I. Procedural Statement
This document is intended to serve as formal guidance for CU Boulder for charging travel-related expenditures to funds received from sponsored projects in like circumstances. The university is committed to ensuring costs incurred in support of sponsored research are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored research. Procedural statements support the CU Boulder Cost Principles Policy by providing definitions and processes for meeting those standards in like circumstances.
Travel Costs are defined in the U.S Office of Management and Budget’s Uniform Guidance, 2 CFR 200.474(a), as:
Expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of the non-federal entity.
CU Boulder allows non-employee travel to be direct charged to sponsored projects when it meets the criteria in Section III.A. below.
A. Federal Awards
Section 2 CFR 200.474 of the Uniform Guidance states that expenditures for travel related expenses are allowable when in travel status on official business of the university. Please note that while federal regulations allow these expenditures, it is important to review each award’s terms and conditions as sponsor guidelines may be more restrictive and may require specific sponsor prior approval, even when included in the proposed budget. When allowed by the federal sponsor, travel must be pre-approved on campus as prescribed by APS 4024, Travel Authorization and determined by department, center, or institute policy.
CU Boulder considers the following criteria key elements in determining whether or not and travel charges are allowable:
Allowable Travel-Related Expenses
The Uniform Guidance specifically allows expenses for lodging, subsistence, and related expenses as long as they follow university policy and procedures. Therefore, travel expenses for these categories need to adhere to Procurement Service Center regulations. CU Boulder provides additional requirements for sponsored research travel in this procedural statement. Transportation expenses are allowable but have additional federal requirements that restrict the acceptable dollar amount that can be charged for these categories.
Other allowable expenses include:
Unallowable Travel-Related Expenses
The Uniform Guidance identifies specific instances when travel expenses are unallowable.
Additionally, CU Boulder also disallows the following charges to sponsored projects in like circumstances:
B. Non-Federal Awards
Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, CU Boulder’s Cost Principles Policy and related procedural statements are also applicable to non-federal awards. The basic criteria for charging travel expenses are similar for non-federal sponsored projects, but it is also important to be familiar with the particular requirements or restrictions of each non-federal sponsor. When allowed by the non-federal sponsor, travel must be pre-approved as prescribed by APS 4024, Travel Authorization, which typically includes a written justification for travel in order to explain why this is necessary to fulfill the research objective of the project and to ensure the cost directly benefits the project being charged, even when the non-federal sponsor may follow more flexible spending guidelines.
Travel should be identified in the proposal budget justification and justified as to why it is necessary and allocable to the performance of the award. Whenever possible, international travel costs should be identified separately from domestic trips. Justification should clearly state the business purpose, the travelers intended for those trips, and how these trips directly benefit the project’s research purposes. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the travel. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.
After an Award is Funded
In the event that unbudgeted travel is required after an award is funded and sponsor prior approval is needed, communicate with your OCG grant or contract officer to contact the sponsor. If it is not required for either the specific trip or for the deviation from the proposed budget, the department should follow the campus guidance for documenting budget deviations (procedural statement coming soon). Substantiating documentation retained by the department should fully describe the purpose and benefit of the travel to the specific project in the justification, and include the criteria listed above in III.A. to explain how travel is necessary and allocable to the project. The department is responsible for keeping this documentation and providing it if the costs are questioned in the future. When required, written sponsor prior approval will be retained in Boulder eRA (BeRA).
When Booking a Trip
According to University APS 4024, Travel Authorization, department approval is required for all travelers on official university business in advance of the trip, including travel funded by sponsored research. Departments should have procedures in place to ensure appropriate prior approval is provided for all trips charged to sponsored research, even if the trip was properly budgeted and/or the sponsor has provided specific prior approval.
The Concur Travel system requires all international travel be approved by the department and by a university officer before the university’s travel agency can book a ticket. Please ensure sufficient time is provided when planning international trips in order to accommodate the additional time needed to complete this system requirement.
Note: Per current HR guidance, 100% remote employees working on sponsored projects are eligible to be reimbursed for travel expenses including air or ground travel to the Boulder campus, lodging (if needed), on-campus parking and/or mileage and tolls to attend a required event or meeting on the Boulder campus. These events and meetings should be infrequent (i.e. no more than 1-2 times/year). Trips for other reasons, such as the use of lab equipment, may be allowable if they are necessary for the work of the project.
For travel expenses that are charged to sponsored projects, all trips must be allowable, allocable (necessary for the project), and reasonable and within the terms and conditions of the award, and these expenses should not exceed more than 2 times per calendar year (combined total for either required onsite meetings or other project-related business need). It is recommended that departments document justification for the trips and why they are necessary to the project. Any trip costs found to be unallowable or denied by the sponsor will be the responsibility of the department, and departments should review the relevant travel policy and guidelines on the PSC website to ensure they comply with established university travel requirements.