Certified Government Travel Professional » DOD http://cgtp.net Fri, 06 Feb 2015 11:16:13 +0000 en-US hourly 1 http://wordpress.org/?v=3.9.3 The Importance of Understanding the Master Contract http://cgtp.net/the-importance-of-understanding-the-master-contract/ http://cgtp.net/the-importance-of-understanding-the-master-contract/#comments Sun, 30 Nov 2014 12:16:21 +0000 http://cgtp.net/main/?p=921 Civilian agencies have placed task orders under the GSA Schedule for their TMCs but, in my experience,  they may often lack an understanding of exactly what is covered in the TMC Master Contract.  This puts agencies at a severe disadvantage when questions do arise since the an agency’s acquisition personnel usually have no familiarity with government travel issues.

It has been my experience that acquisition personnel are also not familiar with the details of the Master Contract when they place the Task Order for the agency.  The Task Order is not a complete contract and it does not have many of the specifics that are in the Master Contract.  And of course, the travel teams at various agencies are most familiar only with their own negotiated Task Order  This leads to unnecessary confusion and even botched negotiations when dealing with exactly what is covered by the Master Contract.

A case in point, a few years ago our travel agency was bought by another TMC vendor,  After introductions they informed us that we would soon owe them an additional fee for segments because the GDS had enacted new fees after an interim law forbidding such increases had recently lapsed.  Now the TMC had known for several years that their GDS fees would increase and would have to be passed on to the civilian agencies, but they were presenting this to us as a “new” fee.  Our Contracting Officer was inclined to agree to the fee under the Task Order, since the TMC said that DOD had agreed to pay the fee without any protests and “other agencies” were also going to be agreeing.  I challenged the fee on the grounds that it should’ve been known prior to the vendor when they were doing their pricing proposal on the GSA Master contract.  The other issue was that we had nothing from GSA indicating that it had ever been approved for reimbursement and it should’ve been handled at the Master Contract level since it would affect every civilian agency.  There was resistance to this view by the new owner of our travel agency vendor, but in the end they left without us approving the new fee.  GSA eventually amended the Master Contract to include the fee at a later date, I believe, but it was not implemented at the Task Order level.  DOD had an entirely different Master Contract and the “new” fee had actually been negotiated in advance on their contract.

Anyone can obtain permission to read the GSA Master Contract/RFP online by requesting permission from the GSA travel acquisition office.  I strongly recommend that Government travel managers do so, or at the very least, sit down with their Contracting Officer and review it online with them to make sure that both parties have a good understanding of both the contracting and technical details.  This was only one example of a problem, and there will not doubt be many more in the course of these contracts.

by Julie Speers

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Travel Industry History http://cgtp.net/travel-industry-history/ http://cgtp.net/travel-industry-history/#comments Sat, 08 Nov 2014 14:16:09 +0000 http://cgtp.net/main/?p=1036 In 1948 the Department of Defense had a need to transport Military passengers and cargo more rapidly than by the railroad. The air industry had a desire to become a part of this industry but almost all military passengers traveled by railroad and the railroads enjoyed a preferential passenger traffic arrangement with the government.

Although the commercial airlines provided major support to the government during World War II, following the war they were generally used as a last resort for emergency movement of traffic or when a senior officer insisted on using air rather than surface transportation.

Airlines were struggling in their attempts to gain entry into this market and made significant headway in 1940. Most of the airlines serving Washington DC created and funded an entity called Combined Airlines Tickets Offices (CATO) to provide service to government accounts.

The CATO offices were also formed in other cities to service specific government markets. These programs were never part of the industry program that would eventually become Joint Airline Military Traffic Offices (JAMTO) 13 years later. On November 4, 1948, frustrated air industry decision makers concluded that getting into the military and government market was an industry problem.

They authorized M.F. Redfern, Vice President of Traffic and Executive Secretary of the Air Traffic Conference to negotiate with the military agencies on their behalf. As a result of these negotiations on April 20, 1949 the ATC Military Bureau, forerunner of the SatoTravel Troop Movement Section, today the oldest branch of Satotravel, came into existence. By January 1951, Joint Military Air Transportation Offices represented 31 airline carriers.

With ATC releasing a draft of the first Military Representation Resolution the way was paved for the establishment of joint airline offices on Military installations. The first Military bases to have JAMTO’s Offices were at Lackland AFB, Great Lakes Naval Base, and San Francisco-Oakland.

