| Question |
Answer |
|
General Compliance Questions |
|
When
can/should I contact FAS? |
You should
contact FAS when you have questions that relate to the scheduling or
performance of compliance reviews (review methodology, not
policy interpretations), specific issues contained in compliance
reports, and documentation required for eligible expenditures (discussed below).
FAS staff can also answer questions relating to the
Federal Travel Regulations (FTRs).
Please remember that your assigned
FAS commodity marketing program specialist should be your first point of contact for all
policy-related inquiries. |
|
How
does FAS schedule reviews? |
Every effort
is made to review as many FAS program participants as possible each year. However,
priority is given to reviewing new participants, large participants
and participants with previous review findings. In addition, FAS commodity and
marketing program managers provide input into the annual
review plan. Although some participants may only be reviewed every
second, third, or fourth year, these reviews will cover the entire
period of time since the last review. FAS contacts each participant at
least 30 days prior to the start of a review and follows up with a
written confirmation of the review dates. |
|
General Program Questions |
|
What
exactly does it mean to say that the
Foreign Market
Development
(FMD) Program
and
Market Access Program
(MAP) are
"reimbursable
programs"? |
The intent of
these programs is to reimburse participants for approved expenditures
that have already been made. Accordingly, participants cannot request
reimbursement: (1) for expenditures that were made prior to the start
of the marketing year in which the activity is approved; and (2) prior
to the actual payment for approved expenses. |
|
When
are
sales and trade relations expenses
(STREs) permitted? |
STREs are
permitted only at overseas events when individuals from overseas
trade, opinion leaders, foreign government officials, and other
similar target groups are present. STREs are not authorized for
reimbursement in the U.S., or at any U.S.-based activities (including
international trade shows held in the U.S.). |
|
Does
FAS reimburse the cost of cell phones and their usage for FMD and MAP?
|
FAS will
reimburse the cost of cell phone "air time" devoted to program
activities. However, phone equipment, equipment repair, insurance, or
other charges are not reimbursable under FMD and MAP. For more
information, please refer to the policy notice "Reimbursement
of Telephone Calls and Internet Expenses" (11/18/03). |
|
Are
product samples reimbursable under FMD and MAP? |
No, product
samples are not reimbursable under FMD or MAP. However, certain
product samples may be reimbursed under the
Quality Samples Program.
|
|
Are
there any limits on awards and gifts? |
Giveaways,
awards, prizes, gifts, and other similar promotional materials are
subject to a $1.00 per-item limitation. The $1.00 per-item
reimbursement is extended to MAP Branded Program participants.
|
|
What is "equal access"? |
Participants
must be able to demonstrate that equal access to FAS-funded activities
is afforded to all eligible companies, growers, etc., in a fair and
transparent manner. Information should include how recruitment is to
be accomplished and guidelines concerning how companies will be
selected to participate in the activities, if participation is limited
because of space, cost, etc. |
|
Documentation/Review Questions |
|
What
do participants need to do prior to an on-site
review? |
Please have
all documentation ready for FAS reviewers when the the review begins.
Please see the checklist (.pdf) for information
on the documents that need to be available for review. Additional
information may be provided in the confirmation letters. |
|
How
does FAS incorporate a participant’s Unified Export Strategy (UES) into
the review? |
FAS reviews
the UES to ensure that the constraints/countries, etc., were consistent
with expenditures made. If, for example, a constraint involving lack
of consumer awareness was associated with expenditures for wholesale
trade magazine ads, FAS would identify and report this as being
inconsistent. |
|
What
are the requirements for program participant accounting systems and
records? |
Although the
applicable program regulations address all of the requirements, three
important requirements are that: (1) financial management systems must
conform to generally accepted accounting principles; (2) records of
expenditures and contributions must include information by activity
plan/marketing plan year, country or region, activity number and cost
category; and (3) receipts are required for all STRE expenses and all
other expenditures in excess of $25. In addition, the accounting
system and records should provide a clear audit trail. |
|
What
is a "clear audit trail"? |
A clear audit
trail consists of: (1) copies of all reimbursement claims; (2) a
general ledger or summary spreadsheet that ties the supporting
documentation to each line item on the reimbursement claims/activity
numbers; (3) invoices and original receipts for expenditures in excess
of $25.00 (all STRE); (4) proof of payment; and (5) supporting
documentation and proof of performance. |
|
Contracting Questions |
|
What
are the important contracting guidelines applicable to FMD and MAP? |
Participants
must ensure that all requirements under the FMD/MAP regulations
are met. Specifically, participants must:
- Conduct all contracting in an openly
competitive manner.
