Travel on Sponsored Projects

Tufts University faculty, staff and students routinely travel in support of sponsored research activities.  The University reimburses these travelers for necessary and reasonable business expenses incurred while traveling.  Reimbursable expenses must conform to university policy, federal and state law and the restrictions placed upon each sponsored project.

Travel is allowable as a direct cost when such travel will provide direct benefit to the project.  Sponsored projects are subject to certain federal laws (if federally funded), the guidelines set forth in the Office of Management and Budget (OMB) Circular A-21, Section J 53, Travel Costs (if federally funded), specific agency restrictions, as well as Tufts University’s Travel Policy. The terms and conditions of the individual agreement should be reviewed prior to incurring and/or processing any travel cost. When there is a conflict between university policy and award requirements the most restrictive policy applies.

Please visit the Accounts Payable website for Tufts’ complete travel policies and travel related forms.

Sponsored travel must be justified, well documented, in compliance with the sponsor requirements and must be incurred within the period of the award.  Charges for travel under a sponsored project must satisfy the following criteria:

  • The costs must be allowable as defined by OMB Circular A-21 and/or by the terms of the particular award and must be in accordance with university policies.
  • The cost must be allocable, that is, the project which paid the expense must benefit from it. (See guidance below for charging two or more projects).
  • The expenses must be reasonable, that is, the cost reflects what a “prudent person” might pay.

Further, OMB Circular A-21 requires that a university consistently implement cost policies. The key to consistency is the application of Tufts policies.  It remains the responsibility of the Principal Investigator to ensure that the expenses follow applicable policies for allowable costs and that the proper authorizations have been made. 

Sponsored project travel has a high audit profile and can be examined by internal, external and sponsor auditors.  Therefore, the transaction must be adequately documented. Sufficient documentation provides clarity so that anyone looking at the transaction is able to understand and determine that it is allowable, allocable and reasonable. 

If costs are not allowable, allocable, reasonable, consistently treated and sufficiently documented they cannot be charged to a sponsored research project.  The authority for determining which travel expenditures are reimbursable under a particular grant or contract lies with Sponsored Programs Accounting. 

Because each award has unique requirements, it is difficult to provide a comprehensive list of sponsor restrictions. The following list only highlights some common restrictions.

Some awards may:

  • Prohibit foreign travel
  • Require pre-authorization for each trip
  • Restrict the number of trips that can be taken
  • Restrict the number of travelers on an authorized trip
  • Set a maximum dollar value per trip
  • Allow attendance to a conference to present research, but not just for the purpose of “staying current in the field”
  • Limit travel to a specific destination or purpose
  • Specify maximum meal, mileage or other cost rate

Travel Charged to Two or More Projects

Auditors carefully review travel charges that are split between two or more projects so as to be sure that charges are properly allocated. When preparing your travel report it is important to be clear about how the trip specifically benefited each project respectively.

Charges split between more than one project must be split on the basis of proportional benefit or other reasonable method. The division of the expenditure cannot be based on available funding or any other type of synonymous methodology. An expenditure that benefited two or more projects cannot be charged solely to one project because the other project is almost out of funding.  OMB Circular A-21 provides two methods for allocating an allowable direct cost to two or more projects:

  • The Proportional Benefit Rule – If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost should be allocated to the projects based on the proportional benefit
  • The Interrelationship Rule – If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved then the costs may be allocated or transferred to benefited projects on any reasonable basis.  The documentation must include a description of interrelatedness.

Foreign Travel

The definition of foreign travel may differ from sponsor to sponsor. Therefore, each award must be examined for this definition. For example, many agencies do not consider travel to Mexico and Canada as foreign travel. The award must also be examined for prior approval requirements, if any.

Under the Fly America Act travelers are required to use United States (US) air carrier service for all travel funded by Federal Agencies. One exception to this requirement is the Open Skies Agreement.  There are four Open Skies Agreements with the US in effect: European Union (EU), Australia, Switzerland, and Japan.  Excluding the EU, you must check to ensure there is no city-pair contract fare in effect in order to use a foreign carrier.  If there is a city-pair contract in effect, a US carrier must be used.

The Open Skies Agreement exception does not apply to travel funded by the U.S. Department of Defense.

