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    My question is, can we require a contractor to pay for this type of travel on a FFP contract and is it even authorized for a person to travel without orders?


    Answer

    The way I understand your question is that you want to contract and pay the contractor for training of government personnel to include both the actual classroom instruction as well as the travel expenses of all the trainees via a FFP type contract.  From a contracting point of view, I cannot find anywhere in the FAR which prohibits including the cost of these travel expenses on a contract.  Not knowing the contract specifics, I am not able to say for certain that a FFP contract would be the best contract type but if it meets the criteria in FAR 16.202 it would potentially be an appropriate contract type.
     
    Your more important question is are you allowed/authorized to contract the travel costs of government personnel outside the DTS system and not on orders?  I am not an expert on travel regulations so I cannot definitively answer that and would recommend referring the question to you organization’s legal department.  My personal opinion is you should not have government personnel conducting official travel not under official orders.  It opens up too many potential liability and accountability issues in addition to the possible ethical problems that may arise when you are paying the contractor to pay for student travel expenses if there isn’t a robust review process in place to prevent fraud or the acceptance of impermissible benefits.
     
    As always, we encourage you to work with your contracting and legal office as well as referencing your agency specific regulations for any acquisition as we don't have all the facts or access to the contract files.



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