Jackie,

I have worked to remove JTRs from prime contracts (and been successful).  Point your sponsor to FAR clause 31.3 - Contracting with Educational Institutions - The important part of this clause segment is subpart b.  I would point out to your sponsor that they need to apply the appropriate clause for your institution's type (educational institution).

31.303  Requirements.
(a) Contracts that refer to this Subpart 31.3 for determining allowable costs under contracts with educational institutions shall be deemed to refer to, and shall have the allowability of costs determined by the contracting officer in accordance with, the revision of OMB Circular A-21 in effect on the date of the contract.

(b) Agencies are not expected to place additional restrictions on individual items of cost.

I hope this helps!
Sandra

Sandra M. Nordahl, CRA
Director, SR Contracting and Compliance
 and Facility Security Officer
San Diego State University Research Foundation
5250 Campanile Drive
San Diego, CA  92182-1934
email: xxxxxx@foundation.sdsu.edu
voice: 619.594.4172
fax:     619.582.9164
www.foundation.sdsu.edu

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-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Jackie Frederick
Sent: Wednesday, September 05, 2012 10:24 AM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] JTR regulations

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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