Travel Expenditures Funded by Rice University Sponsored Programs
This document is intended to serve as formal guidance for Rice University for charging travel-related expenditures to funds received from sponsored programs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs 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 programs. Procedural statements support the Rice University Cost Principles Procedure 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.
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 Rice University Travel Policy and determined by department, center, or institute policy.
Rice University considers the following criteria key elements in determining whether or not and travel charges are allowable:
- The travel is necessary to fulfill the objective of the program and it directly benefits the program 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 program that is provided in the travel documentation. If the traveler receives salary from the program, 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 Rice University Travel Policy. Rice University provides additional requirements for sponsored program 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 foreign travel is in accordance with the Fly America Act
- Car Rental: General Services Administration (GSA) Federal Travel Regulation (FTR) 301-10.450(c) stipulates that the least expensive compact car 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.
- International Travel: Travel internationally must abide by the Fly America Act and Open Skies Agreements. Please refer to the Cost Principles regarding international travel for more information.
Other Allowable Expenses
- Lodging: Lodging can be charged to a program if an overnight stay is necessary to complete the purpose of the trip and it directly supports the program being charged; Rice University considers the traveler to be in travel status when both of these conditions are met. The University will reimburse for a reasonable single occupancy, standard business room rate.
- Meals: Meals for the traveler can be charged to a program 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 Rice University Travel Policy.
- Travel Visas: If the destination country for the travel requires a visa to enter the country and the travel is required to fulfill program objectives, the cost of that visa is allowable for essential program personnel and should be included in the proposed budget. See Visa Policy.
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. These costs are allowable if the costs are a direct result of travel under a sponsored award. Sponsor pre-approval is required.
Additionally, Rice University also disallows the following charges to sponsored programs 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.
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, Rice University’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 programs, 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 travel authorization which typically includes a written justification for travel in order to explain why this is necessary to fulfill the objective of the program and to ensure the cost directly benefits the program 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 program’s 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 SPARC 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 program in the justification, and include the criteria listed above to explain how travel is necessary and allocable to the program. 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 Cayuse.
When Booking a Trip
IRS rules (http://www.irs.gov/publications/p463/ch06.html) require business expenses to be documented in a timely manner. Undocumented, improperly documented or untimely submission of business expenses will require Rice to report these expenses as taxable income to the individual. Thus, travel, business meeting and entertainment expenses should be submitted and approved no later than thirty (30) calendar days after the return from a business trip or end of the meeting or event.
Departments should have procedures in place to ensure appropriate prior approval is provided for all trips charged to sponsored programs, 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.