Guidance for Development Program Contractors – Eligible Costs for Commercial Contracts in Response to COVID-19
In response to COVID-19, commercial contractors have relocated staff to Australia (or a third country) and are working remotely to deliver agreed project deliverables. In some cases staff have redeployed back in-country. The guidance below has been provided to commercial contractors through the International Development Contractors Community.
The guidance below has been updated, given Australia is no longer in a Do Not Travel environment. The Australian Government has reverted travel guidance to country-level information and warnings. Contractors should continue to remain up to date with all relevant travel advice and must continue to manage the risks of travel appropriately.
This guidance is intended to supplement details around existing reimbursable items and arrangements outlined in the relevant contract.
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1. COVID-19 Testing outside of Australia
Costs for mandatory COVID-19 tests conducted outside of Australia are a reimbursable expense to be funded out of the operational budget of the contract. Examples of mandatory tests include, but are not limited to: pre-travel requirements by airlines or governments for international or domestic travel; meetings with partner government officials; or before attendance at site visits; or other program related requirements where testing is mandated by the partner government.
All other costs for meeting COVID-19 testing requirements are to be covered by the Adviser or the Managing Contractor under their insurance cover, as with other medical costs.
2. COVID-19 vaccines
If a contractor is able to access a vaccine in the work location that has been approved or recognised by the Australian Therapeutic Goods Administration (TGA), the cost of the vaccine only may be reimbursed. The TGA is constantly reviewing COVID-19 vaccines that may be recognised for the purposes of inbound travel to Australia, contractors are encouraged to remain up to date with recognised vaccines on the TGA website.
Information on vaccines that Australia has approved for use can also be found here: Approved COVID-19 vaccines | Australian Government Department of Health, and on Smarttraveller.
The Australian Government cannot provide advice on the safety, quality and efficacy of vaccines that have been approved for use outside of Australia's regulatory process. Australian citizens abroad are encouraged to consult their local health professional for advice on vaccine options, including assistance that may be available locally.
DFAT will not reimburse the cost of a vaccine not listed above.
3. Quarantine costs
Mandatory quarantine periods at more than one location will require approval by the Delegate prior to departure.
a) For long term advisers mobilising (back) into the work location overseas:
The costs associated with the mandatory quarantine period when returning in-country (including salary costs) is an operational cost and DFAT will reimburse these where DFAT has agreed that the adviser is critical and can deploy.
- After a period of leave: If the Adviser continues to work during a mandatory quarantine period, DFAT will cover the associated mandatory quarantine costs for the adviser and any dependents.
Where possible the estimated cost for the quarantine period, along with an assessment of what work duties will be able to be completed should be agreed by the relevant Agreement Manager and approval in writing given for the eligible reimbursable costs before the mobilisation.
- For new deployments: DFAT will reimburse mandatory quarantine costs. Mobility and housing allowance will not commence until the quarantine period has ended. The decision to deploy dependents rests with the Managing Contractor, not DFAT.
b) For long term Advisers returning to Australia or a third country – at the completion of a contract:
DFAT recommends the adviser depart from the work location prior to the contract end date, to enable the quarantine period to be completed while under contract. If the adviser continues to work during the mandatory quarantine period, DFAT will cover the associated mandatory costs.
- Mobility allowance will not be paid for periods of mandatory quarantine at the completion of a contract.
- If the adviser is unable to leave the work location before the end of the contract, the Delegate may approve mandatory quarantine costs at the home destination without a requirement to undertake work.
- The expectation is that the Managing Contractors will book flights and support the adviser to enable departure before the contract end date.
If the adviser is unable to leave the work location due to no flight availability, the Delegate may approve a contract extension to cover this period. The Managing Contractor should consult DFAT before the end of the contract to seek approval for such an extension if needed.
Salary and allowances will not be paid for periods in quarantine after a contract has ended.
c) For long term Advisers returning to Australia or a third country – for leave:
The Adviser pays for the airfare, unless it is included in their contract. DFAT will pay the quarantine costs for one 'annual leave' visit in a 6-month period for long-term advisers. Additional annual leave requiring mandatory quarantine may be taken at the Adviser's expense.
- The duration of the leave must be for a minimum of 10 working days in order for DFAT to cover the quarantine costs at the leave destination, and the work location on return.
- Mobility allowance will be paid for the period the adviser is on annual leave, but will not be paid for the period of DFAT funded mandatory quarantine (whether in Australia or a third country, or on return to the work location).
- Additional costs for communications or other adjustments will not be paid by DFAT during the quarantine period.
If the Adviser requests to take annual leave during the quarantine period, then the adviser or the Managing Contractor is responsible for all mandatory costs.
4. Working away from the work location, after leave:
Any approval to undertake a period of work from Australia or a third country following annual leave will require pre-approval from DFAT before the leave commences.
Mobility allowance will not be paid for the period of work undertaken from Australia or a third country.
The Adviser will not be eligible for payment for additional costs from DFAT including accommodation and office costs associated with work undertaken in Australia following an approved leave break.
Advisers are expected to make their best endeavour to return to their work location at the end of an approved leave period, including completing all Australian Border Force checks and health check requirements at the work location (including COVID tests).