- Abide by the bidding thresholds in
the program policy that are based upon the total contract value to any
single vendor. Participants cannot break a single contract into parts
to avoid competition or the bidding threshold (e.g., splitting a
$45,000 contract into three $15,000 parts).
- Obtain receipts for all out-of-pocket
expenditures over $25 made by contractors.
- Ensure that no employee or officer
participates in the selection or award of a contract in which such
employee or official, or the employee’s or officer’s family or
partners has a financial interest.
For more information, please refer to
the "Contracting Standards and Procedures" policy notices for
FMD (10/13/99) and
MAP
(03/13/96).
|
|
What
is the maximum amount that a participant can pay a daily contractor? |
Daily
contractors are subject to the daily gross limitation of a
GS-15 Step
10. This limitation also applies to large contracts that include
contractor fees.
|
|
Travel Questions |
|
What are
participants entitled to in terms of meals and
incidental expenses (M&IE) on their first and last days
of travel? |
Under the
FTRs, a traveler receives 3/4 of a day of M&IE on the first day of an
overnight trip and 3/4 of a day of M&IE on the day of return. Note:
The elapsed travel time is used to calculate M&IE when a traveler
crosses the international date line. |
|
Are
participants allowed to claim business class airfare?
|
Business
class airfare is only permitted under the FMD program and only under certain conditions, as outlined in
FMD policy notice "Business
Class Airfare" (11/18/03; .pdf). The primary
determining factor is that the planned travel time, from the time the
first flight is scheduled to depart the gate until the time the final
plane is scheduled to arrive at the gate, on a given leg of the trip,
exceeds 14 hours. Participants who choose to fly business class when
not permitted under FMD or when traveling for other programs must
cover the cost of the upgraded portion of the ticket. When doing this,
participants must provide documentation from the travel agency
documenting the cost of a full-fare economy ticket at the time the
ticket is issued. FAS/CCC will only reimburse the participant for the
full-fare economy class ticket. |
|
What
is the "Fly America Act"? |
The "Fly
America Act" is a federal law that requires anyone traveling at the
federal government's expense to travel on U.S. flag carriers (includes
services provided under code share agreements) whenever possible. In
terms of documentation, the ticket (or documentation for an
e-ticket) must identify the U.S. flag air carrier’s designator code
and flight number.
|
|
I'm
using e-tickets. What proof of payment do I need for my supporting
documentation? |
When using
e-tickets, participants should obtain and maintain: (1) the passenger
receipt and/or travel agent issued itinerary showing price, carrier
code and point-to-point fares; and (2) the official itinerary, on-line
receipt, boarding pass and, if available, frequent flyer
documentation. Please note that FAS/CCC will reimburse any additional
costs associated with paper tickets/receipts. See the FMD/MAP policy
notice "Electronic
Ticketing for Airline Travel ("E-Tickets")" (11/19/02) for
more information. |
|
Are
participants allowed to purchase bulk airline tickets? |
Yes, provided
that the participant can provide: (1) the passenger receipt and/or
travel agent issued itinerary showing price and carrier code; (2)
proof of payment to the travel agency; and (3) documentation showing
the cost of the full-fare economy ticket for the same route at the
time of purchase (Note: If #3 is not provided, the cost of changing
the tickets, if changes are made after the travel commences, will not
be reimbursed.). |
|
Is it
really necessary to provide travel notifications to
FAS's overseas posts? |
Absolutely.
Participants are required to notify FAS's overseas posts prior to travel. Failure to
provide the required travel notification to an FAS overseas post or to maintain
documentation of such notification may result in the denial of travel
reimbursement requests. |
|
What
telephone calls and Internet expenses are eligible for reimbursement
while on travel? |
Travelers are
eligible for full reimbursement of documented program related
telephone calls and Internet expenses and emergency calls to notify a
family member of an injury or illness. Travelers are eligible for
limited reimbursement of personal telephone calls and Internet
expenses subject to daily limits of $5 domestically and $15
internationally per lodging night. For more information, please refer
to the FMD/MAP policy notice "Reimbursement
of Telephone Calls and Internet Expenses" (11/18/03). |
|
How is my
per diem calculated when I travel across the international dateline
(IDL)? |
When you
cross the IDL, your actual elapsed travel time will be used to
compute our per diem entitlement rather than calendar days. (See
Federal Travel Regulation 301-11.19) |
