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If a contract is CAS-covered, is it in accordance with CAS 401 for a defense contractor to propose the maximum per diem rate for hotel (which is estimated to be 50-75% more than expected actual cost) when the defense contractor will only bill/voucher the DoD for actual cost? Assume that there is a current proposal for a contract modification over TINA for a cost-reimbursement CLIN. Also, assume that the defense contractor's disclosure statement and travel policies both say lodging cost will be reimbursed at the lower of actual cost or per diem. Is there any materiality threshold applicable to CAS 401 besides "significant cost" and "reasonable"? It looks like proposing lodging at the maximum per diem rate simply inflates the NTE ceiling. If the cost reimbursable CLIN is only for travel, there seems to be a low risk of the defense contractor billing the DoD for "unnecessary" costs to cover its fixed expenses.
I was wondering if a late checkout from a hotel is an allowable cost. We are a prime to USAID and one of our Subcontractors hired and sent a consultant to the field The consultant supported project activities in the morning, which were completed by noon. However, the flight that was booked for him did not leave from until 9:00 PM on, leaving him 8 hours to wait before needing to leave for the airport. As such, the consultant stayed in his hotel room and he was charged for half a day extra (as a late checkout fee) The subcontract claims that it’s in their policy to allow a day room or late check-out in circumstances where a consultant has more than 8 hours of wait time because of circumstances beyond his/her control. I have checked the FAR/FTR and AIDAR but see no reference to this cost being allowable or reasonable. Any thoughts? Thank you in advance!