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.

II. Defintions

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.

III. Procedures

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:

  • The travel is necessary to fulfill the research objective of the project and it directly benefits the project being charged, and
  • The cost for travel is reasonable and represents prudent use of the sponsor’s funds, and
  • There is a clearly defined relationship between the traveler and how he/she supports the work of the project that is provided in the travel documentation. If the traveler receives salary from the project, that provides sufficient documentation of the relationship.

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.

  • Airfare: Costs must represent the basic least expensive available unrestricted accommodations class unless those would unduly prolong the trip, require travel at unreasonable hours, increase the routing, or add costs that offset the airfare savings. For Federal awards or when the sponsor requires it, ensure the carrier being used for international travel is in accordance with the Fly America Act Desk Reference.
  • Car Rental: General Services Administration (GSA) Federal Travel Regulation (FTR) 301-10.450(c) stipulates that the least expensive compactcar available must be used, unless an exception for another class of vehicle has been justified. Explanation for the exception can be provided in the proposal budget justification or, if needed after the award is funded, provided with the travel expense reconciliation and stored in Concur. Exceptions include, but are not limited to, when there are multiple travelers in the same vehicle, to accommodate a medical disability, the amount of equipment and/or materials to be carried will not fit into a smaller vehicle, etc. Refer to FTR 301-10.450(c)(1-6) for a full listing of allowable exceptions.

Other allowable expenses include:

  • Lodging: Lodging can be charged to a project if an overnight stay is necessary to complete the purpose of the trip and it directly supports the project being charged; CU Boulder considers the traveler to be in travel status when both of these conditions are met.
  • Meals: Meals for the traveler can be charged to a project only while in travel status or for a day trip lasting longer than twelve hours, and must follow the per diem standards outlined in the Procurement Service Center's Travel Procedural Statement.
  • Travel Visas: If the destination country for the travel requires a visa to enter the country and the travel is required to fulfill research objectives, the cost of that visa is allowable for essential project personnel and should be included in the proposed budget.
  • Non-Employee Travel Expenses: If a non-university employee is essential to the project and requires travel to perform a direct service to the project, those travel expenses are allowable. If the non-employee traveler will be based in Boulder with a local address, their subsistence expenses should be charged as non-employee in-state travel and should reflect a reasonable subsistence allowance rather than the standard GSA per diem used for short-term travel. Expenses must be documented with the following information and retained by the department:
    • The purpose of the travel,
    • What role this non-employee plays on the project,
    • How the travel directly benefits the project,
    • Whether or not it has been pre-approved by the sponsor.

Unallowable Travel-Related Expenses

The Uniform Guidance identifies specific instances when travel expenses are unallowable.

  • Business-Class or First-Class Airfare: This is unallowable except for travelers whose medical needs require these accommodations. These situations are analyzed by the university on a case-by-case basis and the traveler must provide a doctor’s statement explaining the medical need for this exception. In certain cases, sponsor pre-approval may be required.
  • Travel Costs for Dependents: These are unallowable unless the travel is for six months or more and has sponsor prior approval.
  • Temporary Dependent Care: Federal standards allow these costs only when provided for all qualified employees of the university. CU Boulder does not have such a policy, therefore these are unallowable costs to a project.

Additionally, CU Boulder also disallows the following charges to sponsored projects in like circumstances:

  • Passport Fees: Passports are active for 10 years and their use benefits multiple activities, including business and personal, as well as unknown future activities. Therefore, it would be problematic justifying this expense or allocating it with a high degree of reliability.
  • Fees to Expedite Visa Processing: Fees to fast-track visa processing are not allowed.
  • Per diem reimbursement and lodging for local travel: As outlined in the Procurement Service Center's Travel Procedural Statement, travel in the local area will not be eligible for meal or lodging costs; however, reimbursement is allowed for local mileage and parking.

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.

C. Process

At Proposal

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.

D. Related Procedural Statements, Forms, Policies and Tools

While sponsor funding demonstrates approval, DOE, DPA and ARO generally have more restrictive terms that require pre-approval. Please note that the most restrictive terms on an individual award must be followed regardless of sponsor.

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.

Different documentation is required for participants whose travel is supported by a participant support project. Please contact the project’s SPA Grant Accountant for additional information.

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.

Profile

  • Reason for Policy: To establish direct charging procedures for sponsored projects in like circumstances. To determine if an unlike circumstance exists, see: Direct Charging to Sponsored Projects in Like and Unlike Circumstances.
  • Related Policy: Cost Principles Policy
  • Effective Date: 7/1/2016 in accordance with Uniform Guidance regulations effective for new funding received after 12/26/2014
  • Approved by: Laura Ragin, AVC and Controller, CU Boulder
  • Responsible Office: Office of Contracts and Grants (OCG)