders using a set of factors to determine the 
nature of threats to servicemembers arising from civil war, civil 
insurrection, terrorism, or wartime conditions within designated 
imminent danger pay areas. However, the department has not incorporated 
these factors into its imminent danger pay guidance. In addition, DOD 
has not updated its imminent danger pay guidance since 1992 to reflect 
that the Office of the Under Secretary of Defense (Personnel and 
Readiness) has assumed responsibility for initiating reviews of 
imminent danger pay area designations. By conducting annual reviews in 
accordance with its guidance, DOD could strengthen its oversight of 
imminent danger pay designations to ensure that conditions in 
designated areas continue to pose the threat of physical harm or 
imminent danger to servicemembers and that these areas should continue 
to be designated. Furthermore, updating DOD's guidance to include the 
current processes and factors used for reviewing and designating 
imminent danger pay areas would clarify responsibilities and establish 
standard criteria for use in meeting the program's objectives. 

Internal controls over servicemembers' temporary duty travel to areas 
designated for imminent danger pay or combat zone tax relief benefits 
need to be strengthened. While two DOD components have instituted 
policies to regulate and monitor cross-month travel to these areas, 
there is no similar departmentwide policy to ensure that travel to 
areas designated for imminent danger pay or combat zone tax relief 
benefits need to cross calendar months. Data limitations prevented us 
from determining the full extent of temporary duty travel to areas 
designated for imminent danger pay and combat zone tax relief benefits, 
as well as how much of this travel crossed calendar months. The U.S. 
Central Command and U.S. Army, Europe--which collectively account for 
62 percent of imminent danger pay areas and 86 percent of areas 
designated for combat zone tax relief designation--have developed 
policies and controls to monitor and regulate cross-month travel to 
areas designated for imminent danger pay and combat zone tax relief 
benefits to preclude, in their view, the appearance of abuse of these 
benefits. It is DOD's policy to minimize the number of visits and 
visitors to overseas areas as well as demands on equipment, facilities, 
time, installation services, and personnel visited. In addition, DOD's 
temporary duty travel policy and its Foreign Clearance Guide,[Footnote 
17] which implements this policy, provide mechanisms for the combatant 
commands to regulate travel to foreign locations. Before any DOD 
servicemember makes an official visit to a foreign country, including 
areas where servicemembers qualify for imminent danger pay or combat 
zone tax relief, the visit must be reviewed and approved by both the 
U.S. embassy in the host country (country clearance) as well as by the 
sponsoring unified commander (theater clearance). DOD's Foreign 
Clearance Guide permits a unified combatant command to grant theater 
clearance or to delegate this authority to component commands, 
subordinate commands, special agencies, or units to be visited. The 
Standards for Internal Control in the Federal Government[Footnote 18] 
recommend that agencies establish internal controls to monitor and 
review operations and programs to ensure that they meet their goals. 
Moreover, we consider establishing such controls, including policies 
and oversight mechanisms, a best practice that can help ensure 
appropriate application of benefits such as imminent danger pay and 
combat zone tax relief benefits. Two components, the Central Command 
and the U.S. Army, Europe, have developed their own policies and 
internal controls to regulate and monitor cross-month travel to 
preclude, in their view, the perceived abuse of imminent danger pay and 
combat zone tax relief benefits. To enforce its policy, the U.S Central 
Command has established an electronic database with internal controls 
that automatically alert officials to any proposed temporary duty 
travel that crosses calendar months. The U.S. Army, Europe, requires 
that all cross-month travel be approved by at least a colonel and its 
Internal Review and Audit Compliance Office periodically reviews travel 
to specific areas to monitor whether cross-month travel occurs. 
However, DOD's departmentwide policies do not establish internal 
controls to monitor or regulate cross-month travel, including to 
foreign areas designated for certain special pays and benefits, such as 
imminent danger pay and combat zone tax relief, and, with the exception 
of U.S. Army, Europe, DOD does not conduct periodic audits of cross- 
month travel to determine whether servicemembers are scheduling travel 
in a fiscally responsible manner or attempting to maximize this pay and 
benefit through cross-month travel. Our analysis of 28,404 vouchers for 
temporary duty travel that were processed using the Defense Travel 
System between October 1, 2002, and September 30, 2005, found that 
cross-month travel does occur in 3 percent of the vouchers, thereby 
qualifying the servicemember for 2 full months of imminent danger pay 
and combat zone tax relief. We also obtained data from the U.S. Naval 
Forces, Europe, for 56 ship port visits between fiscal years 2003 and 
2005 to areas designated for imminent danger pay or combat zone tax 
relief benefits within the European Command's area of responsibility. 
By establishing internal controls such as a departmentwide policy and 
periodic audits to monitor cross-month travel, DOD could ensure all 
areas are covered and further strengthen its management of imminent 
danger pay and combat zone tax relief benefits. 

DOD tracks the cost of imminent danger pay and servicemembers' 
compensation that qualifies for combat zone tax relief benefits. While 
DOD reports the cost of imminent danger pay to Congress as part of its 
budget request, the department does not report servicemembers' 
compensation that qualifies for combat zone tax relief benefits. Combat 
zone tax relief benefits could allow servicemembers to exclude a 
significant portion of their compensation from federal taxes. For 
example, enlisted personnel and warrant officers may exclude all 
military compensation earned during one month. In 2006, the maximum 
amount of compensation for commissioned officers that is eligible for 
combat tax zone relief is $6,724.50 per month. The reporting of combat 
zone tax relief benefit data to Congress could provide information on 
the extent of this benefit and aid Congress in its oversight role. 

We are making recommendations to strengthen DOD's internal controls and 
management of imminent danger pay and combat zone tax relief benefits, 
including monitoring travel to areas designated for these benefits, as 
well as to assist Congress in its oversight role. In commenting on a 
draft of this report, DOD generally agreed with two of our 
recommendations and disagreed with a third recommendation to monitor 
cross-month travel. DOD believes that it has sufficient travel 
procedures and reviews over cross-month travel. Our work indicates 
otherwise, and, thus, we continue to believe that our recommendation 
has merit. DOD's comments and our evaluation of them can be found at 
the end of this report. DOD's comments are reprinted in appendix V. In 
addition, because of the substantial tax benefits that servicemembers 
receive when performing duty in combat zones, we have added a matter 
for congressional consideration. Congress should consider requiring DOD 
to periodically report the amount of servicemembers' total compensation 
that qualifies for combat zone tax relief benefits. 

Background: 

Congress has given the president the authority to issue executive 
orders designating and terminating areas as combat zones. Since 1950, 
U.S. presidents have designated combat zones in Korea, Vietnam, the 
Persian Gulf area, the Kosovo area, and Afghanistan. U.S. presidents 
terminated combat zone designations for Korea in 1955 and Vietnam in 
1996[Footnote 19]. See appendix II for information on the current 
combat zones. In addition, Congress has established qualified hazardous 
duty areas where servicemembers serving in such areas receive the same 
tax treatment as members serving in presidentially designated combat 
zones.[Footnote 20] Congress has specified in this legislation, 
however, that a servicemember on duty in a qualified hazardous duty 
area is only entitled to combat zone tax relief benefits if that member 
would also be entitled to hostile fire or imminent danger pay. Congress 
has designated seven qualified hazardous duty areas since 1995 (see 
app. II). 

DOD is responsible for prescribing regulations for imminent danger pay 
and for certifying locations where military service is in direct 
support of combat zone operations. Servicemembers who perform duty in 
certain foreign areas may be eligible for imminent danger pay as well 
as income tax relief, in the form of combat zone tax relief benefits, 
as summarized in table 1.[Footnote 21] See appendixes I, II, and III 
for information about the locations designated for imminent danger pay 
or combat zone tax relief benefits. 

Table 1: Summary of Imminent Danger Pay and Combat Zone Tax Relief 
Benefits: 

Benefit: Imminent danger pay; 
Description: Compensates a servicemember on duty in foreign areas 
designated by the Secretary of Defense where the servicemember is 
subject to the threat of physical harm or imminent danger on the basis 
of (1) civil insurrection, (2) civil war, (3) terrorism, or (4) wartime 
conditions. Within a designated area, DOD may limit imminent danger pay 
to servicemembers who perform duty in an area's airspace, land, or 
waters, or designate the entire area depending on the threat; The 
Secretary of Defense has delegated responsibility for designating areas 
to the Under Secretary of Defense (Personnel and Readiness); 
Dollar Amount: $225/ month; Members receive the entire $225 if they 
serve at least part of 1 day in a designated zone during the month; 
Authority: 37 U.S.C. §310(a)(2)(D); DOD Instruction 1340.9. 

Benefit: Combat zone tax relief; 
Description: Servicemembers may qualify for combat zone tax relief when 
serving in (1) presidentially designated combat zones, (2) 
congressionally legislated qualified hazardous duty areas, or (3) areas 
where the Secretary of Defense has certified military service as 
directly supporting military operations in combat zones or qualified 
hazardous duty areas; 
Dollar Amount: Enlisted personnel and warrant officers may exclude all 
military compensation earned during that month. For commissioned 
officers, compensation is free of federal income tax up to the maximum 
amount of enlisted pay plus any imminent danger or hostile fire pay 
received; 
Authority: 26 U.S.C. §112. 

Benefit: Combat zones; 
Description: A combat zone is any area that the president designates by 
executive order as an area in which U.S. Armed Forces are or have 
engaged in combat after June 24, 1950. An area ceases to be a combat 
zone on the dates the president designates by executive order; 
Dollar Amount: Enlisted personnel and warrant officers may exclude all 
military compensation earned during that month. For commissioned 
officers, compensation is free of federal income tax up to the maximum 
amount of enlisted pay plus any imminent danger or hostile fire pay 
received; 
Authority: Pub. L. No. 104-117 (1996); Pub. L. No. 106-21 (1999). 

Benefit: Qualified hazardous duty areas; 
Description: Congress designates qualified hazardous duty areas by 
legislation. Servicemembers on duty in these areas are entitled to the 
same benefits afforded service in a presidentially designated combat 
zone if the Secretary of Defense also designates the qualified 
hazardous duty area for hostile fire or imminent danger pay.[A];  
Dollar Amount: In 2006, the maximum amount of compensation for 
commissioned officers that is eligible for combat tax zone relief is 
$6,499.50 plus $225 imminent danger pay, or $6,724.50 per month; 
Authority: [Empty]. 

Benefit: In direct support of combat zone operations; 
Description: The Secretary of Defense has delegated responsibility for 
certifying that areas meet eligibility criteria to the Under Secretary 
of Defense (Personnel and Readiness). Certification requires that; 
* service is in direct support of military operations in combat zones,; 
* service qualifies the servicemember for hostile fire payor imminent 
danger pay, and; 
* hostile fire pay or imminent danger pay is related to activities and 
circumstances in the combat zone or qualified hazardous duty area; 
Dollar Amount: [Empty]; 
Authority: 26 C.F.R. §1.112-1; IRS Revenue Ruling 70-671 (1970); DOD 
FMR 44103(c). 

Source: GAO presentation of DOD Financial Management Regulation and 37 
U.S.C. §310, 26 U.S.C. §112, 26 C.F.R. §112-1, Internal Revenue Service 
Revenue Ruling 70-671 (1970), Pub. L. No. 104-117 (1996), Pub. L. No. 
106-21 (1999) and DOD Financial Management Regulation 44103(c). 

