Audit Services RFP Final_.pdf

Request for Proposal:

Audit Services

May 12, 2021

Office of Inspector General Legal Services Corporation

3333 K St, NW Washington, DC 20007 https://oig.lsc.gov/

Inquiries should be directed to:

Alison Ottenbreit Operations Specialist aottenbreit@oig.lsc.gov https://oig.lsc.gov/ mailto:aottenbreit@oig.lsc.gov

T A B L E O F C O N T E N T S

I. PURPOSE

II. BACKGROUND

III. PROCUREMENT STRATEGY

IV. STATEMENT OF WORK

V. PROJECT MANAGEMENT AND QUALITY CONTROL

VI. PROPOSAL INSTRUCTIONS

VII. PROPOSAL EVALUATION

VIII. OPTION YEARS

IX. PROPOSAL DELIVERY

X. PLACE OF PERFORMANCE

XI. CONFIDENTIALITY

XII. LSC OIG’s RIGHTS

XIII. FREEDOM OF INFORMATION ACT

XIV. CONTRACT NEGOTIATION

XV. CERTIFICATIONS

APPENDIX A: TRAVEL REIMBURSEMENT POLICY

I. PURPOSE

The Office of the Inspector General (OIG) of Legal Services Corporation (LSC) has a requirement for various audit type services related to oversight of Congressional appropriations. The purpose of this Request for Proposals is to contract with an organization to conduct performance, operational, and compliance audits of LSC and its 132 grantees operations. The audits will include financial, technology, and internal control related objectives.

II. BACKGROUND

The Legal Services Corporation (LSC) receives the bulk of its funding through congressional appropriations. For example, LSC received $465 million in fiscal year 2021 appropriations from Congress to provide financial assistance for civil legal aid to low-income Americans. Over 90% of these funds will be distributed to 132 grantees. LSC’s 2021 funding continues a four-year increase in funding from Congress. Additionally, as a part of the CARES Act, Congress appropriated $50 million in supplemental funding to the LSC for legal aid work to prevent, prepare for, and respond to coronavirus, domestically or internationally, provided the funds are not expended for purposes prohibited or contrary to any provisions of particular sections of Public Law. LSC awarded and distributed $49.5 million (99%) to grantees and is using the remaining $500,000 for management and oversight costs.

LSC also received $15 million in funding for disaster relief efforts in FY 2017 and again in FY 2019. Additional supplemental funding may be forthcoming. Finally, LSC also receives some private funding through donations.

The LSC Office of Inspector General (OIG) operates under the Inspector General Act of 1978, as amended, 5 U.S.C. App. 3, and has two principal missions: (1) to promote economy and efficiency in the activities and operations of LSC and its grantees; and (2) to prevent and detect fraud and abuse. Within the OIG, the audit division is responsible for conducting audits and reviews of LSC programs and its grantees. The audit division’s work includes:

• Performance, operational, and compliance audits of LSC;

• Performance, operational, and compliance audits of LSC grantees; and,

• Other audit-related activities.

III. PROCUREMENT STRATEGY

The OIG intends to enter into a one-year contract with three option years. During the contract period, the OIG will issue task orders for audit services as needs arise.

The selected offeror will respond to each task order with a draft statement of work (SOW) that includes descriptions of services, price, deliverables, project management plan, staffing, and other elements as requested in accordance with all applicable terms and conditions of this contract. SOWs will be either capped Time and Materials or Firm Fixed Priced, and the offeror will perform the services at prices consistent with labor rates and categories provided in response to this RFP. The OIG and the selected offeror will agree to the terms of the SOW. The OIG anticipates releasing a minimum of 2 task orders in the first contract year and a maximum of 20 task orders over the life of this contract (including option years).

IV. STATEMENT OF WORK

The OIG is seeking a qualified audit firm to conduct various audit type services related to oversight and expenditure of funds appropriated by Congress. Services also may involve some review of privately raised funds. Audit services will be performed in accordance with Generally Accepted Government Auditing Standards, AICPA, and LSC standards. The successful candidate will perform the following audits of LSC and LSC grantees:

A. Performance Audits

Performance audits are engagements that provide assurance or conclusions against stated criteria such as specific requirements, measures, program outcomes, or defined business practices. They are based on an evaluation of sufficient, appropriate evidence. Performance audits should include financial, internal control, and information technology objectives.

Performance audits may be conducted on LSC’s and LSC grantees’ use of CARES Act funding, LSC’s Oversight of CARES Act funding, and physical security and employee health and safety. Other performance audits may also be requested as the OIG deems necessary.

