Glen
You are absolutely correct. I hope you took exception at the proposal phase. It is often a difficult post award negotiation and I have only been moderately successful.

Sandra M. Nordahl, CRA
Director, Sponsored Research Contracting & Compliance
San Diego State University Research Foundation
and
President, SRA International
Sent from my iPhone

On Jun 1, 2013, at 8:09 AM, "Jones, Glen A." <xxxxxx@WRIGHT.EDU> wrote:

> Dear Fellow Research Administrators,
> It is my understanding that the Joint Travel Regulations (JTR) rates are found in FAR 31.2 - Contracts with Commercial Organizations in FAR 31.205-46 (https://acquisition.gov/far/html/Subpart%2031_2.html). Therefore, unless an institution is a Non-Profit Organization listed in Appendix C of A-122 (http://www.whitehouse.gov/omb/circulars_a122_2004), the organization must follow the cost principles found in A-122. Since Colleges and Universities follow A-21, our reference to cost guidelines in FAR is FAR 31.3, which refers us back to the cost principles in A-21. Therefore, it is my understanding that JTR only applies to contracts between the Federal Government and Commercial Organizations or institutions listed in Appendix C of A-122. All other organizations should look to their respective OMB Circulars for guidance on travel costs.
> Thanks,
> Glen
>
> Glen A. Jones, MBA
> Director, Post Award
> Research and Sponsored Programs
> Wright State University
> Dayton, Ohio 45435-0001
> Phone: 937.775.4461
> Fax: 937.775.3781
> Email: xxxxxx@wright.edu
>
>
> -----Original Message-----
> From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Sonavie Ong
> Sent: Friday, May 31, 2013 7:00 PM
> To: xxxxxx@lists.healthresearch.org
> Subject: Re: [RESADM-L] Use of federal per diems for travel reimbursement
>
> If this is at the proposal stage, I don't see any harm with preparing the proposal budget using the federal per diem rate if your institutional rate is lower.   At least you've provided a little cushion if your institutional rates do increase later on.  However, in post award,  you would have to charge the rate based on your institution's policy even though you might have budgeted and been awarded the federal rate.
>
>
>
> -----Original Message-----
> From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Johnny Pham
> Sent: Friday, May 31, 2013 11:08 AM
> To: xxxxxx@lists.healthresearch.org
> Subject: Re: [RESADM-L] Use of federal per diems for travel reimbursement
>
> Agreed. Also, auditors will audit against your institution's policies before federal policies.
>
>
> -----Original Message-----
> From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Spires, Michael
> Sent: Friday, May 31, 2013 11:06 AM
> To: xxxxxx@lists.healthresearch.org
> Subject: Re: [RESADM-L] Use of federal per diems for travel reimbursement
>
> I wouldn't recommend it. Using the federal per diem rates would pass the reasonability test, but if your institution (as my former employer did) has different rates from the federal ones, to be consistent with other work done there, you should use  your institutional rates.
>
>
> Michael Spires
> Proposal Development Specialist
> Office of Sponsored Projects
> Smithsonian Institution
> Mail: MRC 1205, P. O. Box 37012
> Washington, DC 20013-7012
> Voice: (202) 633-7436
> Mobile: (202) 251-4317
> Main office: (202) 633-7110
> Fax: (202) 633-7119
> http://prism.si.edu/osp/FundingSources/ProposalDevelopment/PropDev.html
>
>
> -----Original Message-----
> From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Arlene Heredia
> Sent: Thursday, May 30, 2013 16:53
> To: xxxxxx@lists.healthresearch.org
> Subject: Re: [RESADM-L] Use of federal per diems for travel reimbursement
>
> How about an institution with policies establishing LOWER per diem rates than federal?  Would it be ok to write it up in a proposal as "federally approved per diem rates will be used" (or something to that effect)?
>
>
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