This page will help you assess your travel cost management practices. It is intended for organizations that are submitting a proposal to the U.S. National Science Foundation or have received an NSF award.
Specifically, this page will help your organization verify that:
- Your organization has a travel policy and associated procedures, approved by management and distributed to staff for official use, which help ensure travel is reasonable and necessary for the performance of a project.
- Travel costs are adequately documented, allowable and allocable to NSF-sponsored projects, and reasonable based on award terms and conditions and 2 CFR 200, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or Federal Acquisition Regulations (FAR) as applicable.
On this page
What are travel costs?
Travel costs are "transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of the recipient or subrecipient" (2 CFR 200.475)."
Travel is allowable as a direct cost to a sponsored project to the extent that it provides a direct benefit to that activity and is a necessary and reasonable expense. Awardees must be able to provide documentation (such as a travel authorization) describing the travel and explaining how and why each trip is directly related to accomplishing award objectives.
- Dependent travel is only allowable in very limited instances, which require travel of six months or more and prior written approval of the federal agency. Please consult with the funding federal agency before making dependent travel arrangements.
- Travel by non-commercial carrier (e.g., chartering a plane) is only allowable in very limited instances. Please consult with the funding federal agency before making these travel arrangements.
- Foreign travel has stringent regulations, particularly around the use of U.S. commercial carriers for air travel.
Requirements for travel cost management
NSF requirements
Proposals:
Awards:
- PAPPG Chapter XI.F.1 "Travel to foreign countries"
- Research Terms and Conditions: Agency Specific Requirements (RTC)
- Grant General Conditions (GC-1)
- Cooperative Agreement Financial and Administrative Terms and Conditions (CA-FATC)
Federal requirements and resources
Checklist for assessing your organization's policies
Documented policies and procedures should be approved by your organization's management and distributed to staff for official use to promote thoughtfulness, thoroughness and consistency and ensure that travel costs are allowable.
If your organization lacks an established written travel costs policy, you must apply the rates and amounts established under 5 U.S.C. 5701-11 to any travel under federal awards.
Travel costs may be charged on an actual cost basis, a per diem or mileage basis in lieu of actual costs incurred, or a combination of the two, provided:
The method is applied to an entire trip and not to selected days of the trip.
Charges are consistent with those normally allowed in similar circumstances in your organization's non-federally funded activities.
Charges are in accordance with your organization's written travel reimbursement policies.
NSF recommends and encourages recipients to develop clear definitions to help ensure employees (and the organization) understand what constitutes travel status and that travel is consistently managed.
For most organizations, an employee is in a travel status when they travel more than 12 hours on organization business and more than 35 miles beyond their normal commuting distance; some organizations use a different distance.
NSF does not normally allow grant employees not in travel status to charge local meal expenses to NSF awards.
Frequently asked questions
The "Travel" budget line is only for employee travel. Participant-related travel should be captured in the "Participant support costs" budget line and consultant-related travel should be captured in the "Consultants" budget line.
Each cost must be segregated in your organization's accounting system (i.e., recorded in different general ledger accounts designated for that purpose).
Travel authorizations: Written travel authorizations are a great way to document that proposed travel was evaluated for necessity and reasonableness. Travel documents that either approve the travel in advance or reimbursement requests must explain the purpose of the travel and its relation to award objectives. If your organization's policy requires an authorization, you must maintain that documentation. If you don't have a written travel authorization, your organization may be asked to justify that the travel was necessary or reasonable.
After-the-fact expense reports: A report detailing the types of travel expenses claimed and showing advances, if any, and liquidation of those amounts would provide an overview of the travel expenses and provide a basis for assessing the allowability of those costs.
Original receipts: Receipts should be detailed and/or itemized to clearly show expenses are allowable. For example, the FAR requires receipts for all expenses over $75; most organizations use a lower threshold. Receipts should be maintained with travel records to reduce the possibility of claiming the same expense for reimbursement on more than one award or other funding sources.
Your organization's travel policy should detail what types of records must be maintained and submitted for reimbursement of travel expenditures.
2 CFR 200.475(e) states, "Airfare costs in excess of the basic least expensive unrestricted accommodations class offered by commercial airlines are unallowable" except under certain conditions.
Example 1: A large nonprofit organization made an organizational decision that its president would only fly business class. Reasonable and necessary travel was allowable, but the organization had to exclude the cost of that travel over and above comparable economy travel from both direct and indirect cost pools.
