Some employees have reported that their supervisor or timekeeper asked them to completed an FDA Form 211 to document their request for Compensatory Time for Travel (CTT). This is not the case. FDA Form 211 is not used to request CTT. Melanie Bourcier, the lead ORA timekeeper, says, “It appears that Comp time (COMP) was confused with Comp Time for Travel (CTT), which have two entirely different rules both in earning and documenting.”
CTT is governed by Title 5 of the Code of Federal Regulations (CFR) Part 500, Subsection N, a regulation promulgated by the Office of Personnel Management (OPM). The preamble of this regulation, which contains excellent guidance to best understand OPM’s rationale when creating these rules, appears in Volume 72 of the Federal Register, starting on page 19093. This guidance will help you calculate your CTT estimate and actual CTT used.
In simple terms, if you travel outside of paid status (normal work hours or paid holidays), you are entitled to earn CTT in quarter-hour increments (with some caveats). You must subtract normal commuting time to your post of duty, if applicable (e.g., when traveling from your residence to your local airport), but you do not subtract the time spent on meals. I recommend you read the preamble for more details. You should also read Article 22, Sections 10A – 10E, of the HHS-NTEU Consolidated Collective Bargaining Agreement (CBA) for additional important information about CTT.
I have also received reports of supervisors and timekeepers asking employees that they use a worksheet “form” to submit their estimate and actual CTT earned. To date, the Agency has not notified the Union a proposed change in working conditions that requires the use of a worksheet or form to estimate, request, or report CTT, or provided the Union with opportunity to bargain over such change as required by federal labor law and Article 3 of the CBA. When NTEU asked the Agency about these forms, Agency labor relations officials responded that such worksheets and forms are optional for bargaining unit employees. NTEU is concerned that such worksheets have not been validated to ensure accuracy and reliability.
So, how do you document your request for CTT? You can simply do so with an email to your supervisor with your estimate CTT. Similarly, you can report the actual CTT used in an email to your supervisor with supporting documentation, and provide both these emails to your timekeeper for his/her timekeeping records.
I welcome your input on this subject.