Certified Government Travel Professional » FAR http://cgtp.net Fri, 06 Feb 2015 11:16:13 +0000 en-US hourly 1 http://wordpress.org/?v=3.9.3 ETS and Culture Change http://cgtp.net/ets-and-culture-change/ http://cgtp.net/ets-and-culture-change/#comments Wed, 24 Dec 2014 01:16:01 +0000 http://cgtp.net/main/?p=919 When the ETS became mandatory at our agency, we found that there were several unpleasant surprises that had been lurking under the safety of our diffused paper processes.  A definite advantage of the ETS is that it made it much more difficult for various offices to operate their fiefdoms outside of the internal regulations and policies, and in some cases even appropriation law.  Where there was no political will to correct such violations, the ETS provided  an effective mechanism for bringing all parts of the organization into compliance.

When we were in the initial pilot format, and the problems became more acute and obvious shortly after we required mandatory use of the system agency-side, we discovered several problems in our internal practices.  Many of our managers, especially those in the program areas, are here only as temporary personnel.  These interim managers do not understand appropriations law, government accounting, and they have no interest in complying with the FAR or the FTR.  Civil service staff often understood the rationale for the regulations and agency processes, but had a difficult time enforcing compliance when their management was telling them to do otherwise. There was a strong underlying culture of “make-it-work” and pro-forma paperwork (in some cases no paperwork until the travel vouchers were presented for payment).

Some of the problems discovered had been suspected for years by accounting personnel who did not have the political influence to correct them within the organization.  These issues included such things as traveling without evidence of advance approval for the travel (no written and approved orders); and violations of the Anti-Deficiency Act (traveling without funds committed and obligated in advance of expenditure by an authorizing official);   A significant amount of the organizational resistance to the implementation of the ETS, in my opinion, came not from just the complexity of the ETS, but also from the enforced standardization and compliance with the letter of the law and internal regulations.

Mandatory use of the ETS has successfully standardized travel practices and forced  cultural change at the agency that can only improve financial integrity and compliance with federal regulations, and the internal policies that require us all to be good custodians of the taxpayers’ money.

by Julie Speers

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Roles and Responsibilities in Travel Management http://cgtp.net/roles-and-responsibilities-in-travel-management/ http://cgtp.net/roles-and-responsibilities-in-travel-management/#comments Mon, 25 Aug 2014 07:15:17 +0000 http://cgtp.net/main/?p=1192 Not long after graduating college, I became a travel specialist. At the time I saw it as just a stepping stone to my career that would eventually lead me to a job more closely related to my major.  I now realize that when I started I had no idea how large the travel field was, and all of the parts involved.  I thought it was simply learning how to use the ETS system and being able to read a few regulations, with no regards to the other pieces involved.  It takes a great deal of cooperation from a number of individuals, teams and offices to effectively manage a Government travel management program.  These different components work together in varying degrees.  Some may not work directly at all, yet they indirectly have an affect on the work of others.  These different areas working together can consist of staff in the Budget, Financial Management, Information Technology, and Policy sectors.   Travelers may not be aware of the level of interaction between these groups, but these groups, by working together efficiently, play a big role in the experience of the traveler in processing their travel authorizations and vouchers.

One group of people involved in the travel management process that does not receive the level of visibility that other areas do is the staff working through Acquisitions and Procurement branches.  It wasn’t until I took training on being an Assistant Contracting Officer Technical Representative (ACOTR) that I became familiar with the level of involvement that our Acquisition office had.  It was there that I also became familiar with the Federal Acquisition Regulations (FAR).  I had no prior experience in contract language or the process of how contracts came to be.  Without the acquisition staff doing their part in analyzing/processing contracts we would not have the services that we do today.  This is also important since actual contract staff can sometimes play a big role in travel management.  Contractors with experience in ETS systems and TMC relationships are used to supplement Government staff as travel administrators, and to provide assistance in travel management as a whole.  The contribution from contractors can be invaluable.

The Information Technology team is vital to the implementation of any travel system.  They can assist with making sure the ETS system is compatible to whatever software is currently being used by the Agency.  It can also help troubleshoot problems that may appear to be related to the ETS system, but are actually an issue on the IT side of things.  Some Agencies even use their IT specialist to help with travel related problems.  Although many IT specialists are not travel experts, they may still be inundated with travel concerns simply because that’s who travelers think they should reach out to.  Issues are resolved much faster when IT specialist know who to contact in regards to travel policy, or travel administration.  Excellent travel management is certainly a byproduct of a good relationship between the Policy and IT offices.

