QCR RFP Final.pdf

Request for Proposals For

Audit Review Services

August 6, 2020

Office of Inspector General Legal Services Corporation

3333 K St, NW Washington, D.C. 20007

Inquiries should be directed to:

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

Table of Contents

I. BACKGROUND ____________________________________________________________ 1

II. PURPOSE ________________________________________________________________ 1

III. STATEMENT OF WORK____________________________________________________ 1

A. Project Description _____________________________________________________________ 1

B. Deliverables __________________________________________________________________ 2

C. Communications _______________________________________________________________ 3

IV. OPTION YEARS __________________________________________________________ 4

V. PLACE OF PERFORMANCE ___________________________________________________ 4

VI. SUBMISSION AND PAYMENT OF INVOICES ___________________________________ 4

VII. CONFIDENTIALITY _______________________________________________________ 5

VIII. PROPOSAL INSTRUCTIONS ________________________________________________ 5

A. Technical proposal: _____________________________________________________________ 5

B. Price Proposal _________________________________________________________________ 6

C. Optional Interview _____________________________________________________________ 7

IX. SUBMISSION INSTRUCTIONS _______________________________________________ 7

X. EVALUATION PROCEDURES__________________________________________________ 8

A. Non-responsive Proposals _______________________________________________________ 8

B. Technical proposal _____________________________________________________________ 8

C. Price Proposal _________________________________________________________________ 9

XI. LSC OIG’s RIGHTS ________________________________________________________ 9

XII. FREEDOM OF INFORMATION ACT __________________________________________ 10

XIII. CONTRACT NEGOTIATION ________________________________________________ 10

XIV. CERTIFICATIONS ________________________________________________________ 11

APPENDIX A. LIST OF CURRENT INDEPENDENT PUBLIC ACCOUNTANTS _________________ 12

APPENDIX B: TRAVEL REIMBURSEMENT POLICY ____________________________________ 15

I. BACKGROUND

The Legal Services Corporation (LSC) provides grants to independent legal organizations (grantees) which, in turn, provide free civil legal assistance to those who could not otherwise afford it. Each LSC grantee is required by statute to have an annual audit conducted by an independent public accountant (IPA). Omnibus Consolidated Rescissions and Appropriations Act of 1996, Pub. L. 104-134, 110 Stat. 1321, § 509(a) (April 26, 1996), incorporated by reference in subsequent appropriations measures. The audit is required to be conducted in accordance with auditing standards generally accepted in the United States of America, as well as Generally Accepted Government Auditing Standards (GAGAS), issued by the Comptroller General of the United States, and the Audit Guide for Recipients and Auditors (the Audit Guide), issued by the Office of Inspector General (OIG). The LSC Audit Guide incorporates some requirements of the Office of Management and Budget (OMB) Uniform Grant Guidance, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Grant Guidance). In addition to a financial statement audit, the OIG requires that compliance and internal control audits be conducted as prescribed by the Office of Management and Budget Uniform Grant Guidance, and the LSC OIG Audit Guide for Recipients and Auditors. As part of an ongoing, multi-year Quality Control Program, the OIG intends to contract for a series of Quality Control Reviews (QCRs) to help ensure the quality and integrity of the IPA process.

As a federally funded non-profit entity, the LSC OIG qualifies for General Services Administration (GSA) and non- profit rates. This Request for Proposal is not subject to the Federal Acquisition Regulation.

II. PURPOSE

The purpose of this Request for Proposal (RFP) is to solicit proposals for a fixed-price contract for the services of a public accounting firm to assist the OIG by conducting Quality Control Reviews (QCRs) of the financial statement and compliance audit documentation for 15 to 35 LSC grantee audits over a twelve-month period according to an agreed upon schedule.

III. STATEMENT OF WORK

A. Project Description

The 15 to 35 QCRs to be performed under this contract have two objectives:

https://www.oig.lsc.gov/images/96guide.pdf https://www.oig.lsc.gov/images/96guide.pdf

1. To determine whether the financial statement audit work, compliance audit work, and the associated review of internal controls over both financial reporting and compliance were conducted in accordance with applicable standards, including GAGAS, the published guidance of the OIG, and the American Institute of Certified Public Accountants (AICPA) professional standards. Because the OIG’s guidance incorporates, in large part, OMB Uniform Grant Guidance the QCRs will also determine whether the audits met the applicable requirements of the applicable guidance.

