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Sponsored Travel Cost Guidelines
effective April 1, 2006
amended December 14, 2006
The following guidelines have been adopted and endorsed by the Sponsored Programs Operating Committee (SPOC) as Harvard policy concerning the use of federal funds for travel costs. For further information, please contact Stacey Clifton, Contract Manager, in the Travel Office at 617-495-9308, or Min Xiao, Sponsored Programs Officer and Manager, in the Office for Sponsored Programs at 617-432-6281.
- Air Travel Using Federal Funds
- Federal Regulations Governing Federally Funded Commercial Air Travel
All air travel expenses charged to Harvard sponsored federal funds (fund range 100000-199999), whether incurred by Harvard travelers or non-Harvard visitors, are subject to the federal cost principles detailed in OMB Circular A-21, Cost Principles for Educational Institutions, section J. 53. c. "Commercial Air Travel". Per A-21:
"(1) Airfare costs in excess of the customary standard commercial airfare (coach or equivalent). or the lowest commercial discount airfare are unallowable except when such accommodations would: (a) require circuitous routing; (b) require travel during unreasonable hours; (c) excessively prolong travel; (d) result in additional costs that would offset the transportation savings; or (e) offer accommodations not reasonably adequate for the traveler's medical needs. The institution must justify and document these conditions on a case-by-case basis in order for the use of first-class airfare to be allowable in such cases.
(2) Unless a pattern of avoidance is detected, the Federal Government will generally not question an institution's determination that customary standard airfare or other discount airfare is unavailable for specific trips if the institution can demonstrate either of the following: (a) that such airfare was not available in the specific case; or (b) that it is the institution's overall practice to make routine use of such airfare."Expenses charged to federal funds are audited annually under OMB Circular A-133, Audits of States, Local Governments and Non Profit Organizations, which includes tests for compliance with the cost principles in A-21 and for compliance with the grantee's policies, which must adhere to the OMB A-21 guidelines. To ensure compliance with federal government regulations, Harvard travelers must be aware of and comply with the following requirements.
- Domestic Air Travel Requirements
To comply with A-21 regulations, Harvard travelers who purchase domestic airfares (excluding Alaska & Hawaii) using federal funds must purchase airfares using one of Harvard's preferred travel agencies (see section D below). In addition, domestic airfares purchased through a Harvard Preferred Vendor must be:
- for the lowest cost economy or coach class ticket quoted by the selected preferred vendor,
- for a reasonable itinerary, e.g. non-stop, same day, etc.,
- booked reasonably in advance of travel whenever possible, i.e. 30 days or more, and
- on US Flag Carriers only (see Subtitle F, Federal Travel Regulations); For List of US Flag Carriers– http://vpf-web.harvard.edu/ofs/travel/rei_us.shtml
- International Air Travel
Harvard travelers who purchase international airfares using federal funds (defined as trips taking more than six hours of fly-time, including Alaska & Hawaii, but excluding trips to Canada and Mexico taking under six hours) should follow all the Domestic Air Travel Guidelines noted above, with the following exceptions:
- international travelers may purchase the lowest cost business class tickets quoted by the selected preferred vendor, and
- must fly on US Flag Carriers when departing from the US and where available while abroad, even though less costly foreign flag carriers are available, and
- for foreign air travel completed completely outside the US, travel may be booked using any travel agent or web site and may use foreign carriers when no US Flag Carriers provide service in the area of travel or when use of foreign carriers is a matter of necessity.
- Harvard Preferred Travel Agencies
Harvard has developed strategic partnerships with six preferred travel agencies:
- Expedia Corporate Travel -- http://vpf-web.harvard.edu/ofs/travel/tra_exp.shtml
- BCD Travel -- http://vpf-web.harvard.edu/ofs/travel/tra_wor.shtml
- Great International Travel -- http://vpf-web.harvard.edu/ofs/travel/tra_gre.shtml
- Oriental Tours and Travel -- http://vpf-web.harvard.edu/ofs/travel/tra_ori.shtml
- Travel Collaborative -- http://vpf-web.harvard.edu/ofs/travel/tra_tra.shtml
- USAIR Shuttle kiosk or Shuttle ticket counter (preferred vendor for shuttle service between Boston, NY and DC) -- http://vpf-web.harvard.edu/ofs/travel/security/exc_air.shtml
Given that these vendors are able to offer Harvard travelers fares at competitive, discounted prices, federally-funded airfares must be booked through one of Harvard's preferred vendors and must meet the conditions detailed in Section B above. Airfares booked through one of Harvard's preferred vendors will not require any further documentation proving purchase of lowest available airfare.
