Industry playbook · Government contractors

Government & Defense Contractors: FAR 31.205-46, JTR Per Diem & Fly America Act Travel Audit

For a government contractor, a travel cost is not just high or low; it is allowable or unallowable. FAR 31.205-46 caps lodging, meals and incidentals at the government per-diem rates in effect on the day of travel, limits airfare to the lowest priced fare available during normal business hours unless an exception is documented, and requires every trip to record date, place, purpose and traveler. The Fly America Act adds a carrier rule for government-financed international travel. A travel program built for these contractors enforces per-diem ceilings at booking, captures documentation in the PNR, and routes international trips through U.S.-flag carrier service unless an exception applies.

Updated 6 Nov 2026 · 7 min read · Industry-Vertical Corporate Travel Procurement Playbooks

31.205-46FAR cost principle for contractor travel
3 fieldsdate and place, purpose, traveler documented per trip
49 U.S.C. 40118Fly America Act carrier preference
Oct 1start of the federal fiscal year when CONUS rates reset

What FAR 31.205-46 actually requires

FAR 31.205-46 applies wherever the FAR Part 31 cost principles govern: cost-reimbursement contracts, and the indirect rates and cost-based pricing that flow into other contract types. Its main rules:

  • Per-diem ceiling, paragraph (a)(2). Lodging, meals and incidental expenses are reasonable and allowable only to the extent they do not exceed, on a daily basis, the maximum per-diem rates in effect at the time of travel: the Federal Travel Regulation for the contiguous United States, the Joint Travel Regulations for Alaska, Hawaii and outlying areas, and the State Department’s Standardized Regulations for foreign areas.
  • Only parts of those regulations apply, (a)(4). The FAR incorporates the maximum rates, the definitions of lodging, meals and incidental expenses, and the coverage of special or unusual situations. It does not import every FTR or JTR rule. Many contractors still adopt FTR conventions, such as reduced meal allowances on travel days, as company policy; (a)(6) notes that maximum rates are generally not a reasonable daily charge on partial travel days or when no lodging is incurred.
  • Special or unusual situations, (a)(3). Actual costs above per diem can be allowable up to the higher amounts permitted for federal civilian employees, but only if a condition for the actual expense method exists, an officer of the contractor approves a written justification, repetitive use in an area has advance contracting officer approval, and actual costs are documented, with receipts for each expenditure of $75 or more.
  • Documentation, (a)(7). Costs are allowable only if the date and place, the purpose of the trip, and the traveler’s name and title or relationship to the contractor are documented.
  • Airfare, paragraph (b). Airfare above the lowest priced airfare available to the contractor during normal business hours is unallowable, except where that fare requires circuitous routing, travel at unreasonable hours, excessively prolonged travel, increased cost that offsets the savings, is not adequate for the traveler’s physical or medical needs, or is not reasonably available to meet mission requirements. The exception must be documented and justified.
  • Company aircraft, (c). Owned, leased or chartered aircraft costs are generally limited to the allowable airfare unless the contract requires the aircraft or the contracting officer approves more, with manifests or logs kept.

Alcohol (FAR 31.205-51) and entertainment (31.205-14) are separately unallowable, so a hotel folio with bar charges must be split before it is charged. Expressly unallowable costs included in a final indirect cost rate proposal can draw penalties under FAR 42.709.

Per-diem ceilings: who sets them and how to use them

Contiguous U.S. (CONUS)
GSA sets lodging and meals and incidentals rates by locality for each federal fiscal year, starting October 1, with some localities seasonal. Check the current GSA per-diem table for the date of travel; do not reuse last year’s figure.
Alaska, Hawaii, U.S. territories
Non-foreign OCONUS rates are set by the Department of Defense and published by the Defense Travel Management Office, and can change monthly.
Foreign areas
The State Department Office of Allowances publishes foreign per-diem rates, updated monthly.
Lodging taxes
The FTR treats lodging taxes as a separate allowable expense rather than part of the lodging rate; confirm your treatment with your auditor or counsel.
GSA City Pair fares
City Pair contract fares are a government program for federal travelers. Contractors are generally not eligible for them; check GSA’s eligibility rules before assuming a fare is available.

The procurement point: per diem is a ceiling for allowability, not a price. In most cities, a negotiated commercial LRA rate below the lodging ceiling is available near the sites contractors visit. Near installations and in Washington, the gap between commercial rates and per diem moves with the season; the Washington and Northern Virginia corridor guide covers how to benchmark it, and the LRA vs NLRA page covers rate structure.

Fly America Act and Open Skies exceptions

The Fly America Act, 49 U.S.C. 40118, requires international air travel financed by the U.S. government to use U.S.-flag air carrier service where it is available. It covers contractors, consultants and grantees whose travel the government pays for, not only federal employees. For contracts, FAR subpart 47.4 implements it through the clause at FAR 52.247-63, Preference for U.S.-Flag Air Carriers. Unjustified foreign-carrier costs are not reimbursed.

  • Code-share counts as U.S.-flag service when the ticket is bought under the U.S. airline’s designator code and flight number, even if a foreign partner operates the aircraft.
  • Open Skies exceptions. GSA recognizes four agreements with a government-procured transportation provision: the European Union, Australia, Switzerland and Japan. The United Kingdom is no longer covered by the EU agreement from January 1, 2021, so London itineraries need separate analysis. The Australia, Switzerland and Japan agreements apply only when no City Pair fare exists between the origin and destination.
  • DoD-funded travel is excluded from the Open Skies exceptions. A defense contractor charging travel to a DoD contract cannot rely on them.
  • Cost and convenience are not exceptions. Unavailability of U.S.-flag service, under the time-based tests in the FTR, is; document it on the PNR.

