Comment #3 on FAR Case 2006-024, Travel Costs

31.205-46 Travel costs. * * * * * (b) Airfare costs, in excess of the lowest priced coach class, or equivalent, airfare AVAILABLE TO THE CONTRACTOR during normal business hours are unallowable except when such accommodations require circuitous routing, require travel during unreasonable hours, excessively prolong travel, result in increased cost that would offset transportation savings, are not reasonably adequate for the physical or medical needs of the traveler, or are not reasonably available to meet mission requirements. However, in order for airfare costs in excess of the above airfare to be allowable, the applicable condition(s) set forth above must be documented and justified. I believe that the above clarifies FAR 31.205-46 to the benefit of all contractors. If a small contractor cannot negotiate a discounted price, then this is justification to propose the non-discounted price. It would not be fair for a contractor that could negotiate a discounted price to be able to propose the street fare, and then use discounted fares to accumulate cost. This would just increase the large contractor?s profit, while putting the smaller contractor at a disadvantage. The large contractor would not have to be over burdened to document its lowest fare. The travel agency or internal travel department would be able to do that when the ticket is ordered, certifying that the ticket was the lowest price coach class airfare available. The cost of the employee who negotiated the discount in the first place should already have been recovered in overhead or General and Administrative costs. Since the discount impacts fixed price as well as cost type contracts, the travel discount would benefit the fixed price contract by keeping costs down, without having a related price adjustment; causing a better profit margin for the contractor. This clarification also follows the requirements that all discounts, rebates and credits have been given to the government. Finally, should the contractor not negotiate a discount, the contractor is not harmed because the non-discounted fare is the lowest fare available to the contractor. For this reason, the contractor does not HAVE TO negotiate a discount. The government is not making the contractor do anything that the contractor would not have done already.