[Claims for Reimbursement of Relocation Expenses Incurred Incident to Merit Promotion Transfers]

The National Park Service questioned the entitlement of two employees to relocation expenses. The employees, who had recently transferred to new duty stations, applied for and accepted merit promotion transfers within 1 year of the original transfers. However, the National Park Service has an agency policy not to approve more than one transfer for an employee at Government expense within a year unless the Director approves an exception. GAO has held, in prior decisions, that an employee is entitled to relocation expenses incurred in changing duty stations if the transfer is in the best interest of the Government rather than primarily for the convenience or benefit of the employee. Since an employee transfer pursuant to a merit promotion program is considered an action taken in the interest of the Government, the employee is entitled to reimbursement of relocation costs. In the present case, GAO found that: (1) there was no indication that the agency policy on transfers was clearly communicated in advance and in writing to all applicants; and (2) the agency selected the two employees without seeking prior approval of the Director, thus violating its own internal procedures. Accordingly, the employees were entitled to reimbursement for their claimed relocation expenses.