Thursday, February 3, 2011

Extended Travel

Most contractors are well aware of the FAR limitations on lodging and meal reimbursements paid to employees while in travel status (see FAR 31.205-46). These limits are variable based on location and season. They can be exceeded under limited circumstances and must be reduced for first and last day of travel.

Extended travel however gets a little tricky. There are no specific FAR requirements to guide us here – just the overarching “reasonableness” criteria (see FAR 31.201-3). While FAR makes it clear that contractors do not need to follow the JTRs (Joint Travel Regulations) beyond the maximum lodging and MI&E (meals and incidental expenses) rates and the definition of MI&E, those regulations can still be useful in helping contractors develop reasonable policies and procedures to cover long term travel. 

Under the JTR, long-term travel for more than 180 days is reimbursed for lodging and M&IE at 55% of the applicable standard lodging and M&IE rate, rounded to the nearest dollar (JTR C4552-1). The actual daily lodging rate is computed by dividing the total lodging cost by the number of days of occupancy in the rental period. Expenses of lodging include the rental cost for a furnished dwelling, or if unfurnished, the cost of appropriate and necessary furniture and appliances, utility connect/disconnect cost, cost of reasonable maid fees and cleaning services, monthly telephone fees, cable TV, etc.

Although not bound by this particular section of the JTR, contractors that do not adjust their reimbursement rates for long-term TDY, risk a “reasonableness” challenge by the government auditors.

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