The material covered in sections 2d (rental cars) and 3a (Electronic Travel Systems) is fascinating in both how the government divides responsibility for administering travel and how modern technology has enabled the travel process to become more automated. It is interesting that the responsibility for rental vehicles comes under the Department of Defense rather than either the General Services Administration or even the Department of State. The reason for this may stem from DoD having the largest requirement of mobilizing individuals over land than either the GSA or DOS. Of further interest are the similarities and differences between government employees and contractors. Regarding car rentals, the Defense Travel Management Office’s Joint Travel Regulations indicate that volume 2 is applicable to civilian government employees and certain others. The JTR specifically indicates that the JTR are not applicable to government contractors (JTR C1000(b)(4)). The FAR is consistent with the JTR as far as car rentals (FAR 31.205-46(d)): “Costs of contractor-owned or -leased automobiles, as used in this paragraph, include the costs of lease, operation (including personnel), maintenance, depreciation, insurance, etc. These costs are allowable, if reasonable, to the extent that the automobiles are used for company business.” The reasonableness of auto rentals is a subjective judgment that will be hammered out directly in the contract or negotiated with the Contract Officer. No doubt the DTMO and JTR may be looked to as a source for guidance since the FAR points to the JTR as the rule for government contractor per diem expenses (FAR 31.205-46(a)(2)(ii)). The car rental rates would be probably lowest possible rate available to the government contractor to accomplish the mission as JTR C3330(C)(1) guides government employees to do. No doubt government contractor rates will be higher as the DTMO negotiates specific rates with car rental companies themselves. Although the cost may be lower, it is probably not as startling a difference as one may think since car rental companies charge Government Administrative Rate Supplement (GARS) fees to the government specifically to cover the cost of doing business with the government (see U.S. Government Rental Car Agreement 4, article 4). What the specific cost of doing business with the government is, we are not told. Most likely the car companies have to recoup losses in dealing with extra government paperwork or truly cannot offer autos at the price the government prefers and so tack on the GARS as a way of being able to offer the low rates and remain in business. Whatever the rate difference, and although administered by DTMO, the government car rental rates are available to all federal agencies through the automation of the ETS/DTS systems. These systems have automated compliance and saved countless hours of government employees attempting to navigate complex rules and regulations surrounding travel.
By Olivia Tautkus