[A] Servicemembers who have been (1) subject to hostile fire or 
explosion of a hostile mine; (2) on duty in an area in close proximity 
to a hostile fire incident and the servicemembers are in danger of 
being exposed to the same dangers; or (3) injured, wounded, or killed 
by hostile fire, mines, or any kind of hostile action, receive hostile 
fire pay as opposed to imminent danger pay, at a rate of $225 per 
month. Servicemembers receive the entire $225 if they serve at least 
part of 1 day on a designated zone during the month. 37 U.S.C. §310. 

[End of table] 

The Under Secretary of Defense (Comptroller) in coordination with the 
director of the Defense Finance and Accounting Service is responsible 
for maintaining and updating the Financial Management Regulation, 
Volume 7A, that provides financial management policy and procedures for 
DOD, including imminent danger pay and combat zone tax relief benefits. 
In DOD's imminent danger pay guidance, the Under Secretary of Defense 
(Personnel and Readiness) requires unified combatant commanders to 
continually appraise the conditions within areas designated for 
imminent danger pay to ensure that the designation is warranted, and to 
forward written recommendations, at least annually, to the Chairman, 
Joint Chiefs of Staff, who evaluates these designations to determine 
whether conditions in these areas continue to present the threat of 
physical harm or imminent danger from civil war, civil insurrection, 
terrorism, or wartime conditions. The Chairman forwards area 
designations that he recommends for approval to the Under Secretary of 
Defense (Personnel and Readiness) with support for these 
recommendations. 

The Secretary of Defense has delegated the responsibility for 
designating imminent danger pay areas and certifying military service 
as in direct support of combat zone operations to the Under Secretary 
of Defense (Personnel and Readiness) who is responsible for DOD 
personnel policy, including oversight of military compensation, and as 
such, serves as the focal point for imminent danger pay. DOD's imminent 
danger pay guidance requires the unified combatant commanders to 
continuously appraise conditions within designated areas to ensure that 
these areas continue to present the threat of physical harm or imminent 
danger from civil insurrection, civil war, terrorism, or wartime 
conditions, and to submit their recommendations to continue or 
terminate area designations, at least annually, to the Chairman, Joint 
Chiefs of Staff, for review. At any time, unified combatant commanders 
may recommend that additional areas be designated for imminent danger 
pay or that existing area designations be terminated. The Chairman, in 
turn, evaluates designation recommendations and, if the Chairman 
recommends them for approval, forwards the unified combatant 
commander's recommendations to the Under Secretary of Defense 
(Personnel and Readiness). In practice, however, officials in the 
Office of the Under Secretary of Defense (Personnel and Readiness) have 
assumed responsibility for initiating and directly managing these 
reviews. 

DOD's Management of Its Imminent Danger Pay Program Could Benefit from 
Additional Oversight: 

DOD's processes for reviewing existing imminent danger pay areas and 
combat zones can be improved. While combatant commanders have taken the 
initiative periodically to make recommendations to designate or 
terminate imminent danger pay areas, DOD has not conducted annual 
reviews of existing imminent danger pay areas in accordance with its 
guidance to ensure that conditions in these areas continue to warrant 
such designations. Also, DOD has not updated its guidance to reflect 
that the Office of the Under Secretary of Defense (Personnel and 
Readiness) has assumed responsibility for initiating and managing 
annual reviews. In addition, DOD also has not incorporated factors 
contained in questionnaires completed by combatant commanders that the 
Office of the Under Secretary of Defense (Personnel and Readiness) uses 
to evaluate when conditions in foreign areas pose the threat of 
physical harm or imminent danger to servicemembers performing duty in 
designated locations. By conducting annual reviews of existing 
designations in accordance with its guidance, DOD could strengthen its 
oversight of imminent danger pay designations to ensure that conditions 
in designated areas continue to pose the threat of physical harm or 
imminent danger to servicemembers and that these areas should continue 
to be designated. Furthermore, updating DOD's guidance to include the 
current processes and factors used for reviewing and designating 
imminent danger pay areas would clarify responsibilities and establish 
standard criteria for use in meeting the program's objectives. 

DOD Has Not Conducted Annual Reviews of Imminent Danger Pay 
Designations in Accordance with Its Guidance: 

Imminent danger pay was first authorized in October 1983.[Footnote 22] 
Between 1992--when DOD revised its guidance to require annual reviews, 
as opposed to semiannual reviews, of imminent danger pay area 
designations--and 2006, the number of designated areas increased from 
34 to 54 areas. (See appendix I for a list of areas currently 
designated for imminent danger pay). 

While DOD guidance requires the combatant commanders to continuously 
appraise conditions in designated areas and to forward recommendations 
to the Chairman, Joint Chiefs of Staff, to continue or terminate these 
designations at least annually, in practice, the Office of the Under 
Secretary of Defense has assumed responsibility for initiating and 
managing these reviews. The combatant commanders have not forwarded 
their recommendations on existing designations to the Chairman, Joint 
Chiefs of Staff, at least annually, nor has the Under Secretary of 
Defense (Personnel and Readiness) requested the combatant commanders to 
do so. Between 1992 and 2006, the Under Secretary of Defense (Personnel 
and Readiness) requested the unified combatant commanders to conduct 
six reviews of designated imminent danger pay areas. Reviews were 
conducted in 1992, 1993, 1995, 1997, and 2002; the 2006 review is 
ongoing, and officials in the Office of the Under Secretary of Defense 
(Personnel and Readiness) expect to complete it by October. In the 
absence of annual reviews, the combatant commanders have taken the 
initiative to periodically recommend the designation or termination of 
imminent danger pay areas. 

According to DOD officials, the Under Secretary of Defense (Personnel 
and Readiness) deferred several reviews because of anticipated policy 
revisions and concerns about creating additional work for combatant 
commanders while they are engaged in ongoing operations. For instance, 
DOD deferred the 1998 review pending the anticipated revision of its 
imminent danger pay guidance to incorporate criteria for determining 
whether conditions in designated areas continue to pose the threat of 
physical harm or imminent danger from civil war, civil insurrection, 
terrorism, or wartime conditions to servicemembers. However, this 
revision did not occur. The department initiated the ongoing 2006 
review shortly after we began our review. According to officials from 
the Office of the Under Secretary of Defense (Personnel and Readiness), 
the department deferred reviews between 2002 and 2006 because it did 
not want to create additional work for combatant commanders during 
ongoing operations, and department officials also believe that 
conditions in most designated areas had not changed sufficiently since 
the terrorist attacks of September 11, 2001, and the start of the 
Global War on Terrorism to result in termination of designated areas. 
Although DOD guidance calls for the combatant commanders to forward 
recommendations to continue or to terminate imminent danger pay areas 
at least annually, this has occurred at longer intervals ranging from 2 
to 5 years. 

As a result of combatant commander's recommendations as well as annual 
reviews of imminent danger pay areas conducted by the combatant 
commanders at the request of the Under Secretary of Defense (Personnel 
and Readiness), the department has terminated area designations where 
conditions no longer pose the threat of physical harm or imminent 
danger from civil war, civil insurrection, terrorism, or wartime 
conditions. For instance, as a result of the 1993 review, DOD 
terminated imminent danger pay designation for areas including Oman, 
the United Arab Emirates, Bahrain, Qatar, and the Gulfs of Oman and 
Aden as well as the Arabian Sea because the department determined that 
conditions no longer posed the threat of physical harm or imminent 
danger toward servicemembers. The department has also denied requests 
from unified combatant commanders to designate new areas for imminent 
danger pay when there is not sufficient information to demonstrate that 
conditions pose a threat of physical harm or imminent danger to 
servicemembers on duty in the location, based on criteria used in a 
questionnaire and accompanying threat assessments. 

By conducting annual reviews of existing designations in accordance 
with its guidance, DOD could strengthen its oversight of imminent 
danger pay designations to ensure that conditions in designated areas 
continue to pose the threat of physical harm or imminent danger to 
servicemembers and that these areas should continue to be designated. 

DOD Has Not Updated Guidance to Reflect Current Responsibilities or 
Incorporated Factors to Define Criteria: 

DOD has not updated its imminent danger pay guidance to (1) reflect the 
responsibility of the Office of the Under Secretary of Defense 
(Personnel and Readiness) for initiating and managing annual reviews of 
imminent danger pay areas or (2) to incorporate factors that DOD uses 
to evaluate and define when servicemembers face imminent danger. 
Updating guidance to include the current processes and factors used for 
reviewing and designating imminent danger pay areas would clarify 
responsibilities and establish standard criteria for use in meeting the 
objectives of the imminent danger pay program. 

First, while DOD's imminent danger pay area guidance requires the 
unified combatant commanders and Joint Chiefs of Staff to conduct 
reviews of areas designated for imminent danger pay at least annually, 
in practice, the Under Secretary of Defense (Personnel and Readiness) 
has directly managed these reviews since the mid-1990s. However, as 
previously discussed, the combatant commanders have not forwarded 
recommendations on existing designations to the Chairman, Joint Chiefs 
of Staff, on an annual basis in accordance with DOD's guidance and the 
Under Secretary of Defense (Personnel and Readiness) has not requested 
them to do so on an annual basis. In addition, DOD has not updated its 
imminent danger pay guidance to show that the Under Secretary of 
Defense (Personnel and Readiness) has been assigned the functions, 
relationships, and authorities previously assigned to the position of 
the Assistant Secretary of Defense (Force Management and Personnel). 

Second, the Federal Managers' Financial Integrity Act of 1982 states 
that agencies must establish internal administrative controls in 
accordance with the standards prescribed by the Comptroller 
General.[Footnote 23] The Comptroller General published these standards 
in Standards for Internal Control in the Federal Government, which sets 
out management control standards for all aspects of an agency's 
operations. These standards are intended to provide reasonable 
assurance of meeting agency objectives. Two of the standards of 
internal control--risk assessment and control activities--state that an 
agency should establish clear objectives as well as appropriate 
policies, procedures, and plans with respect to its activities to 
ensure effective and efficient use of resources to meet organizational 
objectives.[Footnote 24] 

Neither the statute that authorizes imminent danger pay nor DOD 
guidance define what constitutes the threat of physical harm or 
imminent danger or contain criteria to determine this. However, in 
1997, DOD developed a questionnaire that contains specific factors that 
it continues to use to evaluate requests from combatant commands to 
designate new imminent danger pay areas as well as to review existing 
imminent danger pay designations. These factors help DOD to gather 
consistent information that supports its goal to limit imminent danger 
pay to those members placed in direct or imminent danger. The factors 
consider: 

* acts of violence against U.S. personnel, such as assassinations, 
homicides, sabotage, kidnapping, aggravated battery, property damage, 
terrorizing, extortion, rioting, and commandeering vessels or hijacking 
aircraft; 

* insurrection, war, or wartime conditions, including fighting that 
occurs sufficiently close to servicemembers that creates a substantial 
probability of death or bodily injury to servicemembers, causes 
servicemembers to fear for their safety, or creates danger to human 
life or property; 

* terrorism conditions, including the existence of terrorist 
organizations that have the intent or ability to harm servicemembers or 
terrorist threat levels indicative of an imminent threat; 

* security environment, that places U.S. forces at risk. DOD also 
considers existing security measures including threat condition levels 
and operating tempo levels, as well as restrictions on leave and off- 
duty travel and measures taken by the host government to protect 
servicemembers; 

* travel restrictions, including restriction of servicemembers to duty 
stations, installations, or defined sections of the area; and: 

* presence of dependents in the area, including school-age dependents, 
whether dependents are targets, and the security measures in place to 
protect them. 