As a result of the Transportation offices opening on the military basis SATO Scheduled Airline Traffic Offices travel became a name that just about every Military person recognized as the travel office for the Military. This is just a small portion of the SATO history from 1940-1990, from the beginning to the early years of incorporation.

I have been employed with Satotravel for 15 years and the history for the company which originally was wholly owned by the air carrier is steeped in tradition. The “can do” attitudes, devotion, high standards and professionalism displayed by the air carrier employees and the guiding principles of the program have carried over to today’s CWT/Satotravel, and they continue to be evident in our work force.

Having worked in a Full service travel office, I have been a part of the Implementation of several government accounts, but it was exciting to learn the GSA Travel Services Solutions portion of contracting. I have worked with both the GSA TSS and full and open competition contracts that are conducted by a government entity and find them both a challenge. They are both handled basically the same except with the TSS contract the rates have already been set so that the rate isn’t as much as a factor.

You can always negotiate less than the rate posted in order to secure the business if necessary. The subcontracting plans that the large businesses are required to provide contracts to small companies makes it possible for small and minority companies to get a piece of the pie.

If this wasn’t part of the GSA service the smaller companies would become non existent and the larger TMC’s would have a monopoly on the money we pay to run our government. I know in our company there have been several times when business was awarded to a small business because of the 23% minimum small business participation goal requirement.

I was fascinated to learned that 90% of travel agencies are small businesses in communities throughout our country which was very surprising to me. In the previous chapters when I learned how the Hotel reporting worked and reported to ARC the reservations made, I wondered how they could possibly have accurate accounting of rooms and hotels that were booked for travel. Working with groups you have better control of the number of rooms blocked, but transient usage would be almost impossible to capture.

Even with groups, I have had scenarios where some of the groups who work with our homeland security may contract to go into a hotel 2 weeks from now and 2 days prior to arrival the group is cut in half or the group cancels completely because their security expertise is needed in another city. Since we move groups into very obscure locations in Alaska, the weather plays a big part on whether the traveler arrives at his destination as planned or is stranded and we have to book a hotel where they become stranded. I don’t think there will ever be a system to capture all the hotels booked and the length of stay.

One good tool that can be used is if the group has a credit card that will capture the hotel property number into a separate data base. This still would not give you an accurate number of nights used because the rate charged to the Individuals credit card may include taxes and other state/hotel charges. It would also be very difficult to capture information from some the Bed and breakfast properties that we have used in remote locations because the charge may be connected to a restaurant and not the actual property that the Government employee stayed in.

I realize that the government can’t use the Non traditional travel agencies such as Expedia, Travelocity and Orbits but what a blessing they are to the hotel, car, air and cruise companies. The fact that they are able to sell rooms that the hotels have determined would be unoccupied at a very cheap rate puts heads in beds and will keep the rooms from being empty.

I myself have used their services to book travel to a quick weekend vacation by looking to see what was really cheap at the last minute and heading to the airport to take a vacation at a preferred location at rates that are cheaper than the travel agent rate. I have had co-workers who book their cruises 2 weeks prior to the cruise and they get a suite with a balcony at rates that would normally place them in the bottom of the ship in an inside room. I say hooray for these companies that are selling the distressed inventory and helping to keep the hotels, air and car rental companies profitable. The Certified Government Travel Professional Training Course has been a lot of information that I will use it in planning and assisting my Government groups.

I have a better understanding of how the Airlines, Hotels, Rental cars, Electronic Travel systems and Payment systems work. I especially found the section on the US Government Ethics Standards of interest and have printed all the reference materials and read it and I know I this information will help me in guiding my clients to make informed decisions. I also understand what their limitations and abilities are.

I think the program is very informative and gives you tons of web sites and referrals to sites to assist you in making informed decisions for your government accounts.

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Procurement and Management, the Federal Travel Disconnect http://cgtp.net/procurement-and-management-the-federal-travel-disconnect/ http://cgtp.net/procurement-and-management-the-federal-travel-disconnect/#comments Fri, 07 Nov 2014 06:17:03 +0000 http://cgtp.net/main/?p=934 When considering travel programs, program management and procurement are both essential.  Once travel is procured, the role of the program manager is to focus on getting the maximum value from any and all negotiated agreements through careful follow up, tracking, and compliance monitoring. In turn, suppliers are more inclined to offer better deals if they believe the corporate client closely tracks usage, trains travelers, and communicates policy in ways that lead to significantly higher compliance levels.  It is the combination of procurement and program management that leads to effective overall travel programs.  In this paper I explore and assess the federal government’s approach to procurement and program management, and offer recommendations to solidify that dynamic.  Let us first look at the corporate market.

