International travel

[a-m...@umn.edu]

I have a PI that wants to attend a conference in France but did not budget for international travel. Is this part of the Uniform Guidance or specific to each agency?

[Heidi Huff]

Hi,

The only thing I had found in UG regarding foreign travel is that a sponsor may have a restriction (some section regarding restrictions I looked up a long time ago).  I think if conferences were budgeted for, the NOGA is not restricting foreign travel, and the NOGA is not requiring sponsor approval for it, then the only other concerns are Fly America and checking to see if the country itself is restricted (see Export Controls).  France would not be a concern for the latter.

[Nicole Pilman]

It's agency specific. I checked the UG as well as the newly implemented Research Terms and Conditions and this is what I found in the UG (there was no mention in the RTCs):

Appendix I to Part 200—Full Text of Notice of Funding Opportunity D. Application and Submission Information6. Funding Restrictions—Required. Notices must include information on funding restrictions in order to allow an applicant to develop an application and budget consistent with program requirements. Examples are whether construction is an allowable activity, if there are any limitations on direct costs such as foreign travel or equipment purchases, and if there are any limits on indirect costs (or facilities and administrative costs). Applicants must be advised if Federal awards will not allow reimbursement of pre-Federal award costs.

[Mary Kosowski]

I have a PI with an NIH award who is going to a conference in Canada. He did not request any foreign travel at the time of proposal. The NOGA does not mention any restriction, but perhaps that is due to his not requesting it in the first place? The NOGA does include the T & C about Fly America must be complied with, so is it fair to conclude that foreign travel would be allowable?

[andrewca...@gmail.com]

Was travel generally approved on the proposal budget, or was it not include at all as a requested item in the orioginal budget?

If travel was generally budgeted at time of proposal/award, then I would suggest checking the budget justification, NOA, and NOGA to see how travel was described in those documents. My understanding is that the detail surrounding whether travel is domestic or international is not always clearly delineated based on the sponsor. I think NIH is one of those sponsors. NSF seems to make applicants clearly state whether travel allocations are domestic or international.

If the grant has broad rebudget authority (scope unaltered), then you could potentially add the needed travel account code if it was never budgeted/requested. However, I would stress that a very strong justification about how the travel benefits the grant research aims is needed. I would also recommend getting a clear statement from the PI that this change will not alter the work scope.
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Given that the Fly America Act language should be on all NOGAs for federally contracted funding, I would not assume that international travel is allowed just because that statement is included.