We reviewed 54 completed questionnaires for imminent danger pay--some 
for the same countries over a period of time--that were submitted by 
combatant commands to the Office of the Under Secretary of Defense 
(Personnel and Readiness) between 1998 and 2005. We found that DOD is 
using information supplied on these questionnaires, in conjunction with 
threat assessments, to inform decisions to designate new imminent 
danger pay areas and to review existing designations to ensure that 
they continue to be appropriately designated. For instance, DOD denied 
requests from the U.S. Central Command to designate Turkmenistan and 
Kazakhstan for imminent danger pay in 2001 because the support provided 
in the questionnaires did not demonstrate an imminent threat of 
physical harm or danger to servicemembers based on civil war, civil 
insurrection, terrorism, or wartime conditions in those areas. DOD also 
denied a request from the U.S. European Command in 2003 to designate a 
number of areas, including Bulgaria, Romania, Hungary, and Cyprus, for 
imminent danger pay based on the probability of increased danger to 
military personnel due to their involvement in combat operations 
related to Iraq as well as general terrorist threats to DOD personnel. 
The Office of the Under Secretary of Defense (Personnel and Readiness) 
determined that there was not sufficient support of an imminent threat 
of personal harm to servicemembers on official duty in these areas. In 
contrast, DOD has designated areas, such as Ethiopia, for imminent 
danger pay based on facts and circumstances that indicate the 
likelihood that U.S. personnel might be harmed as a result of civil 
unrest. Beginning in 2006, Congress authorized the Secretary of Defense 
to retroactively designate an area for imminent danger pay, subject to 
the availability of appropriated funds.[Footnote 25] 

Despite the demonstrated usefulness of these questionnaires to decision 
makers, DOD has not incorporated factors contained in the questionnaire 
into its imminent danger pay guidance. For example, DOD does not 
include minimum terrorist threat levels, one such potential factor 
identified in the questionnaire, in its imminent danger pay guidance. 
While terrorist threat levels for a country may change over time and 
are raised and lowered on the basis of new information and analysis, in 
the past DOD officials responsible for overseeing imminent danger pay 
have considered establishing minimum terrorist threat levels of "high" 
or "significant" to help assess the imminence of threats and dangers 
from terrorism. Although DOD has yet to do so, we believe that 
establishing a minimum terrorist threat level threshold needed for an 
area to be designated for imminent danger pay could help to limit 
imminent danger pay to those servicemembers who truly face an imminent 
threat or danger to their lives and would likely reduce the number of 
imminent danger pay area designations. Currently, DOD identifies 
terrorist threat levels using the Defense Intelligence Agency's four 
step scale (see fig. 1) that describes the severity of a 
threat.[Footnote 26] 

Figure 1: Terrorist Threat Levels and Associated Number of Designated 
Imminent Danger Pay Areas as of July 2006: 

[See PDF for image] 

Source: Defense Intelligence Agency, Air Force Protection Guide, 
Department of the Army, Physical Security Field Manual, and GAO 
analysis. 

[End of figure] 

For example, using Defense Intelligence Agency terrorism threat levels, 
if current threat levels for designated areas remain constant and DOD 
was to establish a minimum terrorist threat level of "significant" for 
areas to be designated for imminent danger pay, then designations for 
19 currently designated areas with threat levels below "significant" 
would be terminated. These areas include Angola, Burundi, Croatia, and 
Haiti. However, 29 areas with "high" or "significant" terrorist threat 
levels, such as Indonesia, the Philippines, Columbia, Iraq, Kuwait, 
Malaysia, Qatar, and Syria, would continue to qualify for imminent 
danger pay. Due to changing world circumstances since July 2006, the 
terrorist threat levels may have changed. 

DOD Does Not Have a Departmentwide Policy to Monitor Cross-Month Travel 
to Areas Designated for Imminent Danger Pay or Combat Zone Tax Relief 
Benefits: 

Internal controls over servicemembers' temporary duty travel to areas 
designated for imminent danger pay or combat zone tax relief benefits 
need to be strengthened. While two DOD components have instituted 
policies to regulate and monitor cross-month travel to these areas, 
there is no similar departmentwide policy to ensure that travel to 
areas designated for imminent danger pay or combat zone tax relief 
benefits needs to cross calendar months. Data limitations prevented us 
from determining the full extent of temporary duty travel to areas 
designated for imminent danger pay and combat zone tax relief benefits, 
as well as how much of this travel crossed calendar months. However, 
the U.S. Central Command and U.S. Army, Europe--which collectively 
account for 62 percent of imminent danger pay areas and 86 percent of 
areas designated for combat zone tax relief benefits--have developed 
policies and controls to monitor and regulate cross-month travel to 
areas designated for imminent danger pay and combat zone tax relief 
benefits to preclude, in their view, the appearance of abuse of these 
benefits. Our review of data from DOD's Defense Travel System as well 
as data for ship port visits to the U.S. European Command's area of 
responsibility show that cross-month travel does occur. By establishing 
internal controls such as a departmentwide policy and periodic audits 
to monitor cross-month travel, DOD could ensure that all areas are 
covered and further strengthen its management of imminent danger pay 
and combat zone tax relief benefits. 

No Departmentwide Monitoring of Cross-Month Travel Occurs, but Two 
Commands Have Taken Steps to Regulate Cross-Month Travel: 

Internal controls over servicemembers' temporary duty travel to areas 
designated for imminent danger pay or combat zone tax relief benefits 
need to be strengthened. It is DOD's policy to minimize the number of 
visits and visitors to overseas areas as well as demands on equipment, 
facilities, time, installation services, and personnel.[Footnote 27] In 
addition, DOD's temporary duty travel policy and its Foreign Clearance 
Guide,[Footnote 28] which implements this policy, provide mechanisms 
for the unified combatant commands to regulate travel to foreign 
locations. Before any servicemember makes an official visit to a 
foreign country, including areas where servicemembers qualify for 
imminent danger pay or combat zone tax relief benefits, the visit must 
be reviewed and approved by both the U.S. embassy in the host country 
(country clearance) as well as by the sponsoring unified commander 
(theater clearance). DOD's Foreign Clearance Guide permits the unified 
combatant command to grant theater clearance or to delegate this 
authority to component commands, subordinate commands, special 
agencies, or units to be visited. The Standards for Internal Control in 
the Federal Government[Footnote 29] recommend that agencies establish 
internal controls to monitor and review operations and programs to 
provide reasonable assurance that these meet their goals. Moreover, we 
consider establishing such controls, including policies and oversight 
mechanisms, a best practice that can ensure that cross-month travel 
needs to cross calendar months, especially to areas designated for 
imminent danger pay or combat zone tax relief benefits. With the 
exception of U.S. Army, Europe, DOD does not conduct periodic audits of 
cross-month travel. 

Although there is no requirement to do so, the U.S. Central Command and 
U.S. Army, Europe--which collectively account for 62 percent of 
imminent danger pay areas and 86 percent of areas designated for combat 
zone tax relief designation--have developed policies and internal 
controls to monitor and regulate cross-month travel to areas for which 
they provide theater clearance. According to U.S. Central Command 
officials, they instituted this policy to preclude, in their view, the 
appearance of abuse of imminent danger pay and combat zone tax relief 
benefits. Specifically, the U.S. Central Command--which consists of 29 
(approximately 55 percent) of the areas currently designated for 
imminent danger pay and 20 (approximately 71 percent) of the areas 
currently designated for combat zone tax relief benefits--precludes 
travel that crosses months to its area of responsibility. According to 
U.S. Central Command officials, the command instituted this policy in 
2003 as a result of the high pace of operations and to preclude, in 
their view, the abuse of imminent danger pay and combat zone tax relief 
benefits. All five sea areas and all but 3 of the 27 countries in the 
U.S. Central Command's area of responsibility are designated for 
imminent danger pay, and 16 of these countries as well as all sea areas 
are designated for combat zone tax relief benefits (see app. I). 

To enforce its policy, the U.S. Central Command has established an 
electronic database with internal controls that automatically alert 
officials to any proposed temporary duty travel that crosses calendar 
months. Officials in the U.S. Central Command's Travel Clearance 
Office, which is responsible for granting theater clearance, review all 
requests from servicemembers not assigned to the U.S. Central Command 
to travel to countries in the command's area of responsibility. If the 
proposed travel dates cross calendar months, the Travel Clearance 
Office requests that the traveler changes the dates of the trip or 
provide justification for why the trip needs to occur at that time. 
According to a command official, appropriate justification may include 
mission requirements or the limited availability of flights. However, 
according to an official, most travelers choose to change the dates of 
travel to avoid crossing months. 

In 2005, U.S. Army, Europe, which was delegated authority by the U.S. 
European Command to approve travel to locations in the former Federal 
Republic of Yugoslavia, instituted a policy precluding cross-month 
travel--although this was minimal--to Bosnia-Herzegovina; Croatia; 
Serbia and Montenegro, including Kosovo; Macedonia; and Slovenia in 
order to prevent, in their view, the perceived abuse of combat zone tax 
relief benefits. These areas, excluding Slovenia, are designated for 
imminent danger pay and combat zone tax relief benefits and constitute 
approximately 8 percent of the areas currently designated for imminent 
danger pay and approximately 14 percent of the areas currently 
designated for combat zone tax relief benefits. In addition, U.S. Army, 
Europe, requires that a colonel or general officer approve all cross- 
month travel, and its Internal Review and Audit Compliance Office 
periodically reviews travel to specific areas to monitor whether cross- 
month travel occurs. According to an official in the U.S. Army, Europe, 
Internal Review and Audit Compliance Office, cross-month travel 
accounted for 1.6 percent of all travel to countries for which U.S. 
Army, Europe, approves theater clearance requests. Although no similar 
policy precludes cross-month travel to Georgia, a country for which the 
U.S. Marine Corps Forces, Europe, has been delegated authority by the 
U.S. European Command to approve travel, an official who is responsible 
for approving travel to this location told us that since January 2005 
the U.S. Marine Corps Forces, Europe, has monitored travel requests for 
potential cross-month travel. Neither U.S. Naval Forces, Europe, nor 
U.S. Air Forces in Europe has policies to monitor temporary duty travel 
that crosses calendar months. We did not determine the amount of cross- 
month travel conducted by servicemembers under these commands. 

In contrast, neither U.S. European Command (excluding U.S. Army, 
Europe), U.S. Pacific Command, or U.S. Southern Command--which 
collectively account for 20 (about 38 percent) imminent danger pay 
areas and 4 (about 14 percent) combat zone tax relief benefits--have 
policies that address temporary duty travel that crosses calendar 
months. 