 

Corporate Procurement

The basis of most corporate travel negotiations is a trade-off between incremental market share to the supplier and discounted pricing to the corporation.  When negotiating contracts, corporations must be able to demonstrate their ability to shift market share to a given supplier.

 

Corporate Program Management

This ability to shift market share depends upon proactive monitoring and management of travel programs.  Key areas that suppliers look to for evidence of effective program management include:

  • Supplier management – ensuring suppliers abide by contract requirements and assist the corporation in promoting use of the preferred program.
  • Demand management – compelling travelers to use the preferred programs via established tools, policies and processes.
  • Consolidated Data – Consolidated company-wide travel data, which includes booked data, credit card data, travel agency data, and supplier data as appropriate.
  • Performance Monitoring – Best practice is to establish centralized management of travel programs either by an individual (typically a Corporate Travel Manager) or by a team (Travel Council).  This team communicates the program, trains travelers, and writes policy.  In addition, they determine Key Performance Indicators (KPI) to monitor program usage, establish corrective action plans and drive continuous improvement.
  • Policy – The Travel Council sets and enforces travel policy.

 

I depict high-level corporate travel program components in the following diagram.

 

 

Federal Procurement

Now let us review travel in the federal market.  Although the government is not able to provide suppliers with the level of travel data put forth by most corporations, the government is proactive in procuring travel.  The government has preferred programs for all major areas of travel including airfare (CPP), lodging (FedRooms) and car rental (Rental Car Program).  Although rates are not negotiated in the truest sense (an exchange of volume for price discounts), rates are pre-determined and auditable.

 

Federal Program Management

The government has worked diligently in the recent past to establish and implement comprehensive travel programs.  It is helpful to review government travel with respect to the same categories provided in the corporate market above.  An assessment of the current state of government travel shows:

  • Supplier management – GSA conducts audits of the GDS to ensure suppliers are correctly loading negotiated rates.  In addition, GSA staff regularly meet with suppliers to discuss future program enhancements.
  • Demand management – Most Federal Agencies have installed and implemented one of three E-Gov Travel Systems.  These systems provide federal agencies the tool and structure needed to guide travelers towards use of preferred travel programs.
  • Consolidated Data – Currently the government is unable to consolidate government-wide travel data.  However, GSA has a contract in place to compile data through implementation of the Business Travel Intelligence system, and meaningful results are expected in the near future.
  • Performance Monitoring – By current design, there is no centralized body within the Federal government that is responsible for monitoring performance or any overall travel program management.  While GSA serves as a central body for procuring travel, performance to policy and compliance to preferred programs are left to individual federal agencies.  In practice, individual agencies do little to ensure usage of preferred travel programs.  This shortcoming breaks the continuum of procurement and program management.  Because future negotiations are heavily dependent upon historical program usage, this lack of proactive oversight significantly reduces the government’s ability to leverage their travel volume.
  • Policy – GSA and DoD establish and set travel policy via the Federal Travel Regulations (FTR) and Joint Travel Regulations (JTR) respectively.  In addition Standardized Regulations (DSSR) are issued by the Department of State for foreign travel.

I show the same travel components within the context of government travel in the following diagram.  As shown here, because the government does not proactively monitor program performance, the ability to leverage travel volume in future procurements is limited.

 

Summary

The federal government has taken great strides in developing a comprehensive travel program.  The government has workable solutions in place for supplier management, demand management, and travel policy.  Although consolidated government-wide travel data is not currently available, GSA does have a contract in place to provide it.  The biggest remaining challenge is centralized management of government-wide travel programs.  While a centralized approach to travel management would require that federal agencies turn over a small amount of control to a central body, the benefits of cost savings and higher traveler satisfaction would far outweigh this perceived loss of control.

