Government Connections - Winter 2014 - (Page 14)

F E AT U R E Per Diem - Familiar but Sometimes Misunderstood TOM HIRANO, CGMP PROJECT MANAGER, IRS W hen asked about the per diem rate in a city, more often than not the response provided is the lodging rate for hotels. However, per diem for a location is actually three allowances: lodging, meals and incidental expenses. Per diem is too complex to cover in a brief article (more than 45 specific sections in the Federal Travel Regulations), so here are just a few thoughts from out West. While this article is based on federal law and regulations, the management of per diem in other government organizations (e.g. state, municipal) is often similar. Can you pay the conference rate? Not anymore. The Federal Travel Regulations (FTR) provided a "Conference Lodging Allowance," that authorized payment of up to 25 percent more than the applicable lodging allowance rate. This allowed an employee attending a government or nongovernment-sponsored conference to stay at the host hotel when the rate was higher than the allowance. However, as of October 1, 2014, the General Services Administration (GSA) will eliminate the use of the "Conference Lodging Allowance." There is still a provision for circumstances where the government lodging allowance rate cannot be acquired. Under FTR §301-11.300 through 306, an agency may authorize actual expenses. There are five situations where an agency may authorize up to 300 percent of per diem for the location where lodging is obtained. These situations include "when lodging is procured at a prearranged place, such as a hotel where a meeting, conference or training 14 session is held" and the classic catchall of "any other reason approved within your agency." So while there is no longer a "Conference Allowance Rate," authorization can still be obtained for a conference hotel offering a higher than per diem lodging rate or to conduct a meeting/ conference with a higher lodging rate. It will likely require a strong justification, but it can be requested and approved by designee(s) within the agency. Keep in mind that this is discretionary and often an agency will simply opt to change dates or location instead of paying the higher rate. Is the government rate at the "Alpha Baker" Hotel really $400 per night? It could be. The lodging allowance rate is based on average daily rate (ADR) data from specific properties that meet GSA criteria. The data is compiled for GSA by a contractor, GSA determines the rate structure, and then the rates for the upcoming fiscal year are generally released in August. To see more detail on how the rates are determined go to "Factors Influencing Lodging Rates" at the GSA website. Approximately 2,600 counties are defined as within the Continental United States (CONUS) and are covered by a standard CONUS per diem rate ($129 for FY 2014 with $83 for lodging, $41 for meals and $5 for incidental expenses). There are about 400 Non-Standard Areas (NSAs) that have per diem rates higher than the standard CONUS rate and often have seasonal variances. While the lodging allowance rate is generally the maximum a traveler may pay, hotels are not required to honor the federal lodging allowance rates. It is each property's business decision whether to offer the rate. So even though GOVERNMENT CONNECTIONS | WINTER 2014 a substantial discount from their usual rate, the government rate from Alpha Baker Hotel could be higher than the per diem lodging allowance. Also, hotels often offer different per diem lodging rates for employees from different government organizations. If for example the hotel is in the state capital, a request for government rate may result in a reservation at the state rate. To ensure the appropriate rate, ask for, or conversely offer "the per diem lodging allowance rate of XYZ dollars" instead of simply stating the "government rate." Isn't that allowed by the Federal Travel Regulations? Yes, except ... Meeting professionals often assume that if a certain action or expenditure is allowed under a regulation, then it is approved. However, a federal agency may implement its own policies as long as they do not exceed what is allowed by regulation. For example, while the FTR allows actual expenses up to 300 percent of per diem, an agency could limit its employees to 200 percent or not allow actual expenses. So use the FTR as guidance and not final approval. Always check for agency specific limitations and procedures early and often to avoid confusion or problems. One last thought. You do not need to be an expert in per diem rules and regulations. You only need to be familiar with the general rules and common situations. However, it is more important to know where to find help. Have a copy of your agency's travel policy, know your agency travel and/or procurement contact, bookmark general sites like the GSA (or your state equivalent) and learn from other sources like SGMP and travel/hospitality industry publications and references. Happy travels!

Table of Contents for the Digital Edition of Government Connections - Winter 2014

President’s Letter
Editor’s Letter
Going Places
Plan Green
Fitness Breaks Recharge the Body and Mind
Per Diem – Familiar but Sometimes Misunderstood
Costs of the Fy2014 Funding Squeeze
Six Technology Solutions to Help Your Meeting Run Smoother
Supplier Strategy
Meet a Member
Cgmp Corner
Question for Our Members
National Updates
Sgmp Nation
Advertisers’ Index

Government Connections - Winter 2014

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