2. To identify any issues that may require additional attention or any additional audit work by the IPA under review.

The Contractor will perform 15 to 35 QCRs of audits covering the 2019 and 2020 fiscal year. The audit work to be reviewed is required by statute, Pub. L.

104-134, 110 Stat. 1321, § 509(a) (April 26, 1996). It is required to be conducted in accordance with GAGAS and guidance issued by the OIG, which, in large part, incorporates OMB Uniform Grant Guidance.

The Contractor may use the Council of Inspector’s General on Integrity and Efficiency Guide for Quality Control Reviews of Single Audits (the QCR Guide) to conduct the QCR. If the Contractor uses the guide, all LSC grantees will be considered major, high-risk programs. The Contractor’s use of the QCR Guide should take into account the audit guidance that the OIG has provided to the IPAs through the Audit Guide. In particular, the QCRs should note all regulations identified in Audit Guide, Appendix A: Compliance Supplement for Audits of LSC Recipients.

The OIG expects all 15 to 35 QCRs to be completed over a twelve-month period according to a specific schedule agreed upon at the time of contracting. The on-site portion of the QCRs will be conducted at the offices of the IPAs that performed the audit work under review barring any concerns for the health and safety of staff. The OIG will facilitate the scheduling of site visits by informing each IPA that it has been selected for a QCR. The Contractor will be responsible for making final scheduling arrangements for on-site work at the IPAs and receiving prior approval for travel from the OIG. The identity and locations of all current IPAs are provided in Appendix A.

B. Deliverables

1. Individual QCR Reports – Within 10 business days of completion of each https://www.ignet.gov/sites/default/files/files/Quality%20Control%20Review%20guide%20for%20Single%20Audits%20-%20final%20(Dec%202016).pdf https://www.oig.lsc.gov/images/96guide.pdf https://oig.lsc.gov/images/pdfs/ipa_resources/April_2016_Compliance_Supplement.pdf https://oig.lsc.gov/images/pdfs/ipa_resources/April_2016_Compliance_Supplement.pdf on-site review, the Contractor will provide:

a. An Individual QCR Report describing the work performed and stating specific and overall conclusions, findings, and recommendations regarding the quality of the IPA audit work reviewed. The Contractor should identify any issues that may require attention or additional audit work by the IPA under review.

b. Copies of all review documentation developed in conducting each QCR and any other documentation required to adequately support the conclusions in the QCR report.

Upon receipt of each Individual QCR Report the OIG will review and assess each report and accompanying documentation to determine what, if any, conclusions, findings, and recommendations will be communicated to the IPA. The Contractor is expected to conduct an exit conference with the IPA to communicate preliminary results of the QCR. However, formal communication of conclusions, findings, and recommendations to the IPA will be the responsibility of the OIG. In addition, the OIG will be responsible for monitoring any remedial action it requires IPAs to take as a result of QCR reports.

2. Final Summary Report – Within 15 business days of the submission of the final Individual QCR Report, the Contractor will submit a separate summary report. This summary report will identify any common issues that may require the attention of the OIG in future guidance to auditors. This summary report is intended to be a brief report and need not repeat every finding in the individual QCR reports.

C. Communications

The selected Contractor will meet with the OIG for a kickoff meeting within 10 business days of contract award at the OIG offices (3333 K Street, NW, Washington, DC 20007) or virtually as determined by the OIG. At the meeting, the Contractor 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 project and an initial list of IPAs to receive QCRs.

Within 30 days of contract award, the Contractor shall provide a project schedule. The schedule should include all approximate dates for site visits and delivery of key deliverables. When it determines that there is sufficient justification for doing so, the OIG may extend this schedule upon written request of the Contractor.

Throughout the project duration, the Contractor shall:

• Provide preliminary schedules of QCR visits to the LSC OIG project manager;

• Provide routine updates of schedule of actual site visits conducted to the OIG project manager;

• Accommodate questions from LSC OIG regarding QCRs;

• Accommodate requests to review and evaluate corrective actions taken by

IPAs to address recommendations in QCR reports; and,

• Accommodate general consultation with LSC OIG regarding the results and performance of QCRs.

IV. OPTION YEARS

The OIG anticipates entering into a contract for the work described in this RFP with one to three option years for performance of QCRs at other, similarly situated IPAs.

Each option year, if exercised, will include between 15 to 35 QCRs. The decision to exercise yearly options and the selection of IPAs to be reviewed will be solely within the OIG’s discretion, provided the Contractor does not have a conflict of interest with selected IPAs for the year in question.

