Expense report compliance as a government contractor
The expense report should include:
- The purpose of the trip, why it was necessary, and how it benefited the Government
- Who attended the trip or received the benefits of the expenses. Include the traveler’s title or relationship to the contractor
- When and where the expenses were incurred
- Copies of receipts for incurred expenses
- Name and signature of the reviewer and the employee filing the expense report
Use location-specific per diem rates that comply with the allowable rates prescribed:
- For travel within the continental United States (CONUS):
- For non-foreign travel outside of the continental United States (OCONUS):
- For foreign travel outside of the continental United States:
If your selected hotel is unable or unwilling to offer rates that comply with the allowable rates discussed above, you should initially try to find a hotel that offers a Federally-compliant per diem lodging rate. If necessary, you may request a letter from your Government customer validating your status as a Government contractor and requesting that the hotel offer you lodging at the allowable per diem rate.
Alternatively, your prime contract may require that you first obtain approval from the contracting officer. If this is not specifically addressed in your prime contract, discuss the issue with your contracting officer at contract start-up. Recognize that FAR 31.205-46(3)(iii), Travel Costs, requires advance contracting officer approval of ongoing travel costs that exceed allowable per diem limits.
If you don’t have prior Government approval or documentation explaining why the per diem amount was unavailable, contractors may allow their employees to incur lodging costs that exceed allowable per diem limits. The amount that is over the maximum rate should be classified as an unallowable cost and treated accordingly. Otherwise, the contractor may incur penalties as per diems exceeding the limit would be viewed as expressly unallowable costs. Note that prescribed allowable lodging rates for CONUS locations do not include the taxes associated with the hotel stay.
For over 40 years, CohnReznick has provided comprehensive services to assist government contractors with a full life cycle approach to winning and managing contracts. We ensure your financial and procurement processes are compliant, efficient and effective - so you can focus on what matters most, profitable growth.
InsightGOVERNMENT CONTRACTING: Effects of multistate teleworking arrangements on state taxationLance E. Rothenberg, John IannottiGovernment contractors with employees working in different states due to COVID-19 may face implications for nexus, apportionment, and withholding. Read more.
InsightNavigating government funding compliance for life sciences companies: Optimize your indirect rateKristen Soles, Robert GutierrezIn order to maximize cost recovery and profitability, government grantees should develop indirect rates based on their organizational structure. Learn more.
Insight2020 GAUGE Report: Industry roadmap of benchmarks and trends for government contractorsExplore CohnReznick and Unanet’s annual insights into GovCon benchmarks and best practices, with special focus on technology and on the impacts of COVID-19.
Press Release2020 GAUGE Report highlights Government Contracting stressors and prioritiesAnalysis from CohnReznick and Unanet reveals how the pandemic, new regulations, technology and other factors are impacting government contractors
InsightDOD updates guidance for CARES Act Section 3610 implementation and reimbursementJeff Shapiro, Lori AllenDOD has issued two new Class Deviations for reimbursement of leave paid to keep government contractor employees “in a ready state.” Here’s what to know.