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RhodesDavis

Purchasing GSA Schedule Item and Travel on GPC

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We have an "item" on our GSA IT-70 schedule for a government-site training class. It has a part number, description (syllabus), and duration (1 week). It also specifies that travel is not included. The cost for the class is about $12k. Additionally, there will be travel expenses (hotel, airfare...) separate from the GSA item. Here is the challenge:

1. Fed customers want to pay with GPC; however, some do not want to see the GSA item and travel costs itemized but want a single total with the training class descriptor.This would show our GSA product billed at a higher amount (not acceptable). The travel is not incurred by a government employee (thus requiring the Gov travel card) but is an actual cost reimbursement for contractor travel to facilitate the training (ancillary). Although the gov can't pay for federal employee travel on GPC, can they pay contractor travel costs itemized on an invoice along with the GSA line item for training?

2. A general question on this: can the government purchase the training before it takes place and pay for the travel after the fact. I've seen where, under the tuition exception to advanced payments, that this could be deemed acceptable but I'm not sure.

I would appreciate any insights!

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RhodesDavis,

Procedures for authorizing and paying for training under $25,000 vary by agency, but my guess is that your Fed customers already gave you their final answer to questions #1.and #2.   To follow up you could ask your customer if they checked with their organization's A/OPC. My view is limited, but in my A/OPC experience I have not had seen any way to allow what you want; either for an invoice to show a separate itemized travel cost or to be split into two invoices, one of which is paid in advance and the other after the fact. I could readily understand an agency allowing advance pay of training and not being bothered by such a charge that included all costs in one line, but I do not know anywhere to hang my hat that would allow a separate itemized charge for reimbursement of contractor travel on a GPC purchase. In my view, GPC is not meant to be  a cost reimbursement mechanism.

In the alternative, what prevents you from giving your customers an open market quote (outside of the GSA Schedule) with the one line item they desire? It may be that the agency's SF 182 training authorization procedures and GPC rules allow an advance purchase of Commercial Off the Shelf Training (COTS) on the open market (non-GSA). That would not give you the safety of billing travel after the fact, but it would keep your customers within their program's guardrails. 

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You can solve the entire problem by issuing a single task order to the contractor and paying for both CLINs through the task order.  

Or, as suggested by far-flung, ask the GSA contractor to give you a FFP per-student quotation that includes all costs.  

Or, better yet, let your agency training officials purchase and pay for the training with the SF-182.  

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Excellent ideas. Thank you for the insight. I am going to investigate the options both of you have suggested that I had not considered before.

BTW: I used "ancillary" incorrectly when referring to the travel expenses. Should have been ODC travel reimbursement.

Many thanks!
Rhodes

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As a follow up, since the forum archives are a great source of acquisition information:

In a GSA Interact answer to the question, "How do I add travel costs to a services task order?"  the terms and conditions below were cited after noting that costs should not be "cost-reimbursement" but a "direct reimbursable"  as described in the T&C. There was also discussion of adding a FFP CLIN or NTE CLIN (as ji20874 suggested).  Both the article and T&C explicitly note that travel should not be included in the offered price but priced separately.

From SCP-FSS-002

(9) Travel will be handled in accordance with clause C-FSS-370. Costs for transportation, lodging, meals and incidental expenses incurred by the contractor are allowable subject to the limitations contained in the Federal Travel Regulations and/or Joint Travel Regulations. They should not be included in the offered prices and will be considered at the task order level.

From C-FSS-370

(b) Travel: The Contractor may be required to travel in performance of orders issued under this contract. Allowable travel and per diem charges are governed by Pub .L. 99-234 and FAR Part 31, and are reimbursable by the ordering agency or can be priced as a fixed price item on orders placed under the Multiple Award Schedule. Travel in performance of a task order will only be reimbursable to the extent authorized by the ordering agency. The Industrial Funding Fee does NOT apply to travel and per diem charges.

Article link: https://interact.gsa.gov/blog/how-do-i-add-travel-costs-services-task-order

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