I. Procedural Statement
This document is intended to serve as formal guidance for CU Boulder regarding the use of funds from sponsored projects for visa costs 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.
Visa costs are defined and described as allowable in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR §200.463(d) as:
Short-term, travel visa costs (as opposed to longer-term, immigration visas) are generally allowable expenses that may be proposed as a direct cost. Since short-term visas are issued for a specific period and purpose, they can be clearly identified as directly connected to work performed on a federal award.
Visa costs discussed in this policy are specifically associated with research-related visas. See International Student and Scholar Services (ISSS) for additional information on visas.
A. Federal Awards
Under the guidelines imposed by the Uniform Guidance, visa costs may be considered allowable direct charges under certain circumstances, and Principal Investigators (PIs) need to demonstrate that such costs fit the criteria provided in the Uniform Guidance. Visa costs are allowable, provided that they meet all four of the following conditions:
The Uniform Guidance categorizes visa costs as a recruitment cost (2 CFR 200.463). Therefore, in like circumstances, visa costs are limited to initial costs only.
The following visa types may be allowable as a direct charge:
The following costs related to visas are unallowable:
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 including visa costs are similar for non-federal sponsored projects, but it is important to be familiar with the particular requirements or restrictions of each non-federal sponsor. When allowed by the sponsor, a justification for the inclusion of visa costs should be provided in order to explain why they are necessary to fulfill the research objective of the project, and to ensure that the cost directly benefits the project.
The visa cost should be identified in the proposal budget justification if possible, and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the cost. 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
Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted visa cost is required after an award is funded, the department should work directly with their OCG grant or contract officer to ensure that this cost is properly documented prior to when the expense is incurred. The purpose and benefit of the visa costs to the specific project should be fully described in the justification and will be retained in Boulder eRA (BeRA).
You may charge the visa application fees, including the filing fee and the Anti-Fraud Fee to the award if the researcher is essential and necessary for the project. Internal CU Boulder processing fees and any expedited processing fees cannot be charged to the sponsored project. The department should retain documentation from the PI that the prospective research associate is essential and necessary for the sponsored project.
No. Visa costs are only allowable as part of recruitment, not retention.
Rush or premium fees are not allowable as direct charges to a sponsored project. The department can pay for these fees through a departmental account.
Internal fees are not allowable as direct charges to a federal award per ISSS. In the event of a non-federal award, allowability is determined by the sponsor.
Unless the spouse is directly involved with work on that sponsored project, visa fees for spouses are not an allowable expense to sponsored projects.
No. Only those visa costs associated with the initial recruitment may be direct charged to a federal award.
Yes, this visa cost is an allowable travel charge to the sponsored project.
This would not be considered a recruiting cost; visas for collaborators may be allowable as travel costs. Contact the Office of International Students and Scholars for more information on appropriate visa types.