Foreign Travel on Federal Awards

Foreign Travel on Federal Awards

INTERNATIONAL TRAVEL ON FEDERAL AWARDS CHANGE IN APPROVAL PROCESS-NOT THE DOCUMENTATION June 19, 2012 1 International Travel The federal government defines international travel as any travel outside the United States, its possessions and territories. For travel coding purposes Canada is now considered domestic. International travel charged to a federal award

should follow university policy unless the funding agency imposes greater restrictions. It is the responsibility of the traveler and the PI to know the terms set forth in the award in reference to allowable travel expenses. 2 Upcoming Change Effective July 1, 2012 international travel on federal awards will no longer need ORS approval. All travel advances and reimbursements will be sent directly to Individual Disbursement Services (Travel Office).

This change in the routing process has no affect on the required documentation. However, the travel justification form has been revised. 3 Travel Considerations International travel should be included in the proposal or otherwise be allowed by the sponsor. Approval for travel not included in the proposal must be documented. The travel must comply with the Fly-America Act. Required internal (IDS) and external (sponsor)

clearances must be obtained as required. Travel must occur during the period of performance and directly benefit the project. 4 Travel Considerations Export Control policies must be adhered to including for travel with laptops and shipment of research materials to foreign collaborators Departments, schools and centers must ensure that all expenses incurred for international travel are allowable and allocable. Expenses should be justified and in compliance with sponsor and university policies.

5 Necessary Documentation Include T&E Expense Justification form (rev. 6/12) Include all original receipts for items $25 or more. Receipts should show the merchant, nature of purchase, date of purchase, amount of purchase and form of payment. Be mindful of private information. Use a black marker to conceal SS #, credit card # etc. 6

Object Codes 5202 - Foreign Travel for faculty and staff 5205 Foreign Student Travel 5207 Non-employee Foreign Travel 5209 Business Meals Traveler must attach an Entertainment & Business Meal Worksheet. If alcohol is consumed it must be charged to 5214 on a dept. account.

5214- Foreign Project Costs (Advances) 7 Meals Meal receipts must be itemized to ensure allowability ( i.e. no alcohol). If requesting reimbursement for meals on a per diem basis, ensure that the correct per diem is used and that this method is used consistently for the entire trip. Business meals must be sufficiently justified. Explanations such as University Business or

Business Meals are not sufficient. Remember, meals with Penn colleagues are generally unacceptable. 8 Lodging Travelers should stay in a standard room at a nonluxury hotel. Travelers should take advantage of any available discounted negotiated rates, conference rates, Penn rates etc. Travelers will be reimbursed for lodging that is commiserate with the government per diem rate. 9

Car Rental/ Mileage Reimbursement If car rentals are allowable, use the prudent person test when choosing a vehicle. Expenses that are reimbursable include gas or mileage, parking and tolls. If an employee uses their personal vehicle they may request mileage reimbursement and reimbursement for tolls and parking. The employee must include the # of miles driven on the request. Please use the current mileage rate. 10

Foreign Currency Conversion Please provide support for foreign currency conversion calculations. Currency rates fluctuate and can change daily so to ensure accuracy include the printout of the rate that was in effect the day the reimbursement was completed. Lack of proper documentation will likely delay the processing of the reimbursement. 11 Travel Advances Travelers can request Advances only when circumstances are such that other payment

options are not feasible. Travelers must document in writing the extenuating circumstances and obtain approval at the designated levels. If the Advance is to cover the costs of out-ofpocket expenses while traveling the meal per diem should be used as a guide. Advances should not be used for taxis, tips, gas and other small incidentals. 12 Travel Advances Advances on ongoing projects must be reconciled before additional advances will be approved. With project Advances it is the responsibility of

the Principal Investigator to determine if the funds have been spent to support the project. It is the responsibility of the higher level approver to ensure that the funds are accounted for in a timely manner. 13 Travel Advances When requesting an Advance, you must complete the Travel Advance form (C-7) and the Advance Justification form (C-7A). Attach documentation based on the scope of the project. Operating expenses may include labor costs,

equipment, supplies, as well as lodging and meals. These expenses should be charged to object code 5212. 14 Non-Reimbursable Expenses

Alcoholic Beverages Credit card late fees or finance charges Movies rentals (in-flight or hotel room) Rental car options such as car GPS, insurance Loss or theft of personal funds or property Clothing or toiletry items Medical expenses Limousine / Sedan services Laundry services(unless trip is longer than 5 days) 15

Expenditure Justification Form Explain all items not contemplated by written policies. Examples include but are not limited to: a. Higher class of service on airlines or rail service b. Employees use of sedan/limo service c. Fees such as bank fees, re-ticketing, lost ticket, no-shows, etc. d. Lack of original receipts e. Missing/incomplete supporting documentation f. Exceeding meal / per diem thresholds 16 Required Signatures

The T&E Reimbursement Form must be signed by the following; a) Payee b)Business/Budget Administrator c) Higher-Level Approver The Expense Justification Form must be signed by the following; a) Principal Investigator b)Business/Budget Administrator c) Higher-Level Approver 17 Reimbursement Requests The travel policy recommends that travelers

submit their reimbursement requests within 10 days of the trip end to ensure compliance with IRS requirements. Department, schools and centers should maintain travel documentation and related justifications in their records per the University record retention policy. 18 Common Issues

1) Incorrect Object Codes 2) PI approval missing 3) Receipt documentation missing (over $25) 4) Conversion of foreign currency omitted 5) Inadequate or no support to demonstrate exception to Fly America Act 6) Requests that include items that are inappropriate or unallowable. 19

Common Issues 7) Traveler does not have effort on the project 8) Inadequate or missing justification 9) Late requests-after 6 months without exceptional circumstances 10) Inadequate Advance request justification 11) Advances not reconciled timely 12) Incorrect funding source identified (period of performance expired) 20 Questions

21 Contact Info For questions regarding the processing of T&E Reimbursements please contact Individual Disbursement Services (IDS) at 215-898-3307 For assistance with travel plans please contact the Purchasing Service Travel Office at 215898-1398 22 Resources Penn Travel Portal http://www.purchasing.upenn.edu/travel/

University Sponsored Projects Expense Documentation Requirements and International Travel Policies: http://www.finance.upenn.edu/vpfinance/fpm/2100/2100_pdf/2134.pdf U.S. Government Per Diem Rates: http://aoprals.state.gov/web920/per_diem.asp http://www.gsa.gov/portal/category/21287

International travel on federal awards: The National Institutes of Health Grants Policy Statement (GPS) Section 4.1.11 & 8.1.2 http://grants.nih.gov/grants/policy/nihgps_2011/nihgps_ch4.htm#fly_americ a_act http://grants.nih.gov/grants/policy/nihgps_2011/nihgps_ch8.htm#_Requests _for_Prior 23 Resources U.S. General Services Administration: http://www.gsa.gov/openskies Office of Management and Budget (OMB) Circular A21- (allowable cost) Section J. 53 http://www.whitehouse.gov/omb/circulars_a021_2004#j Export Control Information: ORS contact: Elizabeth Peloso, Director Export

Compliance http://www.upenn.edu/researchservices/exportcontrols.html Traveling Overseas with Mobile Phones, Laptops, PDAs and Other Electronic Devices: http://www.ncix.gov/publications/reports/traveltips.pdf 24

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