Travel Charged to Federal Sponsored Agreements

 

All travel costs charged to grants and contracts must be reasonable and comply

with policies established by SMU, Federal regulations and the sponsoring agency terms, conditions and regulations. Travel policies of federal and nonfederal sponsors vary. The specific terms and conditions of an award must be consulted before making any travel arrangements. If there is a conflict between a sponsor's rule and SMU’s rule, the more restrictive rule applies.

 

In the event that the trip is completed in the last month of a sponsored

agreement, expenses must be submitted within 30 calendar days of trip

completion to allow for submission of the final financial report.

 

Listed below are two of the general terms affecting Federal funded grants and contracts:

 

1.  Office of Management and Budget Circular A-21 provides principles for determining the costs applicable to research and development, training, and other sponsored work performed by colleges and universities under grants, contracts, and other agreements with the Federal Government. These agreements are referred to as sponsored agreements.   Circular A-21 addresses travel expenses specifically at section J-48.

“48. Travel costs.

a. General. Travel costs are the expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of the institution. Such costs may be charged on an actual basis, on a per diem or mileage basis in lieu of actual costs incurred, or on a combination of the two, provided the method used is applied to an entire trip and not to selected days of the trip, results in reasonable charges, and is in accordance with the institution's travel policy and practices consistently applied to all institutional travel activities.

b. Lodging and subsistence. 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 an institutional policy and the amounts claimed under sponsored agreements represent reasonable and allocable costs. In the absence of an acceptable institutional policy regarding travel costs, the rates and amounts established under subchapter I of Chapter 57 of Title 5, United States Code, or by the Administrator of General Services, or the President (or his or her designee) pursuant to any provisions of such subchapter shall apply to sponsored agreements (41 U.S.C. 420).

c. Commercial air travel. Airfare costs in excess of the lowest available commercial discount airfare, Federal Government contract airfare (where authorized and available), or customary standard (coach or equivalent) airfare, are unallowable except when such accommodations would: require circuitous routing; require travel during unreasonable hours; excessively prolong travel; greatly increase the duration of the flight; result in increased costs that would offset transportation savings; or offer accommodations not reasonably adequate for the medical needs of the traveler. Where an institution can reasonably demonstrate to the sponsoring agency either the nonavailability of discount airfare or Federal contract airfare for individual trips or, on an overall basis, that it is the institution's practice to make routine use of such airfare, specific determinations of nonavailability will generally not be questioned by the Federal Government, unless a pattern of avoidance is detected. However, in order for airfare costs in excess of the customary standard commercial airfare to be allowable, e.g., use of first-class airfare, the institution must justify and document on a case-by-case basis the applicable condition(s) set forth above.

d. Air travel by other than commercial carrier. "Cost of travel by institution-owned, -leased, or -chartered aircraft," as used in this subsection, includes the cost of lease, charter, operation (including personnel costs), maintenance, depreciation, insurance, and other related costs. Costs of travel via institution-owned, -leased, or -chartered aircraft shall not exceed the cost of allowable commercial air travel, as provided for in subsection c.”

 

It is possible that the specific terms and conditions of an agreement will be

more restrictive than the OMB Circular A-21 cost principles. It is

important for the traveler to review the terms and conditions of each

agreement before a trip.

 

2.  Fly America Act

U.S. law, 49 U.S.C. 40118, known as the Fly America Act, requires travelers

whose air travel is being financed by the U.S. government to use U.S. flag air

carrier service for all international air travel when available. The Federal Travel

Regulations Sections 301-10.131 through 301-10.143 define U.S. flag air carrier

service and provide exception criteria for the use of non-U.S. flag air carrier

service. 

 

Travelers using a non-U.S. flag air carrier requesting reimbursement from a U.S.

government-sponsored project must qualify for an exception under the act. The

traveler must complete the Fly America Act Exception Request form. The form

must be signed by the traveler and submitted with the travel report. The traveler must obtain approval of the Exception Request form before booking the trip to ensure that the costs will be allowable on the federally sponsored project. The traveler must use a U.S. flag air carrier on every portion of the route where service is provided unless the traveler qualifies for an exception. Note that cost and/or personal convenience are not included in the exception criteria used to determine the non availability of a U.S. flag air carrier.  Travel Services Online cannot be used when exceptions to the Fly America Act are required.