B. Operational Audits

An operational audit is a systematic process of evaluating an organization's operational effectiveness, efficiency and economy for all operations under management’s control. Then the results of the evaluation are reported along with recommendations for improvement to the appropriate individuals.

Operational audits should include financial, internal control, and information technology objectives. Operational audits may target the effectiveness and efficiency of LSC’s Office of Financial and Administrative Services or selected internal controls at LSC grantees, among other possible subjects.

C. Compliance Audits

Compliance audits are engagements that provide assurance or conclusions to compliance criteria established by laws, regulations, contract provisions, grant agreements, and other requirements (financial or nonfinancial) that could affect the acquisition, protection, use and disposition of the entity's resources and the quantity, quality, timeliness, and cost of services the entity produces and delivers. For this RFP, compliance audits may include financial, internal control, and information technology objectives, and topic areas may include grantee compliance with LSC’s regulations on LSC’s interest in grantee properties, among other possible topic areas.

The OIG may request any of the audit types listed above for LSC or grantees. In addition, the OIG may ask the offeror to recommend audit work that would be beneficial to the OIG or LSC in furthering our mission to promote economy and efficiency.

For each of the audit types listed above, the offeror should describe its approach to risk-based audits. It should include the standard audit phases, including an engagement letter, entrance conference, a risk assessment and risk-based audit plan, fieldwork phase, reporting phase, and wrap-up. The Fieldwork should include a description of the offeror’s general approach to sampling, test work, document review, and auditee exit conference. The offeror should also discuss all reporting to be completed at the end of each audit, to include discussion and final draft reports, and a debriefing meeting with the OIG.

Prior to each audit, the OIG will provide a task order to the offeror for a specific audit to be conducted. The response to this task order will be a draft SOW as discussed above and should detail the work to be conducted in a specific audit aligned with standard audit procedures described in response to this RFP. Once approved, the OIG will hold an audit initiation meeting with the offeror to review the type and purpose of the audit, discuss staffing, discuss all relevant auditee information, provide all necessary documentation, and develop plans for initiation of the audit.

After the initiation meeting, the contractor should develop a workplan within 15 business days. This workplan should include all audit steps to undertake with detailed sampling plans and levels of testing, a list of documents to be reviewed, a list of staff to speak with, questionnaires or other forms to be completed by auditee staff, and other pertinent information to prepare for fieldwork. The workplan should also include a detailed timeline for the project, including major milestones.

Once the OIG has reviewed and approved the workplan and all questionnaires and other documents developed for the audit, fieldwork should begin. The OIG requests a minimum of two weeks to approve the workplan, questionnaires, and other documents. The offeror will be responsible for scheduling and completing the required fieldwork for each audit and should obtain prior approval from the OIG for travel. The OIG will facilitate the scheduling of site visits and document collection by informing each auditee that it has been selected for an audit. The offeror may assist with drafting of communications to auditees to assist the OIG. The offeror must receive approval from the OIG prior to contacting the auditee.

At the completion of fieldwork, the offeror should hold an exit interview with the auditee. Then the offeror should provide a discussion draft report of the audit to the auditee and the OIG. The OIG and the auditee should be allowed up to five business days to review the discussion draft report and provide feedback. The report should detail the steps taken in the audit, the documents reviewed, and the findings and recommendations that result from the audit. Once the OIG and the auditee have provided feedback, the offeror should issue a Final Draft Report. This draft will go to the auditee, who will be allowed 30 days to respond in writing with comments as well as planned corrective actions. The OIG will also be given time to respond. The offeror will then revise the Final Draft Report, incorporate the written comments, and provide the Final Report no more than 10 business days after receipt of the OIG’s comments on the draft report. After the delivery of each final report, the offeror should hold a debriefing meeting with the OIG to review findings and recommendations.

All audit documentation, including full and complete sets of work papers, must be delivered to the OIG in full prior to issuance of draft audit reports. The offeror must factor the OIG’s review into the deliverables timeline and provide sufficient time, as specified by the OIG, for review.

V. PROJECT MANAGEMENT AND QUALITY CONTROL

The selected offeror will conduct all requested audits in accordance with Generally Accepted Government Auditing Standards, AICPA, and LSC standards. Given the number of audits to be performed, project management and quality control will be critical to ensuring the success of this contract and each audit. Project management should include the following activities.

