General Travel Questions
Per University of Colorado PSC requirements, effective January 21, 2014, travel related receipts are required only when an individual expense exceeds $75.
Reference the Campus Controller’s Office Guidelines: Responsibility for Sponsored Projects Receipts and Supporting Documentation.
Government funded travel on grants and contracts at CU where the “Fly America Act” is in effect stipulates that air transportation must be performed by or under a code-sharing arrangement with a United States flag air carrier if service provided by such a carrier is available, regardless of cost or convenience.
For more information, consult OCG’s International Travel and Fly America Act webpages, as well as University of Colorado Procurement Service Center: Fly America Act information.
For purposes of the use of United States flag air carriers, “United States” means the 50 states, the District of Columbia, and the territories and possessions of the United States.
Yes. Any travel costs charged to federal awards must comply with federal regulations, including the requirement to book the lowest economy airfare and comply with the Fly America Act. When traveling on non-federal awards, unless it is specifically prohibited in the terms and conditions of the award agreement, travel does not need to meet the Fly America Act requirement. Regardless of the sponsor, University of Colorado’s travel policy is in effect. See also the University of Colorado Procurement Service Center Travel page.
Pre-approval for travel by your department is always required, per University of Colorado APS 4024.
You may also need pre-approval from the sponsor, even if the trip was included in your proposal budget. While sponsor funding demonstrates approval, DOE, DPA and ARO generally have more restrictive terms that require pre-approval. This condition is part of award terms and conditions. Changes in travel due to a change in the statement of work require that the statement of work change be approved by the sponsor. If you’re not sure if your sponsored project travel needs to be approved, check with your Grant or Contract Officer in OCG.
Note that the most restrictive terms on an individual award must be followed regardless of sponsor.
Per University of Colorado APS 4024, authorization for travel is required in advance of the trip. Travel authorization can be requested after-the-fact. Whether or not the travel is approved is at the discretion of the approver. Reimbursement for travel expenses will depend on allowability per applicable policies and whether the sponsor will allow the costs according to award terms and conditions and if travel occurred during the period of performance. CCO is the ultimate authority on allowability of costs.
The most restrictive policy must be followed. In the case of passport fees, these are no allowed on sponsored projects because they have a general benefit that is not specific to a project.
At the height of the pandemic, the federal government expanded flexiblities for costs related to COVID-19 to help recipients of federal research funding cope with the impacts of the COVID-19 crisis (see OMB Memos M-20-17, M-20-20, M-20-26). Most of the flexibilities, including those related to travel, ended in 2020. Following is the current guidance on costs related to COVID-related quaratine costs while on university travel.
1. Travelers are advised that there is an inherent risk with university-related travel and COVID is no longer considered an unforeseen event. Travelers are responsible for assuming costs associated with COVID (i.e. quarantine related extension of hotel stay, meals, etc.).
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Travelers can elect to obtain University Risk Management (URM) insurance. The insurance URM purchases for business travelers only covers Covid quarantine costs if the person is medically mandated by a doctor to quarantine in a hospital under their supervision.
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URM has updated its travel website to reflect the increased risk while on university-related travel.Some airlines and lodging companies offer travel insurance, which is not an allowable cost on sponsored projects.
2. Campus departments may choose to cover these costs from their own funding.
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If departments decide to provide financial coverage for these expenses, it is preferred that non-general fund speedtypes are utilized.
3. COVID costs related to travel continue to be unallowable on sponsored awards.
No, CCO’s Sponsored Research Travel Authorization Form cannot replace Concur requirements for travel. Concur travel information is required for travel on all funds, not just sponsored projects, and regardless of use of the CCO form. CCO’s Travel Authorization Form is provided as an additional tool for sponsored project travel.
Whether a cost can be charged to CU’s travel card does not determine if the cost is considered a travel cost. CU’s travel card has different restrictions on what can be charged vs. what is considered a travel cost. Typically, travel costs include airfare, lodging, per diem, ground transportation, and conference registration.
No, a PI cannot charge a registration fee to a project for a conference that will be after the POP. While related to the research, because the POP has ended we cannot show that the conference is benefiting the project nor could we include attendance and presenting at the conference in a technical report as part of the project work.
Some sponsors allow dissemination costs related to sharing of data and publication to be charged to a project even if the dissemination or publication activities will take place after the POP. Conference registration fees, however, are considered travel and not dissemination costs and may be charged for conferences occurring during the POP. Conference registration fee for a conference occurring after a project’s period of performance may not be charged to that project.
