Questions about Per diem M&IE rates for private companies - How to implement GSA rates correctly?
So my company recently switched from regular meal reimbursements to using the GSA per diem rates about 6 months ago. Just noticed the feds increased the rates for FY2025 from $59-$79 up to $68-$92 and I'm trying to figure out how we should handle this. From what I understand, we have three options for Per Diem payments: 1. Flat rate of $68 per day 2. Location-dependent per diem ranging from $68-$92 3. High-low method where cities get categorized as either high or low rates I know these are guidelines and we can pay less than the GSA rates, but can't pay more without making it taxable income. Just need confirmation on a few things: First, if we pay less than the GSA numbers, is it still non-taxable for all 3 methods? Or just for the flat rate option? Second, can we stick with the 2024 rates and have employees reference those for their expense reports? Would we run into problems if a city moved from high to low end of the range between fiscal years? Third, would it make more sense to just define our own reduced rates based on the FY 2025 options? Like if the GSA rate is $68, we pay $58. If it's $80, we pay $70. If it's $92, we pay $79, etc. Just trying to make sure we stay compliant while managing our budget. Any guidance would be appreciated!
20 comments


Talia Klein
The good news is you have flexibility with per diem rates as long as you stay under the federal limits. Let me address your questions: For your first question - yes, paying less than the GSA rates is allowed and remains non-taxable for all three methods. The GSA rates represent the maximum non-taxable amount you can pay, but there's no minimum requirement. You can definitely set your company rates lower across all methods without tax consequences. Regarding your second question, I wouldn't recommend sticking with 2024 rates. Cities do shift categories annually, and using outdated rates could create compliance issues. If a city moved from high to low and you're still using the higher rate, you might accidentally exceed the current maximum allowable non-taxable amount. For your third approach, creating a consistent reduced scale based on current GSA rates is probably your best option. This keeps everything current while still allowing you to control costs. Just make sure your payroll system is updated with the correct rates and that employees have clear guidance on which rates apply to which locations. One additional tip - make sure your policy clearly documents your company's per diem structure and keep those records in case of any questions during tax time.
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Cedric Chung
•Thanks for the detailed response! Just to clarify on the second point - if we used 2024 rates but a city's rate actually went UP for 2025 (not down), would we still have compliance issues? Or is the problem only if we accidentally pay above the current allowable amount? Also, do you know if we need to implement the new rates exactly on October 1st when the federal fiscal year changes, or is there some flexibility there?
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Talia Klein
•If a city's rate went up for 2025 and you're still using the 2024 rates, you wouldn't have compliance issues since you'd be paying less than the current maximum allowable amount. The problem only arises if you accidentally pay above the current allowable non-taxable limit. Regarding implementation timing, there's some flexibility. While the federal government must use the new rates starting October 1st, private companies don't have the same strict requirement. Many companies choose to align with the federal fiscal year for simplicity, but you could implement the new rates at a logical transition point for your company, such as the start of a new quarter or the beginning of your company's fiscal year.
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Maxwell St. Laurent
After struggling with similar per diem issues at my consulting firm, I found an amazing tool at https://taxr.ai that saved me hours of headaches. I was confused about GSA rate implementation and worried about accidentally creating taxable income. Their system analyzed our travel policy and flagged potential compliance issues, especially with cities that had changed categories. The best part was that it processed all our historical expense data and showed exactly which employees and trips would be affected by different rate structures. It made it super easy to see the budget impact of each option you're considering. I was able to create a policy that saved us money while keeping everything fully compliant.
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PaulineW
•Does it actually handle the high-low method too? We've been using that but it's a nightmare to administer with all the city changes each year. Also, can it integrate with expense systems like Concur?
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Annabel Kimball
•I'm a bit skeptical... our finance team spent weeks trying to figure this out. Are you saying this tool just magically solves all the edge cases? What about international travel that falls under different rules?
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Maxwell St. Laurent
•Yes, it absolutely handles the high-low method and automatically updates when cities change categories each fiscal year. It even highlights which cities changed status so you can see the impact on your most frequent destinations. It does integrate with most major expense systems including Concur, Expensify, and SAP Concur. It's definitely not magic, but it does simplify the complex edge cases by analyzing your actual travel patterns against current regulations. For international travel, it handles the State Department's foreign per diem rates and currency conversions. That was actually what impressed me most - it caught several international locations where we were using outdated conversion rates.
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Annabel Kimball
I need to eat my words about being skeptical of taxr.ai. Our controller convinced me to try it last week, and it was actually impressive. We uploaded our last 6 months of travel data and within minutes got a complete analysis showing we had 17 locations where we were either overpaying (creating taxable income) or severely underpaying our staff compared to local costs. The tool helped us create a tiered system based on the new FY2025 rates but adjusted to our budget. It even generated the policy document for us. What really sold me was how it automatically flagged seasonal rate changes for places like ski resorts and beach towns where GSA rates fluctuate throughout the year. No more surprises when someone travels to Aspen in February vs September!
