Travel: Situations and rules specific to sponsored research
1. Foreign Travel
DO YOU KNOW what the definition of foreign travel is?
Searches on various websites resulted in the following:
- From NIH Grants Policy Statement:
- Foreign travel is defined as any travel outside of Canada and the United States and its territories and possessions.
- From NSF Grant Proposal Guide:
- Domestic travel includes the U.S., its possessions, Puerto Rico, and travel to Canada and Mexico.
- From USDA CSREES Budget Completion instructions:
- Domestic travel is travel in Canada, Mexico, or the U.S. or its possessions.
- From U.S. Education prior approval terms and conditions and in their clauses for cost-reimbursement contracts:
- Foreign travel is any travel outside Canada and the U.S and its territories and possessions.
From the Federal Travel Regulations:
- NON-foreign area is the fifty states, Puerto Rico, Guam, the Northern Mariana Islands and the territories and possessions of the U.S. (excluding the Trust Territories of the Pacific Islands).
There appears to be a slight variance among the agencies, so it appears that it would be good business practice to carefully identify any specific restrictions, terms, etc., on a particular award prior to planning travel. The Federal Travel Regulations definition appears to be the most limited one and would serve as a “default” in the absence of specific sponsor definitions.
DID YOU KNOW that the “Fly America Act” applies to all federally sponsored research (including federal flow-through sponsored research)?
Several of the federal agencies include explanatory information about the Fly-America Act in their grant policies, while some simply reference the act without further detail included. One of the most complete explanations I have found states:
Grantees must comply with the requirement that U.S. flag air carriers be used by domestic grantees to the maximum extent possible when commercial air transportation is the means of travel between the United States and a foreign country or between foreign countries. This requirement must not be influenced by factors of cost, convenience, or personal travel preference. The cost of travel under a ticket issued by a U.S. flag air carrier that leases space on a foreign air carrier under a code-sharing agreement is allowable if the purchase is in accordance with GSA regulations on U.S. flag air carriers and code shares. (A code-sharing agreement is an arrangement between a U.S. flag carrier and a foreign air carrier in which the U.S. flag carrier provides passenger service on the foreign air carrier’s regularly scheduled commercial flights.)
When making travel arrangements for foreign travel that will be funded by federal (and federal flow-through) funds, travelers should work through a travel agent (not make the arrangements on their own through the internet, etc.). They also need to advise the travel agent that a U.S. Flag Carrier or “code share” carrier is required and that the ticket needs to be purchased through the U.S. carrier, not the foreign carrier, even in code share arrangements. We recently had a desk audit by a federal agency of an award that included foreign travel and the purchase of airline tickets was closely scrutinized for compliance with this requirement. Please make sure your travelers’ purchases could stand up to such examination!
DID YOU KNOW that foreign travel must often be approved in advance to be allowable?
For certain sponsors or awards foreign travel is allowable only if approved in advance. For example, NSF requires that the foreign travel be specifically included in the budget or you must process an OPAS budget revision PRIOR to traveling. We have also seen awards that required trip reports or other specific approval of the travel, either just before travel takes place or just after return. Be sure your traveler is aware of any such restrictions before they plan their travel.
2. Allowability of Travel as a Direct Cost to a Sponsored Project
DID YOU KNOW that to be allowable, all travel must provide direct benefit to the project to be charged as a direct cost?
This is in accordance with OMB Circular A-21’s directives on treatment of costs as direct or indirect and with KSU’s federally approved Cost Accounting Disclosure Statement. In addition, various federal agencies include such a statement in their grant policies. While reviewing other university websites, I found that a number of them incorporate this requirement directly in their travel policies.
Some examples from other universities include:
All travel must be approved via an approval form and the form must be approved by the Contracts and Grants Office prior to travel. Explanation of the relevance of the trip to the funding project is required and the traveler must be paid from or otherwise directly involved in the project for the travel to be approved.
Effort reporting is required for anyone traveling on grant funds.
Only persons participating directly in the research may travel on grant funds.
At KSU, approval of travel is at the departmental level. Departmental documentation of travel purpose in relation to the grant and the traveler’s role in the grant work is highly recommended as good business practice. Remember, awards may be audited for three to five years after the award has ended. That is a long time to remember details that weren’t well-documented at the time!
DID YOU KNOW that in accordance with A-21, travel costs claimed under sponsored agreements must follow institutional policy as applied to regular operations?
Specifically, A-21, Section J 48b, “Lodging and Subsistence” states that
Costs incurred by employees and officers for travel, including costs of lodging, other subsistence, and incidental expenses, shall be considered reasonable and allowable only to the extent such costs do not exceed charges normally allowed by the institution in its regular operations as a result of institutional policy and the amounts claimed under sponsored agreements represent reasonable and allocable costs.
In other words, no special deals for the traveler just because they are traveling on sponsored funds!