In exceptional cases where airfares cannot be booked through one of Harvard's preferred travel agencies, the reason a preferred travel agency was not used must be included in the "Note to Approver" field on the Harvard Web Voucher form (see Section E below). Please note that if a preferred travel agency is not used and an acceptable reason is not provided on the web voucher, travel expenses may not be reimbursed or may be charged to a non-sponsored account. Acceptable reasons for not using a preferred travel agency include:
- Needing to make last minute travel arrangements that preclude use of the preferred travel agencies (i.e., it is not possible to access the Corporate Expedia Site in time to make the necessary reservations - e.g., reservations made at the airport)
- Reimbursements for travel expenses incurred by non-Harvard visitors who made their own travel arrangements.
- Foreign travel to and from destinations not supported by the preferred vendors.
- Group excursions. This exception is generally defined as a group of individuals traveling to the same destination for the same purpose, and book airfares through a travel agency who offers group discount rates, and often provides a pre-determined range of travel services for the group.
- Government airfare rates (generally lower than commercial rates)
- Exceptions may be made for international travel itineraries if the traveler is able to demonstrate savings of 25% or more using a non-preferred vendor as compared to a Harvard preferred vendor (for the same itinerary) AND obtains approval prior to booking the trip. The supporting documentation for web voucher reimbursement should include the following:
- A copy of the airfare itinerary from a Harvard preferred travel agency for the same itinerary and class of service.
- A written approval letter from the Travel Office ( or OSP if necessary) prior to booking the trip
- Air Travel Documentation Requirements
The Travel Office will conduct a pre-audit on all federally-sponsored travel expenses submitted for reimbursement:
For travel booked through a preferred travel agency
- No "lowest available airfare" documentation is necessary
- Airfare will be approved and may be charged in full to a federally sponsored account.
For travel booked through a non-preferred travel agency
- Write an explanation in the "Note to Approver" field on the Web Voucher form. By approving the web voucher, the approver is certifying that the web voucher met criteria as an exceptional case according to the policy.
- Assuming an acceptable justification is provided, the airfare expense will be assessed for reasonableness within the allowable class of service and, if deemed reasonable (i.e., if the expense passes the "Prudent Person" test), may be charged in full to a sponsored account.
- If an acceptable rationale is not provided, or if the purchase fails the reasonableness ("Prudent Person") test, the expense report will be returned to the department and the entire amount will need to be charged to a non-sponsored account.
Please note any other airfare costs incurred outside of this policy (e.g., a visitor who flies business class rather than coach class on a domestic flight) will also be returned to the department and subsequently charged to a non-sponsored account.
- Federal Regulations Governing Federally Funded Commercial Air Travel
- Train Travel Using Federal Funds
Harvard travelers using federal funds may also choose train travel when it is an economical and practical alternative to air travel. Travelers are not required to use the preferred travel agents for purchasing train fares. However, Harvard employees will receive a discount on Amtrak for both the high-speed Acela Express Service and the Regional Metroliner Service. These discounts are only available when tickets are purchased through the Harvard Travel Center (496-8000), or http://www.travel.harvard.edu
- Travel Using Non-Federal Sponsored Funds
While travel charged to non-federal sponsored funds (fund ranges 200000-299999) will not be held to the standards established for federally-funded travel, travel expenses charged to non-federal sponsored funds will be assessed for reasonableness within the allowable class of service and, if deemed reasonable, may be charged in full to the non-federal sponsored account. "Reasonableness" is assessed on a case-by-case basis by the Travel Office (and OSP if necessary), but the cost for the airfare purchased should be similar to prices quoted by one of Harvard's preferred vendors for the same itinerary and class of service. Any expenses deemed to be unreasonable will be returned to the department and will need to be charged to a non-sponsored account.