One of the most important aspects of travel is related to money.  The Financial Management and Budget divisions play a major role in the functioning of travel.  For those not familiar with the world of accounting and finance, just the verbiage alone can seem very complex.  They must make sure that lines of accounting are active and loaded properly.  Funds have to be obligated and tracked.  The use of the Centrally Billed Account (CBA) must be monitored, as well as the GSA SmartPay 2 travel cards.   Once funds are obligated for travel, they assist in getting the traveler reimbursed for those funds.  Financial systems are periodically updated and changed, so financial experts are used to make sure the transition to a new financial system is seamless.

Travel policy experts are essential to the travel management process as well.  As is the case with accounting and financial verbiage, travel regulations can be complex to those unfamiliar with them.  Travelers rely on policy experts to advise them on current regulations, and to make sure they do not inadvertently travel out of policy.  It is highly important to have staff knowledgeable of the Federal Travel Regulations (FTR) and their respective Agency’s travel policy.  Some travelers see regulations as being open to interpretation, so it is up to travel policy specialist to express a clearer and more definite meaning.  The FTR, due to its question and answer format, is more readable and easily understood than even some Agency regulations.  With the advancement of technology in the travel field it is important for travel regulations to be checked and updated regularly.  Agency travel regulations, while being tailored to their specific Agency, should be just as easy to read as the FTR, and be readily accessible to travelers.  Since the FTR takes precedence over agency regulations, both policy experts and travelers must be careful not to solely rely on their agency’s travel regulations.

Much of what I’ve gone over here is familiar to many already.  My hope is that it at least gives individuals who are newer in the travel field an idea of how many parts are involved.  Since I majored in economics in undergraduate school I’m often asked why I’ve stuck with travel and not ventured into something more in line with what I studied in school.  My opportunities have led me to the travel field, but it’s all the different people involved that has probably kept me in it.  There is so much that can be learned I can’t say that I’m ever bored.  It provides a constant challenge, and many opportunities to network with others.  The steady advancement of technology also allows for creativity, innovation, and a chance to constantly improve the travel process.  I look forward to seeing what the future holds.

By Kelvin Dawson

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FAR Part 301-52 http://cgtp.net/far-part-301-52/ http://cgtp.net/far-part-301-52/#comments Tue, 10 Jun 2014 16:18:36 +0000 http://cgtp.net/main/?p=912 In reviewing FAR Part 301-52, which was covered by this chapter, I was interested to find out about the late payment fees required of the Government when a filed voucher is not paid within 30 days. According to this FAR provision, when the Government fails to meet the requisite deadline, it becomes liable for a Prompt Payment Act payment which must be equal to or in excess of what the employee may be charged by the credit card company, or where the employee pays the bill, what he or she would have been charged.

Interestingly enough, the language concerning the tax consequences of these payments is far from clear. In this regard, §301-52.22 notes that the payment is not reported as wages, but rather, is “in the nature of interest.” The section goes on to note that the payment will be reported in accordance with IRS guidelines, but fails to indicate what these guidelines state. On the other hand, § 301-52.23 states that payments in excess of what the card company would have been able to charge are reported as income and listed as wages on the employees form W2. How can a payment that is in the nature of interest be reported as wages? That is, how does it change character simply because it is in excess of the employee debt? Moreover, the fact that the employee is taxed on the amount paid that is owed or would have been owed to the card company, seems inequitable to the employee.

by Scott Goldsmith

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The FAR and How It Came About Where It Went http://cgtp.net/the-far-and-how-it-came-about-where-it-went/ http://cgtp.net/the-far-and-how-it-came-about-where-it-went/#comments Thu, 13 Mar 2014 21:16:58 +0000 http://cgtp.net/main/?p=685 To understand how the FAR (Federal Acquisition Regulations) came into being you have to remember how our country lived in its earlier years. Those who ran the country were predominately plantation owners, small manufacturers or were involved in shipping. When they needed to buy something they simply went to the source and made the purchase. They may or may not have gotten pricing from several sources, but knew where their dollar went the furthest.

Now introduce a new element, the Federal Government Employee. Their basic method of being paid and running an administration was based on the British Colonial model which resembled the British Federal Systems, but with a few changes. Remember that initially being sent to “The Colonies” was not always a reward and many times those who came here were actually not the individual who was intended for the position. It was quite common in the British Federal System for people to be appointed to positions of significant authority and/or political position.  Usually what you would see is the individual who actually arrived here was probably the third to five person in a pyramid set up. Basically someone who had been appointed to a position in the Colonies would offer half of their salary to someone else if they would take the appointed position. Usually that individual would then do the same offering half of what they would make to someone else. The line continued until someone actually looked at America as an opportunity to grow or to escape.

