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Found 2 results

  1. My company has a time and materials contract for which we are a first tier subcontractor. The prime contract is not a FAR 12 procurement. The prime contractor wanted to include a requirement in the contract that travel would be subject to the Joint Travel Regulations (JTR). My company pushed back. We are a subcontractor supplying commercial products and services under the T & M contract. The prime tells us that their contract requires that their travel doesn't exceed the JTR. However, it's my understanding that the JTR is only for military personnel. I suggested to my team that we agree to a clause that commits us to compliance with 31.205-46 which I interpret as requiring that we will use the govt regulations as guidelines but ultimately adhere to our company's internal travel policy which follows the Federal Travel Regulations (FTR) guidelines and requires a Travel Exception Approval be submitted for any thing in excess of those per diem rates. My co-worker doesn't interpret 31.205-46 in the same manner and in fact insists that we should have requested 52.212-4 alt 1. I don't believe 52.212-4 to be appropriate as the prime contract is a FAR 15 procurement. I'm now doubting if we should even mention 31.205-46 since we offer commercial supplies and services, saying only that we would adhere to our company's travel guidelines.
  2. I'm wondering how other contracting offices are looking at the matter of conference travel. Many agencies have restrictions on and high approval levels for "conference" travel. What is your office's position? Is a pre-bid conference (FAR 14.207), pre-solicitation or pre-proposal conference (FAR 15.201( c )( 8 )), or industry or small business conference (FAR 15.201( c )( 1 )) a conference under your agency's restrictions on "conference" travel? Or do you see these as mission travel? I am aware of the FTR definition of conference, but that would make essentially EVERY trip a conference.
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