Approval to exceed GSA lodging for LPSC 2015
It has been noted by some observant planetary scientists that the LPSC 2015 conference hotel rate exceeds the GSA allowable lodging for that time and place. Moreover, that hotel was filled almost immediately and the other options are even more expensive. Since lodging expenses in excess of the GSA charged to a NASA grant could leave some organizations in a difficult situation later (more on this below), we are providing this letter from SARA to make sure that SMD grantees attending LPSC 2015 may be reimbursed for their stay, at most hotels anyway.
The short version is that GSA says for zip code 77380 (which is that given by The Woodlands Waterway Marriott Hotel & Convention Center) that the maximum lodging for March 2015 is $132, less than the conference hotel and most of the other hotels in the area. This letter from SARA authorizes grantees who are paying for accommodations anywhere in the area so they can attend LPSC to charge their grant from NASA’s Planetary Science Division up to $250/night for lodging. This allowance of $250 is based on the quoted prices for the rooms and doesn't include tax. Any applicable taxes are also allowed, of course. If you are satisfied that this has solved your lodging cost problems you need read no further.
For those who want to know more and are wondering about my authority to do this, below is the longer version:
72 CFR 200.474 (c)(3) states: In the absence of an acceptable, written non-Federal entity policy regarding travel costs, the rates and amounts established under 5 U.S.C. 5701–11, (‘‘Travel and Subsistence Expenses; Mileage Allowances’’), or by the Administrator of General Services, or by the President (or his or her designee) pursuant to any provisions of such subchapter must apply to travel under Federal awards (48 CFR 31.205–46(a)).
What this means is that your organization can and probably should have a written policy regarding travel costs that allows you to what makes sense. In the absence of a written policy from your organization, if you charge more than the allowable lodging to your grant, it's possible that later if your travel were audited your organization could loose some $. So, while your organization is working on that policy we understand that you need to go to LPSC and it would be silly if you had to pay that out of pocket. GSA FAQ #17 on per diem notes that the Agency can authorize you to get reimbursed for actuals above the lodging, see http://www.gsa.gov/portal/content/104208#17. I asked the NASA Shared Services Center (who makes the grant awards and confirms what costs are allowable) they wrote ‘…for cases where there aren’t hotels in the area whose rates are within the GSA per diem rates I do not see anything prohibiting you from giving the approval of the actual lodging costs for a conference in “bulk” instead of individual approvals.’ Thus, I have been given the authority to approve the actual lodging costs and determined the threshold on consultation with the ROSES selecting official from the Planetary Science Division. This may not work for contracts, you should always consult with your contracting officer, but you might mention this to them.