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    i have different LOA's on the same Modification, both for travel. One travel CLIN is depleted, can the KTR bill against the second travel CLIN with req. owners approval even though they have two different ESP Codes?


    Answer

    The period of performance (PoP) for each travel CLIN should be looked at to ensure it is not past the end of the PoP. Are the PoPs the same for the two travel CLINs, why two different travel CLINs? The answer to that question may drive the answer of contractor billing. The contractor should bill for travel respective to the scope of work, which in turn will be associated with the respective CLINs, and the funding with its LOA for that scope of the CLIN. So for example, if the LOAs reflect different scope of work in the contract such as different requiring activities who have their own LOA, then the contractor should bill accordingly to the scope of work that the travel was associated with. 

    On a side note, if you have more than one LOA for travel, you can create a parent CLIN that is priced and subCLINs that are informational, one subCLIN for one LOA. This is to be compliant with DFARS PGI 204.7107(c) that addresses how to identify funding respective to legacy systems and more recent systems that enable traceabililty to contract actions and reflect the Agency Accounting Identifier (AAI). If you are using a more recent system that reflects AAIs and ever have a CLIN with more than one LOA, then DFARS PGI 204.7107(c)(2)(i)(B)(2) applies that says to use info subCLINs to identify ACRNs and the amount of the associated funding. 

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