In the early stages of the US Federal Government, there were a few Senior Executives, know has Secretaries and about 20 clerks, most of who were owed back wages. Most of the income the Federal Government received was based on tariffs or other import duties. So as you can, see the administration started and continued for quite a while to be small. It later became not uncommon that those in clerical positions now were making purchases for the government. We had a small standing army of less than 1000 to provide for and a slowly increasing demand for the Federal Government to do more.

When a purchase was made it was quite common for a clerk to write the requirements down, put them in an envelope and gave it to some one they knew could provide what was needed. The idea of getting three bids was not part of the process. Later as the Federal Government grew from more tariff income the purchases became larger. The process though of purchasing did not change until the 19th century when many merchants complained they were being excluded from the purchasing process. Thus the requirement for purchasing had a new element introduced, sending out all bids by the US Postal Service. This later became mandatory as a means to prove that there was competition in the purchasing process.

Now if you have watched many of the old Westerns’ you will remember the Indian Agent who was supposed to provide food and goods to a reservation they served with the funds given to them. You probably also remember that a few of them decided to keep more of that money for themselves and would provide food and goods not quite of the quality that was intended. Now this certainly does not mean that this was the case every where, but there was not a system of checks and balances that had someone such as an Inspector General who would monitor the contracts that had been awarded. In fact most Federal Contracts that did not involve specific products such as fire arms were actually monitored at all.

The purchasing process changed further as more merchants and manufacturers wanted Federal Contracts and needed a way to find out what was needed and when the requirements would be announced. This created the Federal Register which contains a list of all the purchases that were now authorized or requests for bids for proposed purchases including the requirements for the development of specialized equipment such as fire arms. This basic way of purchasing did not change until the early 1990’s when the internet became a reasonable way to distribute this information in a much more timely fashion.

If you have seen the original postings on what is now “Federal Business Opportunities” the process to move into the electronic age was one of kicking and screaming by the agency. If you looked at the “font” you would think that an IBM Selectric Typewriter was at the other end of the screen putting in each entry.

As you see the FAR today being used, it is administered by Contracting Officers and Specialists who have the Warrant to make purchases up to their authorized level. They sign actual contracts that have cancellation clauses and specific performance requirements. They are audited periodically to ensure they are within their authority and that they have competed their purchases through competitive bidding. One of the most important changes though that has come about is the new requirement of “best value” versus lowest price. This is where you see today’s contracting staff many times conflict with the project manager.

Most general contracting staff does not have a specific understanding of everything they are asked to purchase. Meetings or related services are two areas where many contracting staff will tell you where they struggle. Many have never attended a meeting in a city where they do not live or are aware of all that is required to produce the event. Other than by just price they can have a hard time making a determination on how paying more is actually better and produces better results. You usually see this when you pose specific questions to them that they defer to the project manager.

The FAR is an evolving policy and procedure that you must learn to work within. If you find yourself not knowing how to proceed, seek out one of the senior members of our association and ask for help. Any of us can either guide you to where the answer can be found or answer your questions. The power of membership in SGTP is accessing the shared knowledge of the members.

By Ted Miller, CHME, CHSP

Starwood Hotels and Resorts

 

 

 

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Travel Professional Resources http://cgtp.net/travel-professional-resources-2/ http://cgtp.net/travel-professional-resources-2/#comments Fri, 31 Jan 2014 12:17:05 +0000 http://cgtp.net/main/?p=640 The Travel Departments of companies involved in the support to the US Federal Government are subject to Government regulations such as the FAR and FTR; however the interpretation of theses laws is very subjective to the T&E policy of each company.  Government Contractors need to educate their travelers by emulating the government communication process regarding Travel and Ethics training.

According to the DCAA Contract Audit Manual, advanced planning for travel should be an integral part of the contractors internal travel policy.  Such planning to combine visits to the same geographical area into a single trip would minimize the use of above standard fares and accommodations  In 1985, legislation revised the costs allowability criteria from reasonable meals and lodging to use the government employee per diem rates.  The Act creates parity between the allowable Transporation/relocation, and travel expense for contractors and government reimbursement rates. The result is that contractor costs for travel, including lodging, meals and incidentals will only be allowable if reasonable to the extent permitted for federal employees.

