Domestic and Foreign Travel Policy for Sponsored Programs
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It is the policy of New York University (NYU, “the University”) that the University Business Expenses policy applies to all domestic and foreign travel for sponsored programs. However, if specific sponsor guidelines for a sponsored program are more restrictive than University policy, then sponsor rules shall apply.
All travel expenses charged to Federally sponsored projects, (both direct and pass-through) are governed by the cost principles of the Federal Office of Management and Budget Circular A-21 (http://www.whitehouse.gov/omb/circulars_a021_2004).
Therefore, charges must pass the following three tests:
• The cost must be allowable under both the provisions of OMB Circular A-21 and under the terms of a specific award.
• The cost must be allocable; that is, the expense can be associated to a project with a high degree of accuracy.
• The cost must be reasonable, that is, the cost reflects what a “prudent person” would pay in a like circumstance.
Sponsored research awards may be used to cover the costs associated with travel and subsistence associated with the award, e.g. transportation, meals and lodging. However, there are a number of factors provided below to consider for allowability and allocability of travel costs on sponsored awards.
a. Proposal /Budget
Generally, the proposal should include a budget for foreign and domestic travel costs and the proposal must have explicitly stated justification for the travel. This will translate into a budget category for travel when the sponsored project is established.
Travel is allowable as a direct cost where such travel will provide direct benefit to the project and comply with NYU and sponsor requirements. Costs for employees working on the project may include per diems or subsistence allowances and other travel-related expenses, such as mileage allowances if travel is by personal automobile.
All travel charged to sponsored projects must be approved by the Principal Investigator (PI) or the individual responsible for the management of “restricted” funds. Before making travel arrangements, make sure that travel is allowed under the terms of an agreement or contract. In some cases, the sponsor’s written approval may be required prior to any trip. Please see current Office of Sponsored Programs (OSP) Prior Approval System requirements for any travel changes exceeding the approved budget by $1,000 or 25%, whichever is greater.
b. Travel Advances
When travel advances are necessary, the traveler must submit an Advance Request through the University's Accounts Payable payment system at least 10 to 20 days prior to travel.
Travel advance requests and reconciliations must follow the requirements in the Business Expenses Policy.
Requests for travel advances exceeding $500 must include a description of the circumstance that requires the advance and a brief budget of expenses must be provided in the Form.
Advances for sponsored programs must be reconciled within 30 days of the end of the trip. See the Business Expenses Policy for additional guidance. All advances must be cleared prior to closing an award.
If the advances are not cleared at the time of the award closeout, expenses associated with the remaining advance amount will be charged to a discretionary chartfield.
c. Domestic Travel
Domestic travel is travel performed within the recipient’s own country. For the U.S., it includes travel within and between any of the 50 States of the U.S. and its possessions, territories, Canada and, in most cases Mexico.
d. Foreign Travel
Foreign travel is travel outside of the United States, its territories and possessions, Canada and, in most cases, Mexico. However, for a foreign organization as described above, foreign travel means travel outside that country. When an award is Federally funded, the employee must comply with the requirements of the Fly America Act.
(To assist in compliance with the Fly America Act, a Fly America Act Waiver Checklist is included as an Appendix 1 to this Policy.)
The Act requires that U.S.-flag air carriers be used to the maximum extent possible when commercial air transportation is the means of travel between the U.S. and a foreign country or between foreign countries. This requirement shall 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 U.S. General Services Administration (GSA) regulations on U.S. flag air carriers and code shares. There are exceptions to the Act, including but not limited to instances where the use of a U.S. flag carrier would:
a) Require circuitous routing;
b) Require travel during unreasonable hours;
c) Excessively prolong travel;
d) The alternate airline is a flag carrier from a country with open skies agreement with the United States and there is no city‐pair contract flight. City-pair contracts provide for a discounted airline rate and are normally available only to Federal employees and Federal contractors. NYU’s Federal award will establish whether or not NYU can avail itself of the benefits of a city-pair contract.
Such exceptions must be documented by providing a snapshot of flight availability, flight times and duration. Documentation is required to show that the ticket was issued under a code-share agreement. Note: Federal regulations prohibit the charging of business class or first class air travel to Federally sponsored projects.
The cost in excess over the coach fare must be segregated on the employee reimbursement request submitted through the University's Accounts Payable payment system. Any cost in excess over the coach fare will not be reimbursed from other non-sponsored funds unless approved in advance and the request for reimbursement must beaccompanied by a written justification. Airfare costs in excess of the customary standard commercial airfare (coach or equivalent), Federal Government contract airfare (where authorized and available) or the lowest commercial discount airfare are unallowable except when such accommodations would:
a) Result in additional costs that would offset the transportation savings of flying coach; or,
b) Offer accommodations not reasonably adequate for the traveler’s medical needs. The traveler must provide, on a case-by-case basis, a written note from their physician to justify the medical necessity.
Fly America Act and Open Skies Agreements
Generally, if a traveler is traveling on funds provided by the Federal government, the traveler must use a US flag carrier (an airline owned by an American company) regardless of cost or convenience.
If an employee is scheduling Federally-funded international travel, all flights where possible should be scheduled with US flag carriers or on foreign air carriers that code share with a US flag carrier. Code sharing occurs when two or more airlines “code” the same flight as if it were their own. A U.S. airline may sell a seat on the plane of a foreign air carrier. This seat is considered the same as one on a plane operated by a U.S. flag carrier. Compliance with the Fly America Act is satisfied when the U.S. flag air carrier’s designator code is included next to the flight numbers on the airline ticket, boarding pass or on the documentation for an electronic ticket (passenger receipt).
For example: Delta has a code share agreement with Air France to Paris, France. If the boarding pass or e-ticket identifies a flight as DL ##, the requirements of the Federal Travel Regulations would be met, even if the flight was on an Air France airplane. If however, the boarding pass or e-ticket identifies the flight as an AF##, the requirements of the Federal Travel Regulations would not be met.
Open Skies Agreement
The United States Government has entered into several air transport agreements that allow Federally funded transportation services for travel and cargo movements to use foreign air carriers under certain circumstances.
There are currently four bilateral/multilateral “Open Skies Agreements” (U.S. Government Procured Transportation) in effect: the European Union (EU), Australia, Switzerland, and Japan.
Open Skies Agreements also provide a limited exception to the Fly America Act. Where an open skies agreement exists, a traveler may use the foreign airline except when a “GSA City Pair” exists or the travel is funded by the U.S. Department of Defense. Information on GSA City Pairs may be found at: http://apps.fas.gsa.gov/citypairs/search/.
When traveling to a destination serviced by a European Union airline, NYU travelers flying on a Federal grant can fly on either a US carrier or an EU (European Union) carrier as long as they touch down in an EU country.
The rights given to airlines concerning U.S Government procured transportation under the Open Skies Agreement do not apply to transportation obtained or funded by the Secretary of Defense or the Secretary of a military department.
In all cases, travel costs are limited to those allowed by the Business Expenses Policy and in the case of air travel, the lowest reasonable commercial airfares must be used. Researchers are strongly encouraged to take advantage of discount fares for airline travel through advance purchase of tickets where travel schedules can be planned in advance (such as for national meetings and other scheduled events).
Faculty, staff and students working on the sponsored project are responsible for their own expenses. Individuals are personally responsible to ensure travel arrangements meet sponsored travel regulations. Improper or inadequately
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The purpose of this policy is to provide guidance for proposing and administering travel costs, both foreign and domestic, in compliance with Federal and other sponsor requirements, and NYU policy.
This policy is applicable to all schools, departments, units and personnel of the University involved in administering sponsored awards.