Although two commands have instituted policies and internal controls to 
preclude the perceived abuse of imminent danger pay and combat zone tax 
relief by regulating and monitoring cross-month travel, no requirement 
exists for DOD to monitor cross-month travel to 38 percent of areas 
currently designated for imminent danger pay and 14 percent of areas 
currently designated for combat zone tax relief benefits. By 
establishing internal controls, such as a departmentwide policy and 
periodic audits to monitor cross-month travel, DOD could ensure that 
all areas are covered and further strengthen its management of imminent 
danger pay or combat zone tax relief benefits. 

Analysis of Defense Travel System Vouchers Indicates That Cross-Month 
Travel Occurs: 

Our analysis of data from the Defense Travel System indicates that 
cross-month travel does occur during temporary duty travel. We reviewed 
28,404 vouchers for temporary duty travel that were processed using the 
Defense Travel System for travel that occurred between fiscal years 
2003 and 2005. During about 18 percent (5,152) of these trips, a 
servicemember traveled to an area that is designated for imminent 
danger pay or combat zone tax relief benefits at some point during the 
trip regardless of whether the trip crossed months. About 93 percent 
(1,469) of the 1,576 trips that crossed calendar months were to 
countries within the Central Command's and European Command's areas of 
responsibility. 

We found that 1,576 (about 6 percent) of the 28,404 trips processed 
using the Defense Travel System from fiscal year 2003 through fiscal 
year 2005 involved cross-month travel to an area designated for 
imminent danger pay or combat zone tax relief benefits, including trips 
during which servicemembers were eligible for imminent danger pay or 
combat zone tax relief benefits during 1 or 2 months. For instance, 
servicemembers traveling in areas designated for imminent danger pay or 
combat zone tax relief benefits qualified for 2 full months of imminent 
danger pay and combat zone tax relief benefits for 745 (about 3 
percent) of the 28,404 trips. Also, during 831 (about 3 percent) of the 
28,404 trips, individual servicemembers traveled to areas designated 
for imminent danger pay or combat zone tax relief benefits at some 
point during a single month, although their travel crossed calendar 
months. As a result, these servicemembers qualified for 1 month of 
imminent danger pay or combat zone tax relief benefits. As depicted in 
table 2, we also found that the 1,576 cross-month trips ranged in 
duration from 2 days to more than 15 days. 

Table 2: Number and Duration of Cross-Month Trips Eligible for 1 or 2 
Months of Imminent Danger Pay or Combat Zone Tax Relief Benefits, 
October 1, 2002, to September 30, 2005: 

Fiscal year: 2003; 
2 days or less: 0; 
3 to 4 days: 0; 
5 to 6 days: 1; 
7 to 14 days: 0; 
15 or more days: 2; 
Total number of trips: 3. 

Fiscal year: 2004; 
2 days or less: 0; 
3 to 4 days: 2; 
5 to 6 days: 7; 
7 to 14 days: 82; 
15 or more days: 45; 
Total number of trips: 136. 

Fiscal year: 2005; 
2 days or less: 6; 
3 to 4 days: 115; 
5 to 6 days: 154; 
7 to 14 days: 674; 
15 or more days: 488; 
Total number of trips: 1,437. 

Fiscal year: Total number of trips; 
2 days or less: 6; 
3 to 4 days: 117; 
5 to 6 days: 162; 
7 to 14 days: 756; 
15 or more days: 535; 
Total number of trips: 1,576. 

Source: GAO analysis of Defense Travel System data. 

Note: The majority of our data reflect travel that occurred during 
fiscal year 2005. Defense Travel System data for fiscal years 2003 and 
2004 were minimal because DOD locations were just beginning to 
transition from using approximately 43 legacy systems for processing 
travel vouchers during this time frame. 

[End of Table] 

The six trips that involved cross-month travel lasting 2 days or less 
were to Afghanistan, Haiti, Iraq, and the Philippines for training, 
meetings, special missions, and site visits. 

Most of these 1,576 cross-month trips were to the U.S. Central 
Command's area of responsibility and the majority was longer than 7 
days in duration, as shown in table 3. 

Table 3: Duration of Cross-Month Trips Eligible for 1 or 2 Months of 
Imminent Danger Pay or Combat Zone Tax Relief Benefits by Combatant 
Command, October 1, 2002, to September 30, 2005: 

Trip duration: 2 days or less; 
Combatant Command: Central Command: 3; 
Combatant Command: European Command: 0; 
Combatant Command: Pacific Command: 1; 
Combatant Command: Southern Command: 2; 
Combatant Command: Total trips: 6. 

Trip duration: 3 to 4 days; 
Combatant Command: Central Command: 100; 
Combatant Command: European Command: 9; 
Combatant Command: Pacific Command: 3; 
Combatant Command: Southern Command: 5; 
Combatant Command: Total trips: 117. 

Trip duration: 5 to 6 days; 
Combatant Command: Central Command: 117; 
Combatant Command: European Command: 41; 
Combatant Command: Pacific Command: 4; 
Combatant Command: Southern Command: 0; 
Combatant Command: Total trips: 162. 

Trip duration: 7 to 14 days; 
Combatant Command: Central Command: 628; 
Combatant Command: European Command: 71; 
Combatant Command: Pacific Command: 37; 
Combatant Command: Southern Command: 20; 
Combatant Command: Total trips: 756. 

Trip duration: 15 or more days; 
Combatant Command: Central Command: 405; 
Combatant Command: European Command: 95; 
Combatant Command: Pacific Command: 32; 
Combatant Command: Southern Command: 3; 
Combatant Command: Total trips: 535. 

Trip duration: Total; 
Combatant Command: Central Command: 1,253; 
Combatant Command: European Command: 216; 
Combatant Command: Pacific Command: 77; 
Combatant Command: Southern Command: 30; 
Combatant Command: Total trips: 1,576. 

Source: GAO analysis of temporary duty travel vouchers processed using 
the Defense Travel System. 

[End of table] 

The Air Force and the Army account for the majority of cross-month 
travel. In addition, we found that officers at the O-3 and O-4 pay 
grades accounted for the greatest number of cross-month trips by active 
duty officers to areas designated for imminent danger pay and combat 
zone tax relief benefits during fiscal years 2003 through 2005. In 
contrast, officers at the O-7, O-8, O-9, and O-10 pay grades made the 
least number of cross-month trips to areas designated for imminent 
danger pay or combat zone tax relief benefits. Enlisted servicemembers 
at the E-3, E-5, and E-6 pay grades made the majority of cross-month 
trips by active duty enlisted servicemembers to areas designated for 
this special pay or benefit during fiscal years 2003 through 2005. 

In comparison, we found that 23,083 (about 81 percent) of the 28,404 
trips processed using the Defense Travel System from fiscal year 2003 
through fiscal year 2005 involved travel to areas that were not 
designated for either imminent danger pay or combat zone tax relief 
during fiscal years 2003 to 2005.[Footnote 30] Further, we found that 
4,414 trips (about 16 percent) of the 28,404 trips crossed calendar 
months, but did not include travel to areas designated for imminent 
danger pay or combat zone tax relief benefits. Of these 4,414 trips, 
3,058 (about 69 percent) were 7 or more days in duration and 1,356 
(about 31 percent) were less than a week in duration, as shown in table 
4. 

Table 4: Duration of Cross-Month Travel to Areas Not Designated for 
Imminent Danger Pay or Combat Zone Tax Relief Benefits, October 1, 
2002, to September 30, 2005: 

Fiscal year: 2003; 
2 days or less: 0; 
3 to 4 days: 2; 
5 to 6 days: 2; 
7 to 14 days: 5; 
15 days or more: 67; 
Total number of trips: 76. 

Fiscal year: 2004; 
2 days or less: 32; 
3 to 4 days: 47; 
5 to 6 days: 88; 
7 to 14 days: 181; 
15 days or more: 178; 
Total number of trips: 526. 

Fiscal year: 2005; 
2 days or less: 223; 
3 to 4 days: 426; 
5 to 6 days: 536; 
7 to 14 days: 1,479; 
15 days or more: 1,148; 
Total number of trips: 3,812. 

Fiscal year: Total number of trips; 
2 days or less: 255; 
3 to 4 days: 475; 
5 to 6 days: 626; 
7 to 14 days: 1,665; 
15 days or more: 1,393; 
Total number of trips: 4,414. 

Source: GAO analysis of Defense Travel System data. 

Note: The majority of our data reflect travel that occurred during 
fiscal year 2005. Defense Travel System data for fiscal years 2003 and 
2004 were minimal because DOD locations were just beginning to 
transition from using 43 legacy systems for processing travel vouchers 
during this time frame. 

[End of Table] 

However, due to data limitations, we were unable to determine whether 
this travel was representative of temporary duty travel departmentwide. 

U.S. Navy Ships Make Port Visits to Designated Areas and These Visits 
May Cross Calendar Months: 

Data provided by U.S. Naval Forces, Europe, indicate that some ships 
make port visits to areas designated for imminent danger pay or combat 
zone tax relief benefits, and that some of these port visits cross 
calendar months thus qualifying servicemembers for 2 months of imminent 
danger pay, and more significantly, combat zone tax relief benefits. 
Although ship commanders determine ship movements within an operating 
area, U.S. Naval Forces, Europe, determines the location of port visits 
based on security concerns and joint exercises and operations, among 
other considerations. The U.S. Naval Forces, Europe, provided data on 
port visits made by Navy ships for fiscal years 2003 through 2005 to 
areas designated for imminent danger pay or combat zone tax relief 
benefits within the U.S. European Command's area of responsibility. 
According to these data, for which we did not validate the accuracy, 56 
ships made port visits to areas designated for imminent danger pay or 
combat zone tax relief benefits within the U.S. European Command's area 
of responsibility during this time. Seven of these ships made port 
calls to areas designated for imminent danger pay or combat zone tax 
relief that crossed calendar months (see table 5). 

Table 5: Port Visits to Areas within the U.S. European Command That Are 
Designated for Imminent Danger Pay or Combat Zone Tax Relief Benefits: 

Country/sea area of port visit: Croatia; 
Designated for imminent danger pay: June 22, 1992-present; 
Designated for combatant zone tax relief benefits: November 1995-
present; 
Number of ships making port calls: Fiscal year 2003: 4; 
Number of ships making port calls: Fiscal year 2004: 9; 
Number of ships making port calls: Fiscal year 2005: 8; 
Number of port calls that crossed calendar months: Fiscal year 2003: 2; 
Number of port calls that crossed calendar months: Fiscal year 2004: 0; 
Number of port calls that crossed calendar months: Fiscal year 2005: 2; 
Purpose of port visits: Quality of life port visit, refueling, training 
exercise. 

Country/sea area of port visit: Israel; 
Designated for imminent danger pay: January 31, 2002-present; 
Designated for combatant zone tax relief benefits: January 1, 2003-July 
31, 2003; 
Number of ships making port calls: Fiscal year 2003: 4; 
Number of ships making port calls: Fiscal year 2004: 5; 
Number of ships making port calls: Fiscal year 2005: 5; 
Number of port calls that crossed calendar months: Fiscal year 2003: 1; 
Number of port calls that crossed calendar months: Fiscal year 2004: 1; 
Number of port calls that crossed calendar months: Fiscal year 2005: 0; 
Purpose of port visits: Quality of life port visit, training exercise. 

