COVID-19 Research FAQs: Travel

See also: FAQs on business travel (including links to BU preferred travel agencies, current travel advisories, airlines, etc.)

Q: Are travel cancellation costs due to COVID-19 allowable as direct charges to sponsored projects?

Through the release of NOT-OD-20-86, the National Institutes of Health (NIH) has stated nonrefundable costs associated with grant-related travel that has been canceled due to COVID-19 may be charged to the NIH award if they would have otherwise been allowable.

For all other federal agencies, guidance has not yet been released. Boston University’s policy (including policies established for COVID-19 or other emergencies) allows for travel cancellation costs to be charged to institutional fund sources, therefore we recommend that you also charge those same costs to sponsored projects to ensure consistent charging practices. To be allowable, it is reasonable to assume that the traveler has requested and been denied a refund, and that documentation of such a request is stored with the award files. We recommend that you document such transactions to allow for corrections if funding agencies issue guidance that is contrary to this practice. It should be noted that several airlines are waiving travel cancellation fees for at least the immediate future.

Q: How should credits from canceled travel costs be handled on sponsored projects?

If a traveler has charged (e.g., through prepayment or a travel advance) an airline ticket or other travel cost to a sponsored project, and then that trip is later canceled, the credit must accrue to the sponsored project (see 2 CFR 200.406). Some airlines are offering full refunds for trips that need to be canceled due to COVID-19; in these instances, the refund should accrue to the grant, either directly through the institution’s travel system or via reimbursement from the traveler. If a traveler cancels a trip and accrues a credit on their personal account, the traveler should follow BU policy for how to track and manage the credit.

Per NIH FAQs on NOT-OD-20-086: If vouchers have been granted for any of the travel expenses affected by COVID-19, recipients are required to use the vouchers and may not request additional support. BU Departments must document that costs charged to a grant are non-refundable and maintain documentation, following record retention requirements, and make them available to NIH upon request.

Procedure for e-credit
Flight charges may remain on the original account until the travel occurs. If charged to a university account, departments will track the e-credits. Preference is for the faculty members to use the e-credit for the same project before the airline deadline. If the traveler is unable to use the e-credit for the original project, the individual may potentially use the e-credit for other university travel. In cases when e-credits are used for a different project, the institution does internal cost transfer paperwork to the correct account. Documentation about the traveler’s inability to use the e-credit on the original project, and documented communication with program officers and/or vendors must be kept with cost transfer documentation. If a PI has already charged the airline ticket to their own credit card, the university will reimburse via a discretionary fund tagged for COVID-19-related costs.

• The travelers are encouraged to use the e-credit for the same project within the airline deadline to use e-credits.
• If the traveler is unable to charge the original grant project, internal cost transfer paperwork is done to transfer to the correct account.
• Reason(s) stated for using this method: reduction of journal paperwork upfront with emphasis on documenting communication.

Q: What do you know about accommodations airlines are making because of COVID-19?

Various airlines have announced special accommodations, including waiving all or certain change fees. This list is not comprehensive, and policies are subject to change at any time. Travelers should consult the airline’s website directly for the most up to date information:

Delta (updated 3/10/20) – Waiving change fees for all flights from March 1 – April 30, no change fees for all tickets purchased between March 1 – 31 and certain other international flights beyond that time. See https://www.delta.com/us/en/advisories/other-alerts/coronavirus-travel-updates 

United (3/12/20) – Waiving change fees for all flights between March 3-31 and for tickets purchased before March 3 for flights from March 9-April 30. A comprehensive table of waived change fees for specific airports/periods of travel is available at https://www.united.com/ual/en/us/fly/travel/notices.html 

American (3/15/20) – Waiving change fees for all new non-refundable tickets purchased before March 15, 2020, or are scheduled to travel March 11- May 31. See https://www.aa.com/i18n/travel-info/travel-alerts.jsp for more details.

Q: If a traveler can return home from travel (domestic or foreign) but at a much greater cost than usual, is the additional cost allowable on the grant?

The traveler should follow BU’s policy for emergencies.  BU Travel Policy can be found here: http://www.bu.edu/policies/6-4-1-travel-and-business-expense-policy/

BU’s policy or practice related to the criteria for evaluating the status and extent of the emergency and the level of relief that is considered appropriate to those circumstances should be followed.

Per NIH FAQs on NOT-OD-20-086: As outlined in the NIH GPS 7.9.1, travel costs are limited to those allowed by formally established organizational policy, and in the case of air travel, the lowest reasonable commercial airfares must be used. Recipients should continue to comply with their institutional travel policies to determine the allowability of these costs in cases of unforeseen or emergency circumstances.

Q: Can travel insurance be charged to grants?

The traveler should follow BU’s policy for emergency situations. BU does not permit people to buy insurance (nor charge to grants) as we are covered under BU’s insurance coverage for employees and vehicles.

http://www.bu.edu/policies/6-4-1-travel-and-business-expense-policy/

Q: I am a PI on a very large Program Project Grant, which includes hosting a conference in Atlanta with hundreds of collaborators participating from around the world. I have already incurred $35,000 of expense for the rental space at the convention center and hotel. I am working with the venue to get a credit but there will be a sizeable cancellation or penalty fee. Can I charge this to my award? And can I pay the travel fees and any associated costs for the hundreds of collaborations that were planning on attending?