A. Post-Award Conference.

The offeror will meet the OIG for a post-award meeting with within 10 business days of contract execution at the OIG offices (3333 K Street, NW, Washington, DC 20007) or virtually as determined by the OIG. Prior to the meeting, the OIG will provide a contract that all parties will sign in advance of the meeting. At the meeting, the offeror will introduce key staff and establish communication with the OIG. The purpose of this meeting will be to assure a common understanding of contract requirements and to begin project activities. At this meeting the OIG will provide key points of contact for this contract, introduce staff, and discuss initiating contract activities, including the first task order(s).

B. Project Management Plan

Within 15 business days of the post-award conference, the offeror should submit a detailed project management plan. The offeror should describe in this plan its approach to project management, and how it will manage conducting multiple audits simultaneously. Likewise, the project management plan should include a description of the staffing structure and staffing plan for multiple, concurrent audits. The project management plan should articulate the management and communications strategy the offeror will use to ensure the OIG is kept up to date on all project activities, risks, and issues that may arise, and it should detail the offeror’s quality control plan.

The project management plan should include a reasonable potential schedule outline for each audit type with all milestones and deliverables, labor category assignments, levels of effort by staff level, and an approximate timeline for completion of each audit. Milestones should include, but are not limited to, an audit initiation meeting with the OIG, initial communications with the auditee, submission of initial documents to the OIG, beginning of fieldwork, close of fieldwork, draft report, final report, and OIG debriefing.

When developing this schedule outline, the offeror should describe potential schedule slippages due to unknown site conditions or the need for schedule adjustments due to circumstances beyond the offeror’s control. The OIG recognizes that each audit is unique, and many variables impact the schedule, so this schedule outline will not be considered binding for any specific audit, but we will ask that a formal schedule be provided for OIG approval for each audit.

C. Communications Plan The offeror should provide a full communications plan to explain how it will keep the OIG abreast of all ongoing activities throughout the duration of the contract. At a minimum, communications should include monthly status reports (MSR) to the OIG on all audit activities, regular check-in with the OIG as needed, and ongoing communications with the OIG to address any concerns, questions, or issues.

Each MSR should include ongoing audit activities, planned activities, issues and resolution strategies, and risks to the audit(s). The MSR should also indicate any action items for the OIG, including items awaiting OIG approval.

In addition, the offeror should hold regular status check-in meetings (in person and/or virtually), at an interval to be agreed upon between the offeror and OIG, to provide updates on audit status, outstanding issues, action items, risks, and other pertinent audit information.

The offeror should bring serious issues or significant deficiencies to the attention of the OIG promptly. The offeror should communicate with the OIG as frequently as warranted by circumstances, to discuss major impediments that may hamper the progress of the engagement. Any delays or problems that may cause revisions to the project scope or delivery schedule should be brought to the attention of the OIG as soon as they become known. Such communication may be in the form of electronic mail, conference/video call, or personal visits to the OIG office to arrive at appropriate solutions.

Impediments that may entail the need for additional labor hours or funding will require a contract or SOW modification.

D. Quality Control

The offeror should provide a description of its quality control procedures, detailing how it will maintain the highest quality and all accounting standards throughout each audit and across simultaneous audits. The offeror should explain how it plans for quality control at the outset of a project, and then how it carries these through in a project. The description should include any specific processes, checks, or checklists utilized for products and deliverables. The offeror should describe how work products are maintained and audit processes are documented to ensure compliance with GAGAS and the Uniform Guidance. The OIG also should have access to workpapers upon request.

VI. PROPOSAL INSTRUCTIONS

Responses to this RFP shall be submitted on the most favorable terms, from both experience, staff, and price standpoints, that the offeror can propose. The offeror’s proposal should be no more than 15 pages long (excluding resumes, cover page, and Table of Contents (TOC)) in no less than 10-point font.

A. Statement of Work

The offeror should describe its approach to conducting performance, operational, and compliance audits, including all listed components. The approach should describe all tasks and activities, milestones, and deliverables included throughout the audit process as detailed in the SOW and this RFP. The offeror should also describe its approach to communication and coordination with the auditee (LSC and grantees) to conduct the audit. The successful offeror will have the capacity to work in all the audit service areas listed in the RFP.

B. Corporate Capabilities

1. Organization, Size and Structure: The Offeror shall describe its organization history, size, structure, and practice areas. The organization should be an audit firm certified or licensed by DC Board of Accountancy (or other appropriate state licensing authority) that meets applicable requirements.

2. Audit Experience: The offeror should describe in detail its experience conducting performance, operational, and compliance, audits, to include audits with financial, internal control, and IT components in accordance with GAGAS and AICPA standards and Uniform Guidance. The offeror should discuss experience with working with federal OIGs and/or the LSC OIG. Likewise, the offeror should describe experience auditing non-profits, federally appropriated organizations, and federal grantees. The offeror should include experience related to auditing of federal grant-making and grantee organizations. Experience with LSC and the LSC OIG should also be discussed.