 

Recommendation

I recommend that the federal government establish a government-wide travel program management office within GSA for the specific purpose of managing (monitoring performance, enforcing compliance, revising policy, etc) travel programs across the federal government.  Giving GSA the authority to proactively manage travel on behalf of all federal agencies would mimic corporate best practices in that it would align procurement with program management functions.  Without a centralized body managing government travel, the federal government will never be able to effectively leverage their $15+ Billion in annual travel spend.

by Ted Schuerman

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FTR Workshop http://cgtp.net/ftr-workshop/ http://cgtp.net/ftr-workshop/#comments Sun, 10 Aug 2014 12:19:35 +0000 http://cgtp.net/main/?p=999 In January of this year I had the privileged opportunity to attend a FTR Workshop, which was hosted by the General Services Administration (GSA) and the Department of Defense (DOD). GSA & DOD collaboratively enlisted the help of an outside contractor to assist with the task of researching the feasibility of creating a streamlined and updated Federal Travel Regulation draft. Any new draft of the FTR would need to be approved by various high-level government entities, including OMB, and the US Congress on Capitol Hill.

During the FTR workshop, the brainstorming sessions became very interesting, as we discussed various possible directions we could take with regards to the FTR. One of the options mentioned (and the most favorable) was to eliminate a lot of the ‘grey’ areas and make statements more clear and decisive for the reader. A second option was to actually clarify some of the grey areas and to potentially add additional direction, thus ultimately adding more ‘grey’ areas. A third option which was brought up and discussed, with much concern I might add, was to amend the FTR completely, allowing for a ‘pay up front’ system whereby Federal Travelers would simply enter their travel information into a system which would automatically generate/create a direct deposit, depositing travel funds into the travelers’ account prior to them traveling (approximately a day or two before traveling). Obviously this option raised many flags with a great deal of folks within the workshop, including myself.

Three of the big issues with the last ‘pay up front’ option, among many, were; one, lack of control and reporting mechanisms due to no obligations/authorizations, or pre approvals being in place within the financial systems. Two, the concern of travelers spending the funds prior to travel, then possibly having to call their management to have more funds deposited or wired to them while on travel. Thirdly, the possibility of travelers ‘pitching a tent’ or staying in their cars while on travel to save their reimbursements (I’m being a bit sarcastic here, but you get the point).

I am not a supporter of the third ‘pay up front’ option. However, for this writing, I wanted to highlight it and convey that it really forced me to ‘think outside the box’. One big advantage to this ‘far fetched’ system would possibly be a substantial cost savings to the government (by reducing staffing/overhead). However on the flipside, I feel the disadvantages would clearly outweigh the advantages. For one, there would be a complete lack of control, management, and reporting mechanisms in place. Another would be that it would possibly end up creating a system that would be more open and conducive to shady and corrupt practices within what is currently an overall well managed Federal travel program.

by Brian Shears

The contents of this message are mine personally and do not reflect any position of the Government or my agency.

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Travel Professional Resources & Best Government Travel Web Sites http://cgtp.net/travel-professional-resources-best-government-travel-web-sites/ http://cgtp.net/travel-professional-resources-best-government-travel-web-sites/#comments Sat, 24 May 2014 10:15:23 +0000 http://cgtp.net/main/?p=816 Web access becomes almost universal, and travel one of the most common types of e-commerce, more and more federal employees are turning to computers to help them plan trips, check regulations, and more.

GENERAL FEDERAL TRAVEL

http://pub.fss.gsa.gov/services/citypairs/citypairs-mid.html

The mother lode of information on the government’s low negotiated airline fares, including schedules, fares and more.

http://nasdac.faa.gov/internet/fw_search.htm

A Federal Aviation Administration page devoted to aviation safety data. From here you can search the National Transportation Safety Board Aviation Accident/Incident Database; the FAA Incident Data System; the Near Midair Collisions System database; NTSB Safety Recommendations to the FAA with FAA responses; and the Bureau of Transportation Statistics Airline Traffic Statistics database.

http://policyworks.gov/org/main/mt/homepage/mtt/mtthp.htm

The General Services Administration’s travel site–a jumping-off point for your search for most civilian travel information. Authored by the Office of Transportation and Personal Property, it includes information on per diem rates, the Federal Travel Regulations, state tax exemption policies and many other topics. A search engine allows you to search the regulations.

http://pub.fss.gsa.gov/fm/future

Everything you’ve ever wanted to know about the government’s travel and fleet card contracts. Includes the Task Order Guide for GSA’s Fleet, Travel and Purchase cards, which can help if you’re issuing or administering task orders under GSA’s master contract for charge cards.

www.bts.gov

The Bureau of Transportation Statistics’ site has a wealth of studies on airline and surface transportation (including on-time statistics), access to transportation-related databases and the National Transportation Library and other, mostly technical, data.