V. PLACE OF PERFORMANCE

The majority of the work will be conducted at the Contractor’s offices and at the offices of IPAs under review. 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 B. If health and safety concerns attributable to the COVID-19 pandemic remain after contract award, work may be conducted remotely in lieu of the IPAs’ offices. The OIG and contractor will discuss and come to a decision regarding health and safety concerns as needed.

VI. SUBMISSION AND PAYMENT OF INVOICES

The Contractor may submit an invoice to the OIG for payment upon acceptance of Individual QCR Reports and upon acceptance of the Final Summary Report. The OIG will pay invoices on a per report basis. Payments will be made within 30 days of receipt and acceptance of an appropriate invoice for work performed under the contract.

In the event the OIG rejects a report, it will state the reason(s) for the rejection in a written notification. The right to reject any particular report shall extend for thirty

(30) days after the Contractor submits the report in question.

VII. CONFIDENTIALITY

As part of the ensuing contract with the OIG, a successful contractor will be required to enter into a confidentiality clause, requiring information related to these QCRs 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.

VIII. PROPOSAL INSTRUCTIONS

Proposals should be submitted on the most favorable terms, from both technical and price standpoints, that the Contractor can propose. Technical and price proposals shall be submitted as separate volumes, and the technical proposal should not exceed 10 pages. The QCR work will be performed under a fixed-price contract.

Each Contractor shall, at a minimum, include the following in its proposal:

A. Technical proposal:

1. Proposed Solution

The Contractor shall describe in detail its understanding of the work to be performed, a proposed plan for conducting the 15 to 35 IPAs to be reviewed, and a general review plan to be implemented in each review.

2. Prior Experience

The contractor shall describe their prior experience conducting comparable reviews. In addition, the contractor should explain experience with the Uniform Guidance, GAGAS, auditing grantees, LSC, OIGs, and any other relevant prior experience.

3. Past Performance/References

The Contractor shall describe its past performance in comparable review services. Include at a minimum the names, addresses, contact persons, and telephone numbers of three clients with whom the Contractor has worked in the past three years.

4. Examples of Prior QCR Work

The Contractor shall include with its proposal at least two examples of its prior work. Reports from QCR work of Single Audits are preferred, but reports from similar work will be accepted. For instance, QCR reports, and examples of Single Audit work products performed of entities similar in size, structure, and attributes as LSC (e.g., quasi-federal, non-profit, grant making, congressionally funded, etc.) are most helpful.

5. Staff Qualifications

The Contractor shall describe the qualifications and relevant experience of staff to be assigned to support the QCR program. The Contractor shall submit resumes of staff to be assigned, including descriptions of education, position in the firm, years and types of experience, continuing professional education that would satisfy GAGAS standards over the last two years, and professional certifications. Supervisory staff must be Certified Public Accountants (CPAs), and the OIG prefers that lower level staff hold CPAs as well. The proposal should demonstrate that the proposed staff has prior experience auditing in accordance with GAGAS for financial and compliance audits as well as prior experience in conducting quality control reviews of audit documentation.

6. Conflicts of Interest

Contractors are invited to submit proposals even though they may have up to five conflicts of interest with firms on the list of IPAs in Appendix A below. Contractors should specify the IPA firms with which they have conflicts. If the QCR contract is awarded to such a Contractor, the OIG will adjust its list of IPAs to eliminate the conflicts.

B. Price Proposal

1. Base Price

The Contractor will provide a uniform fixed price per QCR conducted as described in this RFP, excluding travel expenses, and a firm fixed price for the final summary report. The OIG intends to have 15 to 35 QCRs performed under the contract exclusive of options, but if for unforeseen reasons that number should change, the OIG will pay on a per-QCR basis for QCRs actually performed. While the OIG intends to enter into a fixed price contract, the Contractor’s price proposal should contain, at a minimum, the estimated number of hours per QCR for planning, field work, and reporting to allow for a full evaluation of the price. The Contractor will also provide number of hours and hourly rates by professional classification. Travel expenses will be paid on a reimbursable basis by the OIG consistent with its policy. This policy is provided in Appendix B. Any out of pocket expenses should also be provided.

2. Option Year Price

The OIG would prefer to enter into a contract with option years as indicated in Section IV above. Recognizing, however, that some Contractors may not be comfortable entering into a contract with three option years, the OIG is willing to consider proposals that include one to three option years. The Contractor shall include with its proposal option year prices per QCR for each yearly option.