5. Other changes to leave entitlements
While many contractors were engaged under ARF conditions, including limits on how leave is to be managed, the unique circumstances associated with COVID-19 warrant some flexibility. We will allow managing contractors to manage staff in accordance with their broader workplace agreements (that is, the usual practice for managing contractors where the ARF is not involved). There should be no additional cost to DFAT associated with applying flexibility to leave.
Note that LTAs, STAs and Non-ARF personnel can now apply for sick leave, leave without pay, bring forward their annual leave, or utilise their annual leave at half pay as per the entitlements allowed in their contracts.
If the Delegate agrees that a temporary leave policy should be approved, ensure that:
- the cost of the policy does not increase the overall cost of the contract to DFAT.
- it cannot be paid from the program activity budget (ie it should come from personnel/administration costs).
- budget is available within the personnel/administration costs line.
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6. Cost of flights for relocation
If a contractor demobilises staff due to an escalation of risk in the work location, DFAT will reimburse the cost of flights to Australia (or a third-country) for the relocation of contractors and their immediate family members.
7. Ongoing accommodation costs in Australia
DFAT will not reimburse ongoing accommodation costs in Australia (or a third country) after the initial one month period after demobilisation in 2021. There is no contractual basis for second accommodation payments (noting that at this point DFAT continues to pay for in-country accommodation).
For staff who wish to have their goods shipped home these costs can be reimbursed under demobilisation allowances in current contracts.
For new deployments, or staff redeploying to the work location, DFAT will not reimburse unexpected accommodation costs due to delays in departure. As above, there is no contractual basis or second accommodation payments when in-country accommodation is still being covered.
8. Reimbursement for working from home costs
DFAT will not reimburse additional costs incurred by contracted staff who have been required to adjust working arrangements as a result of relocation. Where directed by their employer (Managing Contractors) we would expect the employer to cover these costs if they believe they are appropriate. For example, phone costs could be billed by the managing contractor as part of ongoing office costs.
For personal home office equipment to support an individual contractor, there are also legitimate tax deductions that Australian taxpayers can access to offset some costs.
9. Staff salary and conditions after demobilisation due to changes in risk in-country
For all long-term contractors who have relocated to Australia (or a third country) in 2021, DFAT agrees to extend the current salary and conditions arrangement, including mobility allowance, for one month only after demobilisation. Any exemptions are to be approved by AS ABB.
Contracted staff working to deliver agreed outcomes will continue to receive their salary, including the mobilisation allowance and where appropriate, education support as previously approved for one child. The reimbursement of salary and mobilisation allowance will only apply to contractors continuing to work on agreed projects as determined by DFAT. Where DFAT decides to not to continue an aid program in whole or in part, the payments will cease (once the fair notice period has elapsed).
a) Education Supplement
Agreement Managers are requested to review provision of the education supplement with the Managing Contractor for staff that have not yet redeployed.
Reimbursement of the education supplement may continue for relocated Advisers if the Delegate is satisfied that the eligible dependent remains enrolled in a school at the work location and are continuing with distance learning (and have not enrolled in a school in Australia).
In recognition of the extended period that Advisers and their families may be away from their work location, an adjustment can be made to the education supplement.
For Advisers who have relocated to Australia (or a third country) the ARF limit on payment of the education supplement for one child only can be increased to a maximum of three dependent children.
The additional education supplement will cease when the Adviser returns to the work location and is in receipt of mobility allowance.
The education supplement cannot be cashed out or used for any other purpose.
Eligible aid project costs
While acknowledging the unusual circumstances, DFAT expects all partners to be cost conscious in all matters and to continue to adhere to all safeguard requirements. DFAT will work flexibly with partners to maintain progress towards project outcomes while ensuring a value for money approach. DFAT has asked contractors to consider alternate operating models including:
- re-phasing of activities;
- increased utilisation of personnel resident within the project country;
- increased utilisation of suppliers (goods and services) operating in the project country; and
- remote and virtual work.
DFAT Agreement Managers are advised to confirm with their managing contractors revisions to the Annual Plan and agreed milestones for the remainder of 2021-22 and to plan for 2022-23.
c) Residential and commercial office leases
Reimbursement of lease costs may continue for Advisers who have relocated if the Delegate is satisfied that the ongoing accommodation lease costs represent value for money for the Commonwealth.
Agreement managers and managing contractors are requested to review commercial and residential leases for staff that have demobilised in 2021, and to make an assessment of ongoing needs within two months after demobilisation.
Where an Adviser's contract is due to end within three months after demobilisation, or if they have advised that they do not intend to return, we recommend that careful consideration is given to the residential lease and the shipment or storage of household goods and a value for money decision should be made by the Delegate on these costs.
Agreement Managers are requested to review household and commercial leases on a monthly basis with the Managing Contractor for staff that are not in-country.
d) Shipping goods to Australia or placing household goods in storage:
For relocated Advisers who wish to have their goods shipped home these costs can be reimbursed under demobilisation allowances in current contracts.
Advisers may also elect to have their household goods placed in storage at the work location. These costs can be charged to the demobilisation line item.
An agreed end date for goods to be stored at DFAT's expense should be recorded and not extend past the end date for the Adviser's employment contract
Subject to the Delegate's decision, based on a value for money test, DFAT will reimburse the costs for the return of household goods to the work location for redeployed Advisors (i.e. a return shipment).
The Delegate should take account of the period of time between shipments, changes to the household composition and length of time left on the Contract.