www.financenet.gov/financenet/travel/travel.htm

Financenet offers information on DoD-related travel, such as the Joint Federal Travel Regulations, the DOT travel management system, and Federal Travel Regulations.

www.fss.gsa.gov

The Federal Supply Service awards the government’s services contracts, including those for fleet purchase or leasing and shipment of household goods. The site provides a complete list of vendors, among other things.

www.gsa.gov/regions/r9/travel/balv.htm

GSA’s Value Lodging program site provides a list of participating hotels and motels by state.

www.quicktrip.com

The Innovata Web site contains the Authorized Federal Travel Directory and searchable text of major government travel regulations. The site provides information on car rental companies, lodging sites, airlines and other private companies that do business with government travelers.

www.usfa.fema.gov/hotel

On the Federal Emergency Management Agency site, you can search by state for lodgings that meet the requirements of the 1990 Hotel and Motel Fire Safety Act and find out what your agency must do to comply with the law. Also includes a list of fire-safety tips.

www.midatlantic.gsa.gov/fss/travel/training.htm

GSA’s travel training branch trains federal travelers and authorizing officials worldwide in the ins and outs of rules and procedures affecting temporary duty travel and relocation. Their site provides a list of upcoming courses.

 

INTERNATIONAL TRAVEL

http://travel.state.gov

The Bureau of Consular Affairs home page provides recent press releases and travel advisories related to international political conditions. It also contains links to pages with information on passports, visa services, Y2K preparation overseas, U.S. embassies and consulates worldwide, travel publications and other topics. A must-visit if you are going overseas.

www.cdc.gov/travel

The Centers for Disease Control and Prevention’s site for travelers heading overseas includes vaccine recommendations, health information for specific regions and countries, lists of disease outbreaks and other disease prevention information.

www.customs.gov/travel/travel.htm

This site is the U.S. Customs Service’s one-stop shop for info on customs issues, including restricted and prohibited merchandise, medications and regulations governing currency. It includes a special section for business travelers and is useful whether you are traveling overseas or playing host to guests coming from afar.

www.ins.usdoj.gov/graphics/howdoi/inspass.htm

Start here if you want to get on board with the INS program that lets frequent travelers zip through checkpoints when reentering the United States. Go to www.ins.usdoj.gov/graphics/formsfee/forms/i-823.htm to find the enrollment form.

 

DEFENSE DEPARTMENT

http://www.mtmc.army.mil

The Military Traffic Management Command’s site has info on commercial travel offices serving Defense employees, travel regs, the governmentwide car rental contracts (including rates and participating companies) and more.

http://trol.redstone.army.mil/mwr/lodging/acrc_lsp_main.html

The Army’s preferred lodging (“Lodging Success”) program is available to military and civilian travelers on official orders to Army installations and others. This site includes a list of participating hotels and motels and info on how to use the program.

www.defensetravel.com/home.html

Information central for DoD’s travel reengineering project, including the implementation schedule, the vendors, frequently asked questions, and more.

www.dfas.mil

At the home page for the Defense Finance and Accounting Service, click on “Money Matters” to get facts on travel and transportation pay, including information on travel cards and travel advances.

www.dtic.mil/travelink

The home page of the Defense Travel System provides regular updates on the project.

www.dtic.mil/perdiem

The home page for the Per Diem, Travel and Transportation Allowance Committee covers per diem rates, the full text of the Joint Federal Travel Regulations, and lodging and dining information.

 

OTHER RELATED SITES

www.embassyweb.com

This comprehensive source offers links to diplomatic offices, international sites and a bookstore. It also contains links to major newswires and selected media sources, so travelers can keep up with the news in the United States. The “Related Resources” section includes a search engine and links to policy and travel resources. Order foreign currency at discount exchange rates here.

www.fedtravel.com

The Innovata (Previously Patriot) site provides information on the intranet-based version of the Federal Travel Directory, including more than 47,000 hotels and motels and 700 airlines. the subscription information service helps federal offices and individual government travelers manage travel and travel costs with a step-by-step process that stores travelers’ preferences and guides them through trip arrangements.

www.government-travel.org

The site of the Society of Travel Agents in Government, a membership association for federal travel managers and travel agents who have government clients. Here you can find information on airline city pairs, car rentals, federal travel regulations, foreign travel, lodging (including a list of the hotels in compliance with the 1990 Fire Safety Act) and Per Diem rates.

