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    Can/should the government pay/reimburse the contractors for their moving expenses utilizing O&M funds? Does the contract have to be modified to allow this?


    FAR 31.205-35 addresses relocation costs. These costs are incident to the permanent change of assigned work location, for a period of 12 months or more, of an existing employee or upon recruitment of a new employee. The FAR states the following types of relocation costs are allowable as noted:
    Costs of travel of the employee and members of the employee’s immediate family and transportation of the household and personal effects to the new location.
    Costs of finding a new home, such as advance trips by the employee or the spouse, or both, to locate living quarters, and temporary lodging during the transition period for the employee and members of the employee’s immediate family.
    There are a host of additional allowable costs associated with relocation. I invite you to peruse them at your leisure. There are also specific criteria associated with allowable relocation expenses. These are outline as (1) The move must be for the benefit of the employer. (2) Reimbursement must be in accordance with an established policy or practice that is consistently followed by the employer and is designed to motivate employees to relocate promptly and economically. (3) The costs must not be otherwise unallowable under subpart 31.2.
    Particulars regarding funding should be coordinated with your finance office. Operations and Maintenance appropriations (3400) are used for the sustainment of an existing program. The types of funding include civilian payroll, travel, education and training, base operations support, mission support, etc.
    Relocation expenses would, by definition, classify as an allowable O&M cost. However, as is the case in any situation where additional funds are required, a modification to the contract must happen. DFAS cannot pay any type of invoice without proper CLINs, accounting classification reference number, and agency accounting identifier, which are established with a contract or modification.
    Personal services contracts trigger certain rights and responsibilities including payment of benefits and tax withholding. They are discussed in 10 USC 129b. Appropriation categories of government funding are grouped into areas of interest. DoD 7000.14R Volume 2A, Financial Management Regulation provides guidance on the types of funds available for use.

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