Example 2: The only option for an employee to arrive before 2 a.m. was business class travel; the organization maintained its required written justification for the use of business class travel along with the trip travel records. This travel cost was allowable, as avoiding travel during unreasonable hours is one of five allowable reasons for not using the "basic least expensive unrestricted accommodation class" (see 2 CFR 200.475(e)(i)-(v)).
- Travel of the individual is necessary to the federal award.
- The costs are reasonable and consistent with the non-federal entity's established travel policy.
As per 2 CFR 200 and FAR, your organization may not be required to use the "least expensive unrestricted travel" if that travel:
- Requires circuitous routing.
- Requires travel during unreasonable hours.
- Excessively prolongs travel.
- Results in additional costs that would offset the transportation savings.
- Offers accommodations not reasonably adequate for the traveler's medical needs.
To be allowable, your organization must justify and document these conditions on a case-by-case basis; we recommend taking and retaining screenshots of alternative options when you are booking travel. It is also best practice to define terms such as "circuitous routing," "unreasonable hours, "excessively prolonged travel" in your organization's travel policy.
Yes, with restrictions. Temporary dependent care costs (as "dependent" is defined in 26 U.S.C. 152) above and beyond regular dependent care that directly results from travel to conferences is allowable, provided all of the following are true:
- The costs are a direct result of the individual's travel for the federal award.
- The costs are consistent with the non-federal entity's documented travel policy.
- The costs are only temporary during the travel period.
Yes, with restrictions. These costs may be allowable if a caregiver is medically necessary, as documented by a physician, for the primary traveler to perform his or her official business purpose and the caregiver is qualified to deliver the necessary care.
The justification for the caregiver's travel should be well documented in your organization's travel records. These cases are uncommon; we strongly recommend consulting with the federal agency managing your award.
Yes, with exceptions. These rules are complex, but important things to note are:
- The use of anything other than a U.S. air carrier requires an exception to be allowable.
- The airline you book with is irrelevant, your ticket must be for a U.S. or U.S. codeshare carrier.
- Cost is not a consideration.
We strongly recommend that your organization's travel policy cite the requirement to use U.S. carriers and that your organization require additional scrutiny and approval whenever a non-U.S. carrier is used.
Common concerns relating to travel costs include:
- Written policies and procedures do not exist or have not been fully established. In the absence of written guidance, policies and procedures may be inconsistently followed and result in inconsistent treatment of travel costs or unreasonable charges to federally sponsored projects.
- The awardee charged per diem in excess of allowable amounts. The federal government publishes per diem rates for most U.S. and international travel locations. These daily rates are broken down into a lodging portion and a "meals and incidental expenses" portion. (Transportation expenses are not included in the per diem rates.) Per diem rates provide a basis for assessing the reasonableness of claimed travel costs. If allowed by the organization's written travel policy, most NSF awardees may charge actual costs where such reasonable costs exceed per diem rates. For awardees subject to the FAR, actual costs may not exceed federal per diem rates in effect at the time of travel.
- The awardee charged travel costs for employees not in travel status. This is a common concern, often resulting in questioned or disallowed costs. Local meals and entertainment expenses are not considered allowable, by classification, as travel costs. NSF does not normally allow awardee employees not in travel status or in an official business meeting to charge local meal expenses to NSF awards.
The awardee used a non-U.S. flag air carrier. This is a common concern when international travel costs have been charged to an NSF-funded award. Where applicable, the "Fly America Act" requires that NSF awardees make use of U.S. flag air carriers, even if foreign air carriers are cheaper or more convenient.
Foreign flag air carriers may be used under very limited circumstances identified in Article 10 of the CA-FATC, GC-1, and Article 14 of the RTC. Allowable situations for use of foreign air carriers involve:- Non-availability of a U.S. air carrier.
- Intra-foreign country travel.
- Connecting times at a foreign interchange.
- Total trip time.
The awardee should document which exemption applied at the time of travel. In certain situations, U.S. air carriers may also enter into a code-sharing arrangement with a foreign air carrier that will still classify the flight as a U.S. air carrier.
- Premium airfare. First-class and business-class airfare may not be charged to NSF awards unless justified, per criteria stated in 2 CFR 200.475 where applicable. Awardees should charge airfare related to NSF awards at coach or economy rates. Upgrades may be taken to use frequent flyer miles or other promotions, but the rate charged to the federal award should be made at the coach rates. Length of travel, position within the awardee organization (e.g., executive director travel), and/or size of the traveler are not acceptable justifications for using first-class airfare.