1. Does it matter if I elected to cancel it because it was prudent to do so?
2. Does it matter if it was in a CDC level 3 location?
3. Does it matter if my institution is not allowing it?

Federal agencies share institutional concerns about the safety of researchers. If the PI (organizer) believes it would be unwise to hold the conference, the organizer should confer with the program officer and grants management specialist to decide whether to cancel the meeting, postpone the meeting, or convert the meeting to an on-line format. This request for input is consistent with 2 CFR 200.407 which says in part: “the non-Federal entity may seek the prior written approval of … the Federal awarding agency in advance of the incurrence of special or unusual costs.” Note that if the request is made orally, written documentation of the decision should follow (an email from the agency to the PI should be sufficient). Note that for many federal agencies, the program officer cannot independently make this type of decision, and grants office concurrence is required. PIs should follow the requirements for their specific agency. In the course of the discussion with the funding agency, it would be appropriate to discuss the basis for the proposed cancellation (prudent circumstances, CDC level 3 location, or institutional determination that travel will not allow the organizer to attend.) Organizers may wish to make a firm decision about keeping or canceling the meeting early enough to enable their participants to take advantage of discounts offered by airlines or hotels related to COVID-19 changes or early cancellation deadlines (particularly for hotels). Also, a decision by the organizer to cancel the conference may assist some participants in convincing their institution to pay their cancellation costs.

If a conference is canceled with the concurrence of the federal funding agency, the non-refundable costs for the venue may be an allowable charge to the project (if the project was scheduled to incur those costs in the first place). In general, the costs for participants should follow the funding stream intended to pay for their attendance; if the conference grant was reimbursing all or part of the participation costs for all attendees, it may be appropriate to also charge some or all of their cancellation fees. If participants were covering their own attendance costs (from sponsored or non-sponsored sources), then the cancellation costs should follow the sponsor funding their participation or the participant’s employer.

Per NIHNational Institutes of Health Guide Notice NOT-OD-20-086: Scientific meetings, conferences, and workshops supported by NIH funding may be delayed or canceled due to COVID-19. Non-refundable costs associated with NIH supported meetings and conferences affected by COVID-19 are allowable and may be requested as an administrative supplement to the appropriate funding IC. Recipients should contact their assigned grants management specialist and program official to provide documentation demonstrating the effect of COVID-19. The funding institute or center will work with the recipient to address the impact on the NIH Grant.

Q: I am a PI on a sponsor-funded Conference or Travel award, but the meeting has been canceled. Who do I contact regarding the impact to the award? 

National Science Foundation (NSF): You should contact the cognizant NSF program officer about this situation. In light of the public health threat, you may wish to consider alternate plans, such as providing or using options for virtual participation. Also, NSF program officers will be open to rescheduling the conference or using the funds for a future meeting that is consistent with the original scope and objectives of the award.

Department of Defense (DOD): You should contact the cognizant USAMRAA grants official named in the award document to alert them to the situation. Also, copy the program official to ensure all appropriate federal staff is aware of the circumstances. In light of the public health threat, you may wish to consider alternate plans, such as providing or using options for virtual participation.  Additionally, it may be possible to attend if the meeting/conference is rescheduled within a year.  See the question above regarding one-time no-cost extensions.

For meetings that are specified directly in the application or award notice, or that have been required by the Congressionally Directed Medical Research Program (CDMRP) (e.g. Milestone Meetings, In-Progress Reviews, etc.), we will be open to rescheduling the meeting or setting up a virtual presentation.

Q: A conference has been canceled, but I have nonrefundable travel and/or hotel costs. Can these costs be charged to a Conference or Travel grant? 

Please follow all BU Relevant Policies and Procedures, including the BU Travel Policy here: http://www.bu.edu/policies/6-4-1-travel-and-business-expense-policy/

 Q: I am considering submitting a Conference or Travel proposal for a future meeting. The site of the meeting has not yet been selected; should I take into account COVID-19 in conference planning and site selection?

Travel logistics, accessibility, and health and safety considerations of the participants should always be a foremost consideration in any Conference proposal. Since the COVID-19 threat is still evolving, it is important to consider flexibility and alternative plans in a proposal to support travel or a conference. For foreign travel, you should consult the State Department Travel Advisories website.

Q: What should we do about the Department of Justice (DOJ) related conferences, events, and other gatherings?

For Office of Justice Programs (OJP)-sponsored conferences, meetings, training, and other gatherings that are scheduled in the near term, cooperative agreement recipients should work with their OJP program or grant managers to set up meetings as virtual events or postpone or cancel meetings. For events planned farther out, please work on a case-by-case basis with your grant manager.

Grantees should contact their OJP grant managers to address issues resulting from postponed or canceled meetings, such as using grant funds to cover hotel or travel-related cancellation fees and penalties.

Grantees should try to have the airline reimburse the canceled ticket(s) in cash. However, if the airline will only refund the cancellation as a credit:

• The grantee should apply the credit to a future trip for the same OJP grant or project.
• If that is not possible, the grantee should use the credit for another OJP program or project and reimburse the original OJP grant or project with the equivalent dollar amount.
• If neither of those options is possible, then the grantee should process the trip as a cancellation, which OJP approves to be charged to the grant due to this mitigating circumstance.

Grantees should provide similar guidance to sub-recipients (that is, subgrantees). Please document these such changes via a Program Office Approval Grant Adjustment Notice (GAN) in OJP’s Grant Management System (GMS) for record-keeping purposes.