Published: July 7, 2022

A PEO is a professional employer organization (PEO) that partners with the University in the hiring of CU Global Employees. A CU Global Employee is defined as any employee of the University of Colorado, regardless of their country of citizenship, permanent residency, or tax residency, whose work site is located outside of the U.S. and its territories for any relevant tax period in a calendar year.

CU’s PEO is Global PEO Services (GPS), a legal employer in every country they operate (170+ countries) with extensive expertise in navigating complex labor laws and regulations for each of those countries. This allows them to help the University legally employ workers outside of the U.S. and its territories without the University having to set up a local entity in each country or deal with payroll and compliance challenges. Additional information is available on the CU System website.

An individual who is employed by GPS is currently not considered a CU employee.

PEO Details for Sponsored Projects

As of 7/6/22. This is an evolving issue and additional guidance will be provided as decisions are made. The following has been reviewed by the Office of Contracts and Grants (OCG) and the Campus Controller's Office (CCO).

The use of Global PEO Services (GPS) on sponsored projects is allowable in the following situations:

  • Key personnel (PIs and Co-PIs) may use GPS if:
    • Salary for key personnel will be paid from non-sponsored project funds and not from the sponsored project. PIs or Co-PIs must also have an eligible CU Boulder appointment. 
    • In rare cases, such as University personnel moving out of country near the end of a project or transitioning to a CU appointment from another country, an individual may serve as key personnel on a University sponsored project and temporarily be paid through GPS, with the agreement of the responsible CU Unit and eligible CU Boulder appointment (eg, Research Affiliate). Note that tenure and tenure-track faculty are excluded from being paid through GPS.
  • Other personnel (Non-PIs and/or Non-Co-PIs) may use GPS if:
    • They are not currently CU Employees (eg, currently employed PIs, postdocs, researchers, GRAs) and do not knowingly intend to be CU Employees (eg, new or to be new hires), intend to work from another country, and do not have access to U.S. healthcare, a U.S. social security number, or a U.S. bank account. 
    • In rare cases, new employees may be temporarily hired using GPS during an initial transition period until they become CU Employees. 
    • In rare cases, current CU Employees may be temporarily hired using GPS if a visa expires or if they are transitioning from CU to a new appointment in another country.
    • They are not Graduate Student Assistants (GRAs). The Graduate School does not allow GRAs to be paid on a Global PEO.

For all allowable cases:

  • The sponsor must allow or not disallow “Personal Service Contracts.” Costs of the Global PEO are charged as “Personal Service Contracts” and not salary and wages.
  • Personnel paid on the Global PEO are not subject to CU’s effort reporting process.
  • If working in another country is not required for the project work, the unit must pay non-salary and non-fringe costs related to affiliation with GPS.
  • If working in another country is a requirement of the sponsored project, then salary and fringe benefits (social costs) as well as some GPS fees may be paid by the sponsored project (see exclusions in next bullet).
  • GPS refundable deposits and “Transition Fee” are an unallowable cost for all sponsored projects and must be paid from non-sponsored project funds. 

Unit Responsibilities and Risk

CU units are responsible for:

  • Initiation and management of the relationship with GPS. 
  • All costs associated with the use of GPS, including any GPS fees, required payment of salary, and fringe costs that contribute to benefits and foreign country social costs, if not covered by a sponsored project.  
  • Providing GPS employees with an appointment (eg, Research Affiliate) and an agreement, such as the Research Affiliate agreement.
  • Onboarding new GPS employees and advising on required affiliate policies, procedures, and training.
  • Receiving required approvals.
  • Supervisory oversight and management of GPS employee’s work with the University. 
  • Determining annual salary increase. Annual increases are at the discretion of the unit. It is recommended that any salary increase follow the CU parameters for that period (ie. performance review on file “meeting expectations'' or better and adhering to the merit pool limit).
  • For sponsored projects, ensuring the costs are allowable by the sponsor prior to engaging with GPS.
  • All externally incurred costs as a result of engaging in a global affiliate relationship, including potential fines or penalties levied against the University.   