Exceptions to the Fly America Act

Travel that is to be reimbursed from federal grants and contracts must be booked through U.S. carriers except in the following circumstances:

  • Travel met GSA’s Open Skies Agreements / Fly America Exception Criteria.  There are four Open Skies Agreements with the US in effect: European Union (EU), Australia, Switzerland, and Japan.  Excluding the EU, you must check to ensure there is no city-pair contract fare in effect in order to use a foreign carrier.  Under the Open Skies agreement, the use of a foreign carrier is allowable when that airline is a member state carrier, transportation is between the U.S. and any point in the member state or between two points outside the U.S. provided that:
    • No City-Pair fare exists
    • Funding is not provided by the U.S. Department of Defense
  • No U.S. flag air carrier provides service on a particular leg of the route, in which case foreign air carrier service may be used, but only to / from the nearest interchange point on a usually traveled route to connect with U.S. flag air carrier service
  • Service on a foreign air carrier would be three hours or less, and use of the U.S. flag air carrier would at least double your en route travel time

Travel between the United States and another country

  • If a U.S. flag air carrier offers nonstop or direct service (no aircraft change) from your origin to your destination, you must use the U.S. flag air carrier service unless such use would extend your travel time, including delay at origin, by 24 hours or more
  • If a U.S. flag air carrier does not offer nonstop or direct service (no aircraft change) between your origin and your destination, you must use a U.S. flag air carrier on every portion of the route where it provides service unless, when compared to using a foreign air carrier, such use would:
    • ? increase the number of aircraft changes outside the U.S. by 2 or more
    • ? extend travel time by 6 hours or more
    • ? require a connecting time of 4 hours or more at an overseas interchange point

Travel between two points outside the United States

  • You must always use a U.S. flag carrier for such travel, unless, when compared to using a foreign air carrier, such use would:
    • ? increase the number of aircraft changes outside the U.S. by 2 or more
    • ? extend travel time by 6 hours or more
    • ? require a connecting time of 4 hours or more at an overseas interchange point

Please see the Fly America, Open Skies and City Pair Matrix and Fly America Act and Open Skies Agreement Decision Diagram for further guidance.

There are other exceptions to the Fly America Act which may be appropriate as well. A list of exception criteria may be found in the Federal Travel Regulation Guidelines – FTR sections 301?10.135?138 .  Please note that lower cost and personal convenience are not acceptable criteria for justifying the non?utilization of a U.S carrier.

The Apptricity travel and business expense system will have two fields that should be completed for all sponsored projects.  The traveler should indicate how the travel directly benefits/relates to the project – this is a required field.  There will be a second field that should be used to detail the methodology for the allocation of costs to more than one project.  When a traveler uses a non-U.S. flag air carrier on travel to be charged to federally sponsored awards, the Fly America Act Exceptions Form, along with any relevant supporting documentation, is recommended as an attachment to your travel report.  It is important that this information be clearly stated to avoid a delay in reimbursement.

It remains the responsibility of the Principal Investigator to ensure that the expenses follow applicable policies for allowable costs and that the proper authorizations have been made.  User approval in the Apptricity travel and business expense system signifies compliance with university policies & procedures, federal cost principles, sponsored agreement guidelines and that there are no unallowable costs included on the report (i.e. alcohol, entertainment, etc).  See the next section entitledSponsored Programs Accounting Internal Procedure for further guidance on reviewing and approving travel requests.

Please contact your SPA Representative for questions concerning travel requirements and restrictions on specific sponsored agreements.

                                                                                                        

Sponsored Programs Accounting Internal Procedure

All foreign travel reimbursements are reviewed and approved by Sponsored Programs Accounting prior to processing by the Finance Division.  In addition, a post audit of domestic travel will be conducted on a monthly basis.

The following questions should be considered when reviewing and approving travel reimbursements on sponsored projects:

  • Is there justification to how the trip specifically benefited the project?
  • If the charges are split between more than one grant is there justification supporting the basis of proportional benefit or other reasonable method?     
  • Is the travel allowable, allocable, reasonable and necessary?
  • Was the traveler paid from the sponsored project(s) charged?
  • Does the sponsor require prior approval for travel?
  • Do we have prior written approval by the Contracting Officer for USAID and USAID prime foreign travel?
  • Is the proper account code being used (foreign vs. domestic)?
  • Are the invoices and/or receipts attached or, if applicable, is the correct per diem rate being utilized?
    • Was no alcohol charged?
  • Does the travel occur within the period of performance of award?
  • Does the award budget include funds for the travel?
    • If not, do we have rebudgeting authority?
  • Is foreign travel being charged to a federal award? If yes, foreign travel must be in compliance with the Fly America Act. 

 

Last Updated: July 2012