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Sponsored Travel 101. Introduction. Sponsored travel (348) is when a traveler is invited to present or participate at a conference, meeting, or symposium, and the inviting organization (sponsor) covers some or all of the expenses related to the travel and/or per diem. No honorarium permitted.
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Introduction • Sponsored travel (348) is when a traveler is invited to present or participate at a conference, meeting, or symposium, and the inviting organization (sponsor) covers some or all of the expenses related to the travel and/or per diem. No honorarium permitted
Course Objective • Increase your knowledge of sponsored travel, and reduce the number of errors and incomplete packages submitted to Ethics
Vocabulary • Sponsored In-Kind – sponsor is paying costs up front; no reimbursement to NIH • Sponsored Reimbursable – sponsor reimburses NIH upon receipt of expense report from traveler • Travel Card – expenses charged to traveler’s government issued travel card • GTA – expense for fare tickets issued by NIH’s Travel Management Center (Omega) and paid for by NIH • GTA Reimbursable – expense for fare tickets issued by Omega and reimbursed to NIH by the sponsor
Preparing a 348 (Required Forms) • Traveler request form • Letter of invitation • Routing Slip • Travel Authorization (348 & checklist) • Late Memo (if applicable) • Notification of Foreign Travel (NFT – if applicable) • Additional Requests (car rental justification, etc.)
Traveler Request Form • Traveler completes form and obtains supervisor’s signature. Form found on NIH Portal • Traveler submits to the planner • Travel planner uses the request form to prepare the Travel Authorization • Travel planner ensures the OC Code and CAN number are correct Handout 1, 1A, 1B
Letter of Invitation • The letter of invitation should be on sponsored letterhead • Check that the letter clearly states the sponsor. The company that cuts the check to NIH is the sponsor. If you are uncertain, call or email the conference organizer for clarification • No Federal Funds statement included • Expenses and method of payment (In Kind / Reimbursed) • Dates and location of meeting • Name, address, and phone number of the sponsor / contact person Handout 2
Routing Slip / Checklist (Ethics) • Date in the top right corner • Current signature delegations applied • domestic (supervisor’s signature) • foreign (supervisor’s and director’s signature) • Proper assembly of package to ensure completeness and all forms are in order. Additional documentation should be attached at the back of the package (itinerary, WAG, official duty memo, etc.) • Traveler’s name, TA number, dates of travel, and destination Handout 3
Travel Authorization • Create a 348 travel authorization in the NBS system Handout 4
Sponsor Request Form • If the sponsor cannot be found in the NBS travel system, complete a “sponsor request form.” The form is located on the NIH Portal page. Handout 4A
348 Sponsored Travel Form • Item 1 – Name is downloaded from TA. Type the travelers title • Item 2 – Sponsor information is downloaded from the TA. If the full address doesn’t appear, type the remaining information • Item 3 – HNC Code is downloaded from TA • Item 4 – Purpose is downloaded from TA. If the purpose will not fit into the field, type it at the bottom of the 348 form • Item 5 – Make sure you have the appropriate travel authority (see handout 5A). The method of payment is downloaded from TA Handout 5, 5A
348 – Sponsored Travel Form (Continued) • Item 6 – Dates of travel download from TA • Item 7 – Type expenses paid for by the NCI • Item 8 – Type supervisor’s name and title and obtain signature and date • Item 9 – Ethics signature (leave blank) • Item 10 – Traveler signs and dates after trip is complete
Certification Checklist • This form is generated when the traveler certifies the TA. They type in their name and title and verify questions 1-10. The form automatically defaults to “no” for all questions • At the very bottom of the page, type in the supervisor’s name and title and have the supervisor sign and date the form Handout 6
Late Memo • Submit a late memo if the travel cannot reach the ethics office 4 weeks prior to the departure date • The memo should contain a proper justification • Depending upon the urgency, notify the Ethics Office to see if the travel is feasible Handout 7
Notification of Foreign Travel (NFT) • The NFT can be accessed through the portal page at http://ogha.psc.gov/ogha/ • They should be submitted for all foreign travel 35 days prior to the start date of the trip in order to meet State Department deadlines • Enter all the necessary information in the required blocks • The trip departure and arrival dates should be consistent on the NFT, 348, TA, and letter of invitation. • Enter contact information: sponsor, hotel, and US Embassy name, address, and telephone number Handout 8
Requesting Phone Calls • All phone calls for foreign travel must be pre-approved by your AO prior to the trip • Insert comment in “remarks” section of the TA with the breakdown of expenses for phone calls. Some division’s may require a separate memo in addition to remark on TA • Phone calls for foreign travel should be approved up front NOT after the fact Handout 9
Request for Rental Car, Foreign Flag, and Business Class Travel • All requests for the above must be selected on the TA under “other authorizations” • Proper justifications and forms must be submitted with the package (refer to travel guidance) • Requests for these items will NOT be approved after the fact • Submit rental car vs. taxi comparison memo if applicable Handout 10, 10A
Multiple Sponsors • Multiple sponsors require multiple 348’s, checklists, and letters of invitation • Make certain costs are allocated to the appropriate sponsor Handout 11 (copy of multiple sponsored TA)