C. Optional Interview

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

IX. SUBMISSION INSTRUCTIONS

The technical proposal (exclusive of appendices) should be no longer than 10 pages long. Price proposals should be submitted separate from technical proposals.

Examples of prior QCR work and resumes shall be included as appendices.

1. Submission: Each Contractor will submit an electronic copy of their proposal to the OIG, addressed to Alison Ottenbreit at aottenbreit@oig.lsc.gov. To be considered, the proposal, including certifications, must be received no later than 5 PM on September 4, 2020. The OIG reserves the right to exclude late proposals from consideration.

2. Inquiries: Inquiries concerning this RFP should be directed to Alison Ottenbreit (aottenbreit@oig.lsc.gov). As it deems appropriate, the OIG will answer questions related to the RFP by email and will copy all prospective contractors.

Questions should be submitted by August 20, 2020 at 5 PM Eastern Time.

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

mailto:aottenbreit@oig.lsc.gov

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

5. Notification of Award: Upon conclusion of final contract negotiations with the selected Contractor, all contractors will be notified electronically.

X. EVALUATION PROCEDURES

The OIG will use a Best Value source selection to select the most advantageous offer value – the most advantageous balance of price and technical qualifications, including past performance. Evaluation of each proposal will be based on the criteria below, which are not weighted equally.

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. Technical proposal

1. Proposed Solution – The OIG will assess the Contractor’s understanding of the work to be performed under the contract, the proposed plan for covering the 15 to 35 IPAs to be reviewed, and the general review plan to be implemented in each review.

2. Prior Experience – The OIG will assess the Contractor’s prior experience conducting QCRs of audit documentation for financial and compliance audits, particularly where the audit work was subject to GAGAS. In addition, the OIG will assess the Contractor’s experience auditing in accordance with

GAGAS.

3. Past Performance – The OIG will consider past performance as determined through references and other information.

4. Example of Prior QCR Work – The OIG will assess the general quality of reports submitted as examples of prior QCR work and gauge the degree to which similar reports would be an acceptable product of its QCR program.

5. Staff Qualifications – The OIG will evaluate the qualifications of the staff to be assigned to the QCRs based on education, position in the firm, years and type of experience, continuing professional education, and certifications. Additionally, the OIG will assess the mix of staff assigned to the contract.

6. Interview – If an interview is conducted, the OIG will assess the

Contractor’s senior staff introductory presentation and interview.

7. Conflicts of Interest – The impact of this adjustment on the QCR program will be factored into the OIG’s evaluation of the Contractor’s proposal.

C. Price Proposal

1. Base Price – The OIG will assess the uniform fixed price per QCR for which the Contractor proposes to perform the work.

2. Option Year Pricing – The OIG will assess the firm, fixed price per QCR that the Contractor proposes for each option year to the contract. At a minimum, this assessment will consider value to the OIG, the number of option years proposed, and the impact the option year proposal would have on the OIG’s administration of its program.

XI. 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;

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.

XII. 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 the Contractor competitive harm. You are encouraged, however, to label any confidential information contained in your proposal to facilitate our ability to withhold it from disclosure.

XIII. CONTRACT NEGOTIATION

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

XIV. CERTIFICATIONS

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

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

3. The individual signing certifies that the Contractor is a properly licensed certified public accountant.

4. 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.

5. The individual signing certifies that the Contractor, 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 Contractor or any individual assigned to the audit has been found in violation of any state or AICPA professional standards, this information must be disclosed.)

6. The individual signing certifies that the Contractor carries professional liability insurance – errors and omissions.

7. The individual signing certifies that the Contractor is an Equal Opportunity Employer and does not discriminate in hiring, employment or activities because of race, color, religion, sex, age, national origin, disability, or any other basis prohibited by law.

(Contractor's Firm Name)

(Signature of Contractor's Representative)

(Printed Name and Title of Individual Signing)

Dated this day of , 2020.