3. Project Management and Quality Control: The offeror should discuss its approach to project management and quality control to ensure all tasks and activities are completed on time, on budget, and of the highest quality. The offeror should provide a detailed project management plan, describing how it will coordinate multiple LSC projects among staff to ensure on time and on budget delivery. The project plan should include a description of any tools used in project management, such as workplans, project schedules, risk mitigation plans, and any other tools used. Additionally, the offeror should maintain a key point of contact to coordinate all OIG projects and to liaise with the OIG.

The offeror should describe its approach communications with the OIG to keep the OIG informed of ongoing activities, important items of note, and changes to the project scope, timeline, or other issues or risks that might arise. The offeror should explain all elements of its communication plan.

Finally, the offeror should describe their plan and approach to quality control. The plan should describe how quality is assured throughout every step of each audit, from kickoff meeting through all project activities to ensuring all deliverables are of the highest quality.

4. Staff: The offeror shall describe its proposed teaming structure, including the roles and responsibilities of each team member and the distribution of work among each team member. The structure should include a project manager who serves as the OIG’s primary point of contact to keep it updated on all audit activities across all audits.

The offeror should also describe its general approach to staffing, to ensure that all team members have the essential knowledge, skills, and abilities necessary to conduct the work. The offeror should explain how staff will be selected and assigned to audits under this contract, as well as how staff will be replaced in the event it becomes necessary. Finally, the offeror should describe their process for recruitment, hiring, continuous development, and evaluation of personnel to ensure that its workforce has the essential knowledge, skills, and abilities necessary to conduct the engagement.

The proposal should demonstrate that staff have the knowledge and prior experience required for the work to be completed. Staff assigned to this contract must collectively possess the competence needed to address the engagement objectives and perform their work in accordance with GAGAS. Staff should have experience with federal OIGs, federal grantees, federal grantors, LSC, performance, operational, and compliance audits with financial, internal control, and IT elements, non-profit audits, or any other relevant experience. Staff qualifications, certifications, and relevant information should also be included. Partners and Supervisory auditors should hold a CPA, CIA, or CISA. The offeror should submit resumes (as appendices) of representative staff who may work on this project. Resumes should include descriptions of education, certifications, position in the firm, years with the firm, years and types of experience, continuing education, and applicable licensing information.

C. Pricing

The price proposal shall be submitted separately from the technical proposal.

The Offeror should provide labor categories and hourly rates by professional classification for the first year and the following options years for duration of the contract (four years). The Offeror should also provide any anticipated out-of-pocket expenses, excluding travel. The offeror will also identify any conditions that might increase or reduce the cost of the proposed services.

Any out-of-pocket expenses should also be provided. Travel expenses will be paid on a reimbursable basis by the OIG consistent with its policy. This policy is provided in Appendix A. The offeror should provide a list of assumptions considered as a part of this pricing.

D. References

The offeror shall provide the current name, address, contact information (email and COVID appropriate telephone number), and a project description for at least three client references with whom the offeror has worked in the past three years. The work completed should include performance and internal control audits, along with other similar work to that described in this

RFP.

E. Interview At the OIG’s discretion the Offerors’ Partner/Principal and Manager/ Supervisor on the proposal will be available for an introductory presentation and interview during the procurement evaluation.

VII. PROPOSAL EVALUATION

A. Non-responsive Proposals

Proposals may be judged non-responsive and removed from further consideration if any of the following occur:

1. The proposal is not received timely;

2. The proposal does not follow the specified format;

3. The proposal does not include the Certifications; or

4. The proposal is not adequate for the reviewers to form a judgment that the proposed activities/price are sufficient to complete the work.

B. Proposal Evaluation

The OIG will make an award to the offeror whose proposal conforms to the solicitation and provides the best value – the most advantageous balance of price and experience, including past performance. In addition, evaluation of each proposal will include the following criteria, which may not be weighted equally.

1. Statement of Work: The OIG will assess the offeror’s understanding of the work to be performed as demonstrated by the description of the approach to complete all tasks described this RFP.

2. Corporate Capability:

A. Organization, Size, and Structure: The OIG will ensure that the offeror is a licensed audit firm of sufficient size and capacity to conduct the work requested.

B. Audit Experience: The OIG will assess the offeror’s understanding of the work to be performed and their experience conducting similar projects as demonstrated by work described in response to Section VI above. The OIG will give particular focus to previous experience with performance, operational, and compliance audits with financial, internal control, and IT components conducted in accordance with GAGAS and Uniform Guidance. The OIG will also focus on experience with federal OIGs and experience auditing federal grant-makers and grantees.