348 Deadlines – Domestic / Foreign • 348 packages should be received in the Administrative Office at least 6 weeks prior to trip departure • 348’s are due in the Ethics Office 4 weeks prior to trip departure
Annual Leave and Sponsored Travel • No annual leave is permitted in conjunction with sponsored travel for both foreign and domestic
Official Duty Memo • If it is a one time meeting, an official duty memo is not required unless it’s a problematic source (pharmaceutical) • If there are several interactions planned, an official duty memo is required (ex: employee is a member of a committee or board) • Traveler cannot accept an honorarium • Submit the Official Duty memo along with the 348 package if applicable • Websites: http://ethics.od.nih.gov; http://ethics.od.nih.gov/forms.htm Handout 12
Comp Time for Travel • Select comp time on each TA under “other authorizations” • When the traveler returns from their trip, they submit the comp time form to their supervisor for approval • The traveler submits the original approved form to their timekeeper within 5 days of the travel to be filed in the traveler’s ITAS folder. A copy is given to the travel planner to be attached to the voucher • Traveler and supervisor should keep a copy for their records • Tracking and requesting the use of comp time will be handled by the timekeeper, traveler, and traveler’s supervisor Handout 13
Widely Attended Gatherings (WAG) • A widely attended gathering (WAG) is an invitational event not included in the registration fee. For instance, an invitation to attend a social or celebratory event as well as certain fund raising gala events. Participation in these events is cleared in a personal capacity under the gift exception regulations found at 5 CFR 2635.204(g)(2) as WAG events. • An offer of free attendance on the day of the presentation could include waived registration fee, the provision of food, refreshments, entertainment, or materials furnished to all attendees as part of the event when furnished by the sponsor. It does not include travel expenses, lodging, or entertainment not associated with the event, or meals other than those taken in a group setting with all other attendees. If lodging,per diem, transportation, etc. is offered in conjunction with a waived registration, you must submit a 348 travel to cover the those expenses and a WAG to cover the waived registration fee. • No WAG form is needed if the traveler is only staying for the day of their presentation; however, if the traveler stays additional days then a WAG from must be completed. • Please refer to ethics guidance on the WAG at http://ethics.od.nih.gov/Topics/wag.htm Handout 14
Common Errors • Route slip not completed properly • Forms not complete • Lack of signatures • Signature not legible and name/title not typed • Less than the 4 week lead time to ethics • After the fact (event already occurred)
Where to Get More Information • Sponsored Travel Policies and Procedures – Manual Chapter 1500-08-00 http://www1.od.nih.gov/oma/manualchapters/management/1500/08.html • Special Requirements for IC Director Sponsored Travel – Manual Issuance 1500 – Appendix 6 http://www1.od.nih.gov/oma/manualchapters/management/1500/appendix6.html • Sponsored Travel Q&A for Non-FTE – Manual Issuance 1500-Appendix 10A http://www1.od.nih.gov/manualchapters/management/1500/appendix10A.html
Where to Get More Information (Con’t) • Travel Portal https://my.nih.gov • NBS Customer Support: 301-435-6277 • Web Request Support: http://support.cit.nih.gov • Federal Travel Regulations http://www.gsa.gov/Portal/gsa/ep/home.do?tabID=0 • Foreign per diem rates, US Embassies, etc. www.state.gov
Travel Voucher • Compare the TA against the Voucher • Item 1 - Review traveler’s personal information (name, address, HNC Code, etc.) • Item 2 - Review dates of travel to make certain they match the TA • Item 4 - Review Project # / CAN / and OC Codes Handout 15
Itinerary & Transportation Expenses • Item 11 - Make certain departure and arrival dates and destination are correct. Compare against Omega itinerary and the TA • Check Omega’s receipt for fare tickets and TMC fee against voucher. Price may differ slightly from TA • Review taxi / transportation charges. If over $75, a receipt is required. Ensure that taxis and transportation charges are legitimate (not for traveler’s entertainment, transportation to and from restaurant, etc) • Compare all other charges against receipts and TA (POV mileage, airport parking, etc). Price may differ slightly from TA. Make changes accordingly. Any expenses on the TA that are not claimed or used delete (excess taxis, etc) and add new expenses when applicable
Lodging / M&IE / Other Expenses • Item 12 - Check “Actual Lodging” against the receipt. No receipt required if sponsored In-Kind. Must still be entered into system and charged In-kind (*) to sponsor • Traveler should not accept lodging above the “allowed” amount unless the same accommodations are offered to all meeting presenters
Lodging / M&IE / Other Expenses • Item 12 - Break out the portion of M&IE provided by the sponsor vs. NIH. Make certain the total M&IE claimed equals the allowed per diem rate • Ensure that the first and last day of travel reflect the ¾ day maximum allowed per diem rate • Ensure that all expenses are allocated correctly (Reimbursed, In Kind, Travel Card, etc.)
Voucher – Final Details • Verify that the voucher was certified by the traveler prior to approving • Check the 348 page to ensure that the correct amounts have been allocated to the sponsor • Traveler will sign 348 and voucher • Traveler should complete a “trip report” when returning from foreign travel Handout 16
Travel Audit • Sponsored travel must be sent to Travel Audit Building 31- B1B31 • Send copies – No originals • Reimbursable checks should be made payable to DHHS. If a check is made out to the traveler, the traveler must sign the back of check, write the TA#, and write “Pay to the order of DHHS-NIH” • Checklist of items to be sent • Travel Authorization • Travel Voucher • Receipts • Signed 348 • 348 Certification Checklist