Michael11

For several reasons, we are considering changing our travel policy for government contracts from a travel cost reimbursement method to a fixed per diem. We are opting to allot M&IE according to per diem and reimburse lodging at actual cost to our client. Can anyone share their experiences updating their travel policies as Ive described or any potential best practices? In addition to our written company policy, should anything else be updated? For existing/continuing government contracts, where our previous policy was submitted as part of the proposal, do we need consent or a modification to implement this change? We would no longer be submitting detailed receipts with the invoices (for meals but still lodging) but instead using the daily M&IE/lodging.

Navy, I'm afraid I will have to be the first to contradict you (somewhat) that someone who is paid $144,000 for 600 hours is not actually getting paid a "rate" which exceeds $200k because, for purposes of this clause, "rate" seems to be defined as the gross direct salary costs (excluding fringe, OH, G&A) incurred annually. At least that's what I'm going with today (and I think mrsbadexample is also on board). I think the disparity in the interpretation of this clause is proof it's poorly written and leads to unnecessary confusion.

I appreciate the additional info. It seems to me that maintaining compliance with this clause, as a contractor, would be a bit of a moving target. That is, if someone earning a salary which far exceeds the cap charges to several different accounts such as business development or PTO, they would have to be cognizant of how much direct salary has been actually charged to the contract. If we're in agreement that the scenario described above is allowable, I've seen this clause misinterpreted on both sides. COs think a contractor can only propose a salary up to the salary rate limitation (say 200k) when in fact this person may allocate substantial hours to indirect accounts thereby making their effective "direct" salary far less than their current salary may dictate. On the other hand, contractors have withheld billable salary costs far in advance of knowing whether the costs would actually exceed the limitation. Anyway, not trying to beat a dead horse here. If anyone has any objections to the above interpretations or different experience with this clause I would be interested in hearing it. Still curious in how others have worked around the part about not using contract funds to pay for the portion of a person's salary above the limitation. Seems like an awful lot of ambiguity for a clause which could have substantial implications under a services contract.

I found this old thread and, since it didn't seem any conclusions were previously reached, wanted to see if anyone has had any more experience or more clear guidance on this topic. I am wondering about the proper application of this clause on either FFP, T&M, or CR contracts and how folks have administered it internally or how it's been enforced by COs. For instance, staff that make $200k plus and still charge to contracts. I used to think this was fairly straightforward but now I'm not so sure. The guidance on the HHS site is clear as mud http://www.hhs.gov/asfr/ogapa/acquisition/salary-rate-limitation-qa.html As an example, what if someone makes, say, $500k per year. At the end of the year, this person charges 1,200 hours to OH, takes 600 hours of PTO, and another 600 of direct labor to a federal contract (roughly $144k). In this scenario, the portion of their (direct) salary paid with federal funds would be less than the Executive Salary Rate limitation. Also, how do you determine what portion of a person's salary was paid with federal funds in this scenario on a FFP contract?

That makes sense thanks for the quick reply

I've been researching the items required to process a mod to an existing gsa schedule price list. When requesting to add items to an approved SIN, for example ODCs or incidental items, does an entire new CSP need to be submitted? I want to avoid submitting an incomplete request but I'm unsure of the items beyond a detailed justificaiton, price quotes for the items, updated price list, etc. Does anyone have any experience with this?