What You Need to Know To Ensure Compliance January 2015

Governance

 Policies, Rules & Regulations that Govern Sponsored Travel at the University of Oregon

OMB Circular A-21, Section J.53, Travel Costs & Uniform Guidance 2 CFR 200.474

• • • • Costs incurred by employees and officers for travel, including costs of lodging, other subsistence, and incidental expenses, shall be considered reasonable and allowable only to the extent such costs do not exceed charges normally allowed by the institution in its regular operations as the result of the institution’s written travel policy. • Costs charged to an award must meet the direct charging standards of allowable, allocable, reasonable, necessary, and consistent.

If these costs are charged directly to the Federal award, documentation must justify that: Participation of the individual is necessary to the Federal award; and The costs are reasonable and consistent with non-Federal entity’s established travel policy.

What Does The OMB Guidance Mean For UO Travel?

• • • The OMB Circulars require that travel expenses on sponsored awards be treated consistently with the institution’s travel policies.

Unless otherwise restricted/allowed by a sponsor, all travel on sponsored awards must adhere to UO travel policies.

Strong information linking the travel to the goals and scope of the work on the project is required on each document related to the travel expenses.

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Fly America

 The Fly America Act is federal legislation outside of the OMB guidance that also applies to all federal funding.

All foreign travel airfare expenses on federal projects (prime funded or subawarded to UO) must be in compliance with the Fly America Act.

 Air travel to foreign destinations must be on US Flag Carriers unless certain exceptions are met.

   SPS Fly America Compliance form must be completed for all foreign travel on federal funding, and be retained by the department with travel documents. If an exception is being claimed, route the form to your Post Award team for review prior to purchasing the airfare.

Non-compliant airfare is unallowable on the project, and will have to be paid by another funding source.

 Open Skies

Fly America

    Some exceptions to Fly America when utilizing airlines of member countries.

Full list of participating countries on the SPS Fly America web-page (link below).

 Fly America information & forms are available on the SPS Fly America web-page.

https://orsa.uoregon.edu/index.cfm?toplevcat=awar ds&page=AW_14_Fly_America

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Sponsor Regulations & Award Document

 Please be aware of the terms and conditions of your award.

Due to reduced funding and new regulations, many sponsors limit travel expenses. Prior approval from the sponsor may be required for:  Travel not included in the proposal budget and justification   Foreign Travel Other special circumstances Contact Post Award for any questions about the award notice, or for assistance with the prior approval process.

Institutional Policies

Follow standard UO Travel Office Guidance unless otherwise instructed by a sponsor!

Implementation

 The Technical Details of Sponsored Travel

 Follow UO Travel policy unless there are further restrictions from the sponsor.

 Business purpose is required for all travel documents, no exception for sponsored indexes.

 Include the who, what, when, where, why for the trip on all related BANNER documents (reimbursements, airfare, conference registrations, etc.), clearly linking the travel to the project.

Business Purpose & BANNER Text

Airfare Benefitting Multiple Indexes

    When purchasing an airline ticket that will benefit multiple indexes through the travel office, provide a departmental index for the charge. Once the charge posts, JV the allocable amounts to the project indexes with complete justification information in the document text. We cannot charge anything to a sponsored index that does not meet the direct charging guidelines. If part of the funding is federal, ensure that the airfare is Fly America compliant.

Questions?

 Contact Sponsored Projects Services for any travel questions related to your sponsored projects!

THANK YOU!