Frequently Asked Questions
- When making on-line reservations how can I be sure I access the Expedia Corporate Website and not Expedia.com by mistake?
The best way to log onto the corporate website is through Harvard Office of the Controller website: http://vpf-web.harvard.edu/ofs/travel/tra_exp.shtml.
The direct link to the corporate website is: http://www.expediacorporate.com/daily/brochure/default.asp. If you log onto Expedia.com home page first, you should click on Business Travel on the right hand corner of the screen, then clink on Expedia Corporate Travel on the left hand corner of the screen.
Be careful that when logging onto Expedia you are using the Corporate Website and not expedia.com which is what you would use for booking personal travel. You will notice Harvard University in the top right hand corner once you log onto the corporate website. As a preferred vendor, the corporate website includes Harvard negotiated pricing and is now required when booking on-line reservations using federal funds.
- How do I gain access to Harvard's Corporate Expedia website?
For first time users, you should contact the Travel Office to be set-up in the system. The instructions are posted on the travel office website http://vpf-web.harvard.edu/ofs/travel/index.shtml under Expedia Corporate 1st time users.
- What options do non-employees have for using our preferred vendors?
a) Non-employees can gain access to Harvard's Corporate Expedia website by e-mailing the travel office (travelmgr@harvard.edu) with the name and e-mail address of the traveler. A profile can be set up temporarily for non-employees, so that they are able to make their travel arrangements. Another option is to ask to establish a guest account for a non-employee in order to make travel arrangements on their behalf.
b) Non-employees can also book their travel through BCD Travel (the Harvard Travel Center) and have their airfare directly billed to a sponsoring department. The travel reservations would be made directly through BCD Travel and the department would use the web voucher system to create the travel authorization. The complete instructions on the Direct Billing Process can be found on the travel office website http://vpf-web.harvard.edu/ofs/travel/index.shtml under 'How to bill airline tickets to your department'
- I work in a small department with a very limited budget. Each year I plan a trip for 10-12 of my post docs to travel to China. We can't afford Expedia Corporate and I always use a travel agency which offers discount rates for my post docs' travel. This new policy is going to break my budget! What can I do?
Group excursions or group travel discount rates are one of the exceptions to the policy. Please note in the "Note to approver Section" of the web-voucher that this trip was booked under a group rate and is excluded under the policy. Your web-voucher will be approved.
- I have arranged for a very distinguished visitor to come to Harvard and deliver a lecture to my lab regarding a federal research project that we manage. Do I have to make my visitor book through Expedia corporate? They like to use their own travel agency.
Non-Harvard visitors are another exception to the policy, but the traveler must still comply with the restrictions contained in Circular A-21: for domestic airfare, we can reimburse for the lowest coach class fare. Please obtain assurances from the traveler that they complied with the A-21 travel restrictions. By approving the web voucher for this expense, you are confirming that the expense is within policy.
- I do not feel comfortable telling my very prestigious visitor that they have to fly coach. They are very prestigious after all and accustomed to traveling first class.
First class travel is not allowed on either sponsored or non-sponsored funds! You may charge a documented coach fare to the federally sponsored award. Harvard does not reimburse for first class travel.
- I submitted a travel voucher for reimbursement against a federally sponsored award and the traveler did not use a preferred vendor to book their airfare. The travel voucher was returned to the department. The traveler did not know about the policy change and did not use a preferred vendor. Can I charge this to their non-federally sponsored project?
If the projects are closely related, and the travel is allocable to the non-federal project, you may change the coding on your travel voucher to the non-federal project. By approving the web voucher, you are certifying that to the best of your knowledge, this charge is allowable and allocable on the non-federal project. If, however, these projects are not closely related, this expense must be charged to a non-sponsored account.
- I work at an affiliated institution and submitted a travel voucher for my post doc who is charged to a NIH training grant at HMS. The post doc did not use a preferred vendor to book their trip. The voucher was returned to my department. How can I get reimbursed?