C. Project Management and Quality Control: The OIG will evaluate the offeror’s approach to project management and quality control and the steps it will take to ensure all work products are of the highest quality, that all work in completed on time and on budget, and that all work is completed in line with professional auditing standards. The OIG will ensure that the offeror provides a complete project management plan, quality control plan, and realistic schedule estimates.

D. Staff: The OIG will evaluate the offeror’s staffing plan and structure, including the mix of levels, to assess whether staffing will be effective for completing all required tasks and activities for audit projects. The OIG will also assess the offeror’s approach to project staffing and recruitment, hiring, development, and evaluation of staff to ensure staff have the necessary skills, knowledge, and abilities for this RFP. The OIG will evaluate the qualifications of representative staff based on descriptions and resumes submitted.

Evaluation criteria will include education, position in the firm, years and types of experience, continuing professional education, certifications, and applicability of prior project work.

E. Past Performance: The OIG will assess the offerors’ past performance, including:

i. Relevant experience in providing similar services to similar organizations;

ii. References: After the OIG has made a preliminary determination regarding an offeror with whom it may contract, the OIG will contact and assess the references of that firm.

F. Interview: If an interview is conducted, the OIG will assess the offerors’ senior staff introductory presentation and interview.

3. Price (to be separately submitted): The OIG will evaluate the proposed hourly rates for each labor category for each option year for accuracy and reasonableness.

VIII. OPTION YEARS

The OIG intends to enter into a contract for the work described in this RFP with up to three option years for performance of audit services. Each option year, if exercised, will include additional audits. The decision to exercise yearly options and the number of audits to conduct will be solely within the OIG’s discretion.

IX. PROPOSAL DELIVERY

A. Submission: Proposals must be received no later than 5 PM Eastern Time June 11, 2021. The OIG reserves the right to exclude late proposals from consideration. Each Offeror will submit an electronic copy of their proposal to

Alison Ottenbreit at aottenbreit@oig.lsc.gov.

B. Inquiries: Inquiries concerning this RFP should be directed to Alison

Ottenbreit (telephone: 301-440-2175; email: aottenbreit@oig.lsc.gov). As it deems appropriate, the OIG will answer questions related to the RFP by email and will copy all prospective offerors. Questions should be submitted by May 28, 2021 at 5 PM Eastern Time.

C. Conditions of Proposal: All costs incurred in the preparation of a proposal responding to this RFP will be the responsibility of the Offeror and will not be reimbursed by the OIG.

D. Right to Reject: The OIG reserves the right to reject any and all proposals received in response to this RFP.

E. Notification of Award: Upon conclusion of final contract negotiations with the selected offeror, all offerors will be notified electronically.

X. PLACE OF PERFORMANCE

The majority of the work will be conducted at the Contractor’s offices and at the offices of LSC or the grantee being audited. Some meetings may occur at LSC offices (3333 K St., NW, Washington, DC 20007). All travel expenses will be reimbursed in accordance with the OIG’s travel reimbursement policies provided in Appendix A. If health and safety concerns attributable to the COVID-19 pandemic remain after contract award, work may be conducted remotely in lieu of the auditee’s offices. The OIG and contractor will discuss and come to a decision regarding health and safety concerns as needed. The contractor will make its own travel arrangements, at the most reasonable costs that will be advantageous to the OIG, consistent with the LSC OIG Contractor Travel Reimbursement Policy.

XI. CONFIDENTIALITY

As part of the ensuing contract with the OIG, a successful offeror will be required to enter into a confidentiality clause, requiring information related to this audit to be kept in strict confidence, other than the reports submitted to and approved by the OIG. Any such agreement will not limit certain lawful reporting of fraud, waste or abuse.

XII. LSC OIG’s RIGHTS

Notwithstanding any other statement in this RFP or otherwise, the LSC OIG reserves the right to:

A. Accept or reject any or all proposals, or any part thereof; Waive any informalities or technicalities contained in any proposal received;

mailto:aottenbreit@oig.lsc.gov

B. Conduct discussions with respondents and accept revisions of proposals after the closing date;

C. Make an award based upon various selection criteria;

D. Request clarification from any respondents on any or all aspects of its proposals;

E. Cancel or re-issue this RFP at any time;

F. Retain all proposals submitted in response to this RFP; and, G. Invite some, all, or none of the respondents for interviews, demonstrations, presentations and further discussion.