Country/sea area of port visit: Mediterranean Sea (east of 30 degrees 
east); 
Designated for imminent danger pay: March 19, 2003-July 31, 2003; 
Designated for combatant zone tax relief benefits: March 19, 2003- July 
31, 2003; 
Number of ships making port calls: Fiscal year 2003: 1; 
Number of ships making port calls: Fiscal year 2004: 1l 
Number of ships making port calls: Fiscal year 2005: 0; 
Number of port calls that crossed calendar months: Fiscal year 2003: 0; 
Number of port calls that crossed calendar months: Fiscal year 2004: 0; 
Number of port calls that crossed calendar months: Fiscal year 2005: 0; 
Purpose of port visits: Quality of life port visit. 

Country/sea area of port visit: Turkey; 
Designated for imminent danger pay: March 1, 1998-present; 
Designated for combatant zone tax relief benefits: September 21, 2001-
December 31, 2005; 
Number of ships making port calls: Fiscal year 2003: 10; 
Number of ships making port calls: Fiscal year 2004: 9; 
Number of ships making port calls: Fiscal year 2005: 0; 
Number of port calls that crossed calendar months: Fiscal year 2003: 0; 
Number of port calls that crossed calendar months: Fiscal year 2004: 1; 
Number of port calls that crossed calendar months: Fiscal year 2005: 0; 
Purpose of port visits: Quality of life port visit. 

Source: U.S. Navy, Europe. 

Note: Data provided by the U.S. Naval Forces, Europe, are from fiscal 
year 2003 through fiscal year 2005. Areas may have been designated for 
imminent danger pay or combat zone tax relief benefits prior to the 
time of our review, such as was the case with Croatia and Israel. These 
designations may still be in effect. 

[End of table] 

According to U.S. Naval Forces, Europe, the purpose of these port 
visits was generally for quality of life reasons or part of training or 
exercises. 

DOD paid approximately $7.5 million to the 26,849 servicemembers who 
qualified for imminent danger pay for 1 month and the 3,284 
servicemembers who qualified for 2 months of imminent danger pay 
because the port visit crossed calendar months. We did not determine 
how much compensation servicemembers qualified to exclude from federal 
taxes as a result of these port visits. 

We focused on port visits made by ships and did not obtain individual 
ships' logs to determine whether ships crossed into sea areas 
designated for imminent danger pay or combat zone tax relief benefits 
while en route to other destinations or while performing operations. We 
also did not obtain similar data for the U.S. Central Command because 
most ports and all sea areas in its area of responsibility are 
designated for imminent danger pay or combat zone tax relief benefits. 
We also did not obtain this information from the U.S. Southern Command 
or U.S Pacific Command because few countries and no sea areas in their 
areas of responsibility are designated for imminent danger pay or 
combat zone tax relief benefits. 

DOD Tracks Imminent Danger Pay and Combat Zone Tax Relief Benefits and 
Reports Some Data to Congress: 

DOD tracks the cost of imminent danger pay and servicemembers' 
compensation that qualify for combat zone tax relief benefits. While 
DOD tracks and reports the cost of imminent danger pay to Congress as 
part of its budget request, the department does not report the amount 
of servicemembers' compensation that qualifies for combat zone tax 
relief benefits. Combat zone tax relief benefits could allow 
servicemembers to exclude a significant portion of their compensation 
from federal taxes. For example, enlisted personnel and warrant 
officers may exclude all military compensation earned during one month. 
For commissioned officers, compensation is free of federal income tax 
up to the maximum amount of enlisted pay plus any imminent danger or 
hostile fire pay received. In 2006, the maximum amount of compensation 
for commissioned officers that is eligible for combat tax zone relief 
is $6,499.50 plus $225 imminent danger pay, or $6,724.50 per 
month.[Footnote 31] The Defense Finance and Accounting Service reports 
servicemembers' compensation that qualifies for combat zone tax relief 
benefits to the services' financial management offices. However, there 
is no requirement for DOD to report this information to Congress. The 
reporting of combat zone tax relief benefit data to Congress could 
provide information on the extent of this benefit and aid Congress in 
its oversight role. 

Conclusions: 

With concerns about the long-term sustainability of rising costs 
associated with military compensation, it is important that DOD 
effectively manage its imminent danger pay program to ensure that only 
those servicemembers who are subject to the threat of physical harm or 
imminent danger on the basis of civil war, civil insurrection, 
terrorism, or wartime conditions while on duty in a designated foreign 
area receive imminent danger pay. While DOD has significantly increased 
the number of areas designated for imminent danger pay over the past 14 
years, it has conducted reviews of these areas only six times between 
1992 and 2006, and the current review is ongoing. In addition, we 
believe that updating guidance to reflect the responsibility of the 
Office of the Under Secretary of Defense (Personnel and Readiness) for 
reviewing area designations and incorporating factors into its guidance 
to determine what specifically constitutes imminent danger, would 
clarify responsibilities and establish standard criteria for use in 
meeting the objectives of the imminent danger pay program. 

Clearly, it is important that servicemembers are appropriately 
compensated for the duties they perform, particularly when there are 
risks associated with those duties. It is also important that DOD 
ensure the need for cross-month travel as both the U.S. Central Command 
and U.S. Army, Europe, are doing. Although these two commands have 
instituted policies and internal controls to preclude the perceived 
abuse of imminent danger pay and combat zone tax relief by regulating 
and monitoring cross-month travel, no requirement exists for DOD to 
monitor cross-month travel to 38 percent of areas currently designated 
for imminent danger pay and 14 percent of areas currently designated 
for combat zone tax relief benefits. Managing these programs 
effectively is important, as the nation's growing fiscal concerns will 
require DOD and the federal government to consider difficult trade-offs 
in the years ahead. In addition, internal controls to monitor cross- 
month travel could ensure all designated areas are covered and further 
strengthen DOD's management of imminent danger pay and combat zone tax 
relief benefits. 

Finally, combat zone tax relief benefits can be substantial. Congress 
may benefit from obtaining information on servicemembers' total 
compensation that qualifies for combat zone tax relief benefits as a 
means to assist in providing oversight of this benefit. 

Recommendations for Executive Action: 

To strengthen DOD's internal controls and management of imminent danger 
pay and to monitor cross-month travel, we recommend that the Secretary 
of Defense direct the Under Secretary of Defense (Personnel and 
Readiness) to take the following three actions: 

* Update DOD's imminent danger pay guidance to (1) reflect the office 
responsible for reviewing and designating imminent danger pay areas and 
(2) incorporate factors that clearly define what constitutes the 
presence of imminent threat or dangers to servicemembers on duty in 
foreign areas. 

* Request the designated organizations to conduct reviews of areas 
designated for imminent danger pay in accordance with DOD's guidance, 
and, if necessary, update its guidance to reflect the appropriate time 
period for conducting these reviews. 

* Establish departmentwide policies and internal controls that include 
periodic audits to monitor cross-month travel to ensure that the travel 
needs to cross calendar months. 

Matter for Congressional Consideration: 

In light of the substantial tax benefits that servicemembers receive 
when performing duty in combat zones, Congress should consider the 
following action: 

* Require DOD to periodically report the amount of servicemembers' 
total compensation that qualifies for combat zone tax relief benefits 
to Congress. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report, DOD generally concurred 
with two of our three recommendations, but did not concur with our 
recommendation to establish a departmentwide policy and internal 
controls to monitor cross-month travel to ensure that the travel needs 
to cross calendar months. DOD also provided separate technical comments 
which we have incorporated in the report, as appropriate. 

DOD concurred with our recommendation to update DOD's imminent danger 
pay guidance. DOD acknowledged that there are informal processes and 
additional guidance and concurs that its informal policy should be 
updated to reflect the office currently responsible for the review and 
to provide additional clarification and guidance as to what factors are 
considered in determining whether imminent danger pay is warranted. 

DOD partially concurred with our recommendation to conduct 
comprehensive reviews of imminent danger pay area designations, noting 
it had conducted reviews six times since 1992 and expects to complete 
its ongoing review by October 31, 2006. DOD stated that the department 
believes that comprehensive reviews of imminent danger pay should be 
conducted at least biennially. DOD's current imminent danger pay 
guidance requires at least annual reviews of areas designated for 
imminent danger pay. We continue to believe that DOD should conduct 
reviews of areas designated for imminent danger pay in accordance with 
its guidance, which is reflected in our recommendation. If DOD believes 
that the appropriate time period for conducting these reviews is 
biennially, as reflected in its comments, then DOD should update its 
imminent danger pay guidance accordingly. 

DOD did not concur with our recommendation to establish departmentwide 
policies and internal controls that include periodic audits to monitor 
cross-month travel to ensure that the travel needs to cross calendar 
months. DOD stated in written comments that doing so would add 
unnecessary bureaucracy and cost to its travel system and believes that 
our recommended action is already implemented in existing travel 
procedures that require thorough review and management of the necessity 
and cost-effectiveness of travel by DOD personnel. Further, DOD 
commented that our review found no apparent abuse of cross-month travel 
and the two commands that collectively account for the majority of 
imminent danger pay and combat zone tax relief benefits have developed 
theater-specific policies and controls to monitor and regulate cross- 
month travel. As stated in our scope and methodology and the report, 
data limitations prevented us from determining the full extent of 
temporary duty travel to areas designated for imminent danger pay and 
combat zone tax relief benefits, as well as how much of this travel 
crossed calendar months. Further, we reviewed only temporary duty 
travel vouchers processed using DOD's Defense Travel System. We did not 
review travel that was processed in DOD's numerous legacy travel 
systems, and therefore did not reach any conclusions as to whether 
servicemembers have scheduled travel in a fiscally responsible manner 
or have attempted to maximize this pay and benefit by scheduling cross- 
month travel. We recognize DOD has procedures in place to review and 
authorize travel. Our recommendation addresses the need to have greater 
monitoring of travel trends. Moreover, although two commands have 
instituted policies and internal controls to preclude the perceived 
abuse of imminent danger pay and combat zone tax relief by regulating 
and monitoring cross-month travel, no requirement exists for DOD to 
monitor cross-month travel to the 38 percent of areas currently 
designated for imminent danger pay and the 14 percent of areas 
currently designated for combat zone tax relief benefits not covered by 
these two commands. Also, while we recognize that these commands 
currently reflect the majority of areas designated for imminent danger 
pay and combat zone tax relief benefits, security conditions are 
subject to change over time. Therefore, we continue to believe our 
recommendation has merit and that internal controls to monitor cross- 
month travel departmentwide are needed to ensure all designated areas 
are covered and further strengthen DOD's management of imminent danger 
pay and combat zone tax relief benefits. 

In response to the other written comments provided by DOD, we modified 
the report to acknowledge that the global security environment has 
played a role in the increased number of areas designated for imminent 
danger pay since 1992. In addition, we modified the report to reflect 
that danger pay was first authorized on October 1, 1983, by Public Law 
98-94, section 905. 

We are sending copies of this report to congressional committees, the 
Secretary of Defense, the secretaries of the Army, the Navy, the Air 
Force; and the Commandant of the Marine Corps. We will also make copies 
available to other interested parties upon request. In addition, the 
report will be available at no charge on the GAO Web site at 
[Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please call 
me at (202) 512-9619 or pickups@gao.gov. Contact points for our Offices 
of Congressional Relations and Public Affairs may be found on the last 
page of this report. The GAO contact and key contributors are listed in 
appendix VI. 

