Tuesday, May 30, 2017

Travel Cost Principle Too Difficult to Implement - Here's Your Chance to Propose Changes

Back in February, the President signed an Executive Order (EO) entitled "Enforcing Regulatory Reform Agenda" which established a policy to alleviate unnecessary regulatory burdens on the American people. Included in that EO was a requirement for Federal agencies to establish Regulatory Reform Tax Forces to, among other things, evaluate existing regulations and make recommendations to the agency head regarding their repeal, replacement, or modification.

In this regard, agencies are to identify regulations that

  • eliminate jobs, or inhibit job creation
  • are outdated, unnecessary, or ineffective
  • impose costs that exceed benefits
  • create a serious inconsistency or otherwise interfere with regulatory reform initiatives and policies
  • rely on data, information, or methods that are not publicly available
  • derive from or implement EOs or other presidential directives that have been subsequently rescinded or substantially modified.
GSA (General Services Administration) is the first (that we're aware of) to take a swipe at complying with this EO and they are taking on a big project - the Federal Travel Regulations (FTRs). Now the FTRs apply primarily to Federal civilian and military employees. However sections of the FTRs have been incorporated into the Federal Acquisition Regulations (FAR). Those sections include:
  1. maximum per diem rates
  2. the definitions of lodging, meals, and incidental expenses, and
  3. the regulatory coverage dealing with special or unusual situations.
Throughout our experiences, we have noted that many Government contractors have found it burdensome to implement these regulations, particularly the maximum per diem rates. Its not that the concept is problematic but it adds extra steps to the travel reimbursement process. Often, small companies (and sole proprietors in particular) do not collect their travel costs on a voucher or expense form. Air fare gets charged to one account, car rental to another, hotel fees to a third, meals to even another. When it comes time to assemble, say, an annual incurred cost proposal, those contractors find it burdensome to collect and ensure that the sum does not exceed the maximum per diem rates listed in the FTRs. Often times, those business people spend a lot more than the maximum per diem rates, unaware that there are ceilings. Of course, there's the special or unusual situation exemption that allows for higher than maximum per diem but those exceptions must be approved in advance of the travel (usually).

The GSA is giving Government contractors a chance to weigh in on these regulations. Perhaps the implementation costs exceed the benefits. Perhaps some contractors will have data to show just that.

If you want to provide input to this project, follow the instructions published today in the Federal Register.

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