Travel Cost Questions
If a trip is cancelled due to no fault of the traveler, we generally allow those costs to be charged to the award. A credit is usually issued for the flight, and it is the department's responsibility to monitor the flight credits. If the credit ends up getting used to benefit another project, then the department needs to move the expenses to the proper funding source. If the award ends, and the department is unable to book a replacement flight and/or the credit expires before it can be used, then the expense should be moved to a nonsponsored funding source.
Same rationale as with airfare (with some exceptions-i.e. it depends). For example, conference is cancelled and traveler had option to stay at hotel (generally refunded in these cases), but the individual opted to stay at AirBnB or more restrictive option without cancellation. Due to COVID uncertainties and university guidance on PSC website updated as of September 2021, pre-approval is required for trips to assess benefits and risks and enhance safety of traveler.
In general, no. As of June 17th, 2020, with the expiration of OMB memo M-20-17 AND M-20-26, cancellation expenses and fees are no longer allowed to be charged to federal awards. This also applies to cancelled events.
Trip insurance should not be charged to sponsored awards. There were some flexibilities allowed during the height of the pandemic and with OMB memos, but those have since expired. Additionally, the coverage now usually excludes COVID coverage and only applies to luggage loss and personal injury protection. The University of Colorado provides travel insurance for university business international travel. Any domestic travel insurance coverage should be paid for by the traveler.
It depends on the purpose of the trip and if it directly benefits the research objective of the project. If the student is not supported by the project or is not providing a service to the project, it will be difficult to substantiate how his trip directly benefits the project.
The incidentals allowance is meant to cover fees and tips the traveler pays to baggage handlers or hotel staff, and other small miscellaneous items. The per diem allowance covers meal and personal expenses such as personal phone calls, laundry, movie rentals, or other entertainment costs while in travel status.
Along with typical documentation required for travel on sponsored projects, departments should also maintain back-up documentation as required for participants. For details, see CCO’s Participant Support FAQs, “What kind of documentation should a department keep on file for participant support costs?” and “Per FAQ, list of participants is required for documentation. Is the workshop or seminar agenda also required?”
This would not qualify as travel status eligible for meal or lodging reimbursement but you can be reimbursed for your mileage and parking fees. These can be direct charged to the project if the travel was necessary to and directly benefited the project being charged.
Choosing to stay in Denver for personal convenience would not qualify this trip for meals and lodging reimbursement. In order to qualify as an allowable sponsored project cost, the overnight stay must be necessary to complete the purpose of the trip and directly support the project being charged.
Generally not, unless you meet an exception specified in the federal regulations and you are able to meet University of Colorado’s travel policy. See also the University of Colorado Procurement Service Center Travel page.
The Office of University Controller has updated its Sensitive Expenses procedural statement to address how service fees should be treated. Per the item for “Tips,” tip is allowable up to 20% of the final bill which includes tax, service charges or fees, delivery charges, etc.
How allowable and allocable travel for an external party (regardless of whether their salary is paid or not paid on the project) is purchased and paid for is at the discretion of the CU department and project needs. Travel costs for an external party can be paid for directly by CU or paid for by the external party and reimbursed through PSC or a subaward, dependent on subaward or vendor determination, and as it works best for the project and the CU department. In all cases, travel must be allowable and allocable and follow relevant travel policies and regulations.
Fully remote employees do not subtract commute miles from the reimbursed amount since their normal commute is zero miles.
Hybrid employes should subtract “normal commute” miles for normal work days. PSC’s Procedural statement for travel states, “When commuting to sites other than the primary work location, reimbursable mileage is calculated by totaling the number of miles driven that day and subtracting the total number of miles the employee would need to normally commute between home/primary work location/home.” For hybrid employees, their primary work location (or "tax home") is the office location. When an employee is called to travel on a day that would otherwise be a remote-work day for them per the arrangement they have with their department, they are still being called to travel to and for work. IRS regulations treat the commute part of work for hybrid as personal, so any reimbursement made to arrive at the place of work would be taxable if it occurs during a regular work day (usually M-F for CU employees). Accordingly, the commute for hybrid employees still needs to be deducted regardless of the days the employee/deptartment have agreed for the individual to normally be remote. Any amount reimbursed for the cost of the regular daily commute would be considered personal and taxable.
Note: Remote employees continue to be subject to HR’s guidance that eligible travel for meetings and events is reimbursed no more than 1-2 times/year.
The answer to this question depends on the agreement with the consultant and what was included in the statement of work (SOW) submitted to PSC as to how travel costs were agreed to be paid, as a reimbursed cost or part of the consultant rates.
Consultants who are hired as independent contractors must follow PSC guidance on how travel costs are paid to independent consultants. Travel costs should be included in the SOW form and covered using the same procurement method as the service payment. See: Hire an Independent Contractor: “Costs to Include.”