www.nws.noaa.gov

The official U.S. weather site includes current conditions, predictions and weather advisories.

www.oag.com

The online version of the Official Airline Guide provides airline, airport, flight schedule and destination information. To get the full online version of OAG, you must have a subscription.

www.hotelsatperdiem.com

Also available from travel maven OAG, this site lists hotels and motels nationwide that comply with federal per diem limits and fire-safety regulations. Travelers can provide feedback via the site about hotels and per diem rates. Users who have trouble finding a hotel at or below per diem can report that info to GSA; the agency will reconsider an area’s per diem if several travelers point out problems

Information provided by: http://www.govexec.com/travel/sites.htm

by Kimberly Hubbard

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Some Interesting Questions About GSA’s Best Rate http://cgtp.net/some-interesting-questions-about-gsas-best-rate/ http://cgtp.net/some-interesting-questions-about-gsas-best-rate/#comments Tue, 20 May 2014 11:18:08 +0000 http://cgtp.net/main/?p=932 According to the text, Travel Management Centers (TMCs), applying for the GSA Schedule are expected to offer prices better than those offered their best customer. This raises some interesting questions. Does GSA truly get the best rate? First, were this truly the case, it would be of no advantage for agencies to negotiate non-schedule TMC arrangements. They presumably could not get a better rate and presumably the $1.50 transaction fee is not enough to make the issuance of a Request for Proposals (RFP) and competition, an expensive process, a profitable alternative. Why than would an agency choose to run its own competition? Is it solely to add additional requirements not available under the schedule? Does GSA require that TMCs on the schedule offer services in all locations? If so, is it cost effective to contract with TMCs that have more limited locations where an agency does not need the larger scope that GSA may require?

Can Commercial Travel Offices (CTOs) also be TMCs? If so, why would an agency offer GSA a better rate than DoD which presumably would offer more business? Of course, by using a monthly fee in responding to DoD solicitations, the CTO could offer a best rate to DoD while arguably offering a best customer rate to GSA.

Presumably, TMC best rates can be obtained, in part, under the Freedom of Information Act. I would think that large companies would use this information in negotiations with the TMC to get similar rates.

by Scott Goldsmith

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E-Verify and the Travel Industry http://cgtp.net/e-verify-and-the-travel-industry/ http://cgtp.net/e-verify-and-the-travel-industry/#comments Mon, 19 May 2014 20:18:04 +0000 http://cgtp.net/main/?p=908 On November 14, 2008, the General Services Administration (GSA), the Department of Defense (DOD), and the National Aeronautics and Space Administration (NASA) issued a final rule (73 FR 67651), amending 48 CFR Parts 2, 22, and 52, to change the rules on Employment Eligibility Verification.  These new rules require Government contractors to enter into a Memorandum of Understanding (MOU) with the Government to use the Federal E-Verify system to confirm the immigration status of employees working on Government contracts performed within the United States.  Prior to the effective date of the new regulation, January 15, 2009, the use of the E-Verify system was voluntary.

Government contractors, as well as businesses in general, have long been obligated to check the immigration status of employees. The E-Verify system, however, goes beyond the current requirement that employees provide ID evidence of immigration status. Instead, the system requires the electronic transmission of a Social Security Number and picture identification for comparison with Government data bases.  This could be costly, at least to start, be difficult given a 30-day start-up period, and could require the removal of well trained employees who do not meet the requirements.  On the other hand, this does provide employers with reduced likelihood of future problems involved in employing illegal aliens, who may have quality fake identification documents.

The interesting issue for the travel industry is one of coverage.  That is, which components of the industry will be required to E-Verify their employees.  The final rules increase certain limitations from the earlier proposed rules.  Under the final rules, in order to be required to E-Verify employees, a contract must exceed 120 days in performance and be for $100,000 or more.  However, it is not limited to the contractor, but covers subcontractors as well as subcontractors to subcontractors, and makes the prime contractor responsible for subcontractor compliance.  The regulation defines a subcontractor as “. . . any supplier, distributor, vendor, or firm that furnishes supplies or services to or for a prime contractor or another subcontractor.”  A review of the commentary on the regulation indicates that the 120-day limitation applies to the prime contract, but does not apply to subcontracts (a 30-day rule arguably seem to apply).  This commentary further suggests that the $100,000 limitation is also not pushed down to the subcontractor level.  On the other hand, employees of the prime contractor or a subcontractor who normally perform support work, such as indirect or overhead functions and who do not perform any substantial duties applicable to the contract, are excluded from the E-Verify requirement.