Transatlantic joint ventures complicate this, because the cheapest fare on a U.S. carrier’s code may be operated by a partner. The London corridor page and the DACH page cover the carriers involved.

Contractor travel compliance benchmarks

ControlTypical contractorAudited target
Trips with date, place, purpose and traveler documented85%–95%100%, captured in PNR
Lodging nights above ceiling without justification8%–15%<1%
Lowest available fare documented at booking50%–75%100%, OBT fare log retained
International government-funded trips with Fly America record60%–85%100%
Folios split for alcohol and entertainment40%–70%100% before charging
Contract or charge number on every trip80%–95%100%
Commercial LRA rates at or below per diem in top cities20%–40% of nights70%+

Business Travel Consulting 2026 benchmarks from contractor travel files and audits. These are internal control rates, not DCAA findings.

Interactive tool · Savings estimator

Government Contractor Travel Compliance Estimator

Estimate savings and avoided unallowable cost from per-diem enforcement, trip documentation, Fly America routing, lowest-fare control and commercial rates under the ceiling.

1 Annual T&E spend
$
$250K$50M
2 Trips per year
trips
10050,000
3 Share of trips with lodging above per diem and no justification
%
0%40%
4 Average lodging excess over ceiling per affected trip
$
$20$1,000
5 Government-funded international trips per year
trips
05,000
6 Share of those trips on foreign carriers without a documented exception
%
0%50%

Estimated annual savings and avoided unallowable cost

$0

0.0% of annual T&E spend

  • Lodging held at or justified above per diem$0
  • Costs protected by complete trip documentation$0
  • Foreign-carrier costs avoided under Fly America$0
  • Airfare above lowest available fare avoided$0
  • Commercial LRA rates below the lodging ceiling$0
Largest lever 
Monthly run-rate 

Assumes 1% of spend at risk from missing documentation, a $2,400 average non-compliant international ticket, 4% of trips with a $450 fare excess, and 2.2 hotel nights per trip saving $18 a night; this is a cost model, not legal or audit advice.

DCAA-ready travel program playbook

  1. Weeks 1–3 — Test a sample like an auditor. Pull a statistical sample of trips charged to cost-type contracts and indirect pools and test each against (a)(2), (a)(7), (b) and Fly America. The forensic audit method covers the data join.
  2. Weeks 3–5 — Move documentation into the booking. Make trip purpose, contract or charge number and traveler title mandatory PNR fields so the record exists before the trip.
  3. Weeks 4–6 — Enforce ceilings at booking. Load per-diem lodging ceilings by locality into the OBT and require a justification and approval step above them. Store the lowest fare shown at booking with each ticket.
  4. Weeks 6–10 — Source commercial rates under the ceiling. Run a hotel RFP near the sites and installations you visit most, asking for LRA rates at or below the lodging rate.
  5. Ongoing — Monthly compliance file. TMC delivers exceptions: above-ceiling nights, non-lowest fares and foreign-carrier segments, each with its justification.

Clause 6.2 · Allowability data capture

Supplier shall capture, as mandatory PNR fields, trip purpose, contract or charge number and traveler title, shall retain the lowest available fare displayed at the time of booking, and shall flag every lodging rate above the applicable per-diem ceiling and every foreign-carrier segment on a government-funded trip, delivering an itemized exception report monthly.

Clause 6.5 · Fly America routing

For trips coded as government-funded international travel, Supplier shall book U.S.-flag carrier service, including code-share flights under the U.S. carrier’s designator and flight number, unless the traveler’s record documents an applicable exception, and shall not apply an Open Skies exception to any trip coded as DoD-funded.

TMC and OBT selection for contractors should score these fields explicitly; use the TMC RFP guide.

Executive FAQ

Questions procurement teams ask about this

Does FAR 31.205-46 make contractors follow the entire Federal Travel Regulation?

No. The FAR incorporates only the maximum per-diem rates, the definitions of lodging, meals and incidental expenses, and the coverage of special or unusual situations from the FTR, JTR and State Department regulations. Other FTR rules are not imported, although many contractors adopt some of them as company policy because it simplifies audits. Allowability is then judged against the FAR text and the contractor’s own documented practices.

When can a contractor’s lodging exceed the per-diem rate and stay allowable?

Under FAR 31.205-46(a)(3), in special or unusual situations, up to the higher amounts permitted for federal civilian employees under the actual expense method. A qualifying condition must exist, an officer of the contractor must approve a written justification, repeated use in one area needs advance contracting officer approval, and actual costs must be documented, with receipts for each expenditure of $75 or more.

Can a defense contractor use the Open Skies exception to fly a European airline?

Not on DoD-funded travel. GSA states that the Open Skies exceptions do not apply to travel funded by the Department of Defense. For civilian-agency funded travel, the EU, Australia, Switzerland and Japan agreements can apply, subject to their conditions, and the United Kingdom is no longer covered by the EU agreement. Otherwise, use U.S.-flag service, including U.S.-coded code-share flights.

What travel documentation does DCAA expect a contractor to keep?

At minimum what FAR 31.205-46(a)(7) requires: date and place of the expenses, purpose of the trip, and the traveler’s name and title or relationship to the contractor. Auditors also look for receipts consistent with the contractor’s policy, justification for lodging above per diem and for fares above the lowest available, Fly America exceptions, and removal of alcohol and entertainment charges before costs are claimed.

Where should contractors get current per-diem rates?

From the issuing source for the date of travel: GSA for the contiguous United States, reset each federal fiscal year on October 1; the Defense Travel Management Office for Alaska, Hawaii and U.S. territories; and the State Department Office of Allowances for foreign areas. Load the current tables into the booking tool rather than hard-coding a rate in policy.

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