This principal was established to equalize travel cost reimbursements of government and contracted employees.  Per diems limit daily reimbursement on a location by location basis.

The FTR (Federal Travel Regulation) contains three provisions that apply to Government Contractors:

a)      Definition of what constitutes a meals, lodging, and incidental expense.

b)      Daily limits for lodging and per -diem.  Contractor payment limitations are based on combined lodging and per diem each day.  Government employee limitations are based on individual lodging and per diem each day.

c)      Unusual circumstances that permit reimbursement greater than the established limits.

It is the Travel Managers responsibility to ensure complete understanding with effective ongoing communication in order to avoid any perception of inappropriate behavior.  Online booking tools and Expense reporting systems need to be programmed in accordance with Government standards. The Travel Manager needs to have the support of the company’s leadership in order to communicate the nuances associated with travels in performance of Government contracts to the traveling employees and arrangers.

By Maruca Malloy

 

 

 

 

 

 

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Data Collection Under the TRX MIS Contract: Implementation, Deployment, and Strategic Sourcing Issues http://cgtp.net/data-collection-under-the-trx-mis-contract-implementation-deployment-and-strategic-sourcing-issues/ http://cgtp.net/data-collection-under-the-trx-mis-contract-implementation-deployment-and-strategic-sourcing-issues/#comments Wed, 18 Apr 2012 03:34:39 +0000 http://cgtp.net/main/?p=759 The GSA (General Services Administration) often enters into City-Pairs negotiations hampered by a relative lack of hard data on Government travel.  Where substantive data has been available it has not been as detailed or as encompassing as the Government requires to effectively support negotiations.  This lack of effective data caused the Travel Program management Office (PMO) of the GSA to conduct an Full and Open competition for a vendor that could provide services to make up for this lack of information.  The solicitation requirement was to obtain the best travel data aggregation and reporting solution that satisfied government requirements at the best value.  A trade-off analysis was performed between technical and cost and past performance to make the award under the aegis of a best value acquisition as set forth by the Federal Acquisition Regulation (FAR).  TRX Incorporated was awarded the contract by providing the best technical approach and pricing.  In the initial year the solution was used to be aggregate data and report on air spend, unused tickets, premium travel, and City Pair Program utilization.  In the first year, TRX’s performance was evaluated to validate the proof-of-concept before GSA exercised the first option year.

The federal government has not been able to accurately identify its annual travel spend which exceeds $15.4B a year.  An Accenture study found $7B a year in unknown types of travel expenditures, and a difference of over 50% in the travel expenses recorded on the federally mandated SmartPay travel card from expenses recorded in the President’s Budget Object Class 21 (Travel and Transportation of Persons) as submitted by federal agencies.  In the past, the Government has been unable to capture spend, determine the value of the spend, and to determine the level of compliance with federal travel programs.  The inability to know how much has actually been spent on travel means that it cannot effectively be managed.  The Government’s approximately $15.4B a year in travel spending is subject to unknown inefficiencies and costs.  The Government’s inability to wade through a morass of incomplete data from various sources has seriously hampered its ability to effectively negotiate with stakeholders in the City Pairs program among other things.

The intent of the TRX MIS contract was to provide comprehensive data on Government travel for most if not all GDS, and other travel data collection systems.  Market research was performed and the requirements for the MIS system originally were drafted from both DOD (DTMO) and the civilian agencies.  GSA evaluated the proposals and awarded the contract to TRX for the MIS initiative.

This contract provides for the first time the ability to capture and aggregate comprehensive travel data for the federal government.  This will include travel made through the Travel Management Centers (TMCs), through the ETS solutions, through the SmartPay charge card, and directly with suppliers.  A multi-year, phased in approach is being used to mitigate risks associated with technical development, integration, and minimize costs to the government.

Once the government has aggregated its travel data through a central repository for such data as the contractor provides, reports can be generated that will provide management information regarding government travel.  TRX has provided their services to numerous commercial companies which have resulted in the development of a suite of ready-to-use travel management reports.  The government will now be able to use these same reports which have given companies in the commercial marketplace the ability to better manage their travel.

Additionally, custom reports specifically tailored for the government environment are being developed for use by the federal agencies and their stakeholders.  This will include the travel reporting Information profile (TRIP) report which is a statutory requirement.  It is important to note that relocation data and the cost of administering travel is not available from the solution since it is not accumulated electronically in the available data sources at this time.