It would appear that the CTOs and TMCs would be subject to E-Verify as the work involved in operating these offices, while tangential to the travel, would involve the direct work of the contract.  These functions would likely exceed 120 days and $100,000. An interesting question is how the GDS would be classified.  Arguably, the GDS could be considered a subcontractor as it provides services to the contractor, but the services could be considered indirect or overhead functions.  It is, therefore, likely that GDS employees would not be subject to E-Verify.

The primary issue that I see involves suppliers.  That is, are airlines, hotels, conference centers, and rental car companies subject to E-Verify.  If this is the case, every hotel employee, including chambermaids, reception staff, and waiters who might serve a Government employee could be covered.  Likewise, flight crews and check-in personnel and even ground crews could be covered. If so, E-Verify’s 30-day requirement to clear these employees would likely place a tremendous burden on airlines and large hotel chains.

Presumably, most conference centers would not be subject to E-Verify as the performance period involved would not exceed 120 days.  Some long term stay hotels would likely meet the 120 day requirement, but, except where a number of Government employees are located in a facility for an extended period, the $100,000 limit would not be met.  An employee will not be on a flight for 120 days and it would be rare for a car rental to exceed 120 days and $100,000.  Assuming that the limitations apply by purchase order, the impact would not be great.  However, it is unclear how these limitations will be calculated.  Car rental companies, airlines, and hotel are normally purchased off of a GSA schedule.  Therefore, if we look at the schedule as a contract, as opposed to each purchase order, the schedules for most hotel chains, rental companies and airlines surely exceed 120 days of service and $100,000.

The regulation commentary is confusing when dealing with the issue of determining what constitutes a contract for purposes of E-Verify.  On the one hand, the commentary, at 134, implies that the E-Verify requirements are applicable to indefinite delivery, indefinite quantity (IDIQ) contracts.  The GSA website FAQs on schedules states, in pertinent part, that:

GSA Multiple Award Schedule (MAS) contracts, also referred to as GSA Schedule and Federal Supply Schedule contracts, are indefinite delivery, indefinite quantity (IDIQ) contracts that are available for use by federal agencies worldwide. GSA awards and administers MAS contracts pursuant to 40 U.S.C. 501, Services for Executive Agencies.

It would appear, therefore, that schedule agreements with airlines, hotels, and car rental agencies are contracts for E-Verify purposes and, since purchases, under the schedules, in most cases exceed $100,000, and the schedule contracts all exceed 120 days, contracting with GSA to provide schedule services would, in most cases, require use of E-Verify.  In addition as it would be unclear where Federal employees would stay and what services they would use, most front-room employees would be subject to E-Verification.

However, the commentary addresses the issue of application to hotel employees at page 123 of the commentary.  The question addressed points out that compliance by hotels is likely to be a major problem as it is impossible for hotels to know which employees will react with which guests and Government employees are not segregated within hotels.  This was particularly problematic under the draft regulations which had a 30-day limit and which required E-Verify be used for all employees providing services to Government employees, but did not permit its use with other employees.  In responding to this question the regulation commentary states as follows:

First, the revision to the proposed rule that will make the clause inapplicable to contracts that will have a period of less than 120 days may eliminate almost all hotel contracts from being subject to the rule.  Second, the decision to allow contractors the option of using E-Verify for all existing employees, rather than just those assigned to the contract, will likely resolve any remaining issue.

The first part of this response indicates that almost all hotels will not meet the 120 day limitation, this suggests that each purchase order is viewed as a separate contract as it is difficult to see how they could say this if a GSA schedule contract was intended to be the “contract” for purposes of E-Verify.

In short, the regulation does not define what is a contract and the commentary is contradictory as to whether GSA schedule agreements constitute contracts for E-Verify.  It will be interesting to see whether GSA will be sending modification notices to those on the schedules requiring the signing of E-Verify MOUs.

by Scott Goldsmith

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The Department of Defense’s Efforts to Reduce Travel Costs http://cgtp.net/the-department-of-defense%e2%80%99s-efforts-to-reduce-travel-costs/ http://cgtp.net/the-department-of-defense%e2%80%99s-efforts-to-reduce-travel-costs/#comments Fri, 29 Nov 2013 16:15:32 +0000 http://cgtp.net/?p=1355 In March 2011, the Secretary of Defense issued a memorandum titled, “Track Four Initiative Decision.” The memorandum mandated that “all DoD travel requests must include justification that alternate means such as, Secure Video Teleconference (SVTC) or other web-based communication, are not sufficiently able to accomplish travel objectives.”