Since your post doc is assigned to an affiliated institution and not assigned to Harvard, they qualify as a visitor and can be exempted from the preferred vendor requirement. They should, however, be sure to follow their own institution's travel policy, and must still comply with the rules of OMB Circular A-21. Indicate in the note to approver section of the web voucher that the travel was for a non Harvard visitor who made their own arrangements. By approving the web voucher, the approver is certifying that the traveler is a non Harvard visitor who made their own arrangements and that the air fare qualifies as allowable on a federal award under the rules of OMB circular A-21.
- I'd like clarification regarding students (graduate and post docs) traveling on federal research stipend funds administered through the University. In the past, students doing dissertation research travel have not been considered "employees of the university." That is, we can't set them up in Expedia Corporate, they don't receive travel insurance from the University, they are excluded from the 60-day receipt rule, etc. They generally purchase their tickets out of pocket and we reimburse them. Are graduate students and post docs exempt from this policy?
Harvard grad students are NOT non-Harvard visitors (this exception was designed to exempt invited guests, visiting scholars, etc., from having to book their travel through Harvard vs. their own institutions). So unless they qualify through another exception (e.g., large group travel), grad students must purchase their airfare using one of Harvard's preferred travel agencies if their travel expenses are to be charged to federal awards. Please also note that Harvard students may now be set up in Expedia Corporate.
- I am a struggling graduate student and I need every penny of travel money that I have. Previously I have booked my travel through a consolidator so that I could lengthen my research trip. I do not travel with a large group. Can I still book through a consolidator in order to save money?
Harvard students are not considered non-Harvard visitor and if your research trip is funded by federal sponsored money, you must follow the new travel policy and the rules of circular A-21. In order to be reimbursed for this travel on a federal award, you must book your travel through one of our preferred vendor partners.
- I am not clear on the travel policy requiring flight on US flagged carriers. Is this explicitly included in the federal regulations, even when lower fare foreign carrier flights are available? In addition, most US carriers partner with foreign carriers nowadays, so that foreign flights often involved both, can you clarify the policy in this respect?
Use of U.S. flag air carriers when using federal funding to pay for travel expenses is a federal regulation. The Federal Travel Regulation (FTR) provisions pertain to use of U.S. flag air carriers under the provisions of 49 U.S.C. 40118, commonly referred to as the Fly America Act. Use of U.S. Flag air carriers can also include service provided under a code share agreement with a foreign air carrier, when the tickets or documentation for an electronic ticket identifies the U.S. flag air carrier's designator code and flight number. Each airline has a two letter alpha code. Please keep in mind that the determining factor for identifying the use of a U.S. flag air carrier is the air carrier’s designator code which precedes the flight number (UA2344). You can find the Fly America Act (as codified in 41 CFR 301-10.131 to 301-10.143 via the following URL: http://www.access.gpo.gov/nara/cfr/waisidx_01/41cfr301-10_01.html
- We have a visitor who will come from South Africa for collaboration with Professor Smith Lab on chemistry research. Can this person fly on a non US Flag carrier and can his airfare be charged to one of Professor Smith's federal award?
When a U.S. flag air carrier is available, it is required that travelers being reimbursed from federal funds must use a U.S. flag air carrier if their departure/origin is from outside the US. There are a few exceptions to the Fly America Act requirements for travel between the United States and another country, as well as for travel solely outside the United States. You can find those exceptions in the Code of Federal Regulations (CFR 301-10.136 and 301-137 ) via the following URL: http://www.access.gpo.gov/nara/cfr/waisidx_01/41cfr301-10_01.html
- Is use of consolidator fares allowed?
Use of consolidator fares is typically not encouraged. While "consolidator fares" can often save money, there are numerous risks and restrictions associated with consolidator tickets. Some of the restrictions are: consolidator tickets are non-refundable; cannot be transferred from one airline to another; the carrier or exact departure/arrival times may not be known until after the ticket is purchased (this could affect your reimbursement if you end up on a foreign flag carrier and you are using Federal Funds); the traveler generally forfeits their rights to expenses en-route in the event of a delayed or cancelled flight - it will be up to the consolidator to make arrangements with the airline to re- accommodate the traveler. This could delay the arrival/departure of a traveler for several hours if not days. These are just some of the issues related to consolidator tickets. For additional information about consolidator fares contact your travel agent.
