Travel on Non-Federal Sponsor Awards

Review the Award and sponsor regulations to determine the requirements for approval and allowable travel-related expenditures.  Most sponsors require that travel be in accordance with the recipient (UW) travel policies.  If this is the case, see the UW Travel website for more information.

Travel on Federally-Sponsored Awards

Travel is a high risk expenditure on Federal awards.  Some requirements differ from those of the UW and expenses are routinely subject to Federal agency review.  The information below identifies federal requirements and Best Practices for travel on a federal Award.  The Federal Uniform Guidance reference for travel is section 2 CFR 200.474

 

Travel Approval/Review

The Federal Uniform Guidance and most agency-specific regulations do not require sponsor approval for domestic or international travel.  However, always review the Award and agency regulations to determine if there are any specific approval requirements.

While the Federal regulations may not specifically require approval, written sponsor approval minimizes the risk of travel expenses being questioned by the sponsor during or after Award implementation. Documentation of the need for travel, and careful management of travel funds, are best practices for avoiding challenges to travel expenses after the fact, and described below. 

 Document Need for Travel

  • Itemize and describe the need for travel in the proposal and proposal budget.
  • If the travel is not in the proposal:
  • Notify, in writing, the sponsor of the need for travel, even if their approval is not required. 
  • Document how the unbudgeted travel will benefit the award.  Documentation can be part of the sponsor notification or in separate documentation retained with the travel expenditures.
  • Include how the travel benefitted the award in subsequent sponsor required programmatic or progress reports

 

Manage Travel Budget

  • Keep travel expenditures within the Travel budget line item.  Expenditures in excess of the budgeted amount may be questioned, even if the adjustment is within the re-budgeting authority allowed to the recipient (UW).
  • If travel is unbudgeted or actual travel expenses exceed the budget line item, be sure to document (ideally in a progress report) how the travel benefitted the Award and from which line item the funds were re-budgeted.  

 

Timing/Personal Travel

The travel must take place between the start and end dates of the Award (budget) period.  Travel cannot take place after the end of the Budget Period/Award, even if the travel is directly related to the Award. The cost of any airfare purchased during the budget period for travel that will take place after the budget period is unallowable.   See Expenditure Timing for more information.

The length of trip must coincide with travel objectives.  Any additional time added to a trip is considered personal and related costs cannot be allocated to the Award.  The UW Travel webpage has information on how to allocate any personal travel time or expenses.

 

Commercial Air Travel (Airfare)

The Federal Uniform Guidance (2 CFR 200.474 (e)) states that Federal regulations must be followed for airfare purchases.  Unlike other travel expenditures (e.g., per diem, see below), Federal regulations do not allow a recipient’s (UW’s) established policies to supersede the Federal regulations for airfare.

As always, individual Federal agency regulations supersede the Federal Uniform Guidance.  Review the Award and individual Federal agency regulations to ensure compliance with airfare purchases.  Some Federal agencies have regulations that are more restrictive than the Uniform Guidance.  Information on select Federal agency regulations is provided at the end of this section.

 

Fly America Act

Unless exempted in writing, all airfare on a Federal award must comply with the Fly America Act (FAA).  Compliance with the Fly America Act (FAA) includes allowances for itinerary –specific exemptions and for eligible flights under both airline code share agreements and the Open Skies Agreements (which is part of the FAA), both of which are updated on a routine basis.  Thus, compliance for individual flights can only be determined with access to all available flight options and up to date information on Code Share and Open Skies agreements.  As the PAFC team does not have this capacity, the best option is to work with a travel agent to ensure compliance.  Please contact the UW Travel for information on UW Travel agents.

Class of Travel

Travel must be taken using the least expensive class of travel, more commonly known as “economy.”  This is regardless of the total travel time (from point of departure to final destination) or duration of flight(s).   