APPENDIX A. LIST OF CURRENT INDEPENDENT PUBLIC ACCOUNTANTS

IPA Firm IPA City IPA State AAFCPAs, Inc. Westborough MA Alexander Thompson Arnold PLLC Jackson TN Altman, Rogers & Co Anchorage AK Anderson Zurmuehlen & Co., P.C Butte MT Arledge & Associates, P.C. Edmond OK Axiom CPA's and Business Advisors LLC Albuquerque NM Baker Tilly Virchow Krause, LLP Minneapolis MN Barnes Dennig & Co., Ltd Crestview Hills KY Barnes Dennig & Co., Ltd. Cincinnati OH Barnes Wendling CPAs, Inc. Sheffield OH Barnes Wendling CPAs, Inc. Sheffield Village OH BCA Watson Rice LLP Miami FL Bert Smith & Co. Washington DC BKD, LLP Louisville KY Bollus Lynch LLP Worcester MA Brady Martz & Associates, P.C. Grand Forks ND Brady, Martz & Associates, P.C Bismarck ND Brown Armstrong Accountancy Co Bakersfield CA Brown, Ewing & Co., P.A. Ridgeland MS BT&Co, P.A. Topeka KS Burnham & Schumm P.C. Salt Lake City UT C. J. Schlosser & Company, L.L Alton IL Carr, Riggs & Ingram, LLC Houston TX CLA Toledo OH Clifton Larson Allen Lakeland FL Coley, Eubank & Company, P.C. Lynchburg VA Crowe LLP Indianapolis IN Cusack & Company, CPAs LLC Latham NY Dana F. Cole & Company, LLP Lincoln NE David G. Faw CPA Wayne PA David L. Gruber and Associates Newport Beach CA Deloitte & Touche LLC Saipan MP Denman & Company, LLP West Des Moines IA Dixon Hughes Goodman LLP Greenville SC Duplantier, Hrapmann, Hogan, & Maher LLP New Orleans LA EFPR Group CPA Williamsville NY Eide Bailly, LLP Phoenix AZ Eide Bailly, LLP Sioux Falls SD Ellsworth & Stout, LLC Las Vegas NV Esterbrooks Scott Signorelli, Duluth MN

Frank Barcalow, CPA, P.L.L.C. Williamsburg VA Gary McGee & Co. LLP Portland OR Gibson LeClair LLC Augusta ME Gomez, Fragoso & Associates, PC Brownsville TX Green & Associates LLC Brighton CO Grossman St. Amour CPAs PLLC Syracuse NY Harrington Group, CPAs, LLP Pasadena CA Harrington Langer & Associates St. Paul MN HBL CPAs, PC Tucson AZ Herman & Cormany, CPAs, A.C. Charleston WV Hicok, Brown & Company Abingdon VA Hinkle + Landers, CPAs Albuquerque NM HoganTaylor LLP Oklahoma City OK J. Miller & Associates LLC Philadelphia PA Jacobson Jarvis & Co. Seattle WA JMM & Associates Colchester VT Keefe McCullough & Co., LLP Fort Lauderdale FL KraftCPAs PLLC Nashville TN Legacy Professionals LLP Westchester IL Leonard, Mulherin & Greene, P.C. Braintree MA Maher Duessel, CPAs Harrisburg PA Mauldin & Jenkins, LLC Atlanta GA MCM CPAs & Advisors LLP Louisville KY Moore Grider & Company Fresno CA Moss Adams LLP San Diego CA N&K CPAs, Inc. Honolulu HI Ortiz, Rivera, Rivera & Co. San Juan PR Padilla, Medina & Associates,P.S.C. San Juan PR Paremelee Poirier & Associates Warwick RI Plante & Moran, PLLC Grand Rapids MI Purvis, Gray & Company, LLP Gainesville FL Reeder & Associates, PA Tampa FL Roberts, McKenzie, Mangan & Cummings Springfield MO Romeo, Wiggins & Company, L.L.P. Raleigh NC Roy & Rurak, LLC North Andover MA RSM US LLP New York NY RubinBrown LLP St. Louis MO Satty, Levine, & Caicco, CPAs, Jericho NY SB & Company, LLC. Owings Mills MD Schneider Downs & Co., Inc. Columbus OH SingerLewak LLP Riverside CA Sobel & Co. LLC Livingston NJ

Squar Milner LLP San Francisco CA SVA Certified Public Accountants, S.C. Madison WI Vachon Clukay & Company, PC Manchester NH Victor J. Cannistra, CPA, P.C. Mount Kisco NY Warren Averett, LLC Montgomery AL Watkins Uiberall, PLLC Memphis TN Weaver and Tidwell, L.L.P. Fort Worth TX Wegner CPAs, LLP Madison WI Whittlesey PC Hartford CT Winfrey Certified Public Accountants Columbia MO Wipfli LLP Milwaukee WI Wiss & Company, LLP Livingston NJ Yeo & Yeo, P.C. Flint MI Yeo & Yeo, P.C. Lansing MI Yoakum, Lovell & Co. PLC Benton AR Zwygart John & Associates, CPAs, PLLC Nampa ID

APPENDIX B: 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-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 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 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