XIII. FREEDOM OF INFORMATION ACT

The Freedom of Information Act (FOIA) and associated LSC regulations may require the LSC OIG to disclose certain documents to the public, including portions of your proposal. Generally, we will not release any documents that would cause offerors competitive harm. You are encouraged, however, to label any confidential information contained in your proposal to facilitate our ability to withhold it from disclosure.

XIV. CONTRACT NEGOTIATION

The selected Offeror will be invited to enter contract negotiations with the OIG.

XV. CERTIFICATIONS

A. The individual signing certifies that he/she is authorized to contract on behalf of the Offeror and to make these certifications.

B. The individual signing certifies that the Offeror is a properly licensed Certified Public Accountant and/or Certified Internal Auditor.

C. The individual signing certifies that the prices quoted in this proposal have been arrived at independently, without consultation, communication, or agreement for the purposes of restricting competition.

D. The individual signing certifies that the firm complies with the GAO requirement of an external quality control review at least once every three years, where applicable.

E. The individual signing certifies that the Offeror, including any individuals to be assigned to the audit, does not have a record of substandard audit work and has not been debarred or suspended from doing work with any Federal, state or local government. (If the Offeror or any individual assigned to the audit has been found in violation of any state or AICPA professional standards, this information must be disclosed).

F. The individual signing certifies on behalf of the Offeror that the Offeror will not subcontract any portion of the work.

G. The individual signing certifies that the Offeror carries professional malpractice insurance.

H. The individual signing certifies that the Offeror is an Equal Opportunity Employer and does not discriminate in hiring, employment, or activities because of race, color, religion, national origin, sex, age, marital status, personal appearance, sexual orientation, gender identity or expression, family responsibilities, genetic information, disability, matriculation, political affiliation, or any other characteristic prohibited by law.

Dated: ________________________________

Offeror's Firm Name: ____________________________________________

Signature of Offeror's Representative: ___________________________________

Printed Name & Title of Individual Signing: _____________________________________

APPENDIX A: TRAVEL REIMBURSEMENT POLICY

Legal Services Corporation Office of Inspector General

Contractor Travel Reimbursement Policy

I. Purpose

This policy governs the OIG’s reimbursement of travel costs incurred by OIG contractors.

II. Reimbursable Travel Expenses

When a contract calls for reimbursement of travel expenses, the OIG will reimburse (1) the cost of airplane tickets or other appropriate mode of transportation and (2) the cost of necessary lodging, provided the costs claimed by the contractor are reasonable. In such cases, the OIG will also pay (3) a per diem payment for each traveler as determined below. The OIG will not reimburse other travel costs except as described below.

To be reimbursable, travel expenses must be reasonable and necessary to complete the work contemplated by the contract. The expenses must represent the lowest available rates for accommodations of the sort ordinarily used in the contractor’s field of business. The OIG will not reimburse travel costs when the location of the work to be performed under the contract is within 50 miles of the contractor’s offices and/or the traveler’s place of residence. If personal and business travel are combined, the traveler and/or contractor is responsible for any additional transportation cost; LSC will only reimburse the cost of business travel.

A. Mode of Transportation

Travel is to be completed by means of transportation most beneficial to the OIG and the traveler considering cost, time, and other pertinent factors. Travel by common carrier is presumed to be the most advantageous method of transportation and must be used when reasonably available. The OIG will not pay for first class or business class travel unless it is documented that no other options are available. The OIG will reimburse baggage fees based on the requirements of the carrier. Rental cars expenses must be pre-approved. The OIG will not reimburse for rental car insurance other than that minimally required by law or for expenses arising out of any damage to a rental car. If a personal automobile is used, reimbursement for mileage will be available at the IRS established rate, currently 57.5 cents per mile. See -https://www.gsa.gov/cdnstatic/OGP%20Signed%20CY_2020_POV_Mileage_Rate_Bullet in_-_12-9-2019.pdf.

The cost of buses, streetcars, subways and taxicabs incurred in connection with out-of-http://www.irs.gov/ http://www.irs.gov/ https://www.gsa.gov/cdnstatic/OGP%20Signed%20CY_2020_POV_Mileage_Rate_Bulletin_-_12-9-2019.pdf https://www.gsa.gov/cdnstatic/OGP%20Signed%20CY_2020_POV_Mileage_Rate_Bulletin_-_12-9-2019.pdf town travel are reimbursable provided they are reasonable as defined in this policy. The OIG will not reimburse taxi expenses to and from restaurants. If a personal automobile is reasonably used as transportation to and from an airport or the terminal of origin, the OIG will reimburse parking costs. The total reimbursement for mileage to and from that airport or terminal and parking is limited to the cost of the same travel by taxi.