Signed by: 

Sharon Pickup: 
Director, Defense Capabilities and Management: 

List of Congressional Committees: 

The Honorable John Warner: 
Chairman: 
The Honorable Carl Levin: 
Ranking Minority Member: 
Committee on Armed Services: 
United States Senate: 

The Honorable Ted Stevens: 
Chairman: 
The Honorable Daniel K. Inouye: 
Ranking Minority Member: 
Subcommittee on Defense: 
Committee on Appropriations: 
United States Senate: 

The Honorable Duncan L. Hunter: 
Chairman: 
The Honorable Ike Skelton: 
Ranking Minority Member: 
Committee on Armed Services: 
House of Representatives: 

The Honorable C.W. Bill Young: 
Chairman: 
The Honorable John P. Murtha: 
Ranking Minority Member: 
Subcommittee on Defense: 
Committee on Appropriations: 
House of Representatives: 

[End of section] 

Appendix I: Areas Currently Designated for Imminent Danger Pay and 
Combat Zone Tax Relief Benefits: 

Table 6 identifies the areas designated for imminent danger pay or 
combat zone tax relief benefits as of July 2006. 

Table 6: Summary of Areas Designated for Imminent Danger Pay and Combat 
Zone Tax Relief Benefits: 

Area: Adriatic Sea; 
Designated for imminent danger pay: [Empty]; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: European Command. 

Area: Afghanistan; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Albania; 
Designated for imminent danger pay: [Empty]; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: European Command. 

Area: Algeria; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Angola; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Arabian Sea North of 10 degrees North latitude and West of 68 
degrees East longitude; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Azerbaijan; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Bahrain; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Bosnia-Herzegovina; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: European Command. 

Area: Burundi; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Colombia; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Southern Command. 

Area: Cote d'Ivoire; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Croatia; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: European Command. 

Area: Democratic Republic of Congo (formerly Zaire); 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Djibouti; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: East Timor; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Pacific Command. 

Area: Egypt; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Central Command. 

Area: Eritrea; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Central Command. 

Area: Ethiopia; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Central Command. 

Area: Georgia; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Greece (Athens); 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Gulf of Aden; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Gulf of Oman; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Haiti; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Southern Command. 

Area: Indonesia; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Pacific Command. 

Area: Ionian Sea north of the 39[TH] parallel; 
Designated for imminent danger pay: [Empty]; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: European Command. 

Area: Iran; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Central Command. 

Area: Iraq; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Israel; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Jordan; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Kenya; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Central Command. 

Area: Kuwait; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Kyrgyzstan; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Lebanon; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Central Command. 

Area: Liberia; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Macedonia; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: European Command. 

Area: Malaysia; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Pacific Command. 

Area: Oman; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Pakistan; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Persian Gulf; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Philippines; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Pacific Command. 

Area: Qatar; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Red Sea; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Rwanda; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Saudi Arabia; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Serbia and Montenegro, including Kosovo[A]; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: European Command. 

Area: Sierra Leone; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Somalia; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Central Command. 

Area: Sudan; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: Central Command. 

Area: Syria; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Tajikistan; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Turkey; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: Uganda; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: [Empty]; 
Combatant command responsible for area: European Command. 

Area: United Arab Emirates; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Uzbekistan; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Area: Yemen; 
Designated for imminent danger pay: X; 
Designated for combat zone tax relief: X; 
Combatant command responsible for area: Central Command. 

Source: DOD data; GAO presentation. 

Note: Although a geographic command, the Northern Command's area of 
responsibility--the continental United Stated, Alaska, and the 
surrounding waters as well as the Gulf of Mexico, Puerto Rico, and the 
U.S. Virgin Islands--are not eligible for imminent danger pay because 
they are not foreign areas. 

[A] For purposes of this chart, Serbia and Montenegro are presented as 
one area. However, when calculating the number of areas designated for 
imminent danger pay, Serbia and Montenegro are considered separate 
areas. 

[End of table] 

[End of section] 

Appendix II: Presidentially Designated Combat Zones and Congressionally 
Legislated Qualified Hazardous Duty Areas: 

Combat Zones: 

A combat zone is any area that the president designates by executive 
order as an area in which U.S. Armed Forces are or have engaged in 
combat after June 24, 1950. An area ceases to be a combat zone on the 
dates the president designates by executive order. Since 1950, U.S. 
presidents have designated combat zones in Korea, Vietnam, the Persian 
Gulf, the Kosovo area, and Afghanistan. U.S. presidents terminated 
combat zone designations for Korea in 1955 and Vietnam in 1996. 

Enlisted personnel and warrant officers may exclude from taxes all 
military compensation earned during the month that they serve in a 
combat zone. For commissioned officers, compensation is free of federal 
income tax up to the maximum amount of enlisted pay plus any imminent 
danger or hostile fire pay received. In 2006, the maximum amount of 
compensation for commissioned officers that is eligible for combat tax 
zone relief is $6,499.50 plus $225 imminent danger pay, or $6,724.50 
per month.[Footnote 32] Table 7 depicts the current combat zones. 

Table 7: Combat Zones as of July 2006: 

Combat zones: Afghanistan, including airspace above; 
Designated by: Executive Order 13239; 
Date designated: September 19, 2001. 

Combat zones: The Kosovo area including airspace above: Federal 
Republic of Yugoslavia (Serbia/Montenegro), Albania, Adriatic Sea, 
Ionian Sea north of the 39th parallel; 
Designated by: Executive Order 13119; 
Date designated: March 24, 1999. 

Combat zones: Persian Gulf area, including airspace above: 
* Arabian Sea north of 10 degrees north latitude and west of 68 degrees 
east longitude; 
* Bahrain; 
* Gulf of Aden; 
* Gulf of Oman; 
* Iraq; 
* Kuwait; 
* Oman; 
* Persian Gulf; 
* Qatar; 
* Red Sea; 
* Saudi Arabia; 
* United Arab Emirates; 
Designated by: Executive Order 12744; 
Date designated: January 17, 1991. 

Source: Executive Orders 12744, 13119, and 13239. 

[End of table] 

Qualified Hazardous Duty Areas: 

Servicemembers on duty in qualified hazardous duty areas designated by 
Congress are entitled to the same benefits afforded those who serve in 
a presidentially designated combat zone if the Secretary of Defense 
also designates that qualified hazardous duty area for imminent danger 
pay.[Footnote 33] If Congress designates a qualified hazardous duty 
area, but the Secretary of Defense has not designated the area for 
imminent danger pay, servicemembers deployed to the area are not 
eligible to receive combat zone tax relief unless the qualified 
hazardous duty area becomes eligible for imminent danger pay. If the 
Secretary of Defense terminates imminent danger pay for a qualified 
hazardous duty area, members no longer receive combat zone tax relief 
benefits. Table 8 depicts the current qualified hazardous duty areas. 

Table 8: Qualified Hazardous Duty Areas as of July 2006: 

Qualified hazardous duty area: 
* Bosnia-Herzegovina; 
* Croatia; 
* Macedonia; 
Authority: Public Law 104-117; 
Date designated: November 21, 1995. 

Qualified hazardous duty area: 
* Federal Republic of Yugoslavia (Serbia/Montenegro); 
* Albania; 
* Adriatic Sea; 
* Ionian Sea north of the 39th parallel; 
Authority: Public Law 106-21; 
Date designated: March 24, 1999. 

Source: Public Laws 104-117 and 106-21. 

[End of table] 

[End of section] 

Appendix III: Military Service Certified as in Direct Support of Combat 
Zone Operations: 

DOD has certified military service as in direct support of military 
operations in combat zones, thus qualifying servicemembers for combat 
zone tax relief benefits (see table 9). Unlike the other areas 
identified in the table, Jordan is the only area where DOD has 
certified military service as in direct support of combat zone 
operations as part of both Operation Enduring Freedom and Operation 
Iraqi Freedom. 

Table 9: Areas Certified by DOD Where Military Service Is in Direct 
Support of Combat Zone Operations as of July 2006: 

Area: 
* Pakistan; 
* Tajikistan; 
* Jordan; 
Date of designation: September 19, 2001; 
Combat zone: Afghanistan; 
Military operation: Operation Enduring Freedom. 

Area: 
* Uzbekistan; 
* Kyrgyzstan; 
Date of designation: October 1, 2001; 
Combat zone: [Empty]; 
Military Operation; [Empty]. 

Area: 
* Philippines; 
Date of designation: January 9, 2002;
Combat zone: [Empty]; 
Military Operation; [Empty].  

Area: 
* Yemen; 
Date of designation: April 10, 2002; 
Combat zone: [Empty]; 
Military Operation; [Empty].  

Area: 
* Djibouti; 
Date of designation: July 1, 2002;  
Combat zone: [Empty]; 
Military Operation; [Empty]. 

Area: 
* Jordan; 
Date of designation: March 19, 2003; 
Combat zone: Iraq; 
Military operation: Operation Iraqi Freedom. 

Area: 
* Syria; 
Date of designation: January 1, 2004; 
Combat zone: [Empty]; 
Military Operation; [Empty].  

Sources: DOD Financial Management Regulation and Internal Revenue 
Service. 

[End of table] 

[End of section] 

Appendix IV: Scope and Methodology: 

To evaluate DOD's processes for reviewing imminent danger pay areas and 
to understand how servicemembers become eligible for combat zone tax 
relief, we analyzed legislation and DOD regulations and guidance. We 
compared these to the objectives and fundamental concepts of internal 
control defined in Standards for Internal Control in the Federal 
Government and Internal Control Management and Evaluation Tool. We also 
held discussions with knowledgeable officials from the following 
offices, geographic commands, and services: 

* Commander, Navy Installations, Personnel Support Activity, 
Washington, D.C. 

* Defense Finance and Accounting Service, Indianapolis, Indiana: 

* Defense Manpower and Data Center, Monterey, California and Arlington, 
Virginia: 

* Defense Travel System Office, Arlington, Virginia: 

* Department of Defense Inspector General, Inspector General/Hotline 
Cases and Senior Officials Investigation Offices, Arlington, Virginia: 

* Joint Chiefs of Staff, Personnel and Policy, Arlington, Virginia: 

* Office of Management and Budget, Washington, D.C. 

* Under Secretary of Defense (Personnel and Readiness), Arlington, 
Virginia: 

* United States Air Forces in Europe, Ramstein Air Force Base, Germany: 

* United States Army, Europe, Heidelberg, Germany: 

* United States Central Command, MacDill Air Force Base, Tampa, 
Florida: 

* United States Department of State, Office of Allowances, Washington, 
D.C. 

