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  • Question

    We are trying to host an on-site training event with a vendor on a GSA BPA. The cost for the course needs to be paid up front, and we will do that with the GPC. But the instructors travel needs to be reimbursed to the vendor after the event. GPC cardholder indicates we cannot pay for travel. How do we reimburse the vendor?


    Answer

    Instruction is a service (task) and as such all the costs that are required to complete that task are allocable to the purchase (i.e., necessary for performance of the work) when included in the vendor's / contractor's total price and the price is considered reasonable. That includes when thevendor breaks out the travel so it is visible, the travel is part of overhead costs, or when a single lump sum price is provided. The card can be used.

             However, it is highly advised against using the purchase card to pay for vendor / contractor travel costs as a separate charge from the services required or directly to a hotel on behalf of the contractor. It could give the appearance of trying to defeat the micro-purchase threshold (MPT) for services by paying for those costs separately . Even if the charges combined are under the services MPTs, it gives the perception of improper use to auditors. But it doesn't mean it can't be done.

    This is where individual agency purchase card policies come into play; it is an agency-by-agency determination. I'd highly advise you to contact your agency's Level 1 Agency/Organization Program Coordinator (A/OPC) for specific agency guidance.

             

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