 

Code-Shared Flights

Some flights may qualify as a U.S. flag air carrier if they are code-shared flights.

The determining factor for identifying the use of a U.S. flag air carrier is the air

carrier's designator code, which precedes the flight number (e.g., NW2222).

 

A list of the major U.S. flag air carriers is below:

  • Airtran Airways  (FL)
  • Alaska Airlines  (AS)
  • America West Airlines  (HP)
  • American Airlines  (AA)
  • American Trans Air  (TZ)
  • Continental Airlines  (CO)
  • Delta Airlines  (DL)
  • Frontier Airlines  (F9)
  • Hawaiian Airlines  (HA)
  • JetBlue Airways  (B6)
  • Midwest Express  (YX)
  • Northwest Airlines  (NW)
  • Southwest Airlines  (WN)
  • Spirit Airlines  (NK)
  • United Airlines  (UA)
  • US Airways  (US)

Some major airlines that are NOT U.S. Flag Carriers:

  • Aer Lingus
  • Air Canada
  • Air France
  • British Airways
  • Lufthansa
  • Mexicana
  • Olympic Airways
  • Virgin Atlantic

 

** Boarding pass without passenger receipt is not acceptable for reimbursement.

 

A complete list is available through the Department of Transportation at http://ostpxweb.dot.gov/aviation/certific/certlist.pdf

 

 

Other Travel related information:

 

Passports and Visas

Reimbursement may be permitted for actual passport and visa fees for business travel; however, the expense may not be eligible as a direct cost to a sponsored program. Since a passport can be used for multiple trips over several years, the cost is not a project-specific expense and therefore is not allowed on most sponsored projects as a direct cost. Visas are generally required in relation to a specific trip and therefore the cost is generally allowable as a direct cost for a sponsored project.

 

Travel Classifications - CONUS/O-CONUS, Domestic/Foreign

Terminology for foreign travel differentiates between domestic and foreign

destinations and reimbursement methods distinguish between CONUS

(continental United States) and O-CONUS (outside continental United States).

These terms are used throughout sponsored funding programs, and do affect the reimbursement when per diem is approved in lieu of receipts.  If per diem is approved, it must be used to determine reimbursement for the entire trip.  Per diem allowances may be for meals and incidental expenses (M&IE) or lodging or both.

 

Agency Pre-Approval – Many agencies require 45 days advance notice and pre-approval for foreign travel even if it is specified in the Statement of Work, Budget and Award document.   Be ware, agencies have been known to wait until the day before the expected travel date to notify the Principal Investigator that the travel is NOT approved.

 

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The following is presented as a sample of locating per diem rates using the NIH definition of domestic vs. foreign travel.

 

 

CONUS Rates

O-CONUS Rates

Domestic travel includes

these areas:

48 continental United

States

Alaska, Hawaii, Canada, US

Territories*

Foreign travel includes

these areas:

None

 

All locations EXCEPT:

Alaska, Hawaii, Canada, US

Territories*

 

 

 

*Puerto Rico; Guam; U.S. Virgin Islands; American Samoa; Northern Mariana

Islands; Midway Islands; Wake Island; Johnston Atoll; Baker, Howland, and

Jarvis Islands; Kingman Reef; Navassa Island; Palmyra Atoll

 

 

NSF defines Domestic Travel as: travel in the US, its possessions, Puerto Rico and travel to Canada and Mexico.

 

DOD Travel Regulations defines foreign area and foreign country as:  Any area or country outside the 50 States, District of Columbia, the Commonwealths of Puerto Rico and the Northern Mariana Islands, Guam and the U.S. territories and possessions.

 

Federal Travel Regulations define foreign area as:  “Any area, including the Trust Territories of the Pacific Islands, situated both outside CONUS and the non-foreign areas.”  CONUS is the 48 contiguous States and the District of Columbia.  Non-foreign area contains the States of Hawaii and Alaska, Commonwealths of Puerto Rico, Guam and the Northern Mariana Islands and the territories and possessions of the United States (excludes the Trust territories of the Pacific Islands).

 

Department of Energy (DOE) refers to the Federal Travel Regulations.

 

Department of State distinguished between international and domestic travel by saying that international travel is outside of the United States.  The United States is defined as the fifty states, Commonwealth of Puerto Rico, possessions of the United States, and the District of Columbia.

 

It is safe to say that any travel outside of the 48 contiguous states should be looked at carefully before making arrangements.