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INTERNATIONAL TRAVEL ON FEDERAL AWARDS. CHANGE IN APPROVAL PROCESS-NOT THE DOCUMENTATION June 19, 2012. International Travel.
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INTERNATIONAL TRAVEL ON FEDERAL AWARDS CHANGE IN APPROVAL PROCESS-NOT THE DOCUMENTATION June 19, 2012
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.
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.
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.
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.
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.
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)
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.
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.
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.
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.
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-of-pocket 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.
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.
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.
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)
Expenditure Justification Form • Explain all items not contemplated by written policies. Examples include but are not limited to: • Higher class of service on airlines or rail service • Employee’s use of sedan/limo service • Fees such as bank fees, re-ticketing, lost ticket, no-shows, etc. • Lack of original receipts • Missing/incomplete supporting documentation • Exceeding meal / per diem thresholds
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
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.
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.
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)
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 215-898-1398
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_america_act • http://grants.nih.gov/grants/policy/nihgps_2011/nihgps_ch8.htm#_Requests_for_Prior
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