Consultants who are hired as independent contractors must follow PSC guidance on how travel costs are paid to independent consultants. Travel costs should be included in the statement of work (SOW) form submitted to PSC and paid for using the same procurement method as the service payment. See: Hire an Independent Contractor: “Costs to Include.”
Project personnel who are not independent contractors may have travel paid for by the university following non-employee travel processes. See: Concur How-to: Booking Non-Employee Trips
International Travel Questions
"International travel" is defined differently by the University of Colorado Procurement Services Center (PSC), the Fly America Act and federal sponsors. PSC defines international travel as travel that is outside of the 48 contiguous United States, Alaska, Hawaii and the District of Columbia. US territories and possessions are considered domestic travel in the Fly America Act and, typically, by federal agencies. There are some federal agencies that treat travel to Canada and Mexico as domestic travel for award budgetary purposes.
Expenses for international travel should be charged to account codes according to University of Colorado institutional policies and classification of international travel. Under these policies, (see above FAQ on definition of travel) travel to the 50 states is considered as domestics travel. Travel to all other destinations, includuing US territories and possesions, is considered as international travel.
An air carrier which holds a certificate under 49 U.S.C. 41102 but does not include a foreign air carrier operating under a permit. The full list can be found on U.S. Department of Transportation’s website here.
Please review the Fly America Act page on the OCG website to determine if a non-U.S. air carrier can be used. If it is determined that a non-U.S. air carrier can be used, the Fly America Act Waiver can be used to document why a particular carrier is permitted. This resource is also available on the OCG website here. If you have any questions, contact your OCG Grant or Contract Officer.
No. You must use a U.S. air carrier regardless of cost on a project funded by the DOD or by a department of the U.S. Military.
It should be documented why a non-U.S. air carrier is used. This can be done using the Fly America Act Waiver form found on the OCG website here.
No. Only the traveler and the Principal Investigator (if not the traveler) need to sign the form. The completed form should be attached to the other trip records, such as the travel authorization and expense report, and kept with the award records with the department.
No. If the grant or contract requires compliance with the “Fly America Act”, then a foreign air carrier service may not be used solely based on the cost or convenience.
There are a number of parties involved with booking international travel, including the traveler, department administrative staff, the university’s Procurement Services Center (PSC) systems and Christopherson Business Travel (CBT). CU Boulder’s OCG and PSC also provide guidance on Fly America Act and Open Skies Agreements requirements.
As part of international travel on a sponsored project, the responsibility for compliance with Fly America Act is as follows:
- Per PSC, it is ultimately the responsibility of individual departments to work with their travelers to determine how they are meeting the Fly America Act requirements that pertain to their funding source as they differ in requirements. OCG has detailed guidance on the Fly America Act to assist travelers through the process of selecting eligible flights, determining what exceptions may apply, and providing the Fly America Act waiver to document exceptions. If these steps are being followed with the direction of the department, the traveler should be able to determine what flights they are able to purchase and will have the supporting documentation to provide to sponsors when needed.
- Travelers can provide information, based on OCG and PSC’s resources for Fly America Act, to a CBT agent who can assist in booking the correct flights based on the information provided by the traveler.
- CBT is aware of Fly America Act regulations and Open Skies Agreements and general related guidance. PSC has advised CBT to not provide specific guidance on Fly America Act since restrictions vary based on each individual fund type. If the traveler is unsure, CBT has been directed to provide the traveler with PSC’s Fly America Act webpage or OCG’s Fly America Act webpage.
Exceptions to the Fly America Act
- Documentation of exceptions to the Fly America Act, including use of an Open Skies Partner carrier, are the responsibility of the traveler and department. CBT does not document exceptions. OCG provides a Fly America Act waiver form that may be used to document exceptions by the department.
- Departments are responsible for documenting exceptions to the Fly America Act.
- CBT does not document these exceptions outside of any of their required ticketing system information nor do we (PSC) require them to. PSC is unaware of any agency that will certify compliance for Fly America Act outside of having a traveler sign an affidavit or waiver.
- OCG and CCO do not document these exceptions.
OCG and CCO have two points of contact should a traveler need additional guidance on the Fly America Act. If the website resources do not provide enough information for a specific travel situation, contact Penny Mathews, OCG Compliance Manager, or Evan Blaisdell, CCO’s Compliance/Financial Reporting Supervisor.
Yes, and you should use the Fly America Act Decision Guide to help ensure you are complying with all airfare requirements. Please note that depending on the location and travel requirements, City-Pair Agreements nullify the Open Skies Agreements.