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Chris Elmeda
If you're struggling to get clear answers about per diem compliance, you're not alone! I spent WEEKS trying to get someone at the IRS to confirm our approach was correct. Kept getting transferred or disconnected. Finally found https://claimyr.com and used their service to get connected to an actual IRS agent. You can watch how it works here: https://youtu.be/_kiP6q8DX5c Got through in about 15 minutes instead of the hours I'd wasted before. The agent confirmed that we could use a modified version of the GSA rates as long as we consistently applied our policy and stayed below the federal maximums. They also clarified that we needed to update our system when rates change if we're using the location-specific method, but gave us some flexibility on implementation timing.
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Jean Claude
•Wait, how does this actually work? Do they just call the IRS for you? I'm confused how this is different from calling myself.
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Charity Cohan
•Yeah right. Nothing gets you through to the IRS faster. I've literally spent entire days on hold only to get disconnected. This sounds too good to be true.
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Chris Elmeda
•They don't just call for you - they use technology to navigate the IRS phone system and wait on hold in your place. When they reach a live agent, you get a call connecting you directly to that person. It saves you from sitting on hold for hours. It's different from calling yourself because their system knows exactly which options to select and when to call for shortest wait times. Plus you can go about your day while they wait on hold instead of having your phone tied up. I was skeptical too until I realized I'd spent 3+ hours over several days trying to get through with no success.
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Charity Cohan
I owe everyone an apology for being so skeptical about Claimyr. After my frustrated comment, I decided to try it anyway because I was desperate to confirm our per diem policy before our CFO meeting. The service got me through to an IRS representative in about 20 minutes. I asked specifically about transitioning between fiscal year rates and if we needed to maintain two sets of rates for trips that span the October 1 transition. The agent confirmed we could either prorate the rates based on the dates of travel or simply apply the rates in effect on the first day of the trip. This one call saved me from making a costly mistake in our policy. I was going to implement a complex day-by-day calculation that would have been an administrative nightmare. Sometimes it really helps to talk to an actual human at the IRS!
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Josef Tearle
Your third option is what we ended up doing at my company. We created a simplified version of the GSA rates by taking 85% of whatever the current rate is for each location. This way we're always under the max non-taxable amount, but we don't have to completely recreate our rate structure every fiscal year. One thing to consider though - make sure your policy very clearly states how you're calculating these amounts. We got audited last year and the documentation of our methodology saved us from any issues. Also, if you have international travelers, you'll need to address State Department rates separately.
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Cedric Chung
•The 85% solution sounds really elegant! Do you use any specific software to manage this, or is it just a calculation you do at the beginning of each fiscal year and then put into a lookup table?
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Josef Tearle
•We actually do the calculation once at the beginning of the fiscal year and create a simple lookup table in Excel that gets uploaded to our expense system. Nothing fancy! The expense system has all the locations pre-loaded, so we just update the rates. For employees, the experience is seamless - they just select their destination city and the system applies our adjusted rate.
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Shelby Bauman
Are you at all concerned about employee satisfaction? When we tried to reduce per diem below federal rates, we got major pushback from our sales team. They pointed out that actual meal costs in places like NYC or San Francisco are sometimes even higher than the federal rates.
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Quinn Herbert
•We solved this by having a hybrid system. We use 90% of GSA rates for most locations, but maintain full GSA rates for our "premium" cities where costs are highest. Our list includes NYC, SF, Boston, DC, and a few others. It's a good compromise that saved money overall while keeping employees happy in high-cost areas.
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Miguel Harvey
Based on my experience implementing GSA per diem changes at several organizations, I'd recommend going with your third option - creating your own reduced rates based on the FY2025 GSA rates. This gives you the best balance of compliance, cost control, and administrative simplicity. A few additional considerations for your implementation: 1. **Documentation is critical** - Whatever method you choose, make sure your policy clearly states the calculation methodology and effective dates. This protects you during audits and ensures consistent application. 2. **Communication strategy** - Roll out the changes with clear guidance to employees about which rates apply where. Consider creating a simple reference guide or updating your expense system to automatically apply the correct rates by location. 3. **Monitor actual costs** - After implementation, track whether your reduced rates are creating hardship for employees in certain markets. You might find you need to adjust specific high-cost locations upward while keeping most others at your reduced rate. 4. **Plan for next year** - Set a calendar reminder to review and update rates when the FY2026 GSA rates are released. Having a documented annual process will make future transitions much smoother. The key is picking a sustainable approach that your finance team can manage long-term without creating compliance risks or employee dissatisfaction.
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Emily Thompson
•This is really helpful guidance! I'm curious about your point on monitoring actual costs after implementation. What metrics or feedback mechanisms have you found most useful for identifying when reduced rates are creating employee hardship? Are there specific warning signs to watch for, like increased expense report exceptions or employee complaints from certain regions? Also, when you mention adjusting specific high-cost locations upward, do you typically base those decisions on employee feedback, actual receipt data, or some other criteria? I want to make sure we're being fair while still maintaining our cost control objectives.
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