B. Lodging

Lodging expenses are reimbursable when reasonable and incurred in connection with out-of-town travel. While the contractor may not be eligible for GSA rates, the OIG will use those rates as one factor when evaluating the reasonableness of lodging expenses.

Lodging expenses may exceed the GSA rate and still be deemed reasonable.

C. Per Diem

The OIG will reimburse meals at a per diem rate as specified in Chapter 5, Part III.D of LSC’s Administrative Manual. Per diem rates are available on the GSA website at http://www.gsa.gov/portal/content/101518.

D. Other Allowable Expenses

For purposes of this policy, the term “other allowable expenses” shall refer to baggage fees, reasonable and necessary taxi fees, mileage to and from a principal mode of transportation, airport or terminal parking fees, reasonable internet connectivity at a place of lodging to the extent that other access is not available, and similar items, as limited by other sections of this policy.

E. Non-Reimbursable Expenses

Expenses that will not be reimbursed include the following:

(1) Alcoholic beverages and entertainment;

(2) Laundry, dry cleaning, and pressing;

(3) Travel insurance;

(4) Parking fines;

(5) Charges incurred because of indirect travel for personal reasons;

(6) Gratuities and tips paid to potters, waiters, bellboys, and hotel maids inside the lodging facility;

(7) Nonproductive time related to official travel to and from one’s out-of-town destination;

(8) Any charges, fees, or other associated costs related to the making of reservations or other accommodations for travel; and

(9) Similar expenses.

http://www.gsa.gov/portal/content/101518

III. Authorization of Travel

Excepting emergency situations and expenses qualifying as “other allowable expenses,” the OIG will only pay travel costs that are preapproved. The contractor will submit proposed travel costs using the attached Travel Request Form at least three weeks in advance of travel to the Administrative Manager1. If the proposed costs are reasonable and consistent with this policy, the Administrative Manager will forward the Travel Request Form to the Project Manager with a recommendation for approval. To the extent he or she agrees with the recommendation, the Project Manager will sign the Travel Request Form. The Project Manager’s signature indicates approval. Once signed, a copy will be forwarded to the contractor via email by the Administrative Manager. Other allowable expenses, defined in Section II.D of this policy, need not be submitted for preapproval provided they are reasonable.

When the field work under an OIG contract necessitates changes in preapproved travel plans, the contractor shall inform the Administrative Manager of the changes as soon as possible. If the change occurs before scheduled travel, the contractor shall submit updated approval requests. Emergency travel expenses, defined to include unforeseeable travel costs that arise in the course of business travel, will be reimbursed if they are reasonable and consistent with this policy. In such emergencies, the contractor will submit details of the change and a justification by email to the Administrative Manager at the earliest date possible.

Official travel by independent contractors of the OIG outside the contiguous 48 states of the United States must be approved in advance by the Inspector General.

IV. Submission and Payment of Travel Expense

The contractor will submit a Travel Expense Report for each instance of travel to the Project Manager with supporting documentation, including receipts for transportation, lodging, and fees associated with Other Reimbursable Expenses. It is recommended that the traveler keep a record of all expenditures to be used in the expense report. The contractor will specify the number of full and partial days of travel for each traveler. All Travel Expense Reports must be signed and returned within 15 days of the conclusion of the travel.

Travel Expense Reports will be reviewed by the Administrative Manager. Where the OIG determines that the full claim is not adequately supported or reimbursable, it will communicate its determination to the contractor as soon as possible and allow the contractor to provide additional documentation. Any corrected Travel Expense Report must be returned for processing within 10 days.

The Administrative Manager will determine which expenses are allowable (based on the contractor’s submitted Expense Report form and supporting documentation) and indicate his or

1 Should the needs of a particular contractor dictate that it gives shorter notice; the OIG will be amenable to establishing a shorter deadline on a per-contract basis.

her determination on a copy of the contractor’s reimbursement form. The Project Manager will then review the submission, indicate approval or disapproval by notation and signature, and, if approved, forward the package to the Comptroller of LSC for payment. The OIG has the final authority to determine whether claims are reimbursable under this policy.

V. GSA Rates

The OIG is not entitled to use the GSA rates for airplane tickets where those tickets will be used by contractors or other persons not employed by LSC.

VI. Applicability of LSC’s Travel Policy

To the maximum extent possible, the OIG will interpret consistent with the LSC Travel policy contained in Chapter 5 of LSC’s Administrative Manual. Use of LSC’s travel Policy as an interpretive guide is not, however, intended to establish an employer employee relationship between the OIG and a traveler employed by or working at the direction of a contractor.