Employee Responsibilities and Risk

Employees of GPS are not considered CU Employees. However, they must adhere to prescribed University policies and procedures in order to maintain University affiliation.

Employees of GPS are expected to keep current on all mandatory University training and reporting required of their work with the University. Performance management completion in the annual performance cycle is at the discretion of the department and not required for Global Affiliates. 

While an employee of GPS is employed through the PEO, all employment risk is assumed by the vendor (Global PEO) and not CU.  When an employee of GPS works abroad in a standard employee relationship through the PEO, there is some risk assumed by the individual. However uncommon, this may include potential fines or penalties levied against the individual, which must be paid by the individual. 

Related Documents and Resources

https://www.cu.edu/cu-global-employee 

Frequently Asked Questions

If working in another country is required for the sponsored project, the costs of the Global PEO Services (GPS) can be charged to the sponsored project with the exception of the Global PEO refundable deposit and the “Transition Fee” of the Final Invoice.

If working in another country is not required for the sponsored project and is for the convenience of the employee, only salary and fringe benefits (social costs) of Global PEO Services (GPS) costs can be charged to a sponsored project. The unit must pay non-salary and non-fringe costs related to affiliation with GPS.

The Global PEO refundable deposits are an unallowable cost because by paying a refundable deposit from sponsor funds, those funds become unusable for the project itself because they are held and then refunded after the end of the project. They can then not be used for the project, which has ended, and sets up a scenario of needing to possibly refund the sponsor, depending on the award terms and conditions.

The “Transition Fee” is unallowable because it is difficult to justify this fee as 100% allocable to the award.

 

Guidance as of 4/23/21. Replaced by above guidance on 7/6/22.

As of 4/23/21. This is an evolving issue and additional guidance will be provided as decisions are made. The following has been reviewed by the Office of Contracts and Grants (OCG) and the Campus Controller's Office (CCO).

  • The use of Global PEO Services (GPS) is allowable on sponsored projects ONLY for personnel who are not currently CU Employees (eg, not allowable for currently employed PIs, postdocs, researchers, GRAs) and do not knowingly intend to be CU Employees (eg, new or to be new hires) and intend to work from another country. 
  • The allowable case of GPS on sponsored projects is foreign nationals who will be/are research personnel working in another country on the proposed/awarded project when a subaward is not appropriate/cannot be used. Additional characteristics of such personnel: no access to US healthcare; no US social security number; not a CU employee; no US bank account. 
  • Working in the remote location must be necessary to the scope of work.
  • Use of GPS on sponsored projects is also only allowable if the sponsor allows/does not disallow “Personal Service Contracts.” 
  • For proposal budgeting, GPS - PEO should be budgeted as a “Personal Service Contract” in Other Direct Costs. For the purposes of determining the applicable indirect cost rate, this cost is considered an off-campus cost.
  • On the financial side for CCO, GPS - PEO will be charged as a Personal Service Contract.
  • For allowable cases, departments must use GPS and cannot use another PEO. Departments should follow the PEO process, starting with requesting a quote. (Note that the link to the Generate a Quote Form in the PEO Process does not direct to the form – link below).
  • The quote should be requested during the proposal budget process so that accurate numbers can be used. The cost of this service can be quite expensive. This link can be provided to departments for the Generate a Quote Form: https://www.cu.edu/docs/generate-quote-form.
  • Inflation rates on the PEO service in out years may be adjusted if required by the lead. To date, we’ve seen the lead require a higher rate of inflation on the PEO service based on the foreign country’s labor laws.

This guidance will be updated as we have more information. If you are budgeting GPS on a proposal, contact your Proposal Analyst with questions. For general questions about GPS on sponsored projects, contact Alexa Van Dalsem at alexa.vandalsem@colorado.edu.