The Federal regulations do provide some exemptions for this requirement, which can be found in 2 CFR 200.474 (e).  Departments should review these exemptions and determine if travel needs meet any of these exemptions.  Keep in mind that individual Federal agency sponsors can make a determination if the use of any exemptions is reasonable and prudent. 

Note that under the Federal Uniform Guidance, total travel time in excess of 14 hours is NOT listed as an exception for the least expensive class of travel.  This exception is listed as part of the Federal Travel Regulation (FTR) but Federal sponsored awards are subject to the Uniform Guidance and not the FTR.  There is no exception to travel in other than coach or economy class based solely on the length of the trip.   

If a traveler purchases airfare other than in the least expensive class of travel, the cost of the airfare in excess of the least expensive class of travel is not allowable on a sponsored award.

If any of the exemptions to the Federal travel regulations are used:

  • Include the anticipation of and the reasoning for any exemptions in the proposal.
  • Clearly document the use of any exemptions and rationale for their use.  Retain this documentation with the travel expenditures so it can be easily retrieved if questioned by the sponsor.

 

Type of Ticket

The least expensive unrestricted fare is allowable.  Unrestricted airfare allows for cancellation or change with a penalty value that is less than the cost of the ticket.

Airfare purchased on a restricted fare is allowable as long as the ticket is used.  If the restricted ticket is not used, then the cost of the ticket is unallowable. 

 

Seat Fees

Any fee paid to obtain a more desirable seat is considered to be the traveler's personal choice and therefore is not allowable on a federal award.  Seat fees paid using non-federal awards must follow the UW Travel policy.

 

Non-Commercial Air Travel

The cost of non-commercial air travel (e.g., leased or chartered aircraft) includes the cost of lease, charter, operation (including personnel costs), maintenance, depreciation, insurance, and other related costs.  The use of this type of travel, in lieu of commercial air travel, l must be justified as being reasonable (i.e., commercial air travel is unavailable).  If commercial air travel is available, then the cost of non-commercial travel in excess of commercial travel is unallowable.

 

Travel Other Than by Air

Federal regulations require that travel be taken by the most direct and expeditious routing, which typically involves, when available, commercial air travel.  If commercial air travel is available but the traveler wishes to travel by another means (e.g., vehicle, bus, train) any cost for this conveyance that is above the cost of commercial air travel is unallowable.

For example:  The traveler is traveling from Seattle to San Francisco.  The cost of the least expensive class of travel or unrestricted airfare plus the cost of transportation to/from the airports is $500.  The traveler elects to take the bus to San Francisco and the cost of the bus fare plus transportation to/from the bus station is $300.  The routing via the bus would be allowable as the total cost is less than the total cost via airfare.

 

Best Practices

  • Purchase airline tickets through the UW contract travel agent to ensure FAA compliance and take advantage of any negotiated fare agreements.
  • If personal time is added to a trip, ensure that the cost allocations are clearly documented and any personal-related costs are not allocated to the Award.

 

Per Diem

The Federal Uniform Guidance allows for the use of the recipient’s (UW’s) established policies and practices for Per Diem.  See the UW Travel webpage for information.

  • Any meals that are reimbursed directly (instead of included as part of per diem allowance) must be within the meal allocation for the per diem rate.  This includes any meals for the traveler as well as meals paid by the traveler for other people.
  • Conference centers may charge lump sum amounts for lodging, meals and conference fees.  In this case, an itemized list of each expenditure must be obtained from the conference center.  This is to ensure that the cost for meal(s) and lodging does not exceed the allowable per diem amount(s). 

 

 

 

Agency-Specific Travel Regulations

As always, an Agency’s specific policies supersede these Federal regulations and any Award specific Terms and Conditions would supersede agency regulations (see link for information on the Federal Regulation Hierarchy).  Below are some links to some of the Federal agencies regulations on travel:

National Science Foundation (NSF) Grant Policy Guide (GPG):  Section II.C.2.g. (iv)

National Institutes of Health (NIH) Grant Policy Statement (GPS):   Section 7.9, Allowable Cost, see “Travel/Employees”