Travel Request Form

FROM: (Contractor Name)

(Contractor Address)

PROJECT: _

AUTHORIZING OFFICIAL:

AUTHORIZING SIGNATURE:

TRAVELER NAME:

DATE:

PURPOSE OF TRAVEL:

Dates of Travel

Departure City & State

Arrival City & State

Departure Time

Carrier & Flight/Train # Fare Other

Fees

Total: $ $

Total Fares and Fees: $

Booking Agent:

Fare & Fees Confirmed Through (Date):

Optional

Name and Locations of Hotel No. of Nights Cost Per Night

Total Per Trip $

Rates Confirmed Through (Date):

Rental Car Company City & State No. of Days Vehicle Type Total Cost

Total: $

Rates Confirmed Through (Date):

Other Requirements:

Approval (Initialize)

Office of Financial and Administrative

NON-EMPLOYEE TRAVEL REIMBURSEMENT FORM

INSTRUCTIONS

1. Complete the top half of the form.

2. Submit the following to Bernie Brady at bradyb@lsc.gov within 30 days of completing your travel.

Please complete and sign the reimbursement form electronically.

o Reimbursement Form o W-9 o Receipts

HOW TO COMPLETE THE REIMBURSEMENTS TABLE

To complete the table, enter any expenses for which you are seeking reimbursement.

*If LSC made your travel arrangements, do not include those expenses.

1. Enter the date of the expense in the first column.

2. Describe the expense (e.g., “cab to airport”) in the second column.

3. Select the type of expense in the third column.

4. Enter the amount of the expense in the fourth column.

GUIDELINES

All reimbursements are limited to the cost of the allowable government fare, or the actual cost of the expense if less.

Meals

• You will only be reimbursed for meals up to the per diem amount. You will be reimbursed for 75% of per diem on days you are traveling to and from the event. LSC will not reimburse you when meals were provided.

• Per diem rates can be found at https://www.gsa.gov/portal/content/104877.

Mileage

• Mileage is reimbursed at $0.535 per mile traveled.

• Tolls are reimbursed where applicable.

• Include a Google Maps printout showing the mileage traveled.

Parking

• At the hotel, parking fees are reimbursable for personal vehicle use.

• At the airport, parking is reimbursable up to the economy lot rate.

Cab fare

• Cabs to and from the airport/hotel will be reimbursed.

• If you share a cab, one person should pay for it and write the names of those who shared the ride.

• Tips will only be reimbursed up to 15%.

• Private transportation will be reimbursed up to the prevailing cab fare.

*We encourage using the hotel shuttle (or other hotel-provided transportation) when possible.

If you have any questions, please contact Bernie Brady, Travel Coordinator, at (202) 295-1568 or bradby@lsc.gov or Martin Polacek, Accounting Manager, at (202) 295-1517 or polacekm@lsc.gov.

mailto:bradyb@lsc.gov http://www.gsa.gov/portal/content/104877 mailto:bradby@lsc.gov mailto:polacekm@lsc.gov

Office of Financial and Administrative

NON-EMPLOYEE TRAVEL REIMBURSEMENT FORM

NAME: ________________________________________ PHONE: ____________________________________

EMAIL ________________________________________ DATES OF TRAVEL: _________________________

START LOCATION: _____________________________DESTINATION: ______________________________

MAKE CHECK PAYABLE TO:

*Must match the name on the W-9 form.

MAILING ADDRESS:

REIMBURSEMENTS

DATE

DESCRIPTION

TYPE OF EXPENSE

AMOUNT

[SELECT]

[SELECT]

[SELECT]

[SELECT]

[SELECT]

[SELECT]

[SELECT]

[SELECT]

[SELECT]

TOTAL 0.00

□ I CERTIFY THAT THIS REIMBURSEMENT REPORT IS TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE.

TRAVELER’S ELECTRONIC SIGNATURE DATE

FOR INTERNAL USE

TRIP PURPOSE: DEPARTMENT CODE:

PROJECT:

LSC PAID

DATE

DESCRIPTION

TYPE OF EXPENSE

AMOUNT

[SELECT]

[SELECT]

[SELECT]

APPROVING SIGNATURE DATE

REIMBURSEMENT 0.00

LSC PAID 0.00

Travel Coordinator: Initials Date Accounts Payable Coordinator: Initials

Date Accounting Manager: Initials

Date

NON-EMPLOYEE TRAVEL REIMBURSEMENT FORM