FOREIGN TRAVEL ON FEDERAL AWARDS

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INTERNATIONAL TRAVEL ON
FEDERAL AWARDS
CHANGE IN APPROVAL PROCESS-NOT
THE DOCUMENTATION
June 19, 2012
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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.
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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.
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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)
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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.
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Lodging
• Travelers should stay in a standard room at a
non-luxury 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.
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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.
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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.
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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.
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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.
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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)
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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. Employee’s 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
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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
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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.
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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.
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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)
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Questions
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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
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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
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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, PDA’s and Other Electronic
Devices:
http://www.ncix.gov/publications/reports/traveltips.pdf
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