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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!

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What type of contract is the prime contract and what type of contract is the subcontract, e.g., cost reimbursement, FFP, T&M? What does the subcontract say about payment of travel costs? Would it have been possible for the consultant to rebook to an earlier flight? Would rebooking incur a rebooking fee? If it would, would that fee exceed the late check-out fee?

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The Prime Contract type is Cost-Plus-Fixed-Fee Completion
The subcontract type is: Cost-Plus-Fixed-Fee Term
The contract says the following" Travel expenses such as lodging, per diem, fuel and others, as required during the performance of this Subcontract, will be reimbursed subject to the terms and conditions herein, and in accordance with Federal Travel Regulations and / or other regulations identified in the prime contract with its Client" and "The Subcontractor shall comply with the maximum lodging and per diem rates established by the Department of State and available at www.state.gov/m/a/als/prdm"

In the General Provisions is does qoute FAR article # 752.7002 TRAVEL AND TRANSPORTATION

Thank you!

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Seems to me the issue can be put thusly:

Assuming the original departure time made business sense at the time of booking, how much would it have cost to change the departure time once it was determined that 9 PM was no longer necessary? Was it even possible to book an earlier departure?

If it wasn't possible to book an earlier departure, then the employee would have stayed an extra night and paid for it. And it would have been allowable.

If it was possible, how much would it have cost. Compare that amount to the amount paid for the "late checkout fee." If the late checkout fee is smaller, then it's allowable as cost avoidance. If it is bigger, then the amount in excess of the change fee is unallowable.

Hope this helps.

What's my regulatory cite? I don't have one. Just common sense and experience.

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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!

A similar thing happened to me in Anchorage Alaska, as a gov't employee. I noted it in the remarks section on my travel voucher and the examiner at DFAS and my supervisor allowed it as reasonable. If the ultimate skinflints at DFAS allowed it for a gov't employee, it would seem to be reasonable and allowable for a contractor, too, if there is no hard and fast rule. Often, return flights only leave late at night. One has to stay somewhere in the meantime. A 1/2 room rate seems to be reasonable to me.

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Guest Vern Edwards

The JFTR expressly states that late checkout is a miscellaneous expense that will be reimbursed. I could find nothing similar in the FTR. I presume that one would have to show that the expense was reasonable.

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rose2010,

Here’s some info that may be helpful in establishing reasonableness and allowability.

You’ve mentioned that the subcontract incorporates the AIDAR clause at 752.7002 Travel and Transportation. This clause says determination of cost reasonableness for travel expenses will be made “based on the applicable cost principles, the Contractor’s established policies and procedures, USAID’s established policies and procedures for USAID direct-hire employees, and the particular needs of the project being implemented by this contract.”

You’ve stated that the consultant spent the morning of his day of departure supporting the project. If there was no earlier flight available after the work was complete, I doubt that anything in the applicable cost principles would prohibit payment for a day room, and the timing of the departure sounds like it was based on project needs. That covers the first and fourth criteria above.

You’ve stated that payment for the day room is consistent with the subcontractor’s established policies and procedures, so that covers the second criterion.

On the third criterion, 14 FAM 574 (http://www.state.gov/documents/organization/88661.pdf) discusses when per diem is payable for USAID direct-hire employees:

14 FAM 574.4 Awaiting Transportation

(CT:LOG-72; 06-08-2010)

(Uniform State/BBG/USAID/Commerce/Agriculture)

Per diem is allowed only for such periods awaiting onward transportation as are reasonably necessary under the circumstances. The travel voucher should contain an explanation of the circumstances necessitating any waiting period in excess of 12 hours at transfer points in the United States and 24 hours at transfer points abroad. Not more than 5 days per diem will be paid while awaiting ship transportation.

In this case, if there was no earlier flight available, then it would seem “reasonably necessary” to incur the per diem costs, so they should be allowable.

The only caveat is that under 14 FAM 573 all per diem calculations are based on calendar days, and the daily maximum lodging amount applies; 14 FAM 563.1 specifies that the cost of a day room is considered part of the lodging portion of per diem and cannot be reimbursed outside it. So if a traveler who used a day room before his departure (say, on a Friday afternoon) happened to need additional lodging during a stopover on his way home (Friday night), the reimbursements for the day room plus the night room on the same calendar day could not exceed the maximum lodging amount.

In this case, since the consultant’s flight left at 9 PM, I assume he spent the night on the plane and didn’t need another hotel that night. If that’s true, then the above shouldn’t be an issue.

Hope that helps.

ktr1999

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