We are receiving a number of subcontracts that have the U.S. Air Force
as their prime that the companies are attempting to flow down travel
regulations based on FAR Contract Clause 31.205-46.  They are requiring
us to follow the Joint Travel Regulations rather than our own government
approved travel policy which is in conformance with OMB Circular A-21
"Cost Principles for Educational Institutions." We are trying to
negotiate this clause out or have them agree to abide by our own travel
policy, but they insist that this regulation must be flowed down to us
as it is in their prime contract.   We understand that they must abide
by the clause in the contract between them and the federal sponsor, but
are we required to abide by that clause if it differs from our own
approved travel policy? We have gotten them to agree that we could use
our own approved rate as long as it is equal to or less than the JTR
rate but does not go over the JTR rate.  This requires quite a bit more
proof of compliance as we must show that we have checked out each rate
for each trip and documented which was the lower rate at that time.  It
also gives the PI the impression that he can get a higher rate if JTR
allows for a higher rate.

Are any of you having this problem, and if so, can you tell me how you
are handling it?

Thanks,

--
Jackie Frederick
Director, PreAward
Research and Sponsored Programs
Wright State University
201J University Hall
Dayton, OH  45435-0001
937-775-2664
xxxxxx@wright.edu

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