Initially it was thought that the main objections in delaying implementation would come from the airlines and vendors providing the GDS data links to the government vendor.  As it turned out, and much to everyone’s surprise, most of the delays resulted from other vendors who did not provide timely, accurate, and complete data feeds.

Initial data feeds were also somewhat delayed as additional security requirements were implemented to incorporate personally identifiable information (PII) transmission.  These requirements ensure the secure transmission of the data through an encrypted portal called Dataman.  There were some unexpected challenges regarding security on the Government side as an Authority to Operate (ATO) certificate was required to secure these records.

The rights to all of the data remains with the government, and the deployment of a third party aggregator provides the necessary consolidation of aggregated data, standardized processes, and streamlined reporting requirements.  It also provides a steady data stream necessary to accomplish strategic sourcing of services.  This process will also unencumber each of the TMC’s from trying to meet regulatory requirements processes reports such as TRIP reports and Premium Class Travel Reports.

GSA addressed the only other objection to providing this data by providing free software to transmit already available back-office data to GSA.  Although this software was originally intended primarily to ease the transmission of data from smaller TCS it is now widely used for most of the TMC data feeds as a more secure method of data transfer.  GSA also provided no-cost technical support for the system.  DataMan extracts data from back-office systems and transmits it directly to the TRX MIS system – 256k encrypted.   It is secure and automated, easily configurable, and the smaller TMC subcontractors/vendors that provided data with it to date are happy with it.  It sends the data automatically every month and requires no human intervention once set up.  At this point in time data is collected monthly and will not include some of the IBA data.  As the ATO is granted – one years worth of data will be collected to include PII as requested by the Government Agency.  TRX rolled out the pilot of the system for government wide use on 12/15/08.

Included in the MIS is the ability to perform analysis of strategic sourcing opportunities.  The capability was exercised this past year as an analysis was performed upon the request of the airline carriers.  The carriers wanted to enforce a ticketing time limit to purchase seven days prior to departure of within twenty-four hours, if within the seven day period.  This would, the carriers claimed, allow the airlines the ability to resell their seats in a timely manner to the general public and to ensure revenue opportunities were available at every juncture.

It was important to have a solution to analyze the substantial amount of  data available and provide a significant response to the request.  For the first time the government was able to view data patterns not readily seen, for instance:  Twelve percent (12%) of all airline tickets are issued for the same day of travel.  Airlines have also added several fees (fuel surcharge, baggage and interactive fees for such things as telephonic reservations and ticketing at the airline counter, etc.) to the  price of the ticket.

Under the TRX contract GSA was able to review the entire download of FY 2007 ARC airline travel data in order to preview the caliber of information that might be expected under the TRX MIS contract.  Upon review, the analysis showed 72% of government travel spend either used a TCA or CA fare on City Pair contract tickets.  76% of the segments were also City Pair routes.  An additional 16% used DG (discounted government fares), so 88% of tickets purchased were actually Government fares.  Commercial fares were used 12% of the time either as lower than contract fares, or because they were in markets not serviced by City Pair fares.  Data from ARC was broken by origin and destination, by passenger count and fare basis by passenger count.  This analysis indicated a high rate of compliance with the City pairs contract policy and showed the government to be a strong proponent of the program.  The analysis supported the government’s contention that we were a valuable customer to the airlines, as in the instances noted, the Government actually helped to fill seats for the carriers at the last minute and at an acceptable yield to the airlines.

TRX data will eventually also provide the Government with additional critical data for effectively managing other areas of their contracts.  This data is sorely needed, since prior to this time, there was  no way to efficiently manage the effectiveness of the programs nor that business activities were actually being conducted in the best interests of their customer, the U.S. Government.

New  analytical capabilities are expected to realize significant improvements for strategic sourcing, utilization of federal travel programs, compliance with federal travel policy, and travel spend data.  New benefits will include:

  • Improved travel supplier agreements that provide best cost and quality choices.
  • Improved use of existing programs that maximize cost savings and flexibility.
  • Increased compliance with travel policy and new policy creation, improving adherence to the Federal Travel Regulation (FTR).
  • Near real-time travel usage and pattern information analyses allowing for adjustments and changes in travel management that provide the required response to the needs of the federal traveler.

In conclusion, despite some unanticipated obstacles, the MIS has been launched and is now available for GSA and Government-wide use for the benefit of our government travelers, and the success of our government programs.  The data aggregation and information analyses it yields will be invaluable as GSA continues to improve strategic sourcing under the City Pairs programs, and to monitor and adjust policy to ensure compliance with the FTR and associated regulations.

by Julie Speers

 

 

 

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