The Joint Federal Travel Regulations (JFTR) and the Joint Travel Regulations (JTR) were subsequently updated to include this mandate. The regulations require that all DD 1610 forms, Request for Authorization for TDY Travel of DoD Personnel, and other order formats like the Defense Travel System (DTS), include a statement justifying that alternate methods noted in the memorandum are not sufficient to accomplish the travel objectives.

It is my understanding that DTS is not being modified or changed at the present time, for the most part, except to fix system glitches. They are currently developing the Next Generation DTS system. As a result, this statement is not automatically added to DTS orders. There is a work-around in that travelers and Approving Officials (AOs) can manually add the justification comments to the travel authorizations, but the question remains as to whether the majority of travel requests DoD-wide are being updated to include this language.

To raise awareness at our agency, we created a digital sign to be displayed on monitors throughout the building, and we have incorporated this requirement into our FY 2012 AO training course. If the present DTS system will not be modified to add this statement automatically, this should be added to the list of requirements for the Next Generation DTS system to ensure that DoD travelers are compliant with this mandate.

K. Barnoski, 2012. Disclaimer: The contents of this message are mine personally and do not reflect any position of the Government or my agency.

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Tracking Travel Expenditures http://cgtp.net/tracking-travel-expenditures/ http://cgtp.net/tracking-travel-expenditures/#comments Wed, 05 Jun 2013 11:16:28 +0000 http://cgtp.net/main/?p=974 From my experience working with the federal government, they still have difficulty tracking their travel expenditures. “The government presently has very limited capability for management information reporting of its travel usage and spend.” This phrase appeared in the statement of objectives for GSA’s Business Travel Intelligence RFP in 2006. Although the government has the foundational tools (ETS/DTS), vendors (TMC/CTO, SmartPay) and processes (FTR) in place, they still are unable to determine how their money is spent to any degree of specificity.

One key reason is that, unlike corporate clients who maintain a single travel agency for all transactions*, GSA allows each agency to contract with individual travel agencies. Having various travel agencies with various reports and reporting formats adds a layer of complexity and administration that is not present in the corporate market, and makes the task of rolling up all information into a government-wide summary complex and cumbersome. The same is true if not more intricate on the DoD/DTS side, which I understand has current contracts with up to 100 travel agencies. Add on top of that the dynamic that travelers sometimes deal directly with travel vendors (hotels, airlines, etc) and by-pass travel agencies all together, and the data becomes even more diluted.

In 2007, the federal government contracted with TRX to facilitate the consolidation and analysis of travel data. Effective implementation of this project will finally give the federal government the data they so desperately need.

By Ted Schuerman

*According to Runzheimer International 94% of corporations who negotiate lodging rates rely upon travel agency provided reports for negotiations.

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DTS, ETS & FedRooms http://cgtp.net/dts-ets-fedrooms/ http://cgtp.net/dts-ets-fedrooms/#comments Fri, 02 Nov 2012 06:16:07 +0000 http://cgtp.net/main/?p=976 The federal government has taken on monumental tasks implementing the DTS system and ETS systems, and I commend DoD and GSA for their actions. Surprisingly, although the systems have been in place for many years now, my experience has been that neither group has been able to obtain the type of management reports necessary to effectively alter traveler behavior or leverage their purchasing power during negotiations.

As a simple example, let’s take the FedRooms program. Currently DoD does not participate in the program. Therefore the FedRooms rates, according to GSA’s FedRooms manager, are not even loaded into the DTS system for display to DoD travelers. On the ETS side of the house, while FedRooms rates (XVU code) are displayed, they are displayed with up to 20 other hotel rates as returned from the GDS, including the government rate (GOV code). This tends to confuse travelers who end up logging out, calling the hotel directly, and booking the government rate. Currently the FedRooms program has a paltry 2% adoption rate.

So, while DoD and GSA have had the systems in place to capture travel data for 10 and 6 years respectively, they have yet to take the next logical step to effectively manage their travel programs.

By Ted Schuerman

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