* United States European Command, Patch Barracks, Stuttgart, Germany: 

* United States Marine Corps Forces, Europe, Boeblingen, Germany: 

* United States Naval Forces, Europe, Commander, U.S. Sixth Fleet, 
Naples, Italy: 

* United States Pacific Command, Camp H.M. Smith, Honolulu, Hawaii: 

United States Southern Command, Miami, Florida: 

To gain an understanding of DOD's rationale for designating certain 
areas and to determine whether DOD followed its policy for designating 
and reviewing imminent danger pay areas and areas certified as in 
direct support of combat zones, we reviewed 54 imminent danger pay area 
questionnaires completed by combatant commanders and used by DOD to 
evaluate area designations and the threat of imminent danger. This 
nonprobability sample of areas was selected to ensure that each 
geographic combatant command was represented. In addition, we sought to 
include imminent danger pay areas where designation was limited to 
either land, or airspace, or water areas, or the designation was for 
the entire area including land, air, or water areas. For purposes of 
our analysis, we considered an area to be designated for imminent 
danger pay if DOD had designated any portion of the area (land, 
airspace, or water) for imminent danger pay. We also reviewed other 
relevant DOD documents related to DOD's review of imminent danger pay 
and combat zone tax relief benefits from 1992 through 2006. We compared 
these against the standards for oversight envisioned in Standards for 
Internal Control in the Federal Government and the Internal Control 
Management and Evaluation Tool. 

To understand how DOD regulates and monitors temporary duty travel, and 
cross-month travel in particular, we reviewed DOD's temporary duty 
travel policy and its Foreign Clearance Guide that establishes DOD 
policy for military personnel traveling overseas. We also reviewed 
travel policies from the U.S Central Command and U.S. Army, Europe. We 
discussed these policies with officials responsible for approving 
travel in accordance with the Foreign Clearance Guide, and compared 
these with the standards for internal control activities contained in 
the Standards for Internal Control in the Federal Government. In 
addition, we interviewed personnel in the U.S. Pacific Command and U.S. 
Southern Command who are knowledgeable about these command's travel 
policies and requirements. Because the U.S. European Command does not 
have a travel clearance office, we spoke with service officials at the 
U.S. European Command who are responsible for authorizing travel to 
certain locations. 

To determine the extent to which servicemembers were making cross-month 
trips to areas that would make them eligible to receive imminent danger 
pay and combat zone tax relief benefits, we also analyzed 28,404 travel 
vouchers obtained from the Defense Travel System for servicemembers 
traveling on temporary duty between October 1, 2002, and September 31, 
2005. In addition, we obtained data from the U.S. Naval Forces, Europe, 
on ship port visits to areas within the U.S. European Command's area of 
responsibility that are designated for imminent danger pay or for 
combat zone tax relief benefits. We did not obtain similar data for the 
U.S. Central Command because most ports and all sea areas in its area 
of responsibility are designated for imminent danger pay or combat zone 
tax relief benefits. We also did not obtain this information from the 
U.S. Southern Command or U.S. Pacific Command because few countries and 
no sea areas in their areas of responsibility are designated for 
imminent danger pay or combat zone tax relief benefits. Under DOD's 
Financial Management Regulations, authorizing officials are responsible 
for determining the necessity of trips and funds availability for 
temporary duty travel.[Footnote 34] Further, DOD guidance states that 
DOD airlift authorizing officials shall ensure that an official purpose 
is served by air travel.[Footnote 35] Therefore, we did not evaluate 
whether the purposes of the trips were valid. We analyzed travel 
vouchers from the Defense Travel System because it is the only system 
that captures temporary duty travel from all four services. 

We also reviewed data from the Defense Finance and Accounting Service's 
Operational Data System that captures the balance of travel data for 
the Army that is not processed using the Defense Travel System. Data 
from the Operational Data System frequently were missing information 
about trip destinations. As a result, we were unable to use these data 
to analyze cross-month travel to areas designated for imminent danger 
pay or combat zone tax relief benefits. We also did not review data 
processed in the 43 legacy systems used by the services to process 
travel vouchers because of data reliability concerns. 

Due to the large number of countries and sea areas within the U.S. 
Central Command's area of responsibility that are designated for 
imminent danger pay or combat zone tax relief and because most travel 
vouchers for servicemembers assigned to the U.S. Central Command's 
headquarters during the time period of our review were not processed 
using the Defense Travel System, we sought to obtain travel data 
directly from several combatant commands. We tested this approach with 
the U.S. Central Command. First, we attempted to obtain data from the 
U.S. Central Command's finance office that processes travel vouchers. 
Due to data limitations and concerns about the accuracy of data in the 
automated business service system, a document processing system used to 
approve travel orders, we were unable to use this approach. Second, we 
sought to use theater clearance requests and approvals to determine the 
extent of cross-month travel to the U.S. Central Command's area of 
responsibility. However, database limitations prevented us from using 
this approach. For instance, if more than one servicemember was listed 
on a travel clearance request submitted to the U.S. Central Command's 
travel clearance office, only the name of the most senior official was 
listed in the database and information on the pay grades of junior 
servicemembers would not be available for analysis. In addition, we 
could not determine the accuracy of travel dates contained in the 
Travel Clearance Office's database because itinerary changes are not 
always captured in the database. 

The scope of this review excluded servicemembers deployed or assigned 
to foreign areas. The scope also excluded servicemembers who served as 
part of crews on aircraft and, with the exception of data provide by 
the U.S. Naval Forces, Europe, ships because aircraft and ship 
movements are dictated by operational needs and mission requirements, 
and generally, do not have the same degree of flexibility associated 
with scheduling temporary duty travel. To assess the reliability of 
data obtained from the Defense Travel System, we (1) reviewed existing 
documentation related to the data sources, (2) electronically tested 
the data to identify problems with completeness or accuracy, and (3) 
interviewed knowledgeable officials about the data. We found these data 
to be sufficiently reliable for the purposes of this report. 

For purposes of our analysis, we defined cross-month travel as any 
temporary duty travel of 30 days or fewer that begins during one month 
and concludes during the following month. This cross-month travel may 
encompass travel to a single location or multiple locations during a 30-
day period. During this time, a servicemember may travel to areas 
designated for imminent danger pay or combat zone tax relief, areas not 
designated for these special pays and benefits, or to both areas 
designated and not designated for such benefits. 

However, we do not know the portion of overall travel that these trips 
represent because some DOD locations were not using the Defense Travel 
System to process travel vouchers during the time of our review. As a 
result, we cannot extrapolate travel patterns based on the data we 
obtained and analyzed from the Defense Travel System. We also requested 
and received information on GAO's FraudNet hotline as well as the DOD 
Inspector General hotline on inquiries related to servicemembers 
scheduling cross-month travel to potentially maximize combat zone tax 
relief benefits. GAO's FraudNet did not receive any calls concerning 
servicemembers scheduling travel to maximize imminent danger pay or 
combat zone tax relief benefits. Two calls received by the DOD 
Inspector General's hotline were not substantiated. Additionally, we 
obtained data from the Defense Finance and Accounting Service to 
determine the compensation excluded from federal taxable wages for 
servicemembers for calendar years 2003 through 2005 as a result of 
performing military service that the Office of the Under Secretary of 
Defense (Personnel and Readiness) certified as in direct support of 
combat zone operations and for combat zone tax exclusion overall. We 
also obtained data from the Defense Manpower and Data Center to 
estimate the total dollar amount of imminent danger pay for service 
members for fiscal years 2003 through 2005. However, we did not use 
these data because sufficient information was not available from the 
Defense Manpower and Data Center to validate the accuracy of these data 
for this report. As stated earlier in this report, we previously 
reported on the lack of reliability on DOD's reported costs related to 
the Global War on Terrorism, including military pay. 

We conducted our review from October 2005 through July 2006 in 
accordance with generally accepted government auditing standards. 

[End of section] 

Appendix V: Comments from the Department of Defense: 

Personnel And Readiness: 
Office Of The Under Secretary Of Defense: 
4000 Defense Pentagon: 
Washington, D.C. 20301-4000: 

Sep 15 2006: 

Ms. Sharon L. Pickup: 
Director, Defense Capabilities and Management: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, DC 20548: 

Dear Ms. Pickup: 

This is the Department of Defense (DoD) response to the GAO draft 
report, GAO-06-1011, "Military Personnel: Actions Needed to Strengthen 
Management of Imminent Danger Pay and Combat Zone Tax Relief Benefits," 
dated August 22, 2006 (GAO Code 350758). The Department generally 
concurs with comment on the findings and recommendations. 

The Department notes the GAO draft report appears to infer that 
imminent danger pay areas have increased since 1992 due to an absence 
of sufficient oversight or review of country designations (see draft 
report page 6 beginning with line 8) rather than a recognition that the 
security environment has changed. The Department believes the inference 
is incorrect because areas around the world designated for the receipt 
of imminent danger pay have increased since 1992 due to the global 
security environment and the increase in the number of areas where 
Service members serve in imminent danger. Those areas include countries 
in the former Republic of Yugoslavia (Bosnia, Herzegovina, Croatia, 
Macedonia, etc), East Timor, the numerous dangerous areas our troops 
have served in support of Operation Enduring Freedom and Operation 
Iraqi Freedom, and many other areas of the world. The Department agrees 
program management can be strengthened; however, we believe the 
Department has appropriately designated and reviewed the designation of 
imminent danger areas as well as travel through areas of imminent 
danger and/or subject to combat zone tax relief benefits. 

Additionally, the GAO's statement that "In 1971, only one location was 
designated for imminent danger pay" (page 2 of the GAO draft report) is 
incorrect since imminent danger pay was first authorized on October 1, 
1983, by Public Law 98-94, section 905. However, hostile fire pay has 
been authorized since 1963. In 1971, four locations were authorized 
hostile fire pay: 1. Vietnam; 2. Cambodia; 3. Laos; and 4. A 45 square 
mile area along the Korea demilitarized zone. This error is repeated on 
page 12 of the report and again in Figure 1 on page 13. The error is 
important because it results in the incorrect assertion that imminent 
danger pay areas have increased from 1 to 54 between 1971 and today 
(see page 2 and Figure l, page 13). This leaves the impression that the 
Department has failed to properly review and appropriately remove 
imminent danger pay area designations. In fact, the number of imminent 
danger pay areas were low (actually non-existent) in 1971 because they 
were not authorized, not because the Department has failed to properly 
review their designations. 

Regarding recommendation 3, the Department believes adequate travel 
safeguards are in place to monitor temporary duty cross-month travel in 
countries designated for imminent danger pay or combat zone tax 
exclusion. Detailed comments to the draft recommendations are enclosed. 
Technical comments were provided directly to GAO staff for 
consideration. 

If you have any questions, please contact Major John Johnson at (703) 
693-1066, or m.john.johnson@osd.mil: 

Sincerely, 

Signed by: 

Michael L. Dominguez: 
Principal Deputy: 

Enclosure: 
As stated: 

GAO Draft Report - Dated August 22, 2006 GAO Code 350758/GAO-06-1011: 

"Military Personnel: Actions Needed to Strengthen Management of 
Imminent Danger Pay and Combat Zone Tax Relief Benefits" 

Department Of Defense Comments To The Recommendations: 

Recommendation 1: The GAO recommended that the Secretary of Defense 
direct the Under Secretary of Defense (Personnel and Readiness) to 
update DoD's imminent danger pay guidance to: (1) reflect the office 
responsible for reviewing and designating imminent danger pay areas; 
and (2) incorporate factors that clearly define what constitutes the 
presence of imminent threat or dangers to Service members on duty in 
foreign areas. 

DOD Response: Dod concurs with this recommendation. As noted in the GAO 
draft report (draft report page 5), DoD already has an informal process 
for designating and reviewing imminent danger pay areas. This informal 
process is contained in draft DoD Instruction 1340.9, "Special Pay for 
Duty Subject to Hostile Fire or Imminent Danger," and provides guidance 
as to what factors are considered in designating and reviewing imminent 
danger pay area designations. However, DoD concurs that the informal 
policy should be updated to reflect the office currently responsible 
for the review and to provide additional clarification and guidance as 
to what factors are considered in determining whether imminent danger 
pay is warranted. 

Recommendation 2: The GAO recommended that the Secretary of Defense 
direct the Under Secretary of Defense (Personnel and Readiness) to 
request the designated organizations to conduct reviews of areas 
designated for imminent danger pay in accordance with DoD's guidance. 

DOD Response: DoD partially concurs with this recommendation. As noted 
in the GAO draft report (draft report page 28), DoD has conducted 
comprehensive reviews of imminent danger pay area designations six 
times since 1992. In fact, a review is currently on-going and should be 
completed by October 31, 2006. DoD believes the review of imminent 
danger pay areas should be conducted at least biennially. 

Recommendation 3: The GAO recommended that the Secretary of Defense 
direct the Under Secretary of Defense (Personnel and Readiness) to 
establish Department-wide policies and internal controls that include 
periodic audits to monitor cross-month travel to ensure that the travel 
needs to cross calendar months. 

DOD Response: DoD nonconcurs with this recommendation because it would 
add unnecessary bureaucracy and cost to DoD's travel system. GAO's 
recommended action is already implemented in existing DoD travel 
procedures that require thorough review and management of the necessity 
and cost-effectiveness of travel by DoD personnel. The Joint Travel 
Regulations and the Joint Federal Travel Regulations already include 
requirements to authorize only travel that is necessary to accomplish 
the mission and when the mission cannot be met by other means. DoD 
Directive 4500.54, "Official Temporary Duty Travel Abroad," adds 
additional requirements to ensure that foreign travel is even more 
closely scrutinized by adding country and/or theater clearance 
requirements. These existing requirements already adequately control 
and monitor cross-month travel. For this reason, we disagree with GAO's 
finding that "DoD does not have a Department-wide policy to monitor 
cross-month travel to areas designated for imminent danger pay or 
combat zone tax relief benefits" (draft report page 19). This is 
supported by GAO's draft report which found no apparent abuse of cross-
month travel (draft report pages 19-27). GAO also noted that the two 
commands that collectively account for the majority of imminent danger 
pay and combat zone tax relief benefits (U.S. Central Command and U.S. 
Army, Europe) have developed theater-specific policies and controls to 
monitor and regulate cross-month travel (draft report page 19). 

[End of section] 

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Sharon L. Pickup, (202) 512-9619 or pickups@gao.gov: 

Acknowledgments: 

In addition to the person named above, Ann Borseth, Assistant Director; 
Krislin Bolling; Alissa Czyz; James Driggins; Ron La Due Lake; 
Katherine Lenane; Grant Mallie; Oscar Mardis; David Mayfield; Ken 
Patton; Vanessa Taylor; and John Van Schaik also made major 
contributions to this report. 

FOOTNOTES 

[1] See 37 U.S.C. 310; Department of Defense Instruction 1340.9, 
Special Pay for Duty Subject to Hostile Fire or Imminent Danger Pay 
(Apr. 10, 1992), and the Financial Management Regulation, Volume 7A, 
Chapter 10 (Feb. 2006). Servicemembers who have been (1) subject to 
hostile fire or explosion of a hostile mine; (2) on duty in an area in 
close proximity to a hostile fire incident and the servicemembers are 
in danger of being exposed to the same dangers; or (3) injured, 
wounded, or killed by hostile fire, mines, or any kind of hostile 
action, receive hostile fire pay instead of imminent danger pay. 
Commanders at the lowest level of command certify that the member has 
met the requirements for entitlement to hostile fire pay within a given 
month, except when the member is under orders on official duty in one 
of the IDP-designated areas listed in appendix I. 

[2] In this report, we used the term combat zone tax relief benefits to 
describe tax exclusions provided to servicemembers under 26 U.S.C. 
§112. However, there are other kinds of tax benefits for servicemembers 
serving in combat zones or qualified hazardous duty areas that are not 
addressed in this report, such as extensions for filing income tax 
returns and exemptions from telephone excise taxes. Servicemembers may 
have other tax deductions and exclusions that reduce their taxable 
income. 

[3] 26 CFR §1.1121-1(e) and DOD Financial Management Regulation 7A, 
Chapter 44, §440103(c)(6). 

[4] Servicemembers receive imminent danger pay and combat zone tax 
relief benefits for an entire month regardless of the amount of time 
spent in a designated area. These benefits are not prorated. See 37 
U.S.C. §310 and 26 U.S.C. §112. 

[5] Department of Defense Authorization Act, 1984, Pub. L. No. 98-94 
§905 (1983). 

[6] Under Secretary of Defense (Personnel and Readiness) Memorandum for 
Director, Joint Staff, Annual Review of Designation of Foreign 
Locations as Imminent Danger Areas for Imminent Danger Pay (IDP) 
Purposes (Jan. 30, 2006). 

[7] GAO, Standards for Internal Control in the Federal Government, GAO/ 
AIMD-00-21.3.1 (Washington, D.C.: November 1999), and Internal Control 
Management and Evaluation Tool, GAO-01-1008G (Washington, D.C.: August 
2001). 

[8] GAO, Military Personnel: DOD Needs to Improve the Transparency and 
Reassess the Reasonableness, Appropriateness, Affordability, and 
Sustainability of Its Military Compensation System, GAO-05-798 
(Washington: D.C., July 19, 2005), and Global War on Terrorism: 
Observations on Funding, Costs, and Future Commitments, GAO-06-885T 
(Washington, D.C.: July 18, 2006). 

[9] We have previously reported on the lack of reliability in DOD's 
reported costs related to the Global War on Terrorism, including 
military pay. See GAO, Global War On Terrorism: DOD Needs to Improve 
the Reliability of Cost Data and Provide Additional Guidance to Control 
Costs, GAO-05-882 (Washington, D.C.: Sept. 21, 2005) and GAO-06-885T. 

[10] 31 U.S.C. §717(b)(1)(2000). 

[11] GAO/AIMD-00-21.3.1. 

[12] The Unified Combatant Commands with geographic responsibility are 
composed of forces from two or more services and have broad and 
continuing missions for specific geographic areas. The commands 
organized on a geographical basis include (1) the U.S. Central Command, 
(2) the European Command, (3) the U.S. Northern Command, (4) the U.S. 
Pacific Command, and (5) the U.S. Southern Command. None of the U.S. 
Northern Command's geographic area of responsibility is eligible for 
imminent danger pay or combat zone tax relief. 

[13] DOD Financial Management Regulation 7000.14-R, Volume 9, Chapter 
2, Section 020401(C) (April 2006). (Hereinafter cited as DODFMR, Vol. 
9, Ch. 2, Section 020401(C) (April 2006)). 

[14] DOD Directive 4500.56, DOD Policy on the Use of Government 
Aircraft and Air Travel, Enclosure 2, Section E.2.1.2 (April 1999). 
(Hereinafter cited as DODD 4500.56, Section E.2.1.2 (Apr. 1999)). 

[15] GAO/AIMD-00-21.3.1. 

[16] DODI 1340.9 refers to the Assistant Secretary of Defense (Force 
Management and Personnel) rather than the Under Secretary of Defense 
(Personnel and Readiness). The Secretary of Defense established the 
position of the Under Secretary of Defense (Personnel and Readiness) in 
1994. At this time, the functions, relationships, and authorities 
assigned to the Assistant Secretary of Defense (Force Management and 
Personnel) were assigned to the Under Secretary of Defense (Personnel 
and Readiness). DOD Directive 5124.2, Under Secretary of Defense for 
Personnel and Readiness (P&R), (Oct. 31, 1994). 

[17] DOD Directive Number 4500.54, Official Temporary Duty Travel 
Abroad, November 21, 2003 and DOD Directive 4500.54-G, Foreign 
Clearance Guide, June 6, 2006. 

[18] GAO/AIMD-00-21.3.1. 

[19] See appendix II, table 7 for a list of the regions that constitute 
the Persian Gulf Area and the Kosovo area. 

[20] In addition, Congress has also stated that it was the sense of 
Congress that servicemembers receiving hostile fire pay or imminent 
danger pay should receive the same treatment under federal income tax 
laws as servicemembers serving in combat zones. See Pub. L. No. 106-65, 
§677 (1999) and Pub. L. No. 106-398, §1089 (2000). 

[21] Under Section 5928 of Title 5, U.S. Code and Department of State 
regulations, federal civilian employees serving in foreign areas may be 
eligible for a danger pay allowance when the Secretary of State 
determines that civil war, civil insurrection, terrorism, or wartime 
conditions threaten physical harm or imminent danger to the health or 
well-being of a majority of employees officially stationed or detailed 
to a post in foreign area. To qualify for the danger pay allowance, 
which is paid for those hours for which employees receive basic 
compensation and ranges from 15 to 35 percent of base salary each month 
depending on the level of danger specified for a given area and the 
presence of nonessential personnel and dependents at the post, a 
federal civilian employee must be assigned or on detail to a post for 
at least 4 cumulative hours in 1 day during a given month. 
Alternatively, federal civilian employees who accompany U.S. military 
forces designated by the Secretary of Defense as eligible for imminent 
danger pay receive $225 a month when authorized by the Secretary of 
State. Federal civilian employees may not receive both imminent danger 
pay and danger pay during the same month. Federal civilian employees 
are not eligible for combat zone tax relief benefits. 

[22] Pub. L. No. 98-94 §905 (1983). 

[23] Federal Managers' Financial Integrity Act of 1982, Pub. L. No. 97- 
255, §2 (1982). 

[24] GAO/AIMD-00-21.3.1. 

[25] National Defense Authorization Act for Fiscal Year 2006, Pub. L. 
No. 109-163, §636 (2006) (codified at 37 U.S.C. §310(c)). 

[26] These steps, from highest to lowest, are high, significant, 
moderate, and low. The categories reflect the existence of terrorist 
groups as well as their history, capability, and intent to harm 
servicemembers. 

[27] DOD Directive Number 4500.54, Official Temporary Duty Travel 
Abroad, November 21, 2003. 

[28] DOD 4500.54-G, DOD Foreign Clearance Guide. 

[29] GAO/AIMD-00-21.3.1. 

[30] Between fiscal years 2003 and 2005, individual servicemembers 
processed 23,253 vouchers for temporary duty travel to areas not 
designated for either imminent danger pay or combat zone tax relief 
benefits using the Defense Travel System. However, 170 of these trips 
that involved cross-month travel were dropped from our analysis due to 
incomplete data. As a result, in our analysis we used 23,083 vouchers 
for temporary duty travel to areas that were not designated for 
imminent danger pay or combat zone tax relief benefits. 

[31] Servicemembers may have other tax deductions and exclusions that 
reduce their taxable income. 

[32] Servicemembers may have other tax deductions and exclusions that 
reduce their otherwise taxable income. 

[33] 37 U.S.C. §310. 

[34] DODFMR, Vol. 9, Ch. 2, Section 020401(C) (April 2006). 

[35] DODD 4500.56, Section E.2.1.2 (Apr. 1999). 

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