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01182011 Navigating the Travel Cost Principle
 

01182011 Navigating the Travel Cost Principle

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  • Again, reasonable means less than JTR or FTR so just stick with JTR and FTR
  • Again, it says it doesn’t have to follow FTR or JTR but it does have to be reasonable which means it can’t be more so save yourself the headache and just calculate it off the FTR or JTR.
  • See 75% rule- travel is more than 12 hrs but less than or equal to 24 hours – generally first and last day of travelalso take a look at JTR FAQ’s regarding stopovers etc. See TAB 1M&IE – Meals and Incidental Expenses
  • Continental United States or Outside of Continental United States (Also 48 Contiguous States)
  • Effective January 2010 – general theme was that the lowest airfare available to the public might not be the lowest airfare available to the contractor due to rate negotiations or discounts they might have.
  • See Tab 2
  • Exceptions are things like:Accommodations requiring circuitous routing, travel during unreasonable hours, excessively prolonged travel, physical or health restrictions, or would not meet the mission requirements.
  • Availability – contractor is informed 2/1 that the gov’t needs them in San Diego on 3/1. The contractor books a flight on 2/15. Which of the dates is used to measure lowest available?Bottom line, protect yourself and attempt compliance through consistency and well defined policies and procedures.Also, where are you storing this documentation? Are you making your employees and consultants submit a second quote with their expense report or invoice and you are storing it with the actual receipt of the airfare that was purchased?
  • Bullet three, that’s the documentation we talked about in the prior slide that mirrors IRC section 274Last bullet – you’ll need to update your accounting policies and procedures to provide for how unallowable travel costs are accounted for, where you put unallowable costs if reimbursed or if you don’t reimburse over per diem etc.
  • And for those of you who said George Bush didn’t accomplish anything, I give you…
  • George Bush
  • See Tab 3
  • See Tab 4 See sample pulled from contract, Mileage 2.0Rental Cars / Policies and Procecures 5.0Special Meal Allowance 8.0System Requirements 16.0 – talk about how Jason is going to go through thisOverall – a lot of monitoring for contract complianceSee Tab 5Pull GSA Sample Contract – note that IFF is generally not applied to ODC’s as they are not schedule line items (unless they are)
  • Check out the information for contractors – has good information on preaward surveys, determining CAS coverage (flowchart), list of acronyms, in a little plainer english
  • So this is imaging, I’ve not seen an auditor knock electronic receipts when they were submitted that way originally. I feel a lot of this goes to the controls around transference of receipts from their original paper form over to an imaging system at year end. However, you should still have a procedure in place that hits all three points even if you are using electronic receipts. Making sure they are readable, indexed, etc. In addition provide for that reliable and secure retention period. If you are using a hosted site. What is your procedure if you ever leave for record retention?
  • Documentation standards are very similar to IRC Sect 274
  • See IRC Sect 274 Expense substantiation
  • So basically, you can do an estimate of what you think it will cost and pay the individual based on that lump sum rather than making them keep track of receipts and per diem’s etc.
  • Nothing concrete in writing.The old rule of thumb is to bill as you bid and bid as you bill. If a reduced G&A was bid, a reduced G&A you shall bill.
  • However, DCAA’s definition of materiality these days seems to be anything over 0.We know of one thus far (policies and procedures – segregating unallowable travel costs weren’t defined (mgr review, accounting dept review, spot audits, etc.)

01182011 Navigating the Travel Cost Principle 01182011 